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As background, on November 5, 2025, the Public Utilities Commission of Ohio (PUCO) issued an order seeking comments on staff’s proposed draft net metering rules. (Note that the proposed rules are attached to the order that also include existing copy of rules.)

Parties were directed to file initial comments by November 28, 2025, with reply comments due by December 12, 2025.

In response to this request, initial comments were filed by parties in the net metering standards the Public Utilities Commission of Ohio (PUCO’s) Review of Ohio rules in Adm.Code 4901:1-10-28. 

Ohio Power Company – “The Net Metering Rule unlawfully requires an electric distribution utility to provide net metering service, including a generation credit, for shopping customers when they produce more kWh than they consume during the same billing period. The Net Metering Rule also permits, but does not require, that CRES providers may enter into net metering contracts with their shopping customers. These aspects of the rule conflict with the governing statute, create unlawful subsidies of a competitive service, and foster double credit scenarios where net metering customers get windfall payments for their generation merely because they are interconnected with an electric distribution utility for wires service.”

“But the General Assembly, in R.C. 4928.67, prohibits the Commission from requiring EDUs to offer net metering to shopping customers. It does so through the plain and ordinary meaning of Division (B)(3)(b) of the statute, which provides: If the electricity supplied by the electric utility exceeds the electricity generated by the customer-generator and fed back to the utility during the billing period, the customer-generator shall be billed for the net electricity supplied by the utility, in accordance with normal metering practices. (Emphasis added.) R.C. 4928.67(B)(3)(b). The plain language of this provision confirms that the General Assembly intended net metering to apply to “electricity” (i.e., electrons) that is “supplied by the electric utility.” Yet the EDU only supplies electricity to its non-shopping customers. For shopping customers, the CRES providers supply the electricity.”

“The Commission itself previously agreed with this common-sense reading of the statute, providing in its November 2015 Entry and November 2017 Finding and Order that EDUs need only offer net metering to non-shopping SSO customers. Net Metering Proceedings, Entry (Nov. 18, 2015) (App. at 433, 437); see also id., Finding and Order, ¶ 15 (Nov. 8, 2017) (App. at 457, 463). CRES providers, the Commission determined, should be responsible for providing net metering to shopping customers: The Commission finds that the electric utilities shall offer a standard net metering tariff to standard service offer customers, while [CRES] providers shall be provided greater opportunities to offer diverse net metering products and service to shopping customers. (Emphasis added). Finding and Order (Nov. 8, 2017) at ¶ 1 (App. at 457).”

“The Commission’s current Net Metering Rule also squarely conflicts with the Commission’s own historical usage of the term “supplier” to refer to CRES in the context of promulgating numerous Commission rules codified in the Ohio Administrative Code. For example, Ohio Adm.Code 4901:1-21-03 provides that “CRES providers shall not change or authorize the changing of a customer’s supplier of retail electric service without the customer’s prior consent *** [.]” Ohio Adm.Code 4901:1-21-03(C) (emphasis added). Similarly, the Commission’s rule regarding slamming complaints defines such a complaint as “a customer’s allegation that the customer’s supplier of electric service has been switched without the customer’s authorization.” Ohio Adm.Code 4901:1-21-08(C)(1).”

“The Commission should modify the Net Metering Rule to Require Net Metering customer generators to pay their full amount of distribution costs.”

“The Company recommends that customer-generators be “net billed” similar to the COGEN/SPP tariff rather than the current net usage billing. Net billing calculates the total energy delivered to the customer, which includes energy and related distribution charges. The amount of the credit for energy generated by the customer is then deducted from the total energy and delivery charge.

“Payment of net metering credits to customer-generators 

The Company recommends that the net metering generation energy credit be paid by the entity providing the generation (supply) component of the customer-generator’s bill. Customers are able to participate in net metering if they are on the Standard Service Offer or if they are shopping. OAC 4901:1-10-28(B)(1) provides that electric utilities are required to develop standard and hospital net metering tariffs. OAC 4901:1-10-28(B)(2) states CRES providers may offer net metering contracts in accordance with OAC 4901-1-21.”

Interstate Gas Supply – R.C. 4928.02(C) provides that it is the policy of the state of Ohio to “ensure diversity of electricity supplies and suppliers, by giving consumers effective choices over the selection of those supplies and suppliers and by encouraging the development of distributed and small generation facilities.” It is IGS’s experience that fair and reasonable net metering rules that provide reasonable compensation and incentivize delivery of electricity back onto the grid enable distributed generation development. It is also IGS experience that states without reasonable net metering rules fail to develop distributed generation projects. Thus, in order to effectuate the state policy to encourage the development of distributed generation the Commission should ensure net metered projects receive fair compensation and not place undue costs on distributed generation projects.” 

“IGS supports the no-change draft rules and reserves its right to reply. IGS appreciates the Commission’s efforts in maintaining appropriate net metering rules that fit the needs of shopping and default service customers and promote the state policy in favor of distributed generation deployment.”

Solar Untied Neighbors  – “The Record Supports Maintaining Current Rules Without Modification PUCO Staff has already determined that no changes are needed to the current net metering rules. The record continues to support this conclusion. There is no demonstrated evidence of consumer harm or market distortion under the existing structure. 

By contrast, the last-minute proposal filed by Ohio Power Company (AEP Ohio) would: 

• Introduce confusion by removing net metering access for customers who shop with a competitive supplier 
• Reduce consumer choice and restrict Ohio’s competitive retail electricity market 
• Increase costs to solar households by applying additional distribution-related charges 
• Dramatically extend rooftop solar payback periods, discouraging customer participation 
• Discourage local clean generation that supports the grid during high-demand periods 
• Shift costs to consumers who choose clean energy by undervaluing the power they supply to the grid 

These changes would penalize families for sharing clean energy and undermine customer choice in Ohio’s competitive retail market. 

Most importantly: 

“Rate certainty and consumer value should not be undermined to address speculative utility concerns that belong in rate cases — not in this rule review. There is simply no problem here to solve.”

25-0349-EL-ORD
(In the Matter of the Commission’s Review of Ohio Adm.Code 4901:1-10-28, Regarding Net Metering Standards)