Recently, Ohio residential consumer advocates were invited by the Public Utilities Commission of Ohio (PUCO to file comments of on the rules governing the connection, disconnection and reconnection of gas and electric service and Ohio’s low income assistance program the Percentage of Income Payment program Plus (PIPP Plus) as part of the PUCO’s five-year review. Collectively, the consumer advocates are the only voice for everyday residential consumers before the PUCO, who makes and enforces rules regarding: utility security deposits, appropriate proof of consumer creditworthiness, and the timing and manner of shut off notices. This case is the only place where advocates can make recommendations on behalf of low- income customers who depend on the PIPP Plus program to get and/or remain connected to their utility to have heat and lights. These rules affect over 7 million customers who get gas or electric utility service from one of the regulated utilities in Ohio such as Duke, First Energy, AEP, or Columbia Gas, to name a few.

Consumer advocates urged the adoption of rules or changes to the rules in order to protect customers and maintain service without undue harm to utilities. In addition, the advocates made recommendations to improve PIPP Plus, which makes electric and gas payments affordable for low income Ohioans. The PIPP Plus program was created almost 3 years ago when the “Plus” was added to the existing PIPP program to provide arrearage forgiveness to many residents who had built up significant utility debt. The consumer advocates made the following recommendations for the Credit and Connection rules:

•  Reduce utilities’ use of Social Security numbers to reduce the risk of identity theft
•    Make security deposit requirements reasonable and affordable
•  Connect service within a reasonable time after a request for service has been made

Similarly, the advocates also offered suggestions when disconnection or reconnection of service is an issue:

•   Forbid landlords from using utility shut-offs to force tenants to move
•  Require reconnection soon after payment is received if service is disconnected for nonpayment
•   Make tenants liable only for service for the times that they actually rent and occupy a unit
•   Create uniform rules and allow online access to forms for both residents with health emergencies and their healthcare providers to request temporary waivers of payment during health emergencies

 This is only a sample of suggestions made by the consumer advocates. Click here and here to see all of the topics covered.  Use this link to see the current rules and the rule changes proposed by the Staff of the PUCO.

 As mentioned previously, consumer advocates also made numerous recommendations to improve the PIPP Plus program, such as:

•  Maintain a hardship exemption to waive the $10 minimum payment for up to six months
•  Allow customers the benefits of arrearage forgiveness if they fully or partially pay in advance
•  Extend the time periods for customers cycling off PIPP Plus (for whatever reason) to provide payment schedules that are reasonable and affordable
• Allow the transfer of delinquent accounts to a PIPP Plus account
•  Provide a more expansive definition of “on-time payment.”

 Our positive recommendations will only improve the current rules, and we hope that the PUCO agrees and adopts many of these recommendations. The consumer advocates who jointly submitted comments include: the Ohio Poverty Law Center (OPLC) as well as most of the legal aid programs in Ohio, the Ohio Partners for Affordable Energy (OPAE), the Ohio Consumers’ Counsel (OCC), the Citizens’ Coalition, the Coalition of Homelessness and Housing in Ohio (COHHIO), the Ohio Association of Area Agencies on Aging (OAAA), the Ohio Association of Community Action Agencies (OCAA), and the Ohio Association of Food Banks.