Compliance Filing for Annual Re-calculation of Discount Rate for Baltimore Gas and Electric Company s Gas Purchase of Receivables Program

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1 Kimberly A. Curry Assistant General Counsel BGE Legal Department 2 Center Plaza, 13 th Floor 110 West Fayette Street Baltimore, Maryland Telephone Fax kimberly.a.curry@constellation.com David J. Collins, Executive Secretary Maryland Public Service Commission William Donald Schaefer Tower 6 St. Paul Street, 16 th Floor Baltimore, MD Re: Supplement 392 to P.S.C. Md. G-9 Compliance Filing for Annual Re-calculation of Discount Rate for Baltimore Gas and Electric Company s Gas Purchase of Receivables Program Dear Mr. Collins: Baltimore Gas and Electric Company (BGE) hereby files this revision to Schedule 1 of its Gas Supplier Tariff to update the discount rates for the purchase of supplier receivables (POR). Schedule 1 provides that BGE will re-calculate the discount rate annually and file the updated rates by May 30. The purpose of the discount rate is to enable BGE to recover its prudently incurred costs arising from the purchase of supplier receivables as part of BGE s Gas Choice Programs. For the fourth straight year, the calculation results in a negative discount rate. Negative rates occurred in 2011, 2012, and 2013 as well. In 2011 and 2012, the Commission directed BGE to set the negative rates to zero. In 2012, the Commission approved BGE s tariff revision that, if the discount rate calculation results in a negative rate, BGE would set the discount rate to 0.000% and the associated costs will be included in the future year s reconciliation of costs and revenues. In the 2013 update, BGE set the negative rates to zero in accordance with that tariff provision. BGE again sets the negative rates to zero for the 2014 discount rates. In past filings, BGE has argued that the occurrence of negative discount rates can be minimized or eliminated by the removal late payment charges (LPCs) from the discount rate calculation. BGE objected to the inclusion of LPCs on four bases. First, improper subsidization results from the inclusion of LPCs. If LPCs were not included in the discount rate and instead credited to BGE s base rate cost of service, lower delivery rates would necessarily result. Second, since BGE considers LPCs as an offset to credit and collections expense, transferring late payment revenues to suppliers compensates suppliers for a credit and collection expense they do not incur under the POR construct. Third, the policy to include LPCs in the discount rate

2 David J. Collins, Executive Secretary Page 2 is contrary to the policy evidenced in the Commission s October 2009 utility orders adopting the discount rate method of recovery. Those orders stated the Commission is not willing to impose the cost of implementing customer choice on ratepayers, especially in a manner that absolves the suppliers of all costs and risks. This statement reflects a Commission policy to minimize adverse impacts to ratepayers in POR implementation. Yet, as described above, distribution customers are adversely impacted in the form of higher distribution rates. Finally, LPCs in the POR discount rate is inconsistent with the language in COMAR C that provides [i]f the utility chooses the option of purchasing supplier receivables, supplier receivables shall be purchased with full and timely cost recovery for the utility under terms and conditions approved by the Commission. BGE is responsible for taking collection action on purchased supplier receivables and utility receivables. The current POR discount computation does not allow the utilities to receive full cost recovery from the suppliers for this collection activity. In 2012, the Commission directed the Supplier Coordination Working Group to convene to consider the inclusion of late payment charges in the discount rate or other options that will minimize the possibility of negative discount rates occurring in the future. See Commission s Letter Order (June 21, 2012). The working group discussions have not resulted in a consensus proposal; however, the dialogue is still ongoing. Until a resolution is reached, BGE will continue to re-set the negative rates to zero. A. Discount Rate Computed with LPCs in Accordance with the Tarff, Re-set to Zero BGE s discount rate for its Gas Choice Program is designed to recover uncollectible expenses, and program development costs. Any over- or under- collections are reconciled annually through a reconciliation mechanism. In this filing, BGE has developed a discount rate for the 12-month period beginning in July 2014 that incorporates BGE s projections for these components, as well as reconciliation for the previous 12 months. Below are the gas discount rates, by customer class: Gas Discount Rate Components Residential General Service Uncollectible Expense % % Late Payments % % Program Development % % Reconciliation Component % % Discount Rate % % Attachment 1 contains the supporting documentation for these figures. As can be seen, the General Service discount rate is negative. BGE is setting the negative rate to zero, as required by its tariffs. The discount rates would appear as follows:

3 David J. Collins, Executive Secretary Page 3 Gas Discount Rates Discount Rates As Stated Above Discount Rates With No Negatives Allowed Gas Residential % % Gas General Service % % zero. The tariff pages appended as Attachment 2 reflect discount rates that have been set to B. Conclusion BGE respectfully requests that the Commission accept the tariff pages provided in Attachment 2. Respectfully submitted, /s/ Kimberly A. Curry Kimberly A. Curry Attachments cc: Paula Carmody, People s Counsel

4 Attachment 1

5 BALTIMORE GAS AND ELECTRIC FILING OF GAS PURCHASE OF RECEIVABLES DISCOUNT RATE - DEVELOPMENT OF DISCOUNT RATE TO CHARGE- JUNE 2014 THROUGH MAY 2015 GAS: A B C D E F I=A+SUM(D - H)) Reconciliation Uncollectibles Late Payment Revs. Uncollectibles + Cash Working Program Grand Component Component (LPC) Component LPC Component Capital Development Costs Total Charge / (Refund) Charge / (Refund) Charge / (Refund) Charge / (Refund) Charge / (Refund) Charge / (Refund) Charge / (Refund) Customers Customers Customers Customers Customers Customers Customers 6/14-5/15 6/14-5/15 6/14-5/15 6/14-5/15 6/14-5/15 6/14-5/15 6/14-5/15 Residential- $'s ($156,763) $1,541,657 ($521,534) $1,020,122 $0 $0 $863,359 Residential- Purchased AR, 6/14-5/15 $60,218,907 $60,218,907 $60,218,907 $60,218,907 $60,218,907 $60,218,907 $60,218,907 Residential- Discount Rate % % % % % % % General Service- $'s ($306,187) $48,672 ($122,400) ($73,728) $0 $0 ($379,915) General Service- Purchased AR, 6/14-5/15 $68,391,695 $68,391,695 $68,391,695 $68,391,695 $68,391,695 $68,391,695 $68,391,695 General Service- Discount Rate % % % % % % %

6 Appendix A BALTIMORE GAS AND ELECTRIC FILING OF GAS PURCHASE OF RECEIVABLES DISCOUNT RATE - ACTUALS FOR THE PERIOD FEBRUARY JANUARY 2014 GAS PURCHASE OF RECEIVABLES- FEBRUARY 2013 THROUGH JANUARY ACTUALS: Residential Beg. Imbalance Feb-13 Mar-13 Apr-13 May-13 Jun-13 Jul-13 Aug-13 Sep-13 Oct-13 Nov-13 Dec-13 Jan-14 Total Revenues Discount Rate (revenues) ($52) ($2) ($20) ($28) $28,927 $24,022 $25,971 $26,517 $31,808 $74,252 $179,780 $249,505 $640,679 Late Payment Revenues 72,200 96, ,409 86,458 49,471 37,768 19,580 15,623 16,440 15,801 36,739 76,938 $623,528 Less: Risk Component Total Revenues $72,148 $96,101 $100,389 $86,429 $78,397 $61,790 $45,551 $42,140 $48,248 $90,054 $216,519 $326,443 $1,264,208 Costs Cash Working Capital - Uncollectible Expense 149,517 39, , , , ,424 22,733 69, , , , ,861 1,541,657 Program Development Costs Amortization (6,000) (6,000) Total Costs $149,517 $39,076 $140,886 $193,624 $160,600 $147,424 $22,733 $63,096 $103,327 $141,832 $267,679 $105,861 $1,535,657 Interest Owed (Earned) (2) (11) (8) (11) (16) (21) (26) (5) (43) Over-Collection / (Under-Collection) $225,135 ($77,355) $57,044 ($40,481) ($107,189) ($82,205) ($85,645) $22,809 ($20,966) ($55,095) ($51,799) ($51,186) $220,577 ($46,357) General Services Beg. Imbalance Feb-13 Mar-13 Apr-13 May-13 Jun-13 Jul-13 Aug-13 Sep-13 Oct-13 Nov-13 Dec-13 Jan-14 Total Revenues Discount Rate (revenues) $0 $0 $0 $0 $0 $95 $0 $0 $0 $0 $0 $0 $95 Late Payment Revenues 21,066 18,992 17,678 13,660 8,463 7,828 3,069 6,419 6,686 6,525 14,794 20,896 $146,076 Less: Risk Component Total Revenues $21,066 $18,992 $17,678 $13,660 $8,463 $7,923 $3,069 $6,419 $6,686 $6,525 $14,794 $20,896 $146,171 Costs Cash Working Capital - Uncollectible Expense 16,532 (56,568) (18,646) (219) 4,091 2,610 (10,272) 7,907 15,145 18,638 46,040 23,415 48,672 Program Development Costs Amortization Total Costs $16,532 ($56,568) ($18,646) ($219) $4,091 $2,610 ($10,272) $7,907 $15,145 $18,638 $46,040 $23,415 $48,672 Interest Owed (Earned) Over-Collection / (Under-Collection) $159,682 $4,550 $75,583 $36,352 $13,907 $4,400 $5,343 $13,372 ($1,458) ($8,429) ($12,085) ($31,221) ($2,494) $257,503

7 Appendix B BALTIMORE GAS AND ELECTRIC FILING OF GAS PURCHASE OF RECEIVABLES DISCOUNT RATE PROJECTIONS FOR THE PERIOD FEBRUARY MAY 2014 GAS PURCHASE OF RECEIVABLES- FEBRUARY 2014 THROUGH MAY PROJECTED: Residential Feb-14 Mar-14 Apr-14 May-14 Total Revenues Discount Rate (revenues) $166,814 $130,802 $66,673 $35, ,743 Late Payment Revenues 72,848 84,762 88,998 70, ,226 Less: Risk Component Total Revenues $239,662 $215,564 $155,672 $106,072 $716,970 Costs Cash Working Capital Uncollectible Expense 128, , , , ,886 Program Development Costs Amortization Total Costs $128,471 $128,471 $128,471 $128,471 $513,886 Interest Owed (Earned) Over-Collection / (Under-Collection) $111,194 $87,102 $27,212 ($22,389) $203,120 General Services Feb-14 Mar-14 Apr-14 May-14 Total Revenues Discount Rate (revenues) Late Payment Revenues 21,255 16,751 15,670 11,157 64,832 Less: Risk Component Total Revenues $21,255 $16,751 $15,670 $11,157 $64,832 Costs Cash Working Capital Uncollectible Expense 4,056 4,056 4,056 4,056 16,224 Program Development Costs Amortization

8 Appendix B Total Costs $4,056 $4,056 $4,056 $4,056 $16,224 Interest Owed (Earned) Over-Collection / (Under-Collection) $17,217 $12,714 $11,633 $7,121 $48,684

9 Appendix C BALTIMORE GAS AND ELECTRIC FILING OF GAS PURCHASE OF RECEIVABLES DISCOUNT RATE - PROJECTIONS FOR THE PERIOD JUNE MAY 2015 GAS PURCHASE OF RECEIVABLES- JUNE 2014 THROUGH MAY PROJECTED: Residential Jun-14 Jul-14 Aug-14 Sep-14 Oct-14 Nov-14 Dec-14 Jan-15 Feb-15 Mar-15 Apr-15 May-15 Total Revenues Discount Rate (revenues) Late Payment Revenues 38,642 30,922 18,893 13,077 15,758 16,586 29,202 41,227 72,848 84,762 88,998 70, ,534 Total Revenues $38,642 $30,922 $18,893 $13,077 $15,758 $16,586 $29,202 $41,227 $72,848 $84,762 $88,998 $70,617 $521,534 Costs Cash Working Capital Uncollectible Expense 128, , , , , , , , , , , ,471 1,541,657 Program Development Costs Amortization Total Costs $128,471 $128,471 $128,471 $128,471 $128,471 $128,471 $128,471 $128,471 $128,471 $128,471 $128,471 $128,471 $1,541,657 Interest Owed (Earned) Over-Collection / (Under-Collection) ($89,830) ($97,549) ($109,578) ($115,394) ($112,714) ($111,885) ($99,269) ($87,245) ($55,623) ($43,709) ($39,473) ($57,854) ($1,020,122) General Services Jun-14 Jul-14 Aug-14 Sep-14 Oct-14 Nov-14 Dec-14 Jan-15 Feb-15 Mar-15 Apr-15 May-15 Total Revenues Discount Rate (revenues) Late Payment Revenues 6,611 6,409 2,961 5,373 6,409 6,849 11,760 11,197 21,255 16,751 15,670 11, ,400 Total Revenues $6,611 $6,409 $2,961 $5,373 $6,409 $6,849 $11,760 $11,197 $21,255 $16,751 $15,670 $11,157 $122,400 Costs Cash Working Capital Uncollectible Expense 4,056 4,056 4,056 4,056 4,056 4,056 4,056 4,056 4,056 4,056 4,056 4,056 48,672 Program Development Costs Amortization Total Costs $4,056 $4,056 $4,056 $4,056 $4,056 $4,056 $4,056 $4,056 $4,056 $4,056 $4,056 $4,056 $48,672 Interest Owed (Earned) Over-Collection / (Under-Collection) $2,555 $2,353 ($1,095) $1,317 $2,353 $2,793 $7,704 $7,141 $17,199 $12,695 $11,614 $7,101 $73,728

10 Attachment 2

11 Baltimore Gas and Electric Company Gas Supplier Tariff In the event the calculation results in a negative final Discount Rate, the Discount Rate will be set to 0.000% and the associated costs will be included in the future year s Reconciliation Component. The Discount Rate is as follows: Rate Schedule Discount Rate Residential Schedule D % General Service Schedule C % BGE will file the calculation of the Discount Rate with the PSC by May 30 of each year with the revised percents to be effective with the purchase of receivables beginning in June pending Commission approval. P. S. C. Md. G-9 (Suppl ) Filed 32/1428/1314 Effective 6/01/1314

12 Baltimore Gas and Electric Company Gas Supplier Tariff In the event the calculation results in a negative final Discount Rate, the Discount Rate will be set to 0.000% and the associated costs will be included in the future year s Reconciliation Component. The Discount Rate is as follows: Rate Schedule Discount Rate Residential Schedule D % General Service Schedule C % BGE will file the calculation of the Discount Rate with the PSC by May 30 of each year with the revised percents to be effective with the purchase of receivables beginning in June pending Commission approval. P. S. C. Md. G-9 (Suppl. 392) Filed 2/28/14 Effective 6/01/14