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Updated: DP&L Seeks Change To Default Service Rate Calculation Under New ESP

Two-Year Period Would Have No 12-Month Contracts In SSO Portfolio Under Tentative Schedule (24 & 36 Months Used)

Proposes Utility-Offered Residential Demand Response Program; Utility-Owned EV & Renewable Energy Projects For C&Is

DP&L Proposes Subscription Program Providing Low/Moderate Income Customers With A Personal Electric Vehicle, Including Maintenance, Insurance For Monthly Charge

September 27, 2022

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Copyright 2010-21
Reporting by Paul Ring •

The following story is brought free of charge to readers by EC Infosystems, the exclusive EDI provider of

Under its newly filed electric security plan, Dayton Power & Light (AES) Ohio has proposed a modification to the bypassable Standard Offer Rate ("SOR"), to remove uncollectible expense recovery.

"Uncollectible expenses are being removed from the SOR because the Company proposed that those expenses be recovered in base distribution rates in Case No. 20-1650-EL-AIR, et al.," a witness for Dayton Power & Light said

"If the Commission were to deny AES Ohio's request to include uncollectible expenses in base distribution rates, then AES Ohio proposes to recover the uncollectible expenses through the [nonybpassable] RCR [Regulatory Compliance Rider]," a witness for Dayton Power & Light said

With respect to procurements for Standard Service Offer ("SSO") load, DP&L proposes to maintain 100% competitive bidding for slice-of-system, load-following, "full requirements" service including energy, capacity, firm transmission charges, and ancillary services. Consistent with current practice, Dayton Power & Light plans to supply the Renewable Energy Credits required to cover obligations relating to the SSO load.

However, DP&L did update the auction product definition, "so that unique arrangement customers may be excluded from the SSO load in order to allow AES Ohio more flexibility related to certain renewable energy programs." (discussed further below)

DP&L does propose to conduct two auctions per year for SSO load, departing from the single procurement used in the most recent years. As previously reported, DP&L recently sought and received approval to move to a two-procurement-dates approach for the remainder of its current ESP term.

"[I]ncreasing the number of auction days per delivery year is expected to reduce price volatility," Dayton Power & Light said

"The purpose of multiple bid days is to reduce exposure to short-term market conditions or issues unique to a particular day or period, yielding an SSO price more consistent with longer-term market fundamentals," a witness for Dayton Power & Light said

"[A] single bid day approach adds unnecessary price risk to SSO customers and is more likely to yield more volatile SSO prices than multiple bid days and the SSO may not track the market as well as a process that uses multiple bid days," a witness for Dayton Power & Light said

DP&L's proposed procurement schedule would cover the period through May 31, 2027

DP&L also proposes to return to a mix of laddered 12, 24 and 36-month contracts for SSO. This had historically been a part of DP&L's SSO portfolio, but had been modified due to various delays in the PJM Base Residual Auction

Under the proposed schedule, for the 2024-25 and 2025-26 delivery years, 80% of DP&L's SSO portfolio would be 24 month contracts, while 20% would be a 36 month contract. For the 2026-27 delivery year, 40% of DP&L's SSO portfolio would be 12 month contracts, 40% would be 24 month contracts, and 20% would be a 36 month contract

A proposed "tentative" procurement schedule and portfolio of contracts can be seen here. Note that the schedule may change based on any potential changes in BRA auction dates

C&I Renewable Projects

Dayton Power & Light proposed to, "[p]rovide opportunities for interested mercantile customers to work with AES Ohio on the installation of renewable energy resources through an optional Green Energy Alternative tariff."

Pursuant to R.C. 4928.47, Dayton Power & Light seeks approval of a Green Energy Alternative ("GEA") tariff to allow it to implement such program.

"The purpose of this tariff is to address increasing interest from nonresidential customers to install renewable energy resources," Dayton Power & Light said

"This tariff proposes an optional green generation service for mercantile customers. AES Ohio will identify interested customers after the tariff is approved. Once interested customers are identified, AES Ohio will work with them to develop customer-sited renewable energy resources. Customers will commit to switching to this option upon commercial in-service dates of the renewable energy resource and will agree to other terms regarding length and pricing per a contract between the Company and mercantile customer," a witness for Dayton Power & Light said

"The costs of the program will be borne solely by participating customers," DP&L said

Demand Response & Consumer Programs

Dayton Power & Light proposes to offer three demand response and other energy usage programs to residential customers

Dayton Power & Light sought approval of a nonbypassable Consumer Programs Rider ("CPR") pursuant to R.C. 4928.143(B)(2)(h) and (i) to recover the costs of the programs

Specifically, Dayton Power & Light proposes a remote load control program for residential customers (called the "Demand Response" program)

The Demand Response program will reduce peak demand by controlling electrically powered customer devices during periods of high system demand, DP&L said

The residential Demand Response program will help shape overall residential peak load by providing customer incentives to shift electrical demand activities, including air conditioning and water heating, from periods of high electrical demand to periods of lower electrical demand, DP&L said

Under the residential Demand Response program, DP&L will remotely communicate with connected customer devices including smart thermostats and smart electric hot water heater controls. Communication with these devices will be managed through a demand response management system (DRMS), a software system that enables coordinated control of these enrolled devices during Events, and supports customer communication before, during and after an Event.

DP&L said that the proposed Demand Response program will engage customers to participate in the program during seasonal Events through a combination of rebates for the installation of DRMS connected devices and incentives for participation in Events.

Customers will have the option of participating or not participating in these demand-shifting events.

Additionally, DP&L proposes a "Behavior" program for residential customers that provides them with customized energy usage information, alerts, and other data

"The Behavior program provides eligible residential customers with home energy reports which compare their energy usage to similar homes and offers suggestions for saving energy and money. Eligible customers will be able select their preference to receive the home energy reports via mail or email. In addition, this program provides customers with an online portal that analyzes customer usage data and displays personalized suggestions for saving energy. Lastly, this program further leverages the increasingly granular data from the growing number of smart meters by delivering high usage alerts to customers so that customers have the opportunity to better control their energy bill," DP&L said

"In addition to the home energy reports, customers may receive high usage alerts midway through billing periods to inform them of usage that is trending above normal," DP&L said

"All customers will have access to an online home energy audit, where they can tailor information about their own usage and receive personalized energy saving information. And lastly, all customers will have access to a customer portal that provides usage history and energy efficiency recommendations tailored to the customer’s current and historical usage," DP&L said

Finally, DP&L proposes an Income-Qualified Efficiency program which provides customers in financial need with energy efficiency improvements including energy efficient lighting, appliances, and insulation, to help control their energy costs.

The total cost of the proposed DSM Customer Programs is $5.7 million annually. Collectively, participants in the program are expected to save 15,565 MWh in energy usage and 11.8 MW in peak demand reduction on an annual basis, DP&L said

EV Programs

Dayton Power & Light proposed several EV programs, including instances where DP&L would own EV charging equipment, plus "managed charging" programs for both residential and commercial customers

With respect to electric vehicle supply equipment (EVSE) ownership, DP&L is proposing to install, own, operate, and maintain EVSE as part of an C&I EVSE Lease program, a tariff under which C&I customers would pay a fixed, monthly fee for qualifying DP&L owned/operated EVSE

DP&L proposes a Managed Charging program for both residential and C&I EV customers under which DP&L would be able to curtail the EV load during peak hours

DP&L specifically noted under some of its proposed EV programs, the customers would be able to take supply from a competitive retail supplier or default service. Specifically, DP&L noted this ability under a proposed residential off-peak incentive EV program, and a proposed Low-to-Moderate Income EV Subscription

The Low-to-Moderate Income EV Subscription program, "will provide more affordable, equitable access to popular EV makes and models and home charging through a discounted subscription rate that includes access to a personal EV (i.e., not shared), a qualified Level 2 charger with bundled installation services, insurance, and vehicle maintenance," DP&L said

"The estimated monthly price is $500 but is subject to change based on the outcome of [an] RFP ... In exchange for the discounted subscription rate, and to generate shared benefits for all customers, participants in the Low-to-Moderate Income EV Subscription program will be enrolled in Residential Managed Charging or Off-peak Incentives," DP&L said

"For customers who live in apartments or other multi-unit dwelling properties, AES Ohio will offer a slightly lower monthly subscription price estimated at $450 to reflect the fact that the customer would not be paying for the Level 2 charger and associated installation services. In multi-unit dwellings, the property manager, and not the tenant, would be responsible for the installation of charging infrastructure to allow tenants a place to charge at their residence," DP&L said

"The Company plans to issue a competitive request for proposals to provide turnkey services, including fleet management, level 2 charger installation, participant enrollment, payment fulfillment, insurance, vehicle maintenance, and any other services necessary to deliver the Low-to-Moderate Income EV Subscription offering," DP&L said

Case 22-0900-EL-SSO


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