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RESA Supports Utility’s Limited AMI Waiver Request Based On Delivering Benefits To Customers While Advancing Competitive Energy Marketplace
Excerpts from RESA comments to Duke AMI waiver request:
{***} “This case presents an opportunity to maximize Duke’s AMI capabilities, delivering benefits to customers, individually and collectively, while advancing Ohio’s competitive energy marketplace. As discussed in more detail below, the Retail Energy Supply Association (“RESA”) requests that the Public Utilities Commission of Ohio (“Commission”) extend the waiver of Rule 4901:1-10-24(D)(3), O.A.C., to allow efficient access to residential customer interval data, consistent with the Commission’s recent order addressing FirstEnergy’s smart grid proceedings (the outcome of the FirstEnergy Grid Mod case is also the outcome pending recommendation in the Stipulation in DP&L’s Smart Grid case). Allowing for efficient access to Duke’s residential customer interval data by their own CRES provider will advance competitive supply offerings, provide enhanced market data that reduces market participant estimation error resulting in system wide savings for all customers, will promote consistency across the state, and is consistent with State energy policy.” {***}
{***} “While Duke’s Power Future Initiatives are a solid first step, the current process for residential customer interval data access lacks the efficiency encouraged by statute that is needed for full utilization of the data. More specifically, the current default process specified by administrative rules and orders is a residential customer-by-customer process. The default process is not the type of efficient access specified in statute, as it would take years to complete the customer-by-customer process for more than half a million residential customers in Duke’s service area. The default process would also require significant ongoing resources to manage an individual-by-individual process for the hundreds of thousands of residential customers in the Duke service area.
However, the Commission has recently recognized the benefits of streamlining the default process by granting a waiver to allow a CRES provider to not only have access to its residential customer monthly energy usage but also access to the hourly interval data.8 The Commission recognized that a streamlined process where a CRES provider has access to the interval data for all of its customers provides numerous benefits. In reaching that determination, the Commission cited to the testimony of Joint RESA/IGS witness Dierksheide who testified that streamlined access to residential hourly interval data (1) helps CRES providers develop and bill customers real-time pricing products, (2) facilitates the development of additional products and services based on actual energy usage instead of a load profile, (3) assists with settling loads with PJM including verifying the accuracy of bills, (4) assists in the expansion of residential customer participation in PJM demand response markets, and (5) reduces market estimation error that can reduce system wide costs, for example, by reducing uplift charges and reducing differences in forecasts between day-ahead and real-time energy needs.9 These same benefits could also materialize in the Duke service territory with efficient access to residential customer interval data.
To facilitate efficient access to residential customer interval data, the Commission should, in this proceeding, grant a waiver of Rule 4901:1-10-24(D)(3), O.A.C. Good cause exists for the waiver, as described in the prior paragraphs. Moreover, granting the waiver would promote statewide efficiency as the Rule was waived in the FirstEnergy service area, and the pending settlement in the AES Ohio smart grid proceeding recommends that the outcome of the FirstEnergy case apply in the AES Ohio service area.10 Finally, the Commission has found that granting waiver of this Rule is an appropriate consideration in a proceeding like this.11 For these reasons, as part of the Commission’s consideration of Duke’s Application, the Commission should grant a waiver of Rule 4901:1-10-24(D)(3), O.A.C., to enable efficient access to residential customer interval usage consistent with R.C. 4928.02(O).” {***}
RESA’s Initial Comments (02/24/2025)
24-0039 (02/09/2025)
(In the Matter of the Application of Duke Energy Ohio for Authority To Adjust Its Power Future Initiatives Rider)
