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PUC OKs Increased Utility Promotion Of Default Service Time-Varying Rate Options For Non-Shopping Customers
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The Public Utilities Commission of Ohio approved at the FirstEnergy Ohio utilities a new smart thermostat rebate program open to retail suppliers, and granted a waiver to allow retail suppliers to receive their customers' hourly usage data without customer consent, under an order adopting the FirstEnergy EDCs' second grid modernization plan (Grid Mod II)
PUCO will also allow the FirstEnergy EDCs to increase their promotion of time of use rates for non-shopping customers on default service
The approvals came as PUCO adopted a stipulation among various parties in Grid Mod II, without substantive modification related to the retail market except where noted below
Time-Varying Rates
Under the adopted stipulation, the FirstEnergy EDCs, "will make efforts to try and increase awareness and understanding of their time-varying rate options for eligible residential and nonresidential SSO customers."
The adopted settlement provides that the utilities will continue working with the Grid Mod Collaborative to, "evaluate and consider potential enhancements to the design and marketing plans for their time-varying rates for SSO customers."
More specifically, the approved stipulation provides that, "In the first year of Grid Mod II, the Companies commit to work with the Grid Mod Collaborative to develop a plan to provide customers with information to better compare TVR and SSO rates."
Costs associated with the marketing of the utilities' SSO time-varying rate, "will continue to be recovered through a bypassable charge," the settlement states
Notably, the stipulation provides that, once there are either (a) at least three retail suppliers offering products utilizing AMI data or (b) at least three different types of time-varying products utilizing AMI data, then the utilities, with PUCO approval, will withdraw their SSO time-varying rate offering.
The stipulation further provides that, during the period that the EDCs are offering the SSO time-varying rate, they will not utilize customers’ AMI data to market the SSO time-varying rate to customers, including through new Customer Energy Management (CEM) Reports which will be developed under Grid Mod II
However, upon PUCO approval of the withdrawal of the utilities' SSO time-varying rate offering, the EDCs may utilize customer AMI data, including through the CEM reports, to notify customers that they may benefit from a time of use offering and to direct those customers to PUCO's "Apples to Apples" shopping website, which lists offers from competitive retail suppliers
The stipulation further provides that, effective with the first summer following approval of Grid Mod II, the EDCs are no longer required to offer Rider RCP (Residential Critical Peak Pricing Rider) to customers in the Cleveland Electric Illuminating pilot area.
Addressing time of use rates generally, PUCO encouraged OCC and other parties to continue collaborative efforts to recommend improvements to the TOU offerings throughout the duration of Grid Mod II.
Smart Thermostat Rebates
The approved stipulation provides that, during the
term of Grid Mod II, the EDCs shall budget $3 million per year for a Smart Thermostat Rebate (STR) program which is open to retail suppliers as noted below
As previously reported, in the FirstEnergy Ohio EDCs' separate ESP V proceeding, PUCO had originally approved $2 million annually for a separate smart thermostat rebate program open to retail supplier
Noting that the FirstEnergy Ohio EDCs' withdrawal of ESP V was approved on Dec. 18, PUCO in Gird Mod II confirmed that this ESP V-related smart thermostat program may not proceed, and that the funding under ESP V cannot be combined with the Grid Mod II smart thermostat rebate program. As such, the approved Grid Mod II smart thermostat rebate program remains capped at $3 million annually absent PUCO approval of a change
More specifically, under Grid Mod II, the EDCs shall budget $3 million per year for a Smart Thermostat Rebate (STR) program
The utilities are targeting
STR program participation of at least 16,000 customers per year.
The STR rebates shall be available to:
a. Low Income Residential Customers - Customers who are at or below
300% of the federal poverty level will be eligible for a rebate for the
purchase of a new, qualifying smart thermostat. This rebate shall not
exceed the lesser of the total purchase cost or $150 per qualifying
smart thermostat.
b. All Other Residential Customers - All other residential customers
who are (1) on the EDCs' or a competitive retail provider’s time-varying
rate option, or (2) participating or enrolling to participate in a demand
response program [see note] will be eligible for a rebate for the purchase of a
new, qualifying smart thermostat. The maximum rebate to these
customers shall not exceed the lesser of the total purchase cost or $100 per qualifying smart thermostat
The approved stipulation provides that the utilities will allow retail suppliers to help facilitate the provision of
qualifying smart thermostats to customers. Retail suppliers will be required to
comply with all program requirements and processes.
Under the settlement, in signing up
participating retail supplier customers, a retail supplier must: (1) provide an account number or
SDI so that the EDCs can verify that customer’s identity as a customer
with an active EDC account that is not previously associated with a smart
thermostat rebate under the program, and (2) provide make, model, serial
number, and any other required information of the installed smart thermostat
that qualifies under the EDCs’ program.
"As part of the initial enrollment
process, the CRES [competitive retail electric service provider] will acquire affirmative consent for enrollment and provide
that affirmative consent to the Companies [FirstEnergy Ohio EDCs]," the settlement states
Furthermore, the stipulation states, "If the customer consents, the rebate
can be provided to the CRES provider."
Hourly Interval Data Access For Retail Suppliers
The stipulation proposed that retail suppliers may be provided with hourly interval data for their residential customers
While PUCO will allow such provision of hourly data to suppliers without customer consent, PUCO said that a rule waiver is required in order for such to be accomplished, as PUCO granted the waiver
Ohio Adm.Code 4901:1-10-24(D)(3) provides that a utility may not, without the customer's consent, disclose a residential customer's usage data in a detail more granular than monthly, except where, among other things, such data is required for billing purposes
Stipulating parties had argued that, because the hourly data is now used to determine a retail supplier's PLC in PJM, the customer's hourly data is used for billing purposes, and may be provided to the customer's retail supplier without the customer's consent
However, PUCO found that the use of such data in setting PJM costs does not mean that the data is required for "billing purposes", in cases where the customer is on a retail rate which does not vary more often than monthly, since the interval data is not needed to calculate the customer's monthly bill under such non-TOU rate
PUCO did find that it is appropriate to grant a waiver of this rule, in order to allow the provision of hourly interval data to the retail supplier of a residential customer without the customer's authorization. The waiver shall only be in place through the duration of Gird Mod II or unless otherwise ordered by PUCO
"Because we recognize the numerous benefits of CRES [retail] providers having access to interval data, and that such data access will help materialize many of the benefits contemplated in both the Grid Mod I Case and these proceedings, we grant this waiver request," PUCO said
Addressing concerns about data protection raised by some parties, PUCO said that the Grid Mod Collaborative should to continue
to review this issue and make recommendations to PUCO in advance of the start of the provision of such data, including establishing minimum standards for existing consumer data protection policies.
Concerning the mechanics of providing the hourly data to suppliers, the stipulation notes that PUCO-certified retail suppliers may access residential customer
hourly interval data, without cost, on the EDCs’ Supplier Portal through
Single User-Multiple Request (SU-MR). SU-MR will remain
unchanged and available to PUCO-certified retail providers in Grid Mod II.
Further concerning residential Hourly Interval Data, the stipulation also provides concerning retail supplier data access (specifically for retail electric
generation providers, or, in other words, LSEs) as follows:
a. Upon PUCO approval, the EDCs will undertake
IT system changes and initiate the PUCO EDI Working
Group changes needed to make available to PUCO-certified retail
electric generation providers the hourly interval data for their enrolled
residential customers as follows:
i. Supplier Portal: System-to-System Historical Interval Usage
(StS-HIU), and System-to-System Rolling 10-Day (StS-Rolling
10 day).
ii. EDI: Residential Interval Usage (867IU).
iii. The interval data available to retail suppliers shall include all
interval data utilized by PJM to assign costs to retail suppliers
for billing to shopping customers.
iv. The interval data shall be provided to retail suppliers without
cost.
The stipulation notes that, "In accordance with the Commission-approved settlement in Grid Mod
I, Case Nos. 16-481-EL-UNC, et al., the Companies [FirstEnergy Ohio EDCs] have undertaken
the steps necessary to utilize residential customer interval data for
wholesale market settlements including calculating and settling the
hourly energy load obligation and calculating Peak Load Contribution
('PLC'). That settlement provided further that 'The THEO, PLC, and
NSPL data will be made available to authorized CRES [competitive retail electric service] providers,
consistent with 4901:1-10-24 of the Ohio Administrative Code,
through the pre-enrollment list and electronic data interchange
('EDI') transactions, as applicable.'"
The stipulation also provides for a process for NOPEC to receive hourly interval data
for its aggregated customers through StS-HIU, StS-Rolling 10 day,
and/or EDI 867HIU, with PUCO modifying the stipulation to also include other governmental aggregators as permitted to receive such data
Addressing another customer data issue, the stipulation provides that, subject to Commission Rules and resolution of certain issues to be discussed in a collaborative, the utilities will provide retail customer data to retail suppliers, governmental
aggregators, and third-party aggregators (such as Curtailment Service Providers and Distributed Energy Resource aggregators) to allow them to enroll any
customers and participate in the PJM markets, including but not limited to
ancillary service markets and demand response programs.
A collaborative will address the following concerning the provision of data to allow participation in PJM markets:
a. what data may be available
b. the mechanics of how the data will be disseminated
c. responsibilities of parties to maintain customer consent records, and
obligations of parties to meet customer protection laws and
regulations
d. the mechanism to document such responsibilities and performance
requirements (e.g., a tariff, contract, etc.).
Other Issues
Concerning AMI, the adopted settlement allows the FirstEnergy Ohio EDCs to install the remaining estimated 1.4 million advanced meters in their service area, along with supporting infrastructure
Case 22-0704-EL-UNC et al; 22-704-EL-UNC.
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PUC Approves Another Smart Thermostat Rebate Program Open To Retail Suppliers
PUC Allows Retail Suppliers To Receive Their Customers' Hourly Data Without Customer Consent (Rule Waiver Needed)
December 18, 2024
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Copyright 2024 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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