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THE PUBLIC UTILITIES COMMISSION OF OHIO IN THE MATTER OF THE COMMISSION'S CONSIDERATION OF SOLUTIONS CONCERNING THE DISCONNECTION OF GAS AND ELECTRIC SERVICE IN WINTER EMERGENCIES FOR THE 2019-2020 WINTER HEATING SEASON. CASE No. 19-1472-GE-UNC FINDING AND ORDER Entered in the Journal on September 11, 2019 I. SUMMARY RECEIVED eoarcr of County Commissioners Auglaize County, Ohio {,r 1} The Commission sets forth special reconnection procedures that are effective no later than October 14, 2019, through April 15, 2020, for each gas, natural gas, and electric light company under the Commission's jurisdiction. II. DISCUSSION {,r 2} The gas, natural gas, and electric light companies (utility companies) defined in R.C. 4905.03 are public utilities in accordance with R.C. 4905.02, and, as such, are subject to the jurisdiction of the Commission, pursuant to R.C. 4905.04, 4905.05, and 4905.06. {,r 3} R.C. 4909.16 provides, in part, that, in the event of an emergency, when the Commission finds it necessary to prevent injury to the business or interests of the public or of any public utility, it may temporarily alter, amend, or suspend any existing rates or schedules. {,r 4) Ohio Adm.Code Chapters 4901:1-10, 4901:1-17, and 4901:1-18 address, among other things, the establishment of credit for residential service, the termination and reconnection of residential service by utility companies, and the natural gas and gas Percentage of Income Payment Plan (PIPP) and Graduate PIPP programs. In addition, Ohio Adm.Code Chapter 122:5-3 addresses the electric PIPP and Graduate PIPP programs. PIPP is a program for low-income customers who meet certain qualifications, including having a household gross yearly income at or below 150 percent of the federal poverty guidelines, to pay a reduced gas and/ or electric utility bill. Effective November 1, 2010, all of these 19-1472-GE-UNC -2- administrative code chapters were revised to allow for a PIPP Plus and Graduate PIPP Plus program, which provides that, when a customer pays the monthly payment on time and in full, two types of credits (a credit towards any old debt and towards the rest of that month's billed amount) are applied to the customer's account, thus, incenting the customer to make regular payments. {1 5} For more than a decade, prior to each winter heating season, the Commission has voiced concerns about residential customers who have had their gas and/ or electric utility service disconnected during the winter because they are unable to pay their bills due to limited financial resources and who have been unable to have these services restored because of unpaid balances. Pursuant to R.C. 4909.16, the Commission has determined each year that, in order to prevent injury to these residential customers, it was in the public interest to issue special reconnect procedures for the winter heating season. The Commission notes that all customer classes should have the opportunity to participate in, and receive the benefits of, energy efficiency and conservation programs. Therefore, we have approved many gas and electric utility energy efficiency and conservation programs in order to assist residential customers in controlling their utility bills. These programs, in concert with the financial assistance afforded residential customers through orders such as this one, provide much needed support for residential customers, including customers residing in multi-family housing and low-income customers. {16} For the 2019-2020 winter heating season, October 14, 2019, through April 15, 2020,1 the Commission expects that the utility companies under our jurisdiction will assist customers in every way possible to maintain their service for heating purposes. We expect these utilities to advertise, as much as practicable, the availability of the standard payment plans provided by Commission rule, as well as the availability of the PIPP Plus program. 1 The 2019-2020 winter heating season is defined for limited purposes set forth in this Order. 19-1472-GE-UNC -3- Moreover, the Commission expects the utilities to err on the side of maintaining service when there is a doubt as to the applicability or the interpretation of a rule. {17} In addition, upon consideration of the upcoming 2019-2020 winter heating season, the Commission again finds it necessary and prudent to invoke the emergency provisions of R.C. 4909.16 in order to prevent injury to affected residential customers and support the public interest. We continue to be concerned about those residential customers who have had their gas and/ or electric utility service disconnected because of limited financial resources or who have a disconnection notice because they are unable to pay their bills. While the Commission believes the residential service rules have substantially assisted customers to keep energy service, in spite of their financial situation, we are aware of the fact that a number of Ohio citizens will enter the winter season without utility service for heating purposes. We find this constitutes a continuing emergency. Accordingly, the Commission issues this Order to effectuate the special reconnection procedures for the 2019- 2020 winter heating season. A. Special Provisions for the 2019-2020 Winter Heating Season {18} Pursuant to R.C. 4909.16, in order to prevent injury and support the public interest, we direct utility companies under our jurisdiction for the 2019-2020 winter heating season to reconnect the services of those who have had their services disconnected for nonpayment or to maintain services in accordance with the directives set forth in this Order. {19} Effective dates of the procedures in this Order: A customer can only use the special procedures provided in this Order once from October 14, 2019, through April 15, 2020, to: (a) reconnect service under the special reconnection procedures, if the service has been disconnected for nonpayment; (b) avoid the disconnection of service under the special maintenance procedures; or 19-1472-GE-UNC -4- (c) request the connection of new service under the other special procedures. {~ 10} Initial requirements to restore or maintain service: A customer seeking to have service restored or maintained must do one of the following, whichever is less: (a) pay his/her delinquent amount, as set forth in Ohio Adm.Code 4901:1-18-07(A)(l) and (A)(2); (b) cure any default that he/she may have incurred on a standard payment plan provided pursuant to Ohio Adm.Code 4901:1-18- 05, if the customer is on such a plan; or (c) pay $175 plus a reconnection charge of up to $36 if applicable. Funds for this payment may come in whole or in part from the Winter Crisis Program or other energy assistance programs. {1 11} Reconnection charge: A reconnection charge, as described in Ohio Adm.Code 4901:1-18-07(C), shall not be assessed by the utility company, unless the company has actually disconnected the service. The utility company may assess a collection charge if the collection charge is part of the utility company's approved tariff. {1 12} What is included in the $175: The $175 payment includes any security deposit a utility company may require. The utility company may add the company's approved tariff reconnection charge to this amount, up to $36. ff the company's approved tariff reconnection charge is greater than $36, the balance of the reconnection charge may be billed to the customer the following month. {,r 13} Payment plans and remaining balance with $175 payment: At the time the special reconnection procedures are invoked, a customer who is not enrolled in PIPP Plus who pays the $175 shall be enrolled in a standard extended payment plan provided for in Ohio Adm.Code 4901:1-18-05, or the customer shall be offered all extended payment plans 19-1472-GE-UNC -5- consistent with Ohio Adm.Code 4901:1-18-05 and the procedures for enrollment by the next billing cycle. The utility company shall place the remaining unpaid balance into a standard extended payment plan so that the customer can begin making payment under the terms of the agreed plan beginning with the next billing cycle, as if it were a new plan, subject to the arrearages already incurred. {~ 14} Apportionment of the $175 between regulated utility companies: If the customer's gas and electric service have both been disconnected for nonpayment or have disconnection notices and different utility companies provide these services, the utility companies involved may come to an agreement as to the apportionment of the $175 between them. If an agreement cannot be reached, the utility companies shall apportion the $175 based upon a ratio of the arrearages the customer owes each company. If the same company provides both of these services, then the $175 should be apportioned based upon a ratio of the arrearages the customer owes for each service. {1 15} New service address: A customer requesting service at a new address who has an outstanding balance with the utility company can establish new service upon payment of $175. The customer must also enter into a payment arrangement on the balance before service is connected, in either one of the standard extended payment plans provided for in Ohio Adm.Code 4901:1-18-05(B), or, if eligible, in the PIPP Plus program, whichever is the most appropriate for the customer. If this outstanding balance is a PIPP Plus default, the customer must follow the process set forth in Paragraph 20. {~ 16} New service with no balance and securitv deposit A customer requesting new service with no previous outstanding balance may establish new service upon payment of $175, in lieu of paying the required security deposit, if the required security deposit would be more than $175. When the customer elects this option, the utility company may add the remaining balance of the required security deposit to the customer's next bill. If the required security deposit is less than $175, the utility company shall not count the customer's 19-1472-GE-UNC -6- payment of the lesser amount as the customer's one-time use of the special reconnection procedures described above. {~ 17} Multiple residential accounts: A customer with multiple residential accounts who wishes to utilize the Winter Reconnect Order to maintain or reconnect service may do so only at the property where the customer resides. In addition to payment of $175 to maintain or reconnect service, the customer mustenter into a payment arrangement on the balance of that residential account, in either a standard extended payment plan provided for in Ohio Adm.Code 4901:l-18-05(B), or, if eligible, in the PIPP Plus program, whichever is the most appropriate for the customer. {~ 18} Fraudulent practice or tampering: A customer who has had his/her gas and/ or electric service disconnected due to a fraudulent practice or tampering shall have that service reconnected upon payment for the amount of service obtained fraudulently, plus any investigation fee or nonsufficient fund check charge under the company's approved tariff, plus any defaulted amount not to exceed $175, plus the company's approved tariff reconnection charge, up to $36. H the company's approved tariff reconnection charge is greater than $36, the balance of the reconnection charge may be billed to the customer the following month. {~ 19} Insufficient funds prior to the effect of this Order: The act of a customer who makes payment by check to avoid the disconnection of his/her gas and/ or electric service immediately prior to the start of the special winter heating procedures, and whose check is then returned for insufficient funds after the special procedures are in effect, will be considered a fraudulent practice. A customer under these specific circumstances shall be able to avoid disconnection by paying the amount of the returned check, plus the company's approved tariff return check charge(s), plus any defaulted amount not to exceed $175 prior to disconnection. H the customer's gas and/ or electric service are disconnected, then the procedures set forth in Paragraph 18, for disconnection due to a fraudulent practice, will apply. 19-1472-GE-UNC -7- {,r 20} Reenroll or maintain PIPP Plus or Graduate PIPP Plus: To reenroll or maintain active status in PIPP Plus or Graduate PIPP Plus, a customer will be required to pay the balance of any PIPP Plus or Graduate PIPP Plus default over $175 or over the agreed-upon split amount on or before the due date of the customer's next bill to maintain or be reenrolled in PIPP Plus or Graduate PIPP Plus. Thus, the customer can begin making the established PIPP Plus or Graduate PIPP Plus program payment beginning with the next billing cycle, and be eligible to receive incentive credits for on-time and in-full payments. The time period is not extended to participate in Graduate PIPP Plus. {,r 21} Application for Home Energy Assistance Program (HEAP) required: Households that meet the federal income guidelines must apply for regular HEAP. {,r 22} Procedures for applying for Winter Crisis: A customer who schedules an appointment, as confirmed by fax or electronic communication sent by a Local Delegate Agency (i.e., community action agency, community based organization) to a utility company, in order to apply for Winter Crisis, and who has not utilized the provisions of this Order, shall be granted a reprieve from disconnection until five business days after the appointment. If the utility company has not received confirmation of a Winter Crisis benefit by the start of the sixth business day following the customer's appointment, the utility may proceed with disconnection procedures. The Local Delegate Agency shall also notify the utility company daily by fax or electronic communication concerning any missed appointments. As confirmed by fax or electronic communication sent by a Local Delegate Agency to a utility company, if the customer misses his/her appointment with the Local Delegate Agency, the utility company may proceed with disconnection procedures. {123} Customer notice: Each utility company shall, in writing, by bill insert, or any other form of customer communication, notify its customers whose service continues to be disconnected because of nonpayment that such customers may have their service restored consistent with the procedures set forth herein. 19-1472-GE-UNC {124} Notice to customers inquiring about disconnection or payment arrangements: Utility companies must inform a residential customer of the payment plan options under Ohio Adm.Code 4901:1-18-05, or similar provisions, and other available payment plans and options for financial assistance, as well as all of the payment plan options provided by the Commission herein, when the customer contacts the utility company concerning the disconnection of service or payment arrangements. {~ 25} Customers not utilizing the Order: With regard to the maintenance or reconnection of service for existing customers who do not utilize the special reconnect procedures, the Commission notes that the intent of the special reconnection procedures is to permit customers, with an outstanding balance greater than $175, who have been disconnected or who are facing disconnection, to pay less than their balance to have their service restored or maintained. Therefore, when an existing residential customer makes a payment of less than $175, which cures any default previously owed to the utility company in order to maintain service, or requests reconnection of service, the utility company shall not count this payment as the customer's one-time use of the special reconnection procedures. t, 26} Reconnection process to be followed: With regard to reconnection of service, the utility company involved shall reconnect service as described in Ohio Adm.Code 4901:1- 18-0?(A) and (B), which provides that a customer whose service has been disconnected for nonpayment for ten business days or less can request service be reconnected the same business day by providing proof of payment by 12:30 p.m. ff payment is made after 12:30 p.m., the service will be reconnected the following business day. However, where a customer's service has been disconnected for nonpayment for more than ten business days, the reconnection of the customer's service will be scheduled as if it is a request for new service in accordance with Ohio Adm.Code Chapters 4901:1-10 and 4901:1-13. 19-1472-GE-UNC -9- {,r 27} Enforcement of these procedures: If the Commission determines that a utility company is not following these procedures, we will take those steps we deem appropriate to protect the customers served by that utility. {,r 28} Collaboration with nonregulated utilities: The Commission recognizes that its jurisdiction does not extend to those utilities owned or operated by municipalities, nor do we regulate cooperatives. However, we hope these entities will adopt the program laid out above so that together we can limit the number of Ohioans who will suffer from a lack of heat this winter. B. Application for Energy Assistance and Weatherization Programs {,f 29} Ohio Adm.Code 4901:1-18-12(C) requires anyone applying for the PIPP Plus program to also apply for all energy assistance and weatherization programs for which he/ she is eligible. Included among these programs is the Home Weatherization Assistance Program, the largest weatherization program in the state of Ohio. {,I 30} The Commission finds that the utility companies subject to the jurisdiction of this Commission should continue to assist the Ohio Development Services Agency (ODSA) by providing the data requested in ODSA' s customer information report. {,I 31} As a final matter, the Commission notes that PIPP Plus program customers are required to apply for weatherization services. If a customer refuses weatherization, he/ she will be removed from the PIPP Plus program: C. Data Collection {132} In order to monitor and gather data to aid the Commission in evaluation of winter heating season disconnections of service, the Commission needs to collect data on all disconnection, including non-heating season disconnection. We need to track the number of customers who have gas and/ or electric service reconnected each month, the types of payment plans entered into, and the length of time that customers were without gas and/ or 19-1472-GE-UNC -10- electric utility services. To aid us in making winter heating season determinations regarding the public interest, each utility company under the Commission's jurisdiction is directed to complete the Winter Reconnect Order Report, attached to this Finding and Order as Appendix A, and electronically submit it to Staff each month. Each utility company, with the exception of small gas companies, should upload its Winter Reconnect Order Report data to the Commission's database by the 20th of the following month, except that data for October 2019 shall be reported with the data for November 2019. Small gas companies should file monthly data by either uploading their Winter Reconnect Order Report data to the Commission's database or through the Excel template provided by the Commission. Also attached to this Finding and Order is Appendix B, in which Staff summarizes and analyzes information submitted by the utility companies to the Commission for the 2018- 2019 winter heating season. Ill. ORDER {1 33} It is, therefore, {1 34} ORDERED, That, effective no later than October 14, 2019, each utility company under the Commission's jurisdiction shall restore the service of those customers whose gas or electric utility service has been disconnected for nonpayment, in accordance with the terms set out in this Order. It is, further, {1 35} ORDERED, That, effective no later than October 14, 2019, each utility company under the Commission's jurisdiction shall maintain the service of those customers who have received a notice that their service is to be disconnected for nonpayment, in accordance with the terms set out in this Order. It is, further, {136} ORDERED, That, effective no later than October 14, 2019, each utility company under the Commission's jurisdiction shall establish service for customers who request new service, in accordance with the terms set out above. It is, further, 19-1472-GE-UNC -11- t, 37} ORDERED, That the utility companies comply with the Commission's directives set forth in this Finding and Order. It is, further, {1 38} ORDERED, That the special procedures in this Order to maintain, reconnect, or establish service are available to a customer only once from October 14, 2019, through April 15, 2020. It is, further, t, 39} ORDERED, That each utility company under the Commission's jurisdiction provide the data requested in Paragraph 32 and Appendix A to this Finding and Order, for the preceding month by the 20th day of the following month, except that data for October 2019 shall be reported with the data for November 2019. It is, further, {140} ORDERED, That a hard copy of this Finding and Order be served upon each gas company, natural gas company, and electric distribution utility, and all other interested persons of record. It is, further, {141} ORDERED, That a copy of this Finding and Order be sent to the electricenergy and gas-pipeline industry service lists. COMMISSIONERS: Approving: Sam Randazzo, Chairman M. Beth Trombold Lawrence K. Friedeman Daniel R. Conway Dennis P. Deters JML/hac CASE NO. 19-1472-GE-UNC Winter Reconnect Order (WRO) Report Customer Profile of WRO Use Appendix A A) Number of Total Residential Customer Accounts B) Number of Total PIPP Accounts C) Number of non-Pl PP Accounts D) Number of customers on extended payment plans E) Total number of residential customer accounts that used WRO a. Percent of residential customers using WRO F) Number of PIPP customer accounts that used WRO a. Percent of PIPP customers using WRO G) Number of non-Pl PP customer accounts that used the WRO a. Percent of non-PIPP customers using WRO H) Number of non-Pl PP customer accounts that used WRO and received Winter Crisis I) Number of customers on extended payment plans that used WRO a. Percent of customers on extended payment plans that used WRO Reasons for WRO Use J) PIPP Customer Accounts that used WRO 1) Avoid Disconnection 2) Re-establish service 3) Percent used to avoid disconnection 4) Percent used to re-establish service K) Non-Pl PP Customer Accounts that used WRO 1) Avoid Disconnection 2) Re-establish service 3) Establish service for a new customer 4) Percent used to avoid disconnection 5) Percent used to re-establish service Enrollment on PIPP or Extended Payment Plan Upon WRO Use L) Number of customers placed on extended payment plan within 30 days of invoking use of WRO M) Number of customers newly enrolled in PIPP within 30 days of invoking use of WRO Arrearage Balance Upon WRO Use N) Non-Pl PP Only: The payment plan dollar amount entered into as a result of the WRO 0) PIPP Only: The dollar amount added to PIPP Arrearage Length of Time Without Service Upon WRO Use P) Number of customers disconnected for 10 days or fewer Q) Number of customers disconnected for 11-30 days R) Number of customers disconnected for 31-90 days S) Number of customers disconnected for 91 days or more CASE NO. 19-1472-GE-UNC AppendixB WINTER RECONNECT ORDER REPORT & WINTER RECONNECTION ORDER RECOMMENDATIONS FOR 2019-2020 By Service Monitoring and Enforcement Department Public Utilities Commission of Ohio CASE NO. 19-1472-GE-UNC Appendix B Introduction The following report is an analysis of the Winter Reconnect Order (WRO) data submitted for the 2018-2019 winter heating season. Staff was asked to examine the data regarding customers who used the winter procedures ordered by the Commission to avoid disconnection or to reconnect gas and/or electric service during this time. Facing the prospect of losing utility service or continuing without service during the cold weather months constitutes an emergency for Ohio families. This situation has caused the Commission to issue a WRO each year since 1984. The following report is an analysis of data submitted to the Public Utilities Commission of Ohio by the following utility companies: Arlington Natural Gas Cleveland Electric Illuminating (CEI) Columbia Gas of Ohio (CGO) Dayton Power and Light (DP&L) Dominion East Ohio Gas (DEOG) Duke Energy Ohio (Duke) Eastern Natural Gas (ENG) KNG (KNG) Northeast Ohio Nat. Gas (NEOG) Ohio Edison (OE) Ohio Gas (OG) Ohio Power (OP) Piedmont Natural Gas (Piedmont) Pike Natural Gas (Pike) Sheldon Gas (Sheldon) Suburban Natural Gas (SNG) Swickard Gas (Swickard) Vectren Energy Delivery of Oho (VEDO) Toledo Edison (TE) Each of the above utility companies submitted a WRO metrics (Appendix A 18-1204-GE-UNC) containing information relating to the customers who used the winter reconnect procedures. The following numbers represent the sum totals for the above companies for the term of the winter reconnect procedures effective October 15, 2018 through April 15, 2019: • Total number of residential customers who avoided disconnection or re-established service using the WRO: 219,694 • Total number of residential customer accounts that used the WRO to avoid disconnection: 165,277 • Number of non-PIPP customer accounts that used the WRO: 157,371 • Number of PIPP accounts that used the WRO: 62,232 • Number of non-Pl PP customer accounts that used the WRO and received E-HEAP: 7,899 • Number of customers on extended payment plans that used the WRO: 72,484 • Number of customers newly enrolled in PIPP Plus within 30-days of invoking the WRO: 12,603 • Number of customers placed on an extended payment plan within 30-days of invoking the WRO: 99,212 • Dollar amount owed for non-Pl PP customers after the $175 has been paid: $85,597,459.20 • Number of customers disconnected for 10 days or fewer: 22,009 • Number of customers disconnected for 11-30 days: 2,369 • Number of customers disconnected for 31-90 days: 3,995 • Number of customers disconnected for 91 days or more: 14,342 WINTER RECONNECT ORDER REPORT This report examines the number of customer accounts that used the WRO during the 2018-2019 winter heating season. The 2018-2019 data indicates that of the approximately seven million residential customers in Ohio served by regulated utilities 219,694 (3 percent) customer accounts benefited from the WRO. The data further indicates that of the 219,694 customers who utilized the WRO, 75 percent did so in order to avoid disconnection; therefore, they never went without service. Of the customers (42,713) who were actually disconnected, 52 percent (22,009) were able to reconnect service within ten days under the terms of the WRO. DATA ANALYSIS This section of the report includes charts depicting staff's analysis of the data the utility companies provided concerning the 2018-2019 winter heating season (October 15, 2018-April 15, 2019). Chart 1 below reflects participation levels over the last five winter heating seasons. During the most recent winter season, 219,694 households utilized the WRO. Overall, the number of customers who have utilized the WRO over the last five winter heating seasons has decreased by 20 percent and PIPP Plus utilization has decreased by 32 percent. The decrease in PIPP Plus utilization of the WRO may be a direct result of the overall decrease in PIPP Plus enrollment since 2014-2015. 3 Chart 1 i l 300,000 Number of Customers who Utilized the WRO 270,893 250,000 200,000 150,000 100,000 50,000 246,170 228,561 217,494 219,694 I I 0,270 I 2,323 I Year 2014-2015 Year 2015-2016 Year 2016-2017 Year 2017-2018 Year 2018-2019 • Total Number of Customers who Utilized the WRO • PIPP Customers who Utilized WRO Chart 2 below compares the average number of residential accounts to the number of accounts (per utility) who utilized the WRO. In comparison to the actual number of accounts per utility the number of customers who utilize the WRO is relatively small. However, without the benefit of the WRO, these customers would have either lost their utility service or been unable to have service reconnected without full payment of the past due amount. 1,600,000 1,400,000 1,200,000 1,000,000 800,000 669,646 600,000 400,000 200,000 0 0,952 CEI Chart 2 Residential Customer Accounts who Utilized WRO 467,408 0,087 DPL 6,974 OE 1,303,624 ,466 OP 275,269 ,653 TE ,399 CGO • Average Number of Residential Customer Accounts l,,118,673. - DEO 8 Total Number of Residential Customer accounts that used WRO 300,793 ,736 Vectren 667,203 ,7Ti Duke Chart 3 illustrates the number of customers (by utility type) who were able to avoid disconnection as compared to the number of persons who utilized the Winter Reconnect Order to reconnect services that had already been disconnected. Of the total number of customers (219,694) who 4 utilized the WRO, only 19 percent (42,713) were without utility service prior to the use of the Winter Reconnect Order. The majority of customers who use the WRO did so to maintain utility service, thereby eliminating the need for the utility to dispatch a technician to disconnect service and then return to reconnect service once the $175 is paid. This feature of the Winter Reconnect Order reduces overall costs to the rate payer. 100,000 80,000 60,000 40,000 20,000 Chart 3 Customers who Reconnected Service vs. Customers who Maintain Service (By Utility) Gas Accounts Electric Accounts Duke Energy Accounts • Reconnect Service • Maintain Service Chart 4 below reflects the number of non-Pl PP Plus customers vs. the number of PIPP Plus customers who utilized the winter reconnect order. Of the 219,694 customers who utilized the WRO, only 28 percent (62,317) were enrolled on PIPP Plus at the time they used the WRO. The majority of the customers (72 percent) who used the WRO were non-Pl PP Plus customers. These non-PIPP Plus customers (157,371) would have either lost their utility service or been unable to have service reconnected without the WRO. Additionally, of the 157,371 non-Pl PP Plus customers who benefitted from the WRO, 7,899 received assistance through the winter crisis program. These 7,899 customers were above the income qualifications for PIPP Plus (150 percent) but below the 175 percent of the federal poverty guidelines. This group is often referred to as the "working poor'. 5 80,000 70,000 60,000 50,000 40,000 30,000 I 20,000 10,000 Chart 4 Type of Customer Account who Utilized the WRO 73,594 69,493 14,284 728 ~ 488 471 Electric Gas Duke • Number of non-Pl PP customer accounts that used WRO • Number of PIPP customer accounts that used WRO Number of non-Pl PP customer accounts that used WRO and received Winter Crisis Chart 5 below represents the percentage of payments received from active ( electric and gas) PIPP Plus customers since 2013. PIPP Plus customers are now making more consistent payments and benefitting from the arrearage crediting incentives which has directly reduced the number of PIPP Plus customers who utilize the WRO. Chart 5 Percentage of PIPP Plus Installments Received 90% 79% 80% 77% 78% 79% 79% 79% 70% 60% 50% 40% 30% 20% 10% 0% 2013 2014 2015 2016 2017 2018 8 Percentage of Active Electric PIPP Plus Payments • Percentage of Active Gas PIPP Plus Payments LENGTH OF DISCONNECTION The data below indicate that natural gas customers tend to remain without service longer than electric customers, specifically during the summer months. While 47 percent of natural gas customers were without service for more than 91 days, only 12 percent of electric customers fall in this same category. Of the Duke Energy customers who utilized the WRO to reconnect service, 6 92 percent (electric and gas) reconnected in ten days or less. This further suggests that people find gas service to be more expendable than electric service during the summer months. Chart 6 below reflects the amount of time that gas, electric, and Duke Energy ( combination utility) customers were out of service before using the WRO to have their service reconnected. As the chart indicates, 80 percent of the reconnected electric customers had been without service for 1 O days or less, compared to 33 percent of the reconnected gas customers had been out of service for that same length of time. If customers had been without service for more than ten days, they tended to stay off longerand not reconnect service until after 91 days had passed suggesting that these customers rely on the use of the WRO. Of those disconnected, 12 percent of electric customers and 4 7 percent of gas customers were without service more than 91 days prior to using the Winter Reconnect Order to regain service. In the Duke Service territory, however, only 6 percent of its combination utility customers were without service for more than 91 days. As shown in the bar chart, 92 percent of Duke's customers re-establish their service within ten days or less. Chart 6 Average Time Customers Were Without Utility Service 100% 0 90% 80% 80% 70% 60% 50% 40% 30% 20% 10% 0% Days 91 AMOUNT OWED AFTER USE OF WINTER RECONNECT ORDER • Electric a Gas Duke Chart 7 and Chart 8 below depict the average amount owed per non-PIPP Plus customer after making the $175 payment. The average amount owed by non-PIPP Plus electric customers after using the WRO was $720 while the average amount owed by non-Pl PP Plus gas customers after using the WRO was $337. Non-PIPP Plus customers who utilize the WRO are required to enroll on an extended payment plan to cure any remaining debt owed to the utility company. Non-Pf PP Plus customers have the option of enrolling on the 1/61h payment plan, the 1/91h payment plan or the winter heating season plan. Pf PP Plus customers are required to pay the balance of their defaulted PIPP Plus installments by the due date of the next bill in order to re-join Pf PP after utilizing the WRO. 7 Chart 7 Average Amt. Owed per Non-PIPP Plus Customer after $175 (Electric Companies) $1,000.00 ...--.................. ~----8=52~_~23------------------$ 811.16 $800.00 $600.00 $400.00 $200.00 $0.00 Toledo Edison Ohio Power Ohio Edison Dayton Power & Cleveland Electric Light Illuminating Chart 8 Average Amt. Owed per non-PIPP Plus Customer after WRO (Gas Companies) $900.00 -.------------------------------- $800.00 - - -----~------------------------ $700.00 -i-----------t· $600.00 -i------~==-t; $500.00 -i-------$ 400.00 -i-------$ 300.00 -i-------$ 200.00 $100.00 $0.00 (:P* 0 *Columbia Gas data reflects the amount that the customer owed in order to enroll in the payment plan not the actual total account balance. Duke customers, which does not appear in either of the Gas or Electric charts above, had an average amount owed of $848 after the $175 payment. 8 CONCLUSIONS AND RECOMMENDATIONS As in past years, Staff is concerned about those customers who, because of limited financial resources, are either facing disconnection because of arrearages that they are unable to pay or who are going into the winter without gas and/or electric service. Energy utility service is vital to Ohioans, especially during the winter months. Approximately 7 percent (6,700) of the gas customers who utilized the WRO are considered the ''working poor" (income fell between 151 percent and 175 percent of the Federal Income Guidelines). According to the Ohio Poverty Report issued by the Ohio Development Services Agency (February 2019), an estimated 14;6 percent of Ohio families are poor based on the federal income guidelines. Therefore many Ohioans have come to rely on the availability of the WRO as the only option when facing a financial crisis to maintain utility service during the winter months. By reissuing the WRO, gas and electric utility customers will have the opportunity to maintain or reestablish their energy service during the winter months. It is for these reasons that staff recommends that the Commission issue the WRO for the 2019- 2020 winter heating season, which will allow customers to use the winter procedures to avoid disconnection or to reconnect gas and/or electric service once during that period. Customers who wish to maintain or rejoin participation in PIPP Plus must pay the balance of any PIPP Plus default above $175. PIPP Plus customers will be held responsible for full payment of their PIPP Plus installments to re-join PIPP Plus. The Winter Reconnect Order should begin October 14, 2019, allowing non-HEAP eligible customer's adequate time to reestablish service with their utility company prior to the release of federal funds. This additional time will also ease the reconnection scheduling burden for the utility companies. The Home Energy Assistance Program (HEAP) winter crisis program will begin on Friday, November 1, 2019. Accordingly, Staff recommends, based upon the information provided, that the Commission again issue the Winter Reconnect Order with the following specifications: 1. Reissue the Winter Reconnect Order for the 2019-2020 winter heating season (Monday, October 14, 2019 through Wednesday, April 15, 2020) and set the ceiling amount to retain or reestablish utility service at $175 (which aligns with the available ceiling amount of the Winter Crisis program), plus any applicable reconnection charge (not to exceed $36 per utility). If the tariffed reconnection charge is more than $36, the balance may be billed to the customer the following month. PIPP Plus or PIPP Plus eligible gas or electric customers should be allowed to retain or reconnect service for a payment of $175. To re-join PIPP Plus, if the customer has a PIPP Plus default amount that is more than $175, the customer would be responsible for paying the remaining balance of the PIPP Plus default. The customer should begin paying either his/her established PIPP Plus amount or the terms of the agreedupon, extended payment plan by the due date of the customer's next bill. Extended payment plans should be as prescribed in Ohio Administrative Code (Ohio Adm.Code) 4901:1-18-05. 9 2. If the customer's gas and electric service are threatened with disconnection or are disconnected for nonpayment and different utility companies provide these services, the utility companies involved should split the $175 (either by apportionment based on the arrearages or split equally between the two utilities). For Duke customers who receive both gas and electric service from the company, the $175 should be apportioned based upon a ratio of the arrearages the customer owes for each service. To re-enroll or maintain active status in PIPP Plus, customers should be required to pay the balance of any PIPP Plus default above $175 or above the agreed-upon split amount (per utility) by the due date of the customer's next bill. Thus, the customer could begin making the established PIPP Plus program payment beginning with the next billing cycle, and be eligible to receive incentive credits for on-time and in-full payments. The customer should begin paying either his/her established PIPP Plus amount or the terms of the agreed-upon, extended payment plan during the next billing cycle. Extended payment plans are prescribed in Ohio Adm.Code 4901 :1-18-05. 3. The $175 should cover any deposit amount required by the utility company. Customers who are requesting new service with no previous balance may utilize the Winter Reconnect Order to pay the required security deposit if it is more than $175. In those cases where the deposit is more than $175, the customer may pay $175 to be reconnected and the balance may be billed to the customer the following month. The customer will be connected per Ohio Adm.Code 4901:1-13-05{A) for gas and 4901 :1-10-09(A) for electric. 4. Any former PIPP customer with PIPP arrears, who is income eligible for PIPP Plus but was not put on the program as of November 1, 2010, should have service reconnected for $175 (The $175 could be split between gas and electric.) This customer can join PIPP Plus, and the utility should place the remaining unpaid balance into the PIPP Plus program arrears, which may be eligible for recovery through a rider. 5. Graduate PIPP Plus customers should be allowed to retain or restore utility service with a payment of $175. If the Graduate PIPP Plus customer has a default amount that is more than $175, he or she would be responsible to pay the balance of any default in excess of $175, or the agreed-upon split amount (per utility) by the due date of the customer's next bill to re-join Graduate PIPP Plus. The time period should not be extended to participate in the Graduate PIPP Plus. 6. A customer who either owes a deposit or has an outstanding balance of less than $175 should not be considered to have utilized the Winter Reconnect Order, which is intended to allow customers who owe more than $175, and who are disconnected or are facing disconnection, the opportunity to pay a lesser amount than what is owed. 7. A customer with multiple residential accounts who wishes to utilize the Winter Reconnect Order to maintain or reconnect service should be allowed to do so only at the property where the customer resides. 10 8. A customer, who has an outstanding balance and is requesting new service at a new location, should be allowed to establish new service upon payment of $175, but should be required to enter into a payment arrangement for the balance. Service should be connected per Ohio Adm.Code 4901 :1-13-05(A) for gas and 4901:1-10-09(A) for electric. 9. Utility companies should be required to inform customers of the availability of the Winter Reconnect Order by bill insert or bill message. The utilities should be allowed to supplement that bill insert/bill message with additional forms of customer communication. 10. Utility company customer service representatives should be required to inform any customer who contacts the company regarding disconnection of service or payment arrangements of all the options provided in the Winter Reconnect Order, as well as other available payment plans and sources of financial assistance the company may wish to offer to better serve its customers. 11. At the time the special reconnection procedures are invoked, a customer who is not enrolled in PIPP Plus who pays the $175 shall be enrolled in a standard extended payment plan provided for in Ohio Adm.Code 4901:1-18-05, or the customer shall be offered all extended payment plans consistent with Ohio Adm.Code 4901:1-18-05 and the procedures for enrollment by the next billing cycle. 12. The Winter Reconnect Order should apply to all residential customers (with the exception of customers disconnected for fraudulent practice or tampering) who owe a previous debt to the company. 13. Utility companies should be required to re-establish the service of customers disconnected for fraudulent practice or tampering provided that the customers pay for any fraudulently obtained service; any tariffed investigation fee; any defaulted amount not to exceed $175; and a tariffed reconnect fee of no more than $36 per utility. If the tariffed reconnect fee is more than $36, the balance may be billed to the customer the following month. 14. The Winter Reconnect Order should be used not more than one time per customer during the effective dates of Monday, October 14, 2019 through Wednesday April 15, 2020. 15. Utility companies should be required to delay disconnection (if the customer has not utilized the Winter Reconnect Order) until five business days after the date of the customer's confirmed appointment with any community action agency (as designated by the Ohio development services agency) to administer the winter crisis program. If the utility does not receive confirmation of a winter crisis benefit at that point, the utility should be allowed to proceed with disconnection. 16. The utility companies should reconnect service as currently prescribed in Ohio Adm.Code 4901 :1-18-07(A) & (8)(1). 11 17. On a monthly basis, large utility companies should be required to submit the Winter Reconnect Order Metrics report to Commission Staff (with applicable data collected from Monday, October 14, 2019 through Wednesday, April 15, 2020. 18. On a monthly basis, the small gas companies should be required to submit the Winter Reconnect Order report to Commission Staff (with applicable data collected from Monday, October 14, 2019 through Wednesday, April 15, 2020 via an Excel template provided by the Commission. 12