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Updated: DP&L Seeks Change To Default Service Rate Calculation Under New ESP
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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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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 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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