Update: Amidst the backdrop of the PUCO’s PowerForward discussion on the future of electricity, OMAEG this week filed the testimony of OMAEG witness John Seryak opposing AEP Ohio’s plans for microgrids, renewable energy, submetering, and electric vehicle charging stations. Seryak’s testimony pointed to concerns with AEP Ohio’s request to own assets that are currently obtainable through competitive markets; the lack of time-of-use pricing with the advanced technologies; and the dearth of details, as well as the undefined, unlimited estimated costs to customers (including capital costs, carrying costs, and ongoing operation and maintenance costs).

• AEP Ohio is requesting to purchase and own 1,275 electric vehicle charging stations, at an expense to customers of $6.4 million in direct costs, with $775,000/year of ongoing O&M costs. AEP Ohio’s presumptive request to own charging stations fails to respect that charging stations can be owned and operated by competitive businesses and individual citizens. AEP Ohio would also provide free electricity for its 275 public charging stations, charging the cost of the free electricity back to other customers. Electric vehicles have long been recognized for having the ability to store electricity, and thus charge during off-peak hours when electricity is cheap. The benefit of electric vehicles to Ohio’s ratepayers would be highly dependent on this time-of-use charging. However, AEP Ohio’s plans would have no price signal to encourage off-peak charging.
• AEP Ohio is requesting to purchase, own, and operate 8-10 microgrids at an expense to customers of $52 million in direct costs, with $1.5 million/year of ongoing O&M costs. As part of its request, AEP Ohio would be allowed to own customer-sited small-scale solar generation systems, renewable energy, and batteries, while recovering the costs from other customers. Customers behind the microgrid would not necessarily benefit financially, nor would ratepayers, as AEP would not operate the microgrid based on electric grid prices, but instead would charge net energy production from the microgrid as “unaccounted for energy.”
• AEP Ohio is also requesting cost recovery for above-market charges for costs associated with future renewable energy projects, which AEP Ohio and its affiliates could own. AEP did not estimate the potential cost to customers. The cost recovery mechanism would not by bypassable and could force customers to pay twice for a portion of their electricity.
• AEP Ohio is also requesting cost recovery for the speculative acquisition of the infrastructure associated with submetering complexes, including an allowance for a financial return on this purchase. The submetering infrastructure may have already been paid for, and provided a profit too, their current owners. If originally constructed by AEP Ohio, the infrastructure may have also been paid for by customers.