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Utility Proposes To Hold Retail Suppliers In Default For Continued "Inappropriate Language" On Bill Ready Bills
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As part of a rate case, AEP Ohio is seeking several tariff changes related to competitive retail electric service providers (CRES)
Among other things, AEP Ohio proposes to increase the annual CRES registration renewal fee to $128 from the current $100
For initial CRES registrations, AEP Ohio proposes to increase the initial CRES registration fee to $356 from the current $100
Additionally, AEP Ohio proposes to add a condition under the CRES default provisions of the tariff
Specifically, AEP Ohio proposes that a CRES provider shall be deemed in default of its obligations under the utility's Customer Choice Program if, among other things, "The CRES fails to take suitable and timely action to stop inappropriate language
showing on consolidated bill ready bills."
AEP Ohio said that this change is meant, "to ensure customer bills are kept professional."
Under the existing provisions, a CRES provider deemed in default may be suspended or terminated from the choice program, subject to PUCO review
Notably, with regard to tariff changes, while AEP Ohio has in a separate petition proposed to "immediately" end the supplier consolidated billing pilot, AEP Ohio does not, in the proposed rate case tariff, strike language providing that, "A CRES Provider or its BA [billing agent] may perform supplier consolidated billing pursuant to the terms and
conditions established by the Public Utilities Commission of Ohio in Case Nos. 16-1852-EL-SSO et al."
AEP Ohio proposes to eliminate the bypassable Retail Reconciliation Rider and nonbpyassable SSO Credit Rider, which were designed as a proxy to allow further costs to effectively be unbundled from base rates (with only SSO customers paying the Retail Reconciliation Rider and all amounts which are collected then returned to all distribution customers under the SSO Credit Rider). These riders have each been set by PUCO at $0 since the time that they were created, serving only as placeholders
AEP Ohio also reported in the rate case that it has extended the planning phase for a new CIS whose development was part of the utility's most recent electric security plan proceeding (ESP V)
Implementing the new CIS will take longer than originally estimated
"Since the ESP V proceeding, AEP has made significant efforts to study and plan for the CIS replacement project, recognizing that it is a multi-year endeavor that requires extensive planning and testing to mitigate risks," AEP Ohio said
"AEP has researched CIS rollouts from other companies, learning from both their successes and challenges, particularly noting issues faced by other large, multi-jurisdictional utilities. To avoid similar problems, AEP Ohio extended the planning phase of the CIS rollout," AEP Ohio said
"During this phase, AEP Ohio is focused on improving the quality of its customer data, which is challenging due to the outdated legacy system. The team is also mapping out all business processes that the new CIS will employ. This 'data first' approach aims to establish a strong foundation for the new system. AEP has learned that poor data quality and tracking can lead to failures, even with a robust CIS, especially when dealing with a legacy system that has evolved over three decades. Therefore, AEP is prioritizing data cleanup and process mapping, taking special care with this process before moving to the next phase."
"Based on this more intentional approach, AEP now estimates that the CIS project will take longer than originally estimated," AEP Ohio said
"AEP’s careful and methodical approach to the new CIS is designed to optimize the likelihood of a seamless transition that ultimately benefits customers. By investing time in extensive planning and research, AEP is working to minimize risks associated with the rollout, such as billing errors and unbilled revenue, which could directly affect customer experiences," AEP Ohio said
AEP Ohio said, "AEP Ohio is fully committed to ensuring that the new CIS will incorporate all the functionalities outlined in the ESP V stipulation."
One provision of the ESP V stipulation had stated, "As part of its next base distribution rate case, AEP
Ohio will evaluate the costs, if any, and propose a tariff charge for each method (manual
and EDI) as applicable for CRES providers and third parties that request 15-minute data."
AEP Ohio said that, "This commitment is not applicable [at this time] as the CIS system has not been placed in service at the
time of this filing."
Cases 25-393-EL-ATA, 25-392-EL-AIR, 25-394-EL-AAM, Ohio Power
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Seeks Increase In Retail Supplier Registration Renewal Fee
Implementing Utility's New CIS, With Greater Retail Supplier Functionality, Will Take Longer Than Originally Estimated
June 16, 2025
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Copyright 2025 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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