AEP Ohio Seeking to Institute Charge for Consolidated Billing, Suppliers Protest Additional Changes to Tariff

Retail suppliers have protested numerous changes sought by AEP Ohio to its supplier coordination tariff, governing the utility's interaction with competitive suppliers.

Most notably, AEP Ohio has filed to institute a charge for utility consolidated billing. A specific charge is not included in the tariff; rather, the AEP Ohio proposed tariff states, "The cost to provide consolidated billing services by the Company to the CRES Provider will be no more than half of the total cost of the bill print, insert, and postage incurred and included as part of the executed agreement."

"AEP Ohio has been providing utility consolidated billing for years and has never before sought any recovery of costs from CRES providers. AEP Ohio has offered no reason whatsoever to begin recovering these costs from CRES providers now," FirstEnergy Solutions said in a protest.

"Utility consolidated billing fees are burdensome for many suppliers and therefore inhibit retail competition for residential customers. In addition, AEP Ohio already charges its customers for billing service in its distribution rates. If AEP Ohio is permitted to impose additional charges on CRES providers for utility consolidated billing, shopping customers will be charged twice for AEP Ohio’s bills. Moreover, AEP Ohio has shown no increase in its costs for billing that exceeds what it already recovers in its distribution rates," FES said.

"[N]either the proposed Section 17 nor the proposed Section 23 identifies the specific costs AEP Ohio wishes to recover from CRES providers, nor any formula for calculating these costs and the resulting charge to CRES providers. The Commission should require AEP Ohio to provide detailed information on the specific costs it wishes to recover, the formula for how this revenue requirement would translate into a CRES charge, and the resulting rate that CRES providers will have to pay. Further, the Commission should require AEP Ohio to provide this information in its Tariff, and not merely in the CRES Provider Agreement," FES said.

FES noted that AEP Ohio also proposes to "unilaterally" terminate consolidated and rate-ready billing or consolidated and bill-ready billing upon 30 days’ notice, a provision which drew criticism from numerous suppliers

"AEP Ohio cannot just unilaterally and arbitrarily eliminate these options that benefit customers and are required by the Commission’s rules. See OAC 4901:1-10-29(G) and 4901:1-10-33. Such short notice also places an unwarranted and significant burden on CRES providers to dual bill customers. Accordingly, these provisions which would give AEP Ohio the ability to terminate consolidated billing should be eliminated," FES said.

FES and other suppliers also protested what they called unreasonable security requirements for retail suppliers included in the tariff.

A solution suggested by several suppliers to some of the onerous credit requirements would be for AEP Ohio to have PJM collect FRR capacity charges weekly (as done at Duke Energy Ohio), rather than monthly.

The Retail Energy Supply Association also objected to certain aspects of an FRR capacity contract AEP Ohio is requiring retail suppliers to sign. RESA noted that the contract omits any reference to Ohio Commission oversight and refers to federal authorities.

"Further, once in court, the proposed capacity agreement provides OPC [AEP Ohio] with a cognovits note which would permit OPC to obtain a judgment against the CRES Provider without the CRES Provider being present," RESA said.

RESA agreed that a contract may be appropriate, as AEP Ohio may need additional documentation as to privity of contract between the CRES Provider and AEP Ohio for AEP Ohio to enforce collections from non-capacity paying CRES Providers, but said that the objectionable provisions should be removed.

Suppliers also said that the tariff does not comply with prior PUCO orders to reduce the switching fee to $5 and eliminate the minimum stay period next year.

Case No. 13-729-EL-ATA