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PUC Staff, Utility Agree On Bill Language Directing Customers To Call Utility First With Complaints

Staff Recommends New Choice Service ID Be Afforded Same Protection As Account Number

Staff Supports Utility Changes Which Move Price To Compare Language On Bill


August 22, 2024

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Copyright 2024 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

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Staff of the PUC of Ohio have recommended approval of bill format changes at Dayton Power & Light (AES Ohio) that would, among other things, move the language concerning the price to compare from the second page of the bill to the first page of the bill for several types of customers, including for non-residential customers currently taking supply from a competitive retail supplier

See our prior story for full details on the proposed changes

As previously reported, in moving the PTC language to the first page of the bill for non-residential shopping customers, AES Ohio would include the PTC language in the "Account Level Message Center" section of the bill, grouped with other messages. The PTC language would no longer have its own box or heading stating "Price-to-Compare Message".

AES Ohio would make similar changes to the PTC message for residential and non-residential bills for non-shopping customers. The message would be moved from the second page of the bill to the first page of the bill, and be grouped with other messages under a "Service Level Message Center" (residential) or "Account Level Message Center" (non-residential). In each case, the PTC language would no longer have its own box or heading stating "Price-to-Compare Message".

For utility consolidated bills of residential customers on competitive retail supply, the language concerning the price to compare would remain on the second page of the bill, with no change in the message's language

In recommending approval of DP&L's proposed bill format changes, Staff said that Staff had discussions with DP&L, "clarifying the price-to-compare message". Staff said that DP&L agreed to "minor formatting changes" concerning the PTC message. Staff's recommendation did not specifically discuss further or provide an example of the agreed-upon changes

Staff also reported that DP&L has agreed to include on bills a direction to customers that customers should contact the utility first with questions or complaints

Staff reported that DP&L agreed to include, on the "static billing page", a statement that customers with billing questions or complaints should contact the utility first.

Again, Staff's recommendation did not specifically discuss this change further or provide an example bill showing where this language would be included, and to which bills (if not all bills) it would apply (e.g. default service, shopping utility consolidated, residential vs. non-residential, etc.) and if the statement includes any language about supply versus distribution charges and complaints for each

As previously reported, as part of a CIS upgrade, the new bill format will include a new Choice Service ID for customers.

Staff said that, "Staff also believes the [DP&L] should consider the CHOICE ID as customer specific information to be safeguarded by Ohio Administrative Code 4901:1-10-25(E)(1)." [sic]

The specific OAC provision Staff cited does not appear to exist per the version of the OAC posted on codes.ohio.gov (it was unclear if any re-numbering is pending but the similar OAC 4901:1-10-24 was effective as of April 2024), and it was not precisely clear to what provision Staff intended to cite

OAC 4901:1-10-24(D)(1) does provide that a utility shall not disclose a customer's account number without the customer's consent and proof of such consent, except for certain purposes enumerated in the rule. This would appear to be the protection Staff seeks for the CHOICE ID

Case 24-0067-EL-UNC

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