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Proposed PUC Rule Changes Would Alter Rescission Period Language, Ostensibly Expand To More Customers
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The Public Utilities Commission of Ohio has opened a periodic statutorily required review of the electric utility minimum customer service rules under Chapter 4901:1-10, Ohio Adm.Code, and Staff has proposed several changes to the current rules
Among other things, the rules address utility consolidating billing (including the information which appears on bills such as the price to compare and any associated language), utility-supplier coordination, eligible customer lists, procedures concerning slamming with respect to utility obligations, and partial payment priority.
Among Staff's proposed changes is the deletion of the phrase "residential and small commercial customers" in addressing the requirement for utilities to notify customers of the rescission period in supplier switch confirmation letters
Chapter 4901:1-21 establishes that the rescission period applies only to residential and small commercial customers.
However, it isn't apparent whether the utility customer service rules at Chapter 4901:1-10, nor any other rules, limits the issuance of switch confirmation letters only to residential and small commercial customers
The current rule language avoids any confusion by stating that the utility switch confirmation notice sent to customers shall state, "That residential and small commercial customers have seven days from the postmark
date on the notice to contact the electric utility to rescind the enrollment request or
notify the electric utility that the change of service provider was not requested by the
customer."
However, Staff's proposed deletion provides that the utility switch confirmation notice sent to customers shall state, "That customers have seven days from the postmark
date on the notice to contact the electric utility to rescind the enrollment request or
notify the electric utility that the change of service provider was not requested by the
customer."
To the extent the switch confirmation notices are sent to large customers, at the very least such notices will be confusing to the extent they inform customers of an available rescission period, when none exists for that particular customer
As noted, the rules address utility billing, including utility consolidated bills.
Current residential SSO and utility consolidated bills must include the price-to-compare and a notice that such customers
can obtain a written explanation of the price-to-compare from their electric utility.
Staff does not propose any changes to the price-to-compare notice requirements, but the rulemaking may serve as a forum for other stakeholders to do so
The rules also address the partial payment posting hierarchy, to which Staff has not propose any changes
However, of note to retail suppliers using utility consolidated billing, Staff does propose that the due date for customer payments shall be at least 21 days from the date of postmark (under current rules, the due date is a minimum of 14 days for bills mailed from in-state, and 21 days for bills mailed from out of state)
Staff proposes to delete specific items required on eligible customer lists
Currently, the rule states, "The eligible customer list shall, at a
minimum, contain customer name, service and mailing address, rate schedule (class and subclass), applicable riders, load profile reference category, meter type, interval meter data
indicator, net metering indicator, budget bill indicator, PIPP plus indicator, meter read date or
schedule, and historical monthly customer energy usage data (actual energy usage plus any
applicable demand) for each of the most recent twelve months."
Staff's proposed revision provides instead that, "Such [ECL] lists shall be updated quarterly and
comply with section 4928.10(G) of the Revised Code."
Section 4928.10(G), however, does not delineate any specific items for inclusion in the ECL, and rather provides that customer-specific information shall be made available on a non-discriminatory basis
Staff also proposes to delete certain specific items that are currently required to be included in a summary of customer rights which is provided to customers under various circumstances. The summer would still be required to include, "Information explaining the procedures customers must follow if they believe their generation
and/or transmission service has been switched without their consent," but the rule would no longer delineate specific points that shall be addressed or included in such slamming information.
While mostly dealing with utilities, the rules do also address retail supplier (CRES) net metering. Staff does not propose any substantive changes with respect to the CRES net metering rules. As is the case now, the proposed rules would state that a CRES provider may offer net metering contracts to its customers, consistent with
Chapter 4901:1-21 of the Administrative Code, at any price, rate, credit, or refund for
excess generation. The proposed rules would state that a CRES provider is not required to enter into any net metering
contract with any customer
Case No. 22-872-EL-ORD
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Rules Also Address Utility Consolidated Billing, Supplier Coordination
November 2, 2022
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Copyright 2010-21 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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