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Consumers' Counsel Seeks Shadow Billing Save/Loss Statement On Customer Bills, Switch Block
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In comments in a PUC of Ohio periodic review of natural gas utility customer service and billing rules, the Ohio Consumers’ Counsel has proposed presenting shopping customers with shadow billing information, and has also proposed a switch block
OCC has made similar recommendations in prior proceedings
See background on the proposed rule changes in the customary periodic rule review here
OCC said that PUCO should require that utility consolidated bills should include a shadow billing statement which, "would inform the consumer if they saved or lost money through their current retail natural gas supplier rate compared to the natural gas company’s standard service offer."
OCC proposed that the following language be required under UCB:
(a) When the SCO is lower than the retail natural gas supplier rate: "The natural gas portion of your bill using the SCO of $_____ per CCF or MCF would have been $_____ for the prior month bill, which could have saved $_____ on your natural gas supply charges. Actual savings or losses on your future bills would depend on SCO and supplier rates during that time. Compare this price with your current supplier charges listed on this bill for potential savings. Visit energychoice.ohio.gov to compare rates of all electric suppliers or contact _________ for a written explanation."
(b) When the retail natural gas supplier rate is lower than the SCO rate: "The energy portion of your bill using the SCO of $_____ per CCF or MCF would have been $_____, which could have cost you an additional $_____ on your natural gas supply charges. Actual savings or losses on your future bills would depend on SSO and supplier rates during that time. Compare this price with your current supplier charges listed on this bill for potential savings. Visit energychoice.ohio.gov to compare rates of all electric suppliers or contact for a written explanation."
Note that OCC uses the term "SCO". Presumably the utility-specific term would be used as applicable (Duke is scheduled to move from GCR to wholesale SSO, not retail SCO, next April)
OCC did not limit this recommendation to residential service, and based on where in the rules OCC proposes to add the language, the language would apply to all utility consolidated bills
OCC also proposes that the specific price-to-compare appear on utility consolidated bills (again, not limited to residential customers based on the applicable rule section)
Gas utility consolidated bills must currently contain a specific message informing customers about the nature of the GCR or SCO rate and to visit PUCO's Apples to Apples site for more information, but the message is not required to list the current GCR or SCO rate
OCC proposes that the current PTC message be modified to also include the specific GCR or SCO rate, with language stating, "The current SCO or GCR rate is $________ per CCF or MCF."
OCC also proposes that gas utilities should be required to publicly post aggregate shadow billing data comparing costs under default service and retail supply
OCC proposes rule language that, "Each year a natural gas utility shall publicly file a report with the commission through DIS [docket site] detailing the aggregated customer savings or losses experienced as a result of shopping with retail natural gas suppliers instead of choosing the SCO or GCR."
OCC's language does not specify that such aggregate data shall be broken out by customer class, though large customers may not be eligible for SCO at certain utilities and thus would not be included in any SCO comparison
OCC proposes that utilities shall provide customers with the option to sign up for a switch block mechanism
Under OCC's language, "Each gas or natural gas company will allow any customer to request a retail natural gas supplier block be placed on the customer’s account. The block will prevent the customer’s commodity service provider from being switched until such time as the customer requests that the gas supplier block be removed from the account."
By referring to the, "customer’s commodity service provider," such rule language, absent clarification, would, unintentionally, prohibit the annual switching of customers from one SCO supplier to another SCO supplier (who all must be, by rule, retail suppliers) based on the results of the annual SCO retail auction
OCC proposes that utilities be required to provide an online mechanism for customers to opt-out from inclusion on the utility customer lists shared with retail suppliers
Notably, OCC proposes that this online opt-out functionality shall be provided to customers without the requirement for the customer to establish or maintain an online account with the utility in order for the customer to use the opt-out mechanism
As first reported by EnergyChoiceMatters, PUCO Staff have, in the draft rule changes, proposed that utilities would be allowed to seek to recover from retail suppliers incremental costs associated with correcting an improper initiation of a switch
PUCO Staff proposed that such right be permissive -- that utilities "may" seek such cost recovery from retail suppliers
See full details here
OCC said that utilities should be required to seek cost recovery from retail suppliers for any incremental costs from improper initiation of a switch that is not the utility's fault, rather than giving the utilities the discretion to seek cost recovery
"The customer should (obviously) not be made to bear the costs, as the unauthorized switch is no fault of their own. Neither should the costs be passed along into rate base as an operating expense or unrecovered cost," OCC said
Expanding on a previously reported Staff proposal that utilities should ensure that customers are generally held held harmless if the utility improperly switches the customer to "regulated sales service" (note that, starting in April 2026, no choice utility will generally have regulated sales service for most customers) from retail supply, and the utility is at fault for the improper switch, OCC said that, if the utility is at fault for an improper switch, the utility should credit the customer for any early termination fee that was charged to the customer
The rules in this section only address utility billing responsibilities. The mechanics of OCC's proposal are unclear, particularly if the early termination fee is not billed through UCB. While the utility's responsibility to make the customer whole is clear, the intended proposed outcome may require that the customer submit documentation of the ETF to the utility, which OCC does not address.
Retail suppliers generally opposed Staff's proposal that utilities may seek to recover from retail suppliers incremental costs associated with correcting an improper initiation of a switch
The Retail
Energy Supply Association, among other things, said that Staff's rules do not recognize that inadvertent errors occur with regards to switches
RESA said, "Proposed Rule 4901:1-13-10(H)(3) wrongly gives the LDC full discretion
to determine it was not at fault. There is no reason to allow such latitude."
RESA said, "There is nothing
in Proposed Rule 4901:1-13-10(H)(3) that identifies or ensures fair and impartial criteria must be
followed by Staff when determining whether a customer switch was without customer
authorization. In RESA members’ experience, the Staff analysis related to slamming complaints
today varies based on the Staff member involved. That proposed rule would not ensure against
inconsistencies but would impose a greater obligation on a CRNGS supplier or governmental
aggregator in response to a Staff determination. That proposed rule also does not allow a CRNGS
supplier or governmental aggregator to contest a Staff determination but, again, would impose a
greater obligation on a CRNGS supplier or governmental aggregator in response to the Staff
determination."
In separate comments, IGS Energy said, "Ohio Adm.Code 4901:1-13-10(H)(3), as proposed, allows Staff to make a determination of slamming without providing any process to the supplier—the language does not provide for a supplier to contest the determination. The subsection also allows the natural gas company to impose incremental costs on the supplier, but is vague as to how those incremental costs will be determined and how recovery from the offending supplier will take place."
IGS Energy said that any concerns that Staff has regarding slamming, and costs associated with unauthorized switches, may be addressed by Staff in Staff investigations of suppliers alleged to have engaged in slamming, at which point Staff may seek a forfeiture from such supplier, with such forfeiture reflecting any incremental costs with which Staff's proposal is concerned
Case 25-177-EL-ORD
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October 13, 2025
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Copyright 2025 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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