Utility Proposes New Minimum Stay

July 14, 2023

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Copyright 2010-23 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

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Dominion East Ohio (Dominion Energy or DEO) has proposed a new default service minimum stay, of at least 12-months, applicable to municipal aggregations which return a threshold number of customers to default service prior to the expiration of the aggregation program

DEO specifically proposed to add the following language to its tariff:

"A governmental aggregator, or its natural gas supplier, shall provide written notice to East Ohio 30 days prior to the return of more than 5,000 customers receiving supply service under an opt-out governmental aggregation program to the Standard Service Offer (SSO), including but not limited to at the scheduled expiration of the opt-out aggregation program. The notice shall either specify that the customers are being returned due to the expiration of the opt-out aggregation program or provide the reason for returning such customers to the SSO prior to the scheduled expiration of the opt-out aggregation program. This provision does not apply to a governmental aggregator that returns customers to the SSO due to a supplier default under Paragraph 26. If more than 5,000 customers are returned to the SSO from an opt-out aggregation program prior to its scheduled expiration, the notice shall also be docketed in the applicable PUCO GA-GAG docket created for that aggregation program at the time the notice is sent to DEO, and the governmental aggregator may not offer any new opt-out aggregation programs in DEO’s service territory for a minimum stay of at least twelve months following that return or a later date as may be ordered by the PUCO. Customers returned to the SSO prior to the scheduled expiration of the opt-out aggregation program are not prevented from shopping for competitive retail natural gas from a qualifying Energy Choice supplier."

As noted in the language above, and consistent with the recently adopted electric utility minimum stays in Ohio, customers returned to default service would not be prohibited from leaving default service via individual retail choice (individual shopping)

Dominion East Ohio noted that, as previously reported, the PUC of Ohio recently adopted such minimum stays for electric utilities

"DEO has reviewed [the EDU] dockets and tariff provisions and the situation that gave rise to them and believes that the same concerns justify the inclusion of similar notice and 'minimum-stay' protections in DEO’s tariffs," DEO said

"Approximately thirty-six percent of DEO’s customers are currently served under opt-out aggregations. The same kinds of market forces that led to the issue for electric companies could also occur on DEO’s system, and a large-scale return of gas aggregation customers to SSO default service could destabilize the provision of that service. The risk of this occurring could lead to an increase in the auction bids that establish the price for default service. In addition, unlike the electric supply market, SSO suppliers are subject to ratcheting 'gas in storage' requirements under DEO’s tariffs, tied to the number of customers served, and a large-scale return of gas aggregation customers to SSO default service could materially impact an SSO supplier’s ability to manage those requirements in a cost-effective manner," DEO said

DEO proposed two changes from the provisions generally adopted at the electric utilities

"First, DEO proposes that the Company be provided notice of a large-scale return of gas aggregation customers, even in the case of a return at the expiration of the program (the minimum stay would not apply in such case). This is to address administrative and customer-service concerns associated with the transfer of a larger number of customers to SSO default service; absent such a notice, DEO does not track or have access to the expiration dates of opt-out aggregation programs," DEO said

"Second, DEO does not propose to require the provision of name, address, account number, and usage history of customers being returned to the SSO. DEO does not consider this information necessary," DEO said

"DEO respectfully requests an order approving these tariff additions by December 1, 2023. Approval by this date will ensure that these provisions are in place in time for preparatory supplier meetings for the next SCO/SSO auction and will enable such suppliers to evaluate and consider any impact on default service risk associated with these tariff provisions," DEO said

Case 23-0755-GA-ATA

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