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PUC Issues Order In Rate Case In Which PUC Staff Had Proposed New POR Discount Mechanism, Or Other Cost Assignment To Retail Suppliers
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The Public Utilities Commission of Ohio has issued an order in the rate case of Enbridge Gas Ohio (East Ohio Gas, or EOG, and f/k/a Dominion East Ohio) in which PUCO Staff had originally, "recommend[ed] a discount rate be applied to competitive suppliers to offset," uncollectible and other costs of EOG's purchase of receivables (POR) program.
The EOG POR program has not had any discount for approximately 20 years
See background on Staff's recommendation here
Staff had specifically stated in Staff's initial report on the rate case that: "Staff recommends that competitive suppliers contribute to their collection costs and/or limit the cost to
ratepayers. Staff recommends a discount rate be applied to competitive suppliers to offset these costs.
Staff recommends that the Company explore other options such as limiting the purchase of receivables
to the SCO rate to protect ratepayers. Staff recommends that the Company examine the continued need
for a purchase of receivable program as the Company exits the retail merchant function."
During the proceeding, Staff later said that Staff was not specifically proposing a POR discount rate, but that, "competitive suppliers contribute to the
costs," of POR (listing various potential mechanisms for cost recovery), with Staff also later stating that Staff recommends that POR be addressed in a separate proceeding, and not the rate case. However, parties still briefed Staff's proposal regarding POR -- that a separate proceeding be opened to examine POR -- and it does not appear that Staff withdrew its proposal for such a review of POR
PUCO did not specifically or substantively address the POR issue in its rate case order.
PUCO did adopt Staff's "recommendations regarding service quality," but in summarizing such adopted Staff service quality recommendations, PUCO did not specifically cite POR. PUCO's order referenced certain pages of Staff exhibits in illustrating such service quality recommendations [note that "service quality" was not a heading used in Staff's pre-filed report, with Staff instead including a section on "service monitoring and enforcement"]. Due to the potential for hearing-marked exhibits to differ from the pre-filed Staff report and testimony, it is not precisely clear whether Staff's POR recommendations were included in such pages that were cited in PUCO's order. Moreover, it was not specifically clear if PUCO's adoption of Staff's "service quality" recommendations were limited to those recommendations narratively cited (albeit briefly) in PUCO's order, or whether all such Staff recommendations regarding "service quality" on the cited exhibit pages were adopted
If the exhibit pagination is the same as Staff's pre-filed report, the pages cited in PUCO's order do include a page with a POR recommendation from Staff (with such page from the report also not addressing any of the other topics cited in PUCO's discussion in the order regarding service quality recommendations). Specifically, under this proviso regarding pagination, the cited page would include Staff's original recommendation which was as follows: "Staff
recommends that the Company incorporate a discount rate or explore other avenues for the purchase of
competitive retail natural gas (CRNG) services to offset the percentage of CRNG debt written off and
recovered in the Uncollectible Expense Rider." ECM further notes that this page of the Staff report, under the pagination proviso described above, is not part of Staff's "service monitoring and enforcement" section, but rather is in a section titled as "Riders".
Additionally, under the pagination assumption discussed above, PUCO's order does not cite the pages of the Staff report which contained the bulk of Staff's POR recommendations.
PUCO stated, "We further find that the Staff recommendations regarding service quality should be adopted. The record in this case fully supports the recommendations provided by Staff in the Staff Report."
PUCO also generally stated in the order that, "The Commission has attempted to address all objections raised on brief, but any objection which was not explicitly identified on brief or addressed by the Commission in this Opinion and Order should be deemed withdrawn."
PUCO did generally adopt Staff's recommendations that EOG should more timely disconnect customers to reduce large accrued customer balances. While retail suppliers have emphasized collection issues, due to untimely disconnections, as the primary driver for uncollectibles, Staff has argued that the above-described examination of POR costs should continue even as collections improve.
PUCO did specifically adopt Staff's recommendation that EOG shall annually notify all GTS, DTS and LVTGS [sic, LVECTS] transportation customers with usage at or below 3,000 Mcf (the cutoff for general sales service or, for energy choice, non-large energy choice transportation service) of alternative tariff schedules that enable the customer to obtain more economical utility service conforming to the customer’s stated needs.
If the customer's usage decreases to 500 mcf annually, this will result in Enbridge informing relevant customers of the availability of the Standard Choice Offer, which is not available to customers over 500 Mcf annual usage.
PUCO adopted Staff's recommendation that EOG shall be responsible for informing customers of this option, and that EOG should generally educate customers about available rates and choice. PUCO did not order that customer education issues be delegated to EOG's existing Customer Education Collaborative as suggested by retail suppliers
With regards to other retail market issues, PUCO adopted the recommendation of retail suppliers to add a seasonal reallocation to EOG’s capacity release program. Doing so adds a second allocation each year, since there is already an annual reallocation.
Moving from one to two reallocations per year will, "provide significant financial and operational benefits to suppliers," and a better matching of capacity with the customers served, EOG had said in supporting the proposal
As summarized by PUCO, "RESA and IGS note their understanding that the proposal is based on September 30th customer counts and assigned on a pro-rata basis related to each supplier’s count as of September 30th, such that the assigned capacity will be adjusted to account for individual customer load factors and ensure that the allocation reflects the respective demand profiles of each supplier’s customer base."
The Transportation Surcredit Rider (TSR) will also be maintained under PUCO's order. EOG had initially proposed to end the TSR, but later supported the continuation of the mechanism
The TSR provides a credit to shopping customers for the portion of the Commission and OCC assessment costs attributable to EOG’s commodity sales service but which are collected by the utility through base distribution rates.
Case 23-897-GA-ATA et al.
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June 26, 2025
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Reporting by Paul Ring • ring@energychoicematters.com
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