Consumers Energy Seeks Changes to Retail Open Access Tariff in Rate Case

Consumers Energy Company has filed an electric rate case at the Michigan PSC which includes several proposed changes to the retail open access (ROA) tariff (Case No. U-17087).

Among other things, Consumers Energy is seeking to modify the tariff governing the return of an ROA customer to default service to require greater advance notice.

The current tariff exposes returning Retail Open Access customers to market-based prices for the months of June, July, August, and September if they fail to provide written notice of such return prior to December 1st of the preceding calendar year.

Consumers noted that for service beginning on June 1, 2013, the Midwest ISO will implement a new resource adequacy process that will require the company to forecast, on approximately November 1 of the prior year, the amount of demand it expects to serve during the 12-month period beginning June 1st of each year.

"As a result, notice on or before December 1st will be too late for the Company to include the returning customer's demand into its capacity forecast," Consumers said.

Consumers proposed to modify the return to service notice provision such that notice must be provided by October 1st of the calendar year preceding each June, July, August, and September period in order to avoid market-based rates.

Additionally, Consumers is proposing that if it is unable to access meter data electronically for two or more consecutive months through the customer-provided telephone line or other communication links that allow access to the meter data by the company, Consumers will retrieve the metered consumption data manually and assess a charge of $45 each month it is necessary for the company to obtain the meter data manually.

"The $45 is the same monthly fee that was previously approved by the Commission under the hardship exception, where installation of both land-line and cellular telephone service is impractical," Consumers said.

Consumers is also proposing that Load Profiling be made available only to customers served at the company's Secondary Service who do not have a meter capable of recording or providing interval readings for billing.

Consumers reported that actual calendar year 2011 retail open access sales were 3,900.6 GWh. "The Company's forecast reflects an expectation that the ROA cap will continue to be filled with existing customer choice enrollments. Approximately 792 MW of noncoincident customer load is currently active, and is expected to continue at a similar level through the test year period. The annual energy sales of active ROA load are expected to be 3,934.6 GWH."

Consumers has proposed rolling-in the power supply cost recovery (PSCR) Factor into the base Power Supply. "The Company projects an increase during the test year in the PSCR Factor. In order to reflect the proper cost allocation of the PCSR costs to each rate class, the Company proposes to roll-in the test-year Factor revenues into base Power Supply tariff revenues. This will ensure that each customer class pays their appropriate share of Power Supply costs. It also ensures the Company proper recovery of all Power Supply costs associated with Rate E-1 discounts, which are not reconciled in the annual PSCR reconciliation," Consumers said.

Consumers is also proposing a symmetrical Revenue Adjustment Mechanism that compares the nonfuel rate revenues approved by the Commission in the most recent proceeding to the nonfuel revenue generated through actual sales for the period of time under evaluation. This comparison will be performed by rate class.

"The Company proposes to compare actual total delivery revenues (less customer charges) to the approved rate case delivery revenues (less customer charges), which would apply to all customers, and to compare actual nonfuel power supply revenues to the approved power supply revenues, which would apply only to Full Service customers. The difference in revenues would be deferred on the Company's books, pending an annual reconciliation process. The Company proposes that the revenues be reconciled on an annual basis, beginning with the end of test-year period in this case. If the Company collects more total delivery or total nonfuel power supply revenue during the 12-month period than was authorized by the Commission in this electric rate case, then following Commission review and approval, the Company would refund the amount of the over-collection to its customers on a prospective basis. Over-collected delivery revenues would be refunded to all customers, while the amount of over-collected nonfuel power supply revenues would be refunded to Full Service customers. If the Company did not collect its level of authorized delivery or nonfuel power supply revenues, then following Commission review and approval, the Company would collect the shortfall with approval of the Commission on a prospective basis," Consumers said.