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customers. This would enhance the opportunity that a choice for aggregation customers will be available in Ohio in the future. B. Eliminate Deferrals. Ohio utilities have a history of seeking full collection of many costs, only to moderate their request by offering to defer a portion of the charges. If the utilities want to include new non-bypassable charges for generation, fuel, generation investments, or other items that have been deferred, Ohio should recognize .the very significant costs already paid by consumers through transition charges since 2001. Governor Strickland's plan recognizes these sizable costs already paid by Ohio ratepayers. While returning to cost-of-service regulation may not be practical or possible, consumers have paid utilities billions towards paying off utility assets over the past 7 years. Any new increases, even those tied to past deferrals, must be moderated to recognize the costs already paid by Ohio ratepayers. C. True-up. Any future charges, caps, or deferrals applied to Ohio electric consumers' bills should include true-up or re-look audit mechanisms to ensure consumers are not being overcharged. If audits had been in place during the past seven years; utilities' windfall revenues may have been moderated. D. Extended Period. Governmental opt-out aggregators currently must provide customers an opportunity to exit the aggregation without penalty every 2 years. Our experience has been that consumers who initially choose to participate in the aggregation choose to continue in the aggregation every 2 years at an extraordinarily high rate. The net result is that this provision limits the governmental aggregators' ability to secure longer term supply arrangements that could be highly beneficial to these consumers. Extending the opt- out period to up to 5 years would provide Ohio's governmental aggregators additional opportunities to secure consumers' savings. E. No governmental aggregator switching fee. In the past, opt-out governmental aggregators were charged switching fees that other groups or consumers did not pay when consumers chose to participate in the aggregation. This is a barrier to market entry. For NOPEC alone, the initial switching fee is $2.5 million, -for simply making a computer change on the bills. NOAC and NOPEC believe this switching charge is not justified, is discriminatory and serves only to benefit the utilities and reduce competition. F. Revisit Utility Tariffs. The PUCO should revisit utility tariffs to ensure that market barriers to governmental aggregation are removed. Items such as payment, bad debt expense, stay-out periods for enrolling customers and others need to be reviewed to promote governmental aggregation. zis7oz9vi