Utility Seeks Waiver Of Rule It Says Would Delay Payment Of Receivables To Retail Electric Suppliers Under Change In Bill Mailing

Ohio Power Company (AEP Ohio or the 'Company'), petitioned the Public Utilities Commission of Ohio for a waiver of a rule relating to the due date of bills sent from out of state, with AEP Ohio noting that application of the rule would delay payments to retail electric suppliers

AEP Ohio sought a waiver of Rule 4901:1-10-33 (C)(13) of the Ohio Administrative Code, which states in part that "[f]or residential bills being issued from outside the state of Ohio the due date shall be no less than twenty-one days."

AEP Ohio requested that the Commission grant a waiver of the twenty-one day requirement and authorize the Company to continue its current practice to require that residential customer payment be made 15 days after the date of postmark on their bill

AEP Ohio explained that it has been printing and mailing customer bills from its Canton, Ohio office for over 20 years. AEP Ohio stated that, beginning in 2011, the US Postal Service moved its distribution center from Canton, Ohio to Cleveland, Ohio. AEP Ohio stated that, since then, bills printed and mailed in AEP Ohio’s Canton office are delayed in being picked up from that facility, taken to Cleveland, sorted, and then mailed to customers. This has added an extra day of mail lag between when the Company prints bills and customers receive them, AEP Ohio said

"Because of this USPS change, and as part of AEP Ohio’s continued efforts to find ways to reduce costs to Ohio customers, the Company has decided to move the bill print and mailing functions to a third party located in Indianapolis, Indiana. The bill print and mailing efforts from Indianapolis will result in customers receiving their bills 1 day earlier than is the case today," AEP Ohio said

AEP Ohio said that, under the Company’s proposed new process, customers will actually receive their bills one day sooner after issuance once the bill print and mail functions are moved to third-party business partners. "Since customers will receive their bills one day sooner than they do today, there is no need to extend the bill due date," AEP Ohio said

AEP Ohio also noted that it not only bills for its delivery and SSO services, "but in many cases it also bills for Competitive Retail Electric Service (CRES) provider supply services."

"Delaying the due date for AEP Ohio receivables will also delay the payment of CRES Providers receivables for which AEP Ohio provides consolidated billing," AEP Ohio said

AEP Ohio also said that changing the due date to 21 days, "will confuse customers that are in a 'disconnect for non-pay' situation."

"With a delayed payment date, it is more likely that a customer will receive a disconnect notice telling them the amount to pay to avoid disconnection, then they will receive a second bill that will become due and payable before the disconnect date. This will increase the amount that a customer must pay to avoid disconnection to equal two or more months of bills, which may confuse and frustrate customers, increasing the likelihood that customers will have their electric service disconnected," AEP Ohio said

Case No. 19-1389-EL-WVR