AGR 00005

Question: According to the Master SSO Supply Agreement, the SSO load excludes "PIPP" customers. Can you provide details of the PIPP program and the rules for customers switching from SSO to PIPP and back?

Answer: Percentage of Income Payment Plan (PIPP) is an extended payment arrangement that requires electric companies to accept payments based on a percentage of the household income. As a part of the Universal Service Fund program enabled by Ohio Substitute Senate Bill 3, the Deparment of Ohio Development will administer the PIPP for electricity customers. Please see the following link for further details: http://development.ohio.gov/is/is_pipp.htm

If/when a customer would leave the PIPP program, they would be able to become an SSO customer or shop with a Competitive Retail Electric Service (CRES) supplier.

AGR 00011

Question: Who is the SSO Supplier's counterparty to the Master SSO Supply Agreement and is there a single contract or three?

Answer: The SSO Supplier's counterparty to the Master SSO Supply Agreement is the FirstEnergy Ohio Utilities. There is one contract.

AGR 00046

Question: With respect to FERC’s Electric Quarterly Reports (EQR), please elaborate how a Supplier should record sales among the FirstEnergy Ohio Utilities, and if Suppliers will receive information, and frequency, for reporting of such sales for each of the FirstEnergy Ohio Utilities. For reference: “EQRs include information about cost-based rate sales, market-based rate sales, and transmission service, as well as transaction information for short-term and long-term market-based power sales and cost-based power sales.” https://www.ferc.gov/sites/default/files/2020-05/eqr-requirements-guide_0.pdf

Answer: The FirstEnergy Ohio Utilities are unable to provide a legal opinion as to how reporting should be completed for FERC’s Electric Quarterly Reports (EQR). Such questions should be addressed to each Supplier's legal counsel. Additional resources, such as FAQs on the EQR process, can be found at FERC.gov. The FirstEnergy Ohio Utilities do provide invoices monthly, which include MWh purchased and pricing. PJM currently provides EQR data for suppliers in their MSRS report as a further resource.

AGR 00047

Question: Can you please let me know if the AEPS/REC obligations changing for period covered in the January 2026 CBP Auction. If changing what will be the new obligations. If the obligations change during the delivery period, will the utility be responsible for the changes or will it be suppliers’ responsibility.

Answer: Article 2 of the Master SSO Agreement outlines the requirements for SSO Suppliers - “Each SSO Supplier is responsible, at its sole cost and expense, for any changes in PJM products and pricing during the Term”. Suppliers are obligated to deliver full requirements service of the slice of system of the Companies for purposes of meeting SSO load and assume specified LSE obligations for purposes of PJM settlement. 

AGR 00048

Question: We are reaching out to seek clarification on the impact of the Department of Energy (DOE) Emergency Orders on default service cost allocation and the contractual responsibilities of suppliers in relation to these orders. In 2025, the DOE exercised its emergency authority under Section 202(c) on three occasions to delay the retirement of Eddystone Unit 3 and 4. The initial order, issued in May 2025 extended the operations through August 2025. Subsequently, two additional orders were issued: one in August 2025 extending operations through November 2025, and the latest on November 25th 2025, continuing operations until February 2026. These orders included FERC's approval of PJM's proposal to distribute operational costs across all PJM load obligations. We noticed that billing line items related to these DOE orders are absent from the Master SSO Supply Agreement Appendix G "Sample PJM Invoice". Could you please clarify whether these line items will be added to Exhibit G and specify each party's responsibility? Without clear contractual guidance, these costs could be allocated to suppliers. Adding such charges to the supplier's responsibilities could expose ratepayers to additional risk premiums. This risk has been addressed by utilities in New Jersey and Pennsylvania by excluding DOE emergency charges from the supplier's responsibilities. We recommend following suit and removing DOE emergency charges from supplier responsibility to mitigate the risk premiums.

Answer: At this time, the Companies do not anticipate amending the current Master Standard Service Offer Supply Agreement. However, please refer to Sections 8.2(c) and 2.3 for the treatment of charges that are reflected in a PJM invoice that are not included on Appendix G. The Companies’ interpretation is that Suppliers will not be charged for billing line items related to the DOE’s Eddystone orders, subject to PUCO review.