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<br />similar size should not be permitted. All charges that are not directly related to the local <br />distribution or transmission of electricity should be bypassable by govemmental aggregation <br />customers. This would enhance the opportunity that a choice for aggregation customers will <br />be available in Ohio in the future. <br />B. Eliminate Deferrals. Ohio utilities have a history of seeking full collection of <br />mairy costs, only to moderate their request by offering to defer a portion of the charges. If the <br />utilities Nvant to include new iion-bypassable charges for generation, fuel, generation <br />iilvestments, or other items that have been deferred, Ohio should recognize the very <br />significant costs already paid by consumers through transition charges since 2001. Govellior <br />Striclcland's plan recognizes these sizable costs already paid by Ohio ratepayers. While <br />retul°ning to cost-of-service regulation may not be practical or possible, consluners have paid <br />utilities billions towards paying off utility assets over the past 7 years. Any new increases, <br />even those tied to past deferrals, must be moderated to recognize the costs already paid by <br />Ohio i-atepayers. <br />C. True-up. Any future charges, caps, or deferrals applied to Ohio electric <br />consumers' biils sllould include true-up or re-loolc audit mechanisms to ensure consumers are <br />not being overcharged. If audits had been in place during the past seven years, utilities' <br />?vindfall reveilues may liave been moderated. <br />D. Extended Period. Goverlunental opt-out aggregatars cltrrently must provide <br />customers an opportunity to exit the aggregation without penalty every 2 years. Our <br />experience has beeil that consLimers who initially choose to participate in the aggregation <br />choose to continue in the aggregation every 2 years at an extraordinarily high rate. The net <br />1-esult is that this provision limits the govemmental aggregators' ability to secure longer term <br />supply arrangements that could be highly beneficial to these consumers. Extending the opt- <br />out perioci to up to 5 years would provide Ohio's govemmental aggregators additiorlal <br />opportunities to secure constimers' savings. <br />E. No governmental aggregator switching fee. In the past, opt-out governmental <br />ag)gi-egators were cllarged switching fees that other groups or consumers did not pay when <br />consumei•s chose to participate in the aggregation. This is a barrier to market entry. For <br />NOPEC alone, the initial switching fee is $2.5 million, for simply malcing a computer change <br />on the bills. NOAC and NOPEC believe this switching charge is not justified, is <br />discriminatory and serves only to benefit the utilities and reduce competition. <br />F. Revisit Utility Tariffs. The PUCO should revisit utility tariffs to enstu-e that <br />market barriers to govemmental aggregation are removed. Items such as payment, bad debt <br />expense, stay-out periods for enrolling customers and others need to be reviewed to promote <br />governinental aggregation. <br /> <br />.,. , ,A-. , ?,?<, 11,e . .: .: <br />.?.? . _ _ _