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Some suppliers may require dual billing due to SB 1’s prohibition for residential POR.

From Delmarva and Pepco Response:

[ *** ] Scenario 1 – Assumption that POR ends for all residential accounts as of January 1, 2025

Although the Companies’ existing systems have payment posting functionality, without specific guidance from the Public Service Commission on the method that will replace POR as well as whether the Commission will adopt the prior payment posting prioritization that existing before the adoption of POR, the Companies cannot provide a definitive timeline. Once the Commission makes these determinations, the Companies will need to review the process, finalize payment application requirements, and design the solution. However, the Companies anticipate at least 12-18 months from the date the Commission provides the necessary requirements to implement all the changes necessary to eliminate POR and update necessary functionality for other programs to work in a non-POR environment.    Payment application changes are just one part of the solution. Changes will also be necessary to the following: EDI, Billing, Invoicing, Dunning, Bill Print, Accounting, Credit and Collections, deposit calculations.  In addition, changes will be required from the EDI vendor (Hansen) and Hansen will need to develop/map a write-off transaction. As the Companies discussed during the PC 65 hearing on August 7, 2024, the Companies propose that suppliers switch to dual billing as a temporary measure until this work can be completed.

Scenario 2 – Assumption the POR ends only for residential accounts that entered into or renewed agreements on or after January 1, 2025 If the Commission determines that suppliers must move to Dual billing for customer enrollments after Jan 1, 2025, the Companies will need to develop functionality to reject UCB enrollments. This is work is expected to take approximately 1-3 months after the receipt of final regulations and the completion of any required EDI changes and workgroup requirements. [ *** ]

View full response here.

From Potomac Edison Response:

Compliance Plan Assuming POR ends for all residential accounts as of January 1, 2025

Potomac Edison plans to implement a form of pro-rata per COMAR 20.53.05.06. Potomac Edison estimates that it needs approximately eighteen months of programming time to implement a pro-rata approach to billing for those residential customers who purchase energy from a third-party supplier. The calendar date of implementation will be impacted by key milestones as they are completed. The earliest start date the Company currently estimates for the 18-month timeline is mid-September 2024.

Temporarily, while the Company is developing and implementing a pro-rata billing methodology, if the Company is to continue providing Utility Consolidated Billing (“UCB”) services, the Company would need a waiver of COMAR 20.53.05.06.4 Under UCB, a temporary approach would be to apply the payment posting priorities that currently exist in the Company’s billing system, and could be applied to non-POR and non-pro-rata accounts. See the response to Question 2a in the Appendix for further detail. Dual billing would be an alternative option to UCB.

Key milestones and challenges to implementing pro-rata billing include COMAR revisions, tariff revisions (to both PE’s Retail Tariff and Supplier Tariff), and clarifications needed to begin the 18-month development window, including but not necessarily limited to the following:

• Getting confirmation that “pro-rata” is intended to be synonymous with “proration” pursuant to COMAR 20.53.05.06. 
• Getting clarification regarding how many configurations will be necessary. For example, will POR be eliminated just for residential customers or for all customer classes. 
• Clarification and/or amendment of COMAR 20.53.07.06(A), which as currently written does not allow for the utility to terminate service “for failure of a customer to pay supplier charges” under a pro-rata approach. 
• Clarification on how to treat partial payment postings. 
• Direction on what items are considered part of the pro-rata allocation. Potomac Edison does not believe that all charges should be considered in pro-rata, while items such as security deposits should have priority. 
• Clarification on whether items will be settled in accordance with due date regardless of total amount owed. Potomac Edison believes items should be settled in proportion to the date or the arrears due date and not in totality at allocation.
• Clarification on how to handle billing supplier late payment charges; currently Potomac Edison does not bill for Supplier late payment charges.

The Company further notes that in addition to tariff and regulation changes, it will need to modify its internal processes and procedures to implement a pro-rata approach with regard to the following related items: 

• Developing partial payment 
• Identifying POR vs. non-POR accounts 
• Dunning Processes · Write-Off Processes 
• 3rd Party Collection Processes · Transfer Processes 
• Security Deposit Processes 
• Bankruptcy Processes 
• Human Services Processes

Compliance Plan Assuming POR ends only for residential accounts that entered into or renewed agreements on or after January 1, 2025.

The plan, timelines, and challenges outlined above would be the same under this scenario as the Company would still need to work towards developing a pro-rata billing method for those residential accounts that enter into or renew agreements on or after January 1, 2025. However, a key difference would be the added work and complexity of developing a mechanism to allow suppliers to identify accounts that should remain on POR for some period of time through the EDI system so that Potomac Edison could continue to bill those customers using POR. Currently, Potomac Edison has no way of knowing the length or end date of any individual supply contracts (which the Company understands could extend for up to as long as 60 months). Dual billing would be an alternative option to UCB for residential shopping contracts not eligible for POR.

View full response here.

PC65 (07/23/2024)
(Accounts Receivable Related To Residential Electric And Gas Supply)