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Utility Alleges PUC Staff Report Which Favors Adding Discount To 0% POR Program Used "Mismatching" Data

August 9, 2024

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Copyright 2024 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

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Enbridge Gas Ohio (EOG, and f/k/a Dominion East Ohio) alleged that PUC of Ohio Staff used "mismatching" data sets in a report from PUCO Staff listing the difference in shopping and Standard Choice Offer customer rates, which PUCO Staff cited as part of its recommendation that Enbridge Gas Ohio's 0% purchase of receivables program have a discount added to it

EnergyChoiceMatters.com was first to report in June that PUCO Staff recommended that a discount be added to EOG's POR program, which currently has no discount. Staff further recommended exploration of various other POR design changes, including capping purchased receivables at the SCO rate

As previously reported, Enbridge Gas Ohio already filed objections to the Staff POR recommendations, but Enbridge has now filed testimony in support of such objections

EOG said that, in making the POR recommendation, Staff reviewed and analyzed six months of bills for 99 customers that were disconnected for nonpayment.

EOG observed that, for the relevant year, there had been 37,605 possible customer disconnections, meaning the Staff review of 99 customers represents a sample size of .002%. Furthermore, EOG noted that all disconnections studied by Staff occurred on a single day, July 12, 2023.

"EOG has concerns that this is a very limited and narrow analysis, based on a sample size and method that does not appear to be representative, and does not include any analysis on the impact of such pricing changes on the market," EOG said

Furthermore, EOG alleged that Staff used mismatched data sets in Staff's discussion of the need for POR changes

Staff had said that, "The average SCO rate for the bill sample during the sample period was $3.38 per Mcf. The average shopping rate for the sample during the sample period was $6.84 per Mcf."

EOG alleged, "It appears that the Staff Report did not utilize the sample data but larger scale average rate data, mismatching the sets, and it is unclear what time period is used."

"EOG believes it is inappropriate to recommend such drastic conclusions that would transform the supply market based on an analysis that is incomplete and apparently statistically insignificant," EOG said

EOG considers Staff's POR recommendations to be "extreme", and further warned that the POR changes, "would likely significantly disrupt the Energy Choice program."

EOG said that adding a POR discount could lead to higher customer rates, as retail suppliers would price the discount into offers

Case 23-0897-GA-ATA

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