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Parties File Reply Comments In Net Metering Rulemaking

Dockets: 25-0349-EL-ORD
Category: Ohio
Related Categories: IGS, Net Metering, RESA, Rulemaking, Supplier, Utility

As reported previously, 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 also include an existing copy of proposed rules.

In response several parties including retail suppliers, office of consumer counsel and the utilities provided comments. 

RESA Reply Comments – Contrary to AEP Ohio’s arguments, the Commission’s existing net metering rule aligns with R.C. 4928.67. 

  • AEP Ohio’s Noncompetitive Distribution Metering/Billing Function remains an impediment to customers obtaining value from the PJM market. 
  • PUCO should not accept AEP Ohio’s proposals to dismantle a workable and net metering solution. 
  • AEP Ohio’s proposals would cause undue discrimination among net metering customers. 
  • AEP Ohio’s Proposed Net Billed Approach to Calculating Net Metering Credits Should be Rejected 

IGS Reply Comments  – AEP Ohio’s proposed net metering rule changes are contrary to State Policy and Commission precedent.  

In its Initial Comments filed November 26, 2025, AEP Ohio seeks changes to the existing net metering rules. Among its suggestions, AEP recommended net metering generation energy credit be paid by the entity providing the generation (supply) component of the customer-generator’s bill and alleges that the current rules “creates unlawful subsidies of a competitive service and foster double credit scenarios…”5 AEP Ohio’s proposed changes violate Commission Precedent and State Policy.”

AEP’s proposed net metering rule change contradicts the net metering statutory language.

“AEP contends that that customer-generators be “net billed” similar to the COGEN/SPP tariff rather than the current net usage billing.” This argument conflicts with the statute, which provides that AEP Ohio shall only bill for net electricity supplied in accordance with normal metering practices: “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.”

AEP’s proposed net metering rule change is outside the scope of this proceeding.

“Here, AEP Ohio argues that net metering customers should pay their fair share of distribution costs. AEP Ohio is currently at the Commission for a distribution rate case.10 A rules proceeding is not the venue for setting rates. The Commission should disregard AEP’s Ohio attempt to set distribution rates outside of a distribution rate case.”

Reply Comments of ELPC & Ohio Environmental Counsel –  “In short, the OEC and ELPC disagree with the positions put forth by AEP Ohio as they are contrary to state law, state energy policy, and the best interests of Ohioans, especially net metered customers. At minimum, the Commission should maintain its “no change” position regarding OAC 4901:1-10-28. If it makes any changes at all, those changes should further encourage net metered generation, rather than discourage it.”

OPC Reply Comments  – “AEP Ohio correctly recommended that the net metering rules should require that “customer-generators” (consumers who are capable of producing their own power, e.g., through solar power) pay their fair share of distribution costs. One way this can be accomplished is by shifting from a “net usage” model to a “net billing” model.”

“A net-billing model offers a fair and sustainable path forward for customer-sited generation in Ohio. Net billing provides clear price signals by compensating customers for their excess generation at a rate that reflects its actual value to the grid. This approach preserves important incentives for customers who choose to invest in solar or other distributed resources, while reducing the risk of cost shifting to non-participants who continue to rely on the distribution system. Net billing strikes an appropriate balance; it supports customer choice and market-driven investment in distributed energy resources, while aligning compensation with system benefits and ensuring that all consumers are treated equitably.”

Read all comments here. 

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