Maryland Staff Suggests PSC Direct Utilities to Advise Commission on Any Backoffice System Changes, Citing Impact on Retail Suppliers, Others

The Maryland PSC may wish to direct the state's utilities to advise the Commission of any intentions for significant billing and backoffice system implementations that will affect various market participants, the Maryland PSC Staff has recommended.

Staff's recommendation came in comments on Baltimore Gas & Electric's petition to use lower late payment factors applicable to customer bills during a transition to a new billing system (see 11/21 for discussion of why the revised charges are needed)

"Staff suggests that the Commission may wish to direct Maryland's utilities to advise the Commission of intentions for significant system changes prior to their design and implementation, so that the Commission may be aware of functionality changes and costs before technical specifications are 'locked in'. Maryland's utilities interact with retail suppliers, energy assistance agencies, and other external parties who may provide useful input into (or may be exposed to costs from) the utility plans," Staff said.

Staff noted, as Matters did, that retail suppliers would be impacted by BGE's use of lower late payment charges, because the POR discount rate is set using late fee revenue as an offset to programming and uncollected cost expense. "A reduction in late payment revenue would result in a higher discount rate," Staff observed.

Staff said that this consideration, "would be best reviewed at a point in the future when the specific items are before the Commission. For example, Staff expects that the January through March 2012 period would impact the calculation of the POR discount rate effective in June 2013."

Ultimately, Staff recommended that the PSC accept the tariff with the lower, temporary late payment factors for filing, and direct BGE to track late fee revenues during the months the temporary late fees are in effect.