Discussion
of Issues
Issue 1:
Should the Commission approve TECO’s proposed tariff
modifications?
Recommendation:
Yes, the Commission should approve TECO’s requested
modifications to Tariff Sheet Nos. 5.135 and 6.030, as reflected in Attachment
A, effective June 5, 2017. (Rome, Draper)
Staff Analysis:
TECO’s proposed tariff modifications are designed to
conform TECO’s tariff to the applicable statutes and Commission rules. The two
tariff modifications are discussed below.
Billing Period
Section 366.05(1)(b), F.S., provides that if the
Commission authorizes a public utility to charge tiered rates based upon levels
of usage and to vary its regular billing period, the utility may not charge a
customer a higher rate because of an increase in usage attributable to an extension
of the billing period; however, the regular meter reading date may not be
advanced or postponed more than five days for routine operating reasons without
prorating the billing for the period. The Commission amended Rule 25-6.100,
F.A.C., to implement with the statutory changes.
The prior rule specified that the regular meter reading date may be advanced or
postponed not more than 5 days without a proration of the billing for the
period, but did not address the application of tiered rates to extended billing
periods. Tiered rates, such as TECO’s residential energy charges, apply a
higher energy charge to usage above 1,000 kilowatt hours.
TECO has proposed to add a paragraph on Tariff Sheet No.
6.030 to reflect the statutory requirements and to include TECO’s current
billing practices in its tariff. The proposed tariff language addresses both
the proration of charges when billing periods are varied by more than five days,
as well as the prohibition against charging higher tiered rates if the
extension of a billing period of more than five days causes a customer’s energy
consumption to exceed the Company’s tier threshold of 1,000 kilowatt-hours,
based on average daily usage. TECO has represented to staff that TECO
historically has followed the bill proration practices outlined in Section
366.05(1)(b), F.S.
Customer Deposits
Section 366.05(1)(c), F.S., provides that for an existing
account, the total deposit may not exceed two months of average actual charges.
For a new service request, the total deposit may not exceed two months of
projected charges. Once a new customer has had continuous service for a
12-month period, the amount of the deposit shall be recalculated using actual
data. Any difference between the projected and actual amounts must be resolved
by the customer paying the additional amount that may be billed by the utility
or the utility returning any overcharge.
The Commission amended Rule 25-6.097(1), F.A.C., to state
that the utility’s methodology for determining customer deposits for existing
and new accounts shall conform to Section 366.05(1)(c), F.S. The
prior rule language already required that the total amount of a deposit not
exceed twice the average monthly bill; that provision is contained in TECO’s
current tariff (Tariff Sheet No. 5.130) and TECO is not proposing to modify
that tariff sheet.
TECO’s proposed addition to Tariff Sheet No. 5.135 conforms
to the new statutory language regarding the recalculation of the deposit after
12-months. TECO’s proposed addition to Tariff Sheet No. 5.135 comports with
this language by providing that: (a) if the recalculated deposit amount based
on the previous 12-months billing history is less than the customer’s current
deposit amount, the difference between the deposit amounts will be refunded or
applied as a credit to the customer account; and (b) if the recalculated
deposit amount exceeds the customer’s current deposit amount, the Company may
request an additional deposit amount.
Pursuant to Rule 25-6.097(3), F.A.C., utility customers
receive refunds of their deposits with interest after a period of 23 months of
continuous service, assuming their payment record is satisfactory. Therefore,
for the majority of utility customers, the deposit amount recalculation after a
12-month period of continuous service occurs only once.
Conclusion
Based on a review of the applicable statutes, Commission
rules, and proposed tariffs filed by TECO, staff believes that the tariff sheet
revisions conform to the applicable statutes and Commission rules. Therefore,
staff recommends that the Commission approve TECO’s requested modifications to
Tariff Sheet Nos. 5.135 and 6.030, as reflected in Attachment A, effective June
5, 2017.
Issue 2:
Should this docket be closed?
Recommendation:
If Issue 1 is approved and a protest is filed within
21 days of the issuance of the order, the tariffs should remain in effect, with
any revenues held subject to refund, pending resolution of the protest. If no
timely protest is filed, this docket should be closed upon the issuance of a
consummating order. (Brownless)
Staff Analysis:
If Issue 1 is approved and a protest is filed within
21 days of the issuance of the order, the tariffs should remain in effect, with
any revenues held subject to refund, pending resolution of the protest. If no
timely protest is filed, this docket should be closed upon the issuance of a
consummating order.
