ICC Staff Favor Using Rider UF for ComEd POR Uncollectibles Factor

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November 2, 2010

Illinois Commerce Commission Staff said that they have no objection to using the system average uncollectible factor found in Commonwealth Edison Rider UF if the Commission elects to impose a single discount rate on all customer classes under ComEd's Purchase of Receivables program.

An ALJ's proposed order recommended combining the residential and non-residential discount rates into a single discount rate applicable to all customers served under POR.  After issuing the proposed decision which used a non-residential uncollectibles rate which was not in the record in determining the combined rate, the ALJ requested ComEd to calculate a single uncollectible rate combining residential and non-residential uncollectibles using a weighted average methodology.  

However, ComEd reported that it does not routinely track class-specific uncollectibles for the prior calendar year, and thus was not immediately able to provide an appropriate input reflecting non-residential uncollectibles for POR-eligible customers, since only non-residential customer classes under 400 kW will be included in POR.

ComEd said that it would not able to produce data reflecting a weighted average uncollectibles factor for only those customers eligible for POR until November 8.

ComEd noted that its system average uncollectible rate under Rider UF is 1.5203%.  ComEd stressed, however, that, "[b]ased on historic trends, ComEd suspects that the system average uncollectibles value may fall somewhat below a weighted average [of] uncollectibles for customers with demands under 400 kW, including residential."

Staff responded that, "[g]iven that the non-residential uncollectible factor found in Rider UF, and referenced in the PORCB tariffs, always included uncollectible expenses for all non-residential customers, Staff does not object to using the same factor when calculating a combined uncollectibles value for residential and non-residential customers for purposes of the PORCB tariffs."

"In other words, if the Commission finds that a combined uncollectibles factor should be used for calculating the PORCB discount rate, Staff would have no objection to using the system average supply uncollectibles value of 1.52% as provided by ComEd," Staff said.

"If the ALJ agrees that the information provided by ComEd is sufficient, it would seem to Staff that ComEd would not have to provide the more extensive follow-up to the Post-Record Data Request it contemplates by November 8, 2010," Staff added.

Dominion Retail further stressed this point, opposing any delay in the POR proceeding.

"As indicated by both ComEd in its Post-Record Data Request response and the Staff's letter, the figure provided by ComEd of 1.5203% is a close approximation of what a more detailed analysis would most likely provide and has the advantage of having already been reviewed by the parties.  There is no need to further delay the final order in this proceeding to allow ComEd to provide a new figure on November 8, 2010 along with supporting data and then delay the case even longer in order to allow the Staff and parties to evaluate that information and provide responses." Dominion Retail said.

"Dominion is concerned that any delays in the issuance of the Commission's final order will delay implementation of ComEd's consolidated billing and purchase of receivables program.  It is therefore important to try to keep to the original schedule in this proceeding and not allow delays to obtain minimal refinements of ComEd's tariff," Dominion Retail added.

   
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