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In Ohio parties filed reply comments in the Commission’s mercantile related rulemaking as a result of the enactment of HB15.

RESA – The Commission should reject proposals that would impede the expedited SSO process required by statute. 

“The Commission should adhere to the General Assembly’s intent that EDUs implement a process to return certain mercantile customers to the SSO within three business days. The statutory prerequisites for this to occur are (1) that there be a “service agreement that explicitly authorizes return” to the SSO that was “voluntarily entered into be a mercantile customers” and (2) that the EDU “receive[s] a certified request from a competitive retail electric service provider.”8 There is no wiggle room in the statutory language to provide additional waiting time to “certify” the request or wait to synch up to meter reads or billing cycles. As RESA pointed out in its initial comments, Staff’s seven-day waiting period is contrary to the intent for a three-business day expedited return.” 

First Edison Utilities – Expedited Return of Mercantile Customers to Standard Service Offer. 

“This section anticipates that the “certified request” form will be available on the Commission’s website. RESA recommended that the Commission “clarify that the certified request process does not require a manual process and can be streamlined through use of an EDUs existing electronic EDI interface.”1 If the Commission authorizes the use of the form contemplated in 4901:1-21-21(C), the Companies reiterate their request that the certified request form be publicly provided before the rules are officially adopted and that all interested parties be provided with the opportunity to comment on it.”

“The Companies also agree with RESA that the certified request process should permit the use of the existing EDI interface. Manual processes are slower, more resource-intensive, and more susceptible to human error compared to the existing EDI interface. Use of the existing EDI process, which utilities and CRES providers are already familiar with, will accelerate the return process and increase accuracy.”

Ohio Power – Response to Section A – Notice Period and the Statutory “Complete” Requirement

“The statutory three-day “complete” requirement should be interpreted to govern internal processing, not to mandate mid-cycle effective switches that create prorated billing and system burdens. Practically, completing processing and making a switch effective on a customer’s bill are two separate processes. An EDU can “complete” all processing steps required to enroll a customer back to the SSO within three business days; however, the physical application of that change to customer billing is governed by meter-read and billing cycles. 

In terms of virtual net metering Ohio Power said it “believes that the PUCO should modify the language in proposed Ohio Adm.Code 4901:1-10-37 to clarify that mercantile customers may not engage in virtual net metering.

Duke Energy – Duke Energy Ohio Supports The Revisions and Clarifications Proposed By The Ohio Power Company (AEP Ohio) To 4901:1-10-36(A), Which Would Eliminate The Need For Bill Cycle Proration.

“In its initial comments, Duke Energy Ohio expressed that implementing the proposed Rule 4901:1-10-36 would require the implementation of new bill cycle proration capabilities, which does not exist currently and would require time to complete.1 This was due to the “regardless of bill cycle” language that AEP Ohio proposes to modify.”

“If, however, the revision proposed by AEP Ohio in its initial comments is adopted,2 and also the definition of “complete” proposed by AEP Ohio,3 Duke Energy Ohio will not need to implement bill proration capability, as it would be permitted to effect the submitted change “at the earliest practicable date,” which would be its current practice of either (i) the next meter read date if the request was submitted 13 or more days before; or (ii) the meter read date after the next meter read date, if the request was submitted 12 or fewer days prior to the next meter read date.”

25-0741
(In the Matter of the Consideration of Rules Pertaining to Mercantile Customers, as Required by Substitute House Bill Number 15.)