Discussion
of Issues
Issue 1:
Should
NPUC’s request to implement a late payment charge be approved?
Recommendation:
Yes. NPUC’s
request to implement a $6.77 late payment charge should be approved. The utility
should file the revised tariff sheets and a proposed customer notice to reflect
the Commission-approved late payment charge. The approved charge should be
effective for services rendered on or after the stamped approval date on the
tariff sheet provided customers have received notice pursuant to Rule 25-30.475(1),
Florida Administrative Code (F.A.C.). The
utility should provide proof of noticing within 10 days of rendering the approved
notice. (Sibley)
Staff Analysis:
The utility requested a
$6.77 late payment charge to recover the cost of supplies and labor associated
with processing late payment notices. The utility’s request for a late payment
charge was accompanied by its reason for requesting the charge, as well as the
cost justification required by Section 367.091, F.S. NPUC’s labor cost of $6.00
accounts for the office personnel time to review and process a delinquent
account. The provided justification by NPUC also included costs for supplies of
$0.28 and postage of $0.49 for printing and sending out late payment notices.
The cost basis for the late payment charge is shown in Table 1-1.
Table 1-1
Late Payment Charge Cost Justification
|
Activity
|
Cost
|
|
Labor
|
$6.00
|
|
Supplies
|
0.28
|
|
Postage
|
0.49
|
|
Total Cost
|
$6.77
|
Source:
Utility’s cost justification documentation
Since the
1990s, the Commission has approved late payment charges ranging from $2.00 to
$7.15.[1] The
purpose of this charge is to provide an incentive for customers to make timely
payments and to place the cost burden of processing delinquent accounts solely
upon those who are cost causers.
Based on the above, NPUC’s request to implement a $6.77
late payment charge should be approved. The utility should file the revised
tariff sheets and a proposed customer notice to reflect the Commission-approved
late payment charge. The approved charge should be effective for services
rendered on or after the stamped approval date on the tariff sheet provided
customers have received notice pursuant to Rule 25-30.475(1), F.A.C.
Issue 2:
Should this docket be closed?
Recommendation:
The docket should remain open pending staff’s verification
that the revised tariff sheets and customer notice have been filed by the
utility and approved by staff. If a protest is filed within 21 days of the
issuance date of the Order, the tariff sheets should remain in effect with the
charges held subject to refund pending resolution of the protest. If no timely
protest is filed, a consummating order should be issued and, once staff
verifies that the notice of the charges has been given to customers, the docket
should be administratively closed. (Taylor)
Staff Analysis:
The docket should remain open pending staff’s
verification that the revised tariff sheets and customer notice have been filed
by the utility and approved by staff. If a protest is filed within 21 days of
the issuance date of the Order, the tariff sheets should remain in effect with
the charges held subject to refund pending resolution of the protest. If no
timely protest is filed, a consummating order should issued and, once staff
verifies that notice of the charges has been given to customers, the docket
should be administratively closed.
