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Utility, In Post Collaborative Report, Says Supplier Consolidated Billing Would Require "Significant Financial And Operational Investment" With Little Or No Customer Benefit
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In a report after the completion of a collaborative on supplier consolidated billing, Duke Energy Ohio recommended to the PUC of Ohio that SCB not be implemented for Duke's customers
Duke said that SCB, "would create a number of drawbacks including significant financial and operational investment with little to no benefit to customers."
Duke noted that the only formal proposal provided during the collaborative was made by the Retail Energy Supply Association (the "RESA Proposal")
The RESA Proposal would allow SCB for both electricity and natural gas, with the potential for the customer to be served by a unique entity for each commodity. Duke said that this could result in customers currently receiving a single combined electric and gas bill from Duke being instead subject to receiving two bills
The RESA Proposal would allow retail suppliers to elect to offer SCB, but not mandate SCB
Under the RESA Proposal, while SCB suppliers would send bills to customers, "those Suppliers [would] not take on other utility functions required by statute."
The RESA Proposal was said to have been included as an attachment to the post-collaborative report, but no attachments were present in the report or available as a separate filing in the case as of publication time
Duke said that it understands that, under the RESA Proposal the billing supplier’s role would be limited solely to issuing the consolidated bill, with Duke Energy Ohio handling all other customer-facing functions and continuing the purchase of suppliers’ receivables.
Duke's concerns with SCB include, among others, "The potential for customer confusion, especially in the areas of billing questions, payment processing, customer communications, and aggregations," and "The disconnect for customers related to a change of the billing entity from Duke Energy Ohio to a supplier and Duke Energy Ohio continuing to maintain the rest of the customer relationship that would be created."
Duke said that the RESA Proposal would cost $2.135M in implementation costs
Duke said, "Apart from the monetary costs, the Company anticipates significant non-monetary costs in implementing the RESA Proposal: customer confusion and frustration, a significant learning curve for Company employees, the Commission call center, as well as potentially supplier employees, and other issues as discussed above. The Company does not currently see benefits or interest levels that would justify the monetary and non-monetary costs of implementation."
Among other recommendations if SCB were to be implemented, Duke Energy Ohio said that SCB should be conducted on an individual opt-in basis, requiring affirmative consent, including affirmative consent for municipal aggregation customers
In separate comments, PUCO Staff said that Staff does not support implementation of SCB in Duke’s territory, citing concerns about costs and customer confusion
Staff noted that under the RESA Proposal, Duke would still be required to perform most current functions relating to customer service and billing except for issuance of the bill, with Duke also needing to provide new billing information to the retail supplier
"Staff is concerned about the cost-benefit for Duke’s customers to implement this process when dual billing is a reasonable alternative available today," Staff said
"Staff sees no benefit to SCB if Duke continues to accept and process payments as well as continuing to purchase 100% off receivables from suppliers," Staff said
Concerning the use of SCB by government aggregations, Staff said, "A customer should give affirmative consent for SCB, and an opt-out governmental aggregation does not allow for affirmative consent."
The Retail Energy Supply Association (RESA), Interstate Gas Supply, LLC (IGS), and NRG Energy (collectively, the Joint Suppliers) filed comments in support of SCB and alleged that no real collaboration on SCB occurred
"During the entire Collaborative, there was no actual collaboration from the other stakeholders on how any form of SCB (the RESA proposal here, the AEP Ohio SCB, the Maryland SCB, or other states’ SCB) would be best implemented for Duke. Instead, the meetings covered the agenda topics listed in the stipulation, 'checking those boxes.' At this point, no meaningful collaboration on implementing SCB has occurred," the Joint Suppliers alleged
The Joint Suppliers alleged, "Duke has not provided its customers with adequate billing and continues to have problems, despite Commission requirements. See e.g., Ohio Adm.Code 4901:1-13-11(B). The Commission Staff has been investigating Duke’s billing and related service because of a slew of serious issues following Duke’s April 2022 transition to a new Customer Information System ('CIS'). Before Duke even transitioned to the new CIS, Suppliers flagged billing-related issues and predicted significant
concerns due to their experiences with other similar utility system transitions."
The Joint Suppliers alleged, "Those predictions became reality and Staff has concluded that Duke is and has been in probable
non-compliance with multiple billing-related requirements for a very long period of time," as the Joint Suppliers cited a pending joint stipulation between Duke and PUCO Staff, in Case No. 24-297-GE-UNC, addressing alleged Duke billing deficiencies, under which Duke would pay a forfeiture of $450,000
The Joint Suppliers cited Staff's notice of probable noncompliance to Duke which had alleged, "Staff investigated many customer contacts
to [Consumer Service Division] regarding Duke billing issues, including inaccurate
bills, untimely billing, and unusually high bills resulting from Duke estimating
meter reads for prolonged periods of time."
The Joint Suppliers said, "Since 2022, customers who have been harmed or are dissatisfied by Duke’s billing likely desire the opportunity to select consolidated billing from a Supplier. Allowing the Duke customers the opportunity to change their billing source is, therefore, reasonable."
Case 23-867-EL-UNC
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PUC Staff Also Opposes SCB
Retail Suppliers Cite Utility's Billing Errors & Proposed $450,000 Fine As Demonstrating Need For Alternative
July 29, 2024
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Copyright 2024 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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