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Retail Suppliers Seek Extension Of Compliance Deadline For New Rule Requiring Highlighting On Bill, For Two Consecutive Bills, Any Changes To Rate Or Terms

"Impossible" To Comply By Jan. 1, 2025 Deadline, Suppliers Say, Citing Risk Of Billing Errors


December 11, 2024

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

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The Retail Energy Supply Association has sought from the PUC of Ohio an extension to comply with a new retail natural gas rule which requires retail gas suppliers to highlight and explain on bills, for two consecutive billing periods, any changes in rates, terms, or other conditions of service

As previously reported, in February 2024, PUCO adopted a modification to Ohio Adm.Code 4901:1-29-12(B) to add language requiring that, on any bills issued "by or for retail natural gas suppliers" (including utility consolidated, dual, and supplier consolidated), the billing entity shall highlight and provide a clear explanation of any changes in the rates, terms, and conditions of service, for two consecutive billing periods

As previously reported, an ALJ already granted a waiver for compliance through January 1, 2025, so that utilities and suppliers could work through implementation. Apart from this extended compliance deadline, the rule otherwise became effective on July 15, 2024

RESA said that due to complex issues related to implementation, including testing, a further waiver of Ohio Adm.Code 4901:1-29-12(B) is needed, with RESA seeking an April 1, 2025 compliance date

RESA noted that natural gas utilities in Ohio do not use the same mechanisms to communicate the necessary information required under the rule. Some utilities use EDI, while others require coding to implement proprietary flat files, RESA said. Even when EDI is used by an LDC, there is no standard protocol for gas utilities in Ohio, RESA noted

"To complete the coding necessary for both LDC and supplier systems to send and receive the required customer notifications, the LDCs must provide suppliers with file specifications and the suppliers must then implement those specifications. In short, testing between the supplier and utility must occur," RESA said

RESA said that no testing has occurred to date, and that not enough time remains this year to complete testing

RESA warned that, absent an extension, compliance with the new rule provision may be "impossible" at some utilities, while implementation at other LDCs may result in a "substantial risk" of billing errors

RESA stressed that suppliers and utilities have, "long provided customers with clear explanations of changes in the rates, terms, and conditions of service," but said that the new requirement for such notices to be included on bills for two consecutive billing cycles, "requires substantial operational and IT work to coordinate, test and implement."

RESA also noted that utilities, suppliers, and PUCO Staff have been diligently working to implement the new rule, but that such collaboration has revealed that additional time is needed for completion

Case No. 17-1847-GA-ORD

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