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PUC Issues Proposed Rules To Implement New Retail Supplier Financial Requirements; Enroll By Wallet
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The PUC of Ohio has issued proposed changes to its retail electricity and retail natural gas rules to implement several recent requirements of HB 15, concerning the posting of financial security by retail suppliers, and the adoption of enroll-by-wallet
See background here
Specifically, HB 15 provides that PUCO, "shall establish rules to require an electric services company to maintain financial assurances sufficient to protect customers and electric distribution utilities from default."
"Such rules also shall specifically allow an electric distribution utility to set reasonable standards for its security and the security of its customers through financial requirements set in its tariffs," HB 15 provides
Similar statutory language was adopted for natural gas suppliers
Both statute and PUCO's proposed rules exclude brokers and aggregators from the financial assurance requirements
In proposing to implement the new law, PUCO's draft tracks the "reasonable standards" statutory language, and does not propose specific or prescriptive minimums, or limits, for the financial assurance required from retail suppliers
For the electric rules, PUCO proposes that, "In its supplier tariff, each electric utility shall set reasonable standards for its security and the
security of its customers through financial requirements for CRES [competitive retail electric service] providers sufficient to
protect customers and the electric utility from default. For purposes of this paragraph, 'CRES
providers' excludes power brokers or aggregators."
The electric draft rules further state that retail suppliers shall, "maintain financial
assurance sufficient to protect customers and the electric utility from default."
The draft natural gas rule language for financial assurance is not substantively different
However, the gas draft rules maintain (with a slight revision to reflect HB 15) a current rule that provides that a retail natural gas supplier may bring an action before PUCO seeking review of the
natural gas utility's determination of financial assurance
There is no specific similar provision allowing the challenging of utility-set security for retail electric suppliers
Enroll By Wallet
As previously reported, HB 15 permits a form of enroll-by-wallet for both electricity and gas
To implement this mechanism, the draft rules provide that, for electricity, a CRES provider must verify a customer's identity at the time of enrollment.
"CRES providers
must maintain proof of verificication [sic] of the customer's identity," the draft states
The draft rules do not state a time limit for such maintenance of proof of verification
The draft rules provide that the following forms of
identification may be used to verify a customer's identity:
(1) "Customer account information," as that term is defined in division (A) of section
4928.103 of the Revised Code; [4928.103 provides that "customer account information" means a unique electric distribution utility number or other customer identification number used by the utility to identify a customer and the customer's account record]
(2) A valid form of government-issued identification issued to the customer; or
(3) A sufficient alternative form of identification that allows the CRES provider to establish
the customer's identity accurately.
The draft gas rules to implement enroll-by-wallet are not substantively different than the above-described electric rules
Notably, the rule language for verification of certain electric enrollments is proposed to be revised slightly due to the use of the term "customer account information" rather than "account number"
For example, a telephonic electric enrollment (and any enrollment which must comply with the same verification required under telephonic enrollment) must include, "[i]f applicable, a verbal request for and the customer's account information, as
defined in division (A) of section 4928.103 of the Revised Code." [e.g. the utility account number or similar number as noted in the definition under 4928.103 quoted above]
As previously reported, PUCO Staff interprets the existing language under this rule as requiring that the customer must verbally answer by providing (reciting) their account number during the verification. The reading by the verifier of the customer's account number back to the customer for a Yes/No answer does not comply with existing rule, PUCO Staff has said
However, the existing language explicitly uses the term "customer's provision" as noted below.
While, as quoted above, the draft still requires, "a verbal request for and the customer's account information", suggesting that the same requirement that the customer must provide the account information applies, it is notable that the phrase "customer's provision" is ostensibly being deleted under the draft electric rule, especially when the phrase "customer's provision" is being maintained in the gas rule as noted below (it is possible that the draft's redline reflects a scrivener's error in marking struck language)
The current electric rule reads:
"If applicable, a verbal request for and the customer's provision
of the customer's electric utility account number."
The draft electric rule change reads:
"If applicable, a verbal request for and the customer's account information, as
defined in division (A) of section 4928.103 of the Revised Code."
In contrast, for gas telephonic enrollments, the term "account number" is still used, as is the phrase "customer's provision"
Specifically, under the draft rules, a gas telephonic enrollment shall include, "If applicable, a verbal request for and the customer's provision of the customer's
natural gas company's account number."
The draft rules also update certain provisions related to eligible customer lists
For electricity, the draft revisions provide that electric utilities shall make eligible-customer lists available to certified
CRES providers via electronic media
The electric customer lists
shall be updated quarterly and shall, at a minimum, contain customer name, customer account information, service
and mailing addresses, load profile reference category, meter read date or schedule, and
historical consumption data for each of the most recent twelve months, the draft provides. All information
provided on the eligible-customer lists will be identified in the company tariff and approved
by the commission.
The gas eligible-customer list rule maintains the existing elements required for the lists, but also adds "customer account
information" as an element to be included
Case 25-729-GE-ORD
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November 5, 2025
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Copyright 2025 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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