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Maryland Work Group Files Supplemental Report on Electronic Transaction Standards for Gas Market

August 1, 2011
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On behalf of a working group, Maryland PSC Staff submitted a supplemental report regarding implementation of uniform electronic transactions for the retail gas market.

While electronic transactions using an extensible markup language (XML) have been used on an interim basis, the PSC had previously declined to adopt a working group report on the standards absent further report and detail (see 1/11).

The supplemental report answers the Commission's prior order and contains a revised Maryland Competitive Gas Supply Process and Transactions Standards Manual.

Link to Maryland Competitive Gas Supply Process and Transactions Standards Manual and Related Documents

One area of specific direction from the PSC in its prior order concerned allowing suppliers to submit a customer's name and service address to obtain pre-enrollment information (such as usage).

The working group had originally developed a Pre-Enrollment uniform electronic transaction (UET) which required suppliers to provide an account number to obtain pre-enrollment information. The working group had also originally developed method by which a supplier might obtain pre-enrollment information with no account number by providing the customer name and service address, if there is a single match.

"This alternative method might be used by a [supplier] with a remote office of some type, for example, a kiosk at a shopping center. In these situations, a [supplier] might make contact with a customer who shows interest in the [supplier's] offer but does not have ready access to his account number," the working group explained.

All members of the working group, including suppliers, recognized that this alternative name and address mechanism was not ideal, because if no matches or more than one match occurred, no pre-enrollment information would be forthcoming.

All LDCs not exempt from COMAR 20.59 use the pre-enrollment UET. Currently, Washington Gas Light is able to process the pre-enrollment UET based on the provision of account number or customer name and address. Columbia Gas and Baltimore Gas & Electric have not developed internal support required to implement the name and address option on the pre-enrollment UET.

Columbia has been instructed by the Commission to cease any further COMAR 20.59 implementation. BGE intends to program the internal support required to implement the name and service address option for the pre-enrollment UET as soon as soon as it is able to do so. The exact date for this programming is uncertain because it is dependent on the BGE's new customer care and billing system being up and running. The working group recommends the continued use of the current pre-enrollment UET that may be validated by using either an account number or the customer's name and service address.

The supplemental report also discusses UETs developed to support current or new practices in the market neither required nor prohibited by COMAR 20.59. For example, a UET has been created to allow a 'seamless move" of retail supply service when a retail gas customer moves to another location within the same service territory. Additionally, a "switch" UET was developed and is used by all non-exempt LDCs to inform an incumbent supplier that its customer has a pending enrollment with a new supplier. This transaction was not available as a business practice previously.

The working group did not develop a UET to accommodate COMAR 20.59.04.02D which provides that an LDC shall compensate a supplier for any gas provided by the supplier during the first month of service to a new customer. Because each of the non-exempt LDCs required to provide this compensation does so in a different way, no specific UET was developed for this purpose.

While not recommending a UET for such compensation, the working group noted that BGE provides compensation through the adjustment of usage and uses the usage transaction (USAGE DATA.xml) to do so.

Columbia pays for the gas from the first of the month through the meter reading date and trues up any amount owed to Columbia by suppliers in August of each year. Although there is no provision for this methodology under COMAR, Columbia's practice avoids the need for compensating the supplier for gas supplied by the supplier during the first month of a new contract.

WGL compensates suppliers by adjusting their daily volume requirements through one of three options selected by the supplier: 1) reduction of daily volume requirement; 2) credit to the Accumulated Unbilled Account; or 3) credit to the Imbalance Account. WGL's balancing system is outside the systems affected by the working group's UETs.

The working group also explained its decision to select XML over EDI for the standard transactions as reflecting XML's ease of implementation and use, simplicity, and relative lack of expense when the two methods were compared.

"Ongoing operations costs for EDI are thought to be at least twice that of XML. XML also requires fewer data repairs than EDI. Finally, XML uses more current technology (EDI originated in 1978, XML originated in 1996) and has greater design and layout flexibility which supports more customization and options when creating models that are used to develop UETs," the working group said.

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