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Utilities Express Concern With Proposed Rules To Implement Enroll By Wallet
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Ohio utilities have raised concerns with certain provisions of draft rules to implement several retail market provisions of HB 15, including a form of enroll-by-wallet
As previously reported, HB 15 provides that, "A customer who consents to a change of supplier shall not be required to provide customer account information to the supplier if the customer provides a valid form of government-issued identification issued to the customer or a sufficient alternative form of identification that allows the supplier to establish the customer's identity accurately."
See more background on HB 15 here
As previously reported, PUCO has issued proposed rules to implement this enroll-by-wallet provision
See details on the draft rules here
Although not specifically outlined by PUCO in its proposed rules, the implementation of HB 15's enroll by wallet appears to be as follows. A customer may present a "valid form of government-issued identification" to the retail supplier. The supplier may then obtain the customer's account number, which appears to still be required for enrollment, from the utility's eligible customer list, which PUCO proposes be modified such that the lists now include the customer's account number
This process would maintain the current enrollment mechanisms which are based on account number, while not requiring that the customer provide their account number, which will instead be sourced from the ECL
However, several stakeholders expressed concern or sought clarification on the process
AEP Ohio said, "The Company assigns an account number to each customer that reflects the usage and
billing data at a specific address. The Company also assigns a Service Delivery Identifier (SDI) to
each premise. The customer account number will change if the customer closes and re-opens an
account at the same address or if they move to a new address and start service. However, the SDI
number does not move, it remains at the same premise permanently. The SDI number is key for
CRES providers to enroll customers in the Company’s customer information system, and as
mentioned previously, is different from the customer’s AEP Ohio account number. Currently,
when a customer chooses a certain CRES provider, the Company requires the CRES provider to
obtain the SDI number directly from the customer, which provides at least adequate assurance that
the CRES provider has communicated directly with the customer prior to enrollment."
AEP Ohio said, "The proposed changes to Ohio Administrative Code (Ohio Adm. Code) 4901:1-10-01(J),
4901:1-10-24(E)(4) and 4901:1-21-06(D) regarding the provision of customer account
information jeopardizes this consumer protection and directly provides these unique numbers to
the market. The Company recommends the Commission update the Ohio Adm. Code to allow
electric utilities to provide a redacted version of either the customer account number or the SDI.
For example, showing the last 3 to 4 digits of the account number or SDI, so then CRES can verify
those digits with the customer prior to enrollment. The Company believes this would provide the
information required by the Revised Code, but also provide this important customer protection."
In separately filed comments, Duke Energy Ohio sought that PUCO confirm, under the new rules, that
suppliers will have to submit customer account information to the utility to enroll a customer (with info obtained through the ECL), and
that the utility will not be required to modify its processes to accept other inputs for enrollment
purposes (e.g. customer name, address, etc).
In separately filed comments, Santanna Energy Services also sought confirmation of whether utility account numbers remain required for enrollment under the proposed rules
Retail suppliers also said that an existing part of the telephonic enrollment rules, which is not proposed to be modified, is in conflict with HB15's provision that the customer shall not be required to provide customer account information to the supplier for enrollment
Specifically, the draft maintains language that 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 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
The Retail Energy Supply Association said that HB15, "clearly establish[es] that it is not required for
a supplier to ask for or the customer to provide the customer’s account number or account
information during the enrollment process for any of the types of enrollment process."
In another matter, RESA and Santanna, in separately filed comments, both sought inclusion in the rule of the specific forms of government-issued ID that will be allowed for enrollment, with RESA also suggesting specific alternatives as permitted by HB 15
RESA said that the rules should specify that "government-issued identification" includes, but is not limited to,
valid forms of the following: driver’s license, state-issued identification
card, passport, military identification, green card, employment
authorization document, and the last four digits of the customer’s social
security number.
RESA said that "sufficient alternative" forms of identification permitted under the rule should include, but not be
limited to, the following: the customer’s telephone number assigned to the
utility account number and the amount of the customer’s last three utility
bills.
Financial Assurance
As previously reported, 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."
As previously reported by ECM, 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
Retail suppliers objected to these draft provisions which did not specifically enumerate what may be "reasonable".
RESA said that to ensure transparency and to ensure against disparity, inconsistency
or discriminatory terms, the
rules should require the utility supplier tariffs to include:
• A uniform formula for calculating the financial assurance amounts;
• A nondiscriminatory framework for requiring financial assurance (such
as timing and adjustments based on risk); and
• An ability for a supplier to seek additional information from the utility
regarding the calculation of financial assurance and a requirement that
the utility will respond within a reasonable period of time.
RESA further said that the electric rules should allow suppliers to seek PUCO Staff mediation of any disputes concerning financial assurance (which is currently available in the gas rules), and that suppliers should be able to file complaints at PUCO concerning a utility's application of the financial assurance standards
In separate comments, Santanna likewise said that utility financial assurance requirements should be, "consistent, fair, and follow a known timeline[.]"
Santanna alleged, "Currently, some utilities have sporadic margin calls
and margin reviews, with varying standards, which can place substantial financial stress
and uncertainty on a supplier. Additional transparency and setting-of-financial-expectations around this process for all utilities would help suppliers better plan their
own finances, including the production of financial securities/assurances."
"Suppliers
also need a more proactive approach from all utilities for returning excess collateral to
suppliers in a timely fashion in periods when suppliers are overcollateralized with their
utilities," Santanna said
"In sum, Suppliers needs a transparent, consistent, known, and reasonable
threshold for financial assurance requirements. Suppliers also need a reliable schedule
for margin reviews with at least two scheduled reviews that would fairly account for
varying seasonal demands," Santanna said
Additional Consumer Protections
The Ohio Consumers’ Counsel sought several additional consumer protections in the rule, including:
• Requiring that a switch / rescission notice additionally be sent to a customer's email address, in addition to the current mailed notice
• Requiring additional avenues for notice of the ability of customers to opt-out of customer lists. OCC says that this opt-out notice should be included on all monthly electric and gas bills, "prominently" displayed on the first page. This information should also be available on the home page of the utilities’ website, OCC says
• Requiring that utilities send customer privacy notices twice a year rather than annually, including details on how a consumer can opt-out of having personal information shared
Other Matters
RESA expressed concern that revised language requiring that utilities receive written customer consent prior to any sharing of customer account information, apart from a specific list of exceptions, is overly broad and could interfere with routine market processes and supplier-utility interactions
RESA said, "The utilities ... regularly and on a daily basis include customer account information
in their interactions with suppliers, including in their EDI transactions, supplier portals, and the
like. RESA is concerned that Staff-Proposed Rules 4901:1-10-24(D)(1) and 4901:1-13-12(C)(1)
will unduly restrict and/or prevent these necessary and daily interactions and, thus, harm the
competitive market."
RESA said, "The Commission should, therefore, either add clarifications or revise Staff-Proposed Rules
4901:1-10-24(D)(1) and Rule 4901:1-13-12(C)(1) to ensure that the utilities and suppliers can
disclose and utilize customer account information in their interactions with each other."
Case 25-729-GE-ORD, 25-0729-GE-ORD
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Retail Suppliers Oppose Language That Broadly Implements New Financial Assurance Standard Which Utilities May Impose On Suppliers, Seek Identification Of "Reasonable"
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November 26, 2025
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Copyright 2025 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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