Working on my first deregulated market audit here in Ohio. Client is a packaging plant in Fargo ND but they have a facility in Columbus OH served by AEP Ohio for delivery with an alternate supplier for generation. I submitted my LOA to AEP Ohio and they sent me the delivery charges portion of the bills. But the supply charges are billed by the competitive supplier, and they're telling me I need a separate authorization from the client directed to them. Is that right? Do I really need two LOAs for one electric account?
LOA confusion in deregulated states — utility vs supplier vs both?
Yes, that's how it works in Ohio and most deregulated states. The utility (AEP Ohio in your case) handles the delivery — wires, meters, distribution charges. The competitive supplier handles generation. They're separate companies with separate billing systems. Some suppliers do consolidated billing where everything shows on one bill, but you still need authorization from both entities to get detailed data. Same deal in Connecticut with Eversource for delivery and whatever supplier the customer chose. It's annoying but it's the reality of deregulated markets.
I deal with this constantly in Ohio. Here's my system: I have three LOA templates. One for the local distribution utility, one for the competitive supplier, and one master that covers both. For the master I include language that says the client authorizes release of all billing, usage, demand, and contract information from "any and all energy suppliers, distribution utilities, and service providers associated with the accounts listed below." Then I send that master to both parties. AEP Ohio has always accepted it. Some suppliers push back and want their own form but most don't.
In Texas it's even more complicated. You've got the REP, the TDU (like Oncor or CenterPoint), and sometimes a separate demand response aggregator. The TDU has the meter data and interval data. The REP has the billing data and contract terms. And the contract terms with the REP are often confidential — some REPs will refuse to release pricing details even with an LOA, claiming it's proprietary. I've had to get clients to request their own contract copies directly from the REP and hand them to me. Pain in the neck but the supply-side savings on a bad contract can dwarf the delivery-side findings.
This thread highlights one of the key differences between regulated and deregulated market auditing. In regulated states you have one utility, one LOA, one data source. In deregulated states you may need two or three authorizations per account just to get a complete picture. My advice for anyone getting into deregulated market auditing: build a checklist for each state you work in. List every entity you need authorization from and what data each entity controls. Ohio is different from Texas is different from Pennsylvania is different from Illinois. Don't assume what works in one state transfers to another.
Thanks everyone. I ended up getting separate LOAs for AEP Ohio and the supplier. Took an extra two weeks but now I have both the delivery and supply data. Already found that the supplier contract has a demand ratchet clause the client didn't know about — they're paying for peak demand from last July on every bill even though current demand is 30% lower. That alone is costing them about $2,800/month. Wouldn't have found it without the supplier data.