Staff Calls ComEd POR Uncollectibles Calculation Inconsistent with Ameren Precedent

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November 15, 2010

Commonwealth Edison's most recent calculation of a combined uncollectibles factor to be used in the Purchase of Receivables discount rate for all customer classes appears to have been calculated, "in a manner that is not consistent with the calculation used by Ameren Illinois in Docket Nos. 08-0619/0620/0621," Illinois Commerce Commission Staff said in response to ComEd's filing.

As only noted by Matters, ComEd calculated the uncollectibles factor for the combined classes eligible for POR as 1.8453% (11/9).

While noting the inconsistency, "for purposes of establishing a PORCB discount rate, Staff does not see a benefit in spending further time and resources on attempts to produce a calculation that matches the one undertaken by Ameren Illinois."

Instead, Staff reiterated its position noting that the non-residential factor found in Rider UF, 1.52%, was used by Staff when calculating various potential PORCB discount rates in its testimony, and neither ComEd nor any other party objected to Staff's calculations.  "Given that the non-residential uncollectible factor found in Rider UF, and referenced in the PORCB tariffs, includes uncollectible expenses for all non-residential customers, Staff does not object to using the same factor when calculating a combined uncollectibles value for residential and non-residential customers for purposes of the PORCB tariffs," if the Commission finds that using a single POR discount rate for all customer classes is appropriate, Staff said.

Dominion Retail raised "substantial concern" with ComEd's 1.8453% figure, stating that ComEd has used data outside of the test year upon which current rates are based in its new calculation.

"Data on Attachment 1 of ComEd's November 8, 2010 response illustrate that ComEd has based its calculation on the 2009 FERC Form 1 Account No. 904 data of $84,531,413, which represents the system bad debt.  This is inappropriate as that data is NOT the basis for the current ComEd tariff, which was the result of the 2007 base rate proceeding (Docket 07-0566).  That rate filing was based on the 2006 FERC Form 1 Account 904 data of $33,021,031.  This is the figure that should be used in the determination of the Uncollectable Factor, which would result in a residential Uncollectible Factor of 1.20% and a small commercial Uncollectible Factor of 0.24%. (ComEd Ex. 12.15, Docket 07- 0566).  Using the figures in that exhibit, the weighted Uncollectible Factor would be 1.06%," Dominion Retail said.

"The fact that ComEd has a pending rate case (ICC Docket 10-0467) with an updated test year is not relevant because those rates are not in effect and, after Commission review of ComEd's request, will certainly be different than the tariffs it filed to initiate that proceeding," Dominion Retail added.

   
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