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Ohio Manufacturers’ Association Energy Group File Proposed Rule Changes Including Making All Transmission Costs Bypassable
Ohio Manufacturers’ Association Energy Group or OMAEG –
The Commission Should Amend the Language of Ohio Adm.Code 4901:1-36- 04(B) to Ensure That the Transmission Cost Recovery Rider is Bypassable for Customers Who Shop for Generation.
As proposed, Ohio Adm.Code 4901:1-36-04(B) states, “The transmission cost recovery rider shall be avoidable by all customers who choose alternative generation suppliers and the electric utility no longer bears the responsibility of providing generation and transmission service to those customers.” For the reasons discussed below, OMAEG recommends that the Commission strike the second half of the sentence so that the rule reads as follows:
“The transmission cost recovery rider shall be avoidable by all customers who choose alternative generation suppliers and the electric utility no longer bears the responsibility of providing generation and transmission service to those the customers.”
“While the first half of this rule would indicate that TCRRs must be bypassable for shopping customers, in practice, the current TCRRs of the State’s electric distribution utilities are nonbypassable, which has been allowed due to the second part of this rule provision.3 Customers should have the option to pay for their transmission costs from an alternative generation supplier and not still be beholden to an electric distribution utility. Alternative generation suppliers are likely to pass through transmission costs to customers exactly as how the supplier would be billed for transmission as the load serving entity (LSE).”
The Commission Should Expand Ohio Adm.Code 4901:1-36-06 (A) and (B) to Ensure Transparency.
“OMAEG recommends further amending the language of Ohio Adm.Code 4901:1- 36-06 as follows:
“On a biennial basis, the electric utility shall file in the latest annual update docket provide additional information detailing the electric utility’s policies and procedures for minimizing any costs in the transmission cost recovery rider if where the electric utility has control over such costs, including but not limited to accounting for behind-the-meter and customer-sited generation capacity on associated circuits; a cost-benefit and capacity analysis of ATTs; a cost-benefit analysis and capacity analysis of GETs; alternative transmission hosting locations within a 100 mile radius and these locations load hosting capacity; updated large load addition capacity forecasts; and transmission upgrade costs directly attributable to large load customer(s).”
The Commission Should Ensure that Electric Utilities Appropriately Account for the New Transmission Services for Co-Located Load.
OMAEG recommends that the Commission amend the TCRR rules to ensure retail large load customers, especially those with co-located generation loads in Ohio, are offered all of these new transmission service arrangements at the time of their interconnection request with the electric utility and when Letters of Authorization or Electricity Service Agreements are offered by the electric utility, and that their transmission billing tariff reflects the appropriate FERC-ordered transmission service. Additionally, the Commission should amend Ohio Adm.Code 4901:1-36-04 to preclude electric utilities from seeking cost recovery for any co-located load that is taking service under the new transmission service tariffs where the customer agrees to not use the transmission system during peak times, eliminating the occurrence of transmission costs during those times.
