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PUC Staff Make Recommendations On Changes To Utilities' Default Service Plan
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Staff of the PUC of Ohio have filed recommendations concerning the FirstEnergy Ohio utilities' withdrawal of electric security plan V (ESP V), and the EDCs' sought changes to the prior ESP IV as part of reverting to the previous ESP
See background on the ESP V withdrawal and sought changes to the prior ESP IV here
In brief, with respect to retail market issues, while the FirstEnergy Ohio utilities withdrew from ESP V, the EDCs under reverting to ESP IV are generally still seeking to implement the default service changes approved by PUCO under ESP V, including the elimination of 36-month SSO contracts, and the use of a capacity proxy price mechanism. As proposed by the EDCs, the FirstEnergy Ohio utilities would rely solely on 12-month and 24-month SSO contracts in reverting to ESP IV.
Based on comments publicly posted as of publication time, most stakeholders generally did not oppose the FirstEnergy EDCs' approach to continuing the default service program design approved under ESP V under any reversion to the prior ESP (or SSO)
PUCO Staff recommended that the FirstEnergy Ohio utilities' changes to the SSO procurement process approved under ESP V be adopted under any reversion to ESP IV, as proposed by the EDCs
As previously reported, the FirstEnergy Ohio EDCs also proposed to continue the "modest" expansion of the Rider NMB Pilot Program that had been approved in ESP V.
Under this expansion, the EDCs proposed make available, for new customers under the Rider NMB pilot, an additional 100 MW of space, on a first-come, first-served basis, with each individual new customer capped at 20 MW. The Rider NMB pilot allows a capped number of large customers to avoid paying a nonbypassable Rider NMB charge for certain non-market-based PJM charges, with responsibility for such charges instead assigned to the customer's retail supplier and not the utility
PUCO Staff said that the full expansion of the Rider NMB pilot should not continue under the reversion to ESP IV, as Staff said that any changes to ESP IV should be as limited as possible.
Rather, Staff said that eligibility for the Rider NMB pilot should only be expanded to include those new Rider NMB pilot customers who have signed a contract with a retail supplier for transmission service as of the time that the FirstEnergy utilities revert to ESP IV. Allowing those new Rider NMB pilot customers who have already contracted with a retail supplier to still participate in the pilot will avoid disrupting contractual obligations
Other than including these NMB pilot customers who have already executed a contract with a retail supplier, Staff said that the broadly applicable Rider NMB pilot expansion should not remain open for any further new customers after the reversion to ESP IV occurs (though not addressed by Staff, customers may on an individual basis seek to avoid Rider NMB through a reasonable arrangement application which is subject to PUCO review)
In an October 29 filing, the FirstEnergy Ohio EDCs had stated that, since the approval of the expansion of the Rider NMB pilot under a May 2024 order from PUCO, "some" customers had enrolled in the expanded pilot, but the EDCs had said that the new allotments open under the pilot were "significantly undersubscribed".
Constellation raised a concern with the tariffs filed by the FirstEnergy Ohio EDCs in seeking to implement the reversion to a modified ESP IV
Constellation said that the supplier tariff filed by the EDCs to revert to ESP IV excludes as a PJM Billing Line Item, in Appendix A, PJM Billing Line Item ID #1115, "Transmission enhancement settlement
charge".
The EDCs' current tariffs, reflecting ESP V, include Line Item ID #1115, and the current tariffs also note that the responsibility for Line Item ID #1115 lies with the utility
Note that, under the reversion tariffs filed by the EDCs, Line Item ID #1115 is omitted entirely, as opposed to including the line item but changing the listing of the party responsible for the line item
Constellation said that Line Item ID #1115 should continue to be reflected in Appendix A of the EDCs' Supplier Tariff
"There is no reason to alter the PJM
billing (by omitting that billing line item) simply because of the withdrawal,
but it appears that would occur based on the FirstEnergy Ohio utilities’
October 29, 2024 proposed tariff filings in Case No. 14-1297-EL-SSO," Constellation said
PUCO Staff, the Ohio Consumers' Counsel, and various large customers did raise objections to the reversion to ESP IV with respect to issues not related to the retail market (i.e. distribution service, etc.)
Case No. 14-1297-EL-SSO
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November 13, 2024
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Copyright 2024 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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