Case Background
On December 15,
2023, Florida Public Utilities Company (FPUC or Company) filed a petition
seeking Commission approval of revisions to its optional budget billing program
(program) tariffs for both its electric and natural gas divisions. FPUC also
proposed to expand the program to include certain small general service
customers, to remove unnecessary language related to bill format, and to revise
the terms and conditions of the program. Furthermore, FPUC has proposed to add
details to its electric budget billing tariffs to align with its natural gas program
tariffs. Overall, the Company states that the proposed tariff revisions are
intended to provide consistency across the business units under FPUC’s parent
company, Chesapeake Utilities Corporation (CUC).
Currently, FPUC’s
Customer Information and Billing System (CIS) services are provided by ECIS, a
Vertex business solutions product which the Company has been using for over 20
years. FPUC’s parent company, CUC, will be replacing the current system at the
completion of its contract on December 31, 2024. CUC is currently working with
SAP (a software company for the management of business processes) and IBM to
transition to FPUC’s new billing system known as 1CX with an estimated transition
date of August 2024. FPUC requests approval of its proposed
tariff revisions to be effective on the actual date of the transition date to
the new CIS, expected to be completed in August 2024.
During the
review process, staff issued a data request to FPUC on January 17, 2024, for
which the responses were received on January 31, 2024. The responses included a
corrected version of the First Revised Sheet No. 41. In Order No. PSC-2024-0045-PCO-PU, the Commission suspended the proposed
tariffs. Staff notes that the Commission has approved budget billing programs
and tariffs for Florida Power & Light Company, Tampa Electric Company, Duke
Energy Florida, and Peoples Gas System. The proposed revised tariff sheets are
included in Attachment A to this recommendation.
The Commission
has jurisdiction over this matter pursuant to Sections 366.04, 366.05, and
366.06, Florida Statutes (F.S.).
Discussion
of Issues
Issue 1:
Should the Commission approve FPUC's proposed
revisions to its optional budget billing program tariffs for its electric and
natural gas divisions, including the expansion of the program to small general
service customers?
Recommendation:
Yes. The Commission should approve FPUC's proposed
revisions to its optional budget billing program tariffs for its electric and
natural gas divisions, including the expansion of the program to small general
service customers. The proposed revised tariffs are included in Attachment A to
this recommendation. The proposed tariffs should be effective on the actual
date of the transition of the existing CIS platform to the new CIS platform expected
to occur in August 2024. No later than 30 days prior to the transition date,
the Company should notify the Commission in writing of the actual transition
date. (Guffey)
Staff Analysis:
The Company, in its petition, explained that as it
working through the process of changing to the new billing system and the need
for consistency for the program for both electric and natural gas divisions was
emphasized. The Company is not seeking Commission approval of its new CIS
platform. In its response to staff’s data request, the Company stated that it has not yet determined the timing or mechanism for
recovery of the costs associated with the implementation of the 1CX system.
Natural Gas Budget Billing Program
FPUC’s natural gas budget billing program tariff is an
option for residential customers and is designed to help customers stabilize
their monthly payments. To qualify for the program, a customer must be a year-round
customer with 12 months of consecutive bills and not owe past payments to the
Company (i.e., have a zero balance). The
customer’s monthly payment is based on an average of the previous 12 months of
bills and applicable fees and taxes. FPUC currently has 194 natural gas
customers enrolled in its program. Pursuant
to the currently effective tariff, the budgeted monthly payment is recalculated
from time to time and if the recalculated monthly payment varies by 10 percent
or more from the budget monthly payment, the Company may begin charging the
recalculated amount on the customer’s next bill. Additionally, a customer’s
budgeted monthly payment will be recalculated on each anniversary of the
customer’s initial participation in the Program.
Proposed Tariff Revisions
In its petition, FPUC proposed to remove the requirement
that the recalculated budgeted monthly payment vary by 10 percent before the
utility may begin charging the recalculated amount. In response to staff’s data
request, FPUC stated that removing the 10 percent variable requirement would
allow the system to calculate based on the factors necessitating the change,
which would produce a more accurate budget billing amount.
The Company also explained that it would recalculate budgeted monthly payments due
to circumstances including changes to rates, taxes, or new load which would
impact a customer’s usage.
Staff believes this methodology is reasonable and should reduce the imbalances
between the budgeted monthly payment and a customer’s actual total bill.
In addition to the above proposed tariff revision, the
Company is also proposing to expand its budget billing program to include
non-residential customers in Rate Schedules GS-1 (customers using less than
1,000 therms annually) and GS-2 (customers using 1,000 to 4,999 therms
annually). FPUC asserts that the proposal will enable general service customers
to better budget their utility expenses and states that this proposed expansion
will not impact the general body of ratepayers. FPUC is also proposing to
remove the requirement that customers who request to end their participation in
the program may not rejoin the program until after six months. Finally, FPUC
proposes to reserve the right to waive the requirement that customers must join
the program with a zero balance, on a not-unduly discriminatory basis.
Electric Budget Billing Program
FPUC currently has 258 electric customers enrolled in its budget
billing program. The existing tariff provides that a customer participating in
the program will remain a program participant unless the customer requests
termination from the program or is delinquent in payment. In comparison to the
natural gas budget billing tariff discussed above, existing budget billing
electric tariffs are less detailed. The terms for FPUC’s electric budget
billing program are quoted in their entirety in Paragraph 8 of the Petition.
Proposed Tariff Revisions
In order to add details similar to the natural gas budget billing
tariff, FPUC proposed to add language stating that the customer must be a
year-round customer with 12 months of consecutive bills and not owe past due
payments to the Company to enroll in the program. The customer’s monthly
payment will be based on an average of the previous 12 months of bills and
applicable fees and taxes. FPUC has also proposed program tariff language to
state that the budgeted monthly payment may be recalculated from time to time, and
that the Company may begin charging the recalculated amount on the customer’s
next bill. Additionally, a customer’s budgeted monthly payment will be
recalculated on each anniversary of the customer’s initial participation in the
program. Staff believes the above tariff modifications would better specify the
terms of the program and would align more closely with the natural gas budget
billing tariff.
Other revisions include removing language on applying a
factor which typically has not been utilized, removing the monthly 10 percent
payment variable margin (the new CIS platform will automatically calculate the
customers budget billing amount), and removing the terminated customer waiting
period before reenrolling in the budget billing program.
In addition to the above discussed proposed tariff
revisions, the Company is also proposing to expand its electric budget billing program to customers in Rate Schedules GS-Non
Demand (customers using 25 kilowatts or less), and GS-Demand (customers using
25 to 500 kilowatts). The Company asserts that the proposal would enable
smaller commercial customers to better budget their utility expenses and the
proposed expansion would not impact the general body of ratepayers.
Overall, the added detail to the electric budget billing tariffs
would provide more consistency with the natural gas tariff. Furthermore, the
replacement of the CIS platform would allow FPUC to enhance its billing and
payment platforms, streamline and automate the billing system, consolidate
customer information, and onboard customers quickly.
Conclusion
The Commission should approve FPUC's proposed revisions to
its optional budget billing program tariffs for its electric and natural gas
divisions, including the expansion of the program to general service customers.
The proposed revised tariffs, in Attachment A to this recommendation, should be
effective on the actual date of the transition of the existing CIS platform to
the new CIS platform expected to occur in August 2024. No later than 30 days
prior to the transition date, the Company should notify the Commission in
writing of the actual transition date.
Issue 2:
Should this docket be closed?
Recommendation:
Yes. If 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. (Stiller)
Staff Analysis:
If 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.
