Maryland PSC Allows Uniform Electronic Transactions on Interim Basis, Withholds Permanent Approval

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January 11, 2011

The Maryland PSC has rejected as unsupported a largely consensus working group report which would have governed the use of standard electronic transactions between natural gas local distribution companies and competitive suppliers, per COMAR 20.59.

However, in order to avoid delaying implementation of uniform electronic transactions, the PSC approved the use of the proposed extensible markup language (XML) standard electronic transactions methodology on a temporary, trial basis.  Further evidence supporting the selection of XML will be required before final approval of XML on a longer-term basis, the Commission said.

The working group report, first reported by Matters (10/25), had asked that the standard electronic transactions be authorized effective December 1, 2010 for those LDCs ready to use the standards, while other LDCs had planned to start using the standards after this winter's heating season.

The PSC's order rejecting the working group report directs that a revised report shall be resubmitted by June 30, 2011 for Commission approval.  The revised working group report shall recommend a deadline by which all non-exempt LDCs and competitive gas suppliers will implement the revised gas standards, associated implementation plans, and the uniform electronic transactions required by COMAR 20.59.

The working group had agreed that information should be exchanged through files in standard extensible markup language (XML) schemas over secured websites.  Using this method, transactions were developed to accomplish the following tasks: 1) the request for and the sending of pre-enrollment information; 2) the management of customer enrollments, customer drops, and customer switches under various circumstances; 3) communication of usage and billing information including rate changes, allowance for taxes and tax exemptions, and provision for budget billing; and 4) transmission of financial data including reconciliation of financial data in special circumstances and communication regarding write-offs.

However, the PSC found that, "[t]he specific rationale for selecting Extensible Markup Language ('XML') for use in coding electronic transactions over other techniques is not explained."

"No actual experience or examples of the use of XML in this type of application was presented.  Consequently, without a review of successful test results, there is no evidence that XML Uniform Electronic Transactions ('UET'), as proposed, will adequately perform the required process functions," the Commission said.

The PSC further held that the proposed gas standards, "lack adequate content, structure, and clarity to serve as a reference document for providing a uniform approach by the Maryland gas Local Distribution Companies ('LDC') and for fostering understanding by Competitive Gas Suppliers ('CGS') and other interested parties about the required information and processes."  The Commission ordered additional details in the subsequent working group report, including implementation guidelines for each uniform electronic transaction set (e.g., Enrollment, Consumption Requests, Write-off, etc.)

In terms of specific requirements, the Commission found that the requirement for a supplier to provide a customer account number in order to obtain pre-enrollment consumption information from a gas LDC is "not acceptable."  The alternative process detailed in the working group's report, which allows the supplier to submit customer's name and service address to obtain pre-enrollment information, is "balanced and reasonable in that it may produce the information sought by the CGS without undue effort by the LDC," the PSC said.

While the working group reached consensus that the standard electronic transactions shall be posted together on the Commission's website, consensus was not reached on whether other standards, which are not covered under the uniform electronic transactions and remain LDC-specific, should be posted on the Commission's website.  The PSC found that, "a central, public web site containing all utilities transaction standards and related business processes and technical standards would facilitate the development of the Maryland competitive gas market by making it easier for a CGS to obtain the communication and transaction information that it seeks."

Accordingly, within 30 days, "all gas transaction practices and related business and technical standards utilized by each Maryland gas LDC will be provided by each gas LDC to the Commission for posting on the Commission web site."

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