Contrary To Mechanism Envisioned By PUC, Utility Would Not Allow Retail Suppliers To Reject Seamless Moves Requested By Customer

Several Ohio electric utilities have filed compliance plans to implement seamless moves

PUCO had previously directed utilities to file the compliance plans to implement seamless moves (see background here)

As previously reported, in Ohio, PUCO described seamless move as: "Seamless move allows a customer to transfer an existing CRES contract to a new address, if the customer and CRES provider both consent to the transfer of the contract. The customer would receive generation service from the CRES provider on the first day of service at the new address."

Unlike contract portability, in Ohio, a seamless move requires that the customer affirmatively choose that opportunity when calling the EDU to transfer service

During a retail market investigation, PUCO Staff characterized seamless moves as a mechanism only available to residential customers. PUCO orders, however, apparently do not include any specific description concerning applicability, and, as noted above, refer to only "a customer"

Duke Energy Ohio filed a compliance plan which notes its pending application for a new customer care system (see story here)

Duke said that seamless moves, under the terms included in its implementation plan, can potentially be accommodated in its new customer care system (Customer Connect).

As previously reported in connection with the new customer care system, the seamless move capability would be available in the fall of 2022, assuming approval of the existing proposal with minimal exceptions. "Thus, Duke Energy Ohio proposes to incorporate and implement the seamless move function along with its proposed new CIS system," Duke said

"However, if the Commission were to require that the Company provide an interim proposal, it is anticipated that implementation of the plan as a stand-alone function, absent inclusion in Customer Connect, will incur costs of approximately $850,000 to $1 MM," Duke said

"Further, implementing seamless move on an interim basis is still expected to take between 12 and 18 months to complete. Assuming a start date of January 2020, Seamless Move could be implemented in early to mid-2021. The new CIS is expected to be put into operation in the third quarter of 2022," Duke said

"The difference between moving forward on an interim plan and otherwise delaying a short time to allow for the seamless move function to be provided with the new CIS is a significant cost, and certainly not the best option for customers. Duke Energy Ohio does not believe it prudent to expend close to $1M dollars in order to enable seamless move more quickly. Accordingly, the Company's proposes herein to make seamless move available with the CIS system coming online in 2022," Duke said

With regards to the specific terms of Duke's proposed implementation plan, one provision provides that the new location under a seamless move must be an "active premise" within Duke's service territory. As noted above, PUCO defines the seamless move mechanism as a process under which, "The customer would receive generation service from the CRES provider on the first day of service at the new address."

Duke's plan also provides that a supplier may reject a seamless move requested by the customer, as contemplated by PUCO's order. During the process, a Duke CSR, "will tell the customer that their current supplier will be notified of their request and that the supplier will respond either accepting or rejecting their request," Duke said

Duke's plan lists seamless move "availability" as, "[a]ll residential customers."

Addressing an issue separate from seamless moves, Duke also notes in the plan that, "This work will also include changes so that businesses that change their name, while keeping the same tax ID, will not result in a drop of their electric supplier contract."

Separately, Dayton Power and Light filed an operational plan, "that will lead to the implementation of a Seamless Move process as part of a future Customer Information System ('CIS') upgrade, to the extent the Company has the ability to perform such an upgrade."

DP&L said, "Due to current regulatory uncertainty, however, the Company is unable to commit to specific timeframe [sic] for implementing seamless moves due to restrictions on cashflow for investments that have limited benefits for all of DP&L’s customers."

DP&L said, "DP&L requested to implement a CIS as part of its Distribution Modernization Plan filed in Case No. 18-1875-EL-GRD. DP&L intended to include seamless move functionality as part of the CIS. Implementing a seamless move process at this time within the Company’s current system would then require the additional implementation of a seamless move process within the new CIS. It is not an efficient use of now limited funds and resources to implement functionality of which only a small percentage of DP&L’s customers (e.g. approximately 3.5%) may be eligible to benefit. Further, having to undertake multiple implementations of the same seamless move functionality is also burdensome on DP&L’s IT resources and likely results in excessive IT labor costs."

"Most importantly, given DP&L’s distressed financial situation, DP&L is focused on doing what is necessary to maintain safe and reliable service. Implementing a seamless move process is unnecessary to provide safe and reliable service and is therefore not in the best interests of the Company or its customers at this time. Under these circumstances, the future of grid modernization, including the CIS, is in jeopardy," DP&L said

"Pursuant to the Second Entry on Rehearing dated March 13, 2019, and the findings in Case Nos. 14-2074-EL-EDI, et al., DP&L respectfully submits a prospective operational plan for implementation of seamless move functionality at a future date upon further financial certainty for DP&L," DP&L said

Unlike at Duke, DP&L's implementation plan provides that a supplier cannot reject the Seamless Move once the customer affirmatively chooses to move their contract to the new address.

This, "enhances the customer focused experience," DP&L said

If the supplier needs to drop the customer after relocation, a drop can be sent under normal timelines (meaning at least one month being served by supplier before drop will become effective), DP&L said

Eligible customers for seamless moves at DP&L would be residential customers only

As previously reported, PUCO ordered that the customer shall be granted a rescission period for seamless moves

DP&L's Seamless Move Future Operational Plan includes the following language concerning such rescission period

Confirmation Letter/Rescission Period

• Provide letter that gives the customer the right to rescind enrollment at new premise

• Send letter to mailing address of old account (should be updated during relocation call)

• Rescission period is 7 days

• Billing will be held until expiration of rescission window

• After expiration of the rescission window, all subsequent enrollments and drops will be conducted pursuant to normal switching rules

Case No. 19-2144-EL-UNC, 19-2151-EL-EDI