Utility Seeks Waivers To Suspend New Retail Supplier Certifications For Nearly Two Months; Suspend Supplier Enrollments For Two Weeks -- EnergyChoiceMatters.com

Utility Seeks Waivers To Suspend New Retail Supplier Certifications For Nearly Two Months; Suspend Supplier Enrollments For Two Weeks

January 3, 2024

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

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AES Ohio (Dayton Power & Light or the Company) has petitioned the PUC of Ohio for waivers of applicable rules and tariff provisions described below to execute a cutover to a new CIS and billing and related systems

While specific actions that AES Ohio intends to undertake have specific dates affected further described below, AES Ohio generally said that a temporary disruption to its legacy systems will occur Friday, March 29 until Wednesday, April 3 (the Cutover Period), but that, "given the immensity of this project," disruptions may occur between February 15 and May 1, 2024 (the Conversion Period),

AES Ohio intends to undertake the following actions:

Suspend certification of new CRES supplier (February 15 to April 8, 2024)

From February 15 until April 8, 2024, AES Ohio intends to suspend certifying and activating any new CRES (retail) supplier in the legacy CIS. A supplier who completes certification after February 15, 2024 will be activated in the new system after April 8, 2024 and will then be able to serve customers.
AES Ohio requests temporary waivers of Rule 4901:1-10-29 and any relevant provisions in Tariff G8 requiring otherwise to permit this suspension.

Suspend inbound transactions for CRES enrollments, drops, changes, and reinstatements (March 20 to April 3)

From March 20 until April 3, 2024, AES Ohio intends to suspend accepting inbound transactions for CRES enrollments, reinstatements, and drops. During this period, suppliers will be able to contact the Company via email until March 28 to manually reinstate pending drops during the recission period. Any requests that are submitted to AES Ohio during the suspension will be stored and processed after the Cutover Period.
Accordingly, AES Ohio requests a waiver of the relevant portions of Rule 4901:1-10-29 and Tariff G8, which require the Company to take certain actions upon receiving enrollment and drop transactions, from March 20 until April 3, 2024. Additionally, the Company further requests a waiver of the time limits for correcting unauthorized switches either to another provider or to the utility’s standard service offer, as otherwise required by Rule 4901:1-21-08(C).

Suspend processing requests for new CRES provider rates for Rate Ready billing (March 1 to April 3).

From March 1 until April 3, 2024, AES Ohio intends to suspend processing requests to implement new rates for CRES providers for Rate Ready billing. For rates effective April 1, 2024, CRES Providers would need to send change requests by March 1, 2024. On April 3, 2024, the Company will resume accepting and processing such requests.
Accordingly, during this period, the Company requests a waiver of any provisions in Tariff G8 requiring otherwise.

Suspend outbound transactions to CRES providers (Marcil [sic] 29 to April 3)

From March 29 until April 3, 2024, AES Ohio intends to suspend outbound transactions to CRES providers. Outbound transactions will resume on April 4, 2024.
Accordingly, for this period, the Company requests a waiver of any provisions in Tariff G8 requiring otherwise.

Suspend access to historical usage requests on CRES Web Portal (March 29 to April 3)

From March 29 until April 3, 2024, AES Ohio intends to suspend accepting historical usage requests from CRES providers. The current historical usage feature on the Company’s CRES web portal performs a real time call to the legacy system to retrieve usage. This feature will be unavailable during the Cutover Period.
During this time, a maintenance message will displayed [sic] on the CRES Web Portal page notifying users of limitations. On April 3, 2024, the Company will resume access to historical usage.
For this brief period, AES Ohio requests a waiver for any provisions in Tariff G8 requiring otherwise.

Suspend processing of bill-ready billing transactions (March 29 to April 3)

From March 29 and until April 3, 2024, AES Ohio intends to suspend the processing of bill-ready billing transactions from CRES providers. During this time this Company expects that it will be unable to adhere to the three-day processing window for Bill Units nineteen through twenty-one.
Accordingly, AES Ohio requests a waiver during this period of any provisions in Tariff G8 requiring otherwise.

AES Ohio also sought various rule and other waivers on behalf of CRES providers due to the following:

CRES providers will need to wait to send electronic enrollment requests (March 20 to April 3)

From March 20 until April 3, 2024, AES Ohio will be unable to process electronic inbound transactions. In most cases, CRES providers will have to wait longer than three business days to send electronic transactions for customers enrolled during this suspension period and, therefore, will require a temporary waiver of the following rules to the extent they require otherwise during that time period:

• Rule 4901:1-21-06(D)(1)(g) requires a CRES provider to send an electronic enrollment request to the electric utility within three business days following completion of the enrollment transaction with the customer, unless a later start date is agreed to in the contract.
• Rule 4901:1-21-06(D)(2)(c) requires the CRES provider to send an electronic enrollment request no sooner than three business days and no later than five business days after sending the customer the written contract, unless a later start date is agreed to in the contract.
• Rule 4901:1-21-06(D)(3)(d) requires a CRES provider to send an electronic enrollment request within three business days following completion of the enrollment transaction with the customer, unless a later start date is agreed to in the contract.

CRES providers will be unable to implement service commencements or contract terminations (March 20 and April 3)

From March 20 until April 3, 2024, CRES providers may not be able to adhere to exact dates previously provided for the service commencement and terminations that were previously agreed on with customers. Furthermore, if a customer initiates a termination of an automatically renewing contract, whose expiration date falls between the mentioned period this will not be processed until after April 3, 2024 when all service commencements and terminations resume.
Rule 4901:1-21-06(D)(2)(a)(vi)(d) and (e) require, as a condition of enrolling a customer, that CRES providers obtain the customer’s acceptance of, among other things, an approximate service commencement date and a contract termination date. Due to the limited capabilities during this brief period, AES Ohio requests a waiver of Rule 4901:1-21-06(D)(2)(a)(vi)(d) and (e) on behalf of CRES providers.
Moreover, Rule 4901:1-21-12(B) requires that all CRES provider contracts with residential and small commercial customers disclose, among other things, an approximate contract duration, including the estimated starting and expiration dates. Accordingly, AES Ohio, on behalf of CRES providers, also requests a temporary wavier of this rule during this period.

Case 24-0008-EL-WVR

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