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Dominion Retail, IGS Energy Oppose Use of XML in Maryland Gas Transactions
September 20, 2011
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Dominion Retail and IGS Energy have separately raised objections to a working group's recommendation to use extensible markup language (XML) for uniform electronic transactions (UETs) in the Maryland retail gas market.
The recommended use of XML, which has been used on an interim basis for several months at some utilities, was affirmed in a supplemental working group report filed in July (see 8/1).
As only noted by Matters, the working group, which met for nearly three years, 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.
Working group meetings were attended by representatives of, among other stakeholders, Washington Gas Energy Services; Maryland Energy Marketers Coalition; MXenergy; Pepco Energy Services; IGS Energy; Dominion Retail; Stand Energy; and Energy Services Group.
"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.
Dominion Retail on Friday filed comments opposing the use of XML. An electronic version of Dominion Retail's comments was not immediately available, but a PSC Staff response to the comments was available Monday. Separately, Interstate Gas Supply, in testimony in the merger proceeding of Constellation and Exelon, sought the use of EDI rather than XML at BGE (see related story today)
Staff said that no objection to the recommended use of XML had been raised in the working group, which first recommended XML in October 2010.
"No non-consensus position is noted in either report because none was offered in either case. All parts of the Working Group's work product were circulated to all members of the Working Group multiple times. All members of the Working Group were expected to note their changes and/or objections to any part of the Working Group's work product. It is significant that no objection to the use of XML was noted in either the Report or the Supplemental Report. With regard to Dominion this means that none of the objections that are now raised in its September 16, 2011 filing were ever sent to the Working Group or to Staff which would have sent these objections or red-line to the Working Group on Dominion's behalf," Staff said.
In its comments, Dominion Retail offers alternatives such as the use of flat files or EDI.
In its comments filed Monday, Staff reiterated that, "XML was chosen over flat files due to its self defining and self describing nature and higher degree of validation. XML was chosen over EDI due to its comparative ease of use and lower expense."
"The non-exempt LDCs in Maryland have been using the [XML-based] UETs proposed here since November 2010. Numerous suppliers have gone through testing without major incident. EDI cannot be ported to gas directly from the electric side, and Staff does not believe there would be substantial, if any, savings to [retail suppliers] through the adoption of yet to be developed EDI gas UETs. In addition, not all gas [retail suppliers] and not all LDCs have the hardware required for EDI, the addition of which would represent a major expense that would be flowed through to [retail suppliers]," Staff added.
In its testimony in the Constellation-Exelon proceeding, IGS Energy said that practices using EDI are "superior" to XML and should be adopted for the BGE gas choice program.
The use of XML transactions, "requires gas choice suppliers to transfer data manually," IGS Energy noted.
IGS noted that choice programs at Exelon utilities PECO and ComEd both feature automatic data transfer that uses EDI.
While automated EDI transactions are preferable, "the immediate step of automating the existing XML data transfer would be advisable," IGS said.
"Because choice suppliers are dealing with the mass market, one of their critical business drivers is efficiency. An important component of efficiency is the ability to transmit data on large numbers of customers electronically using the internet. BGE must create a secure electronic data interchange system for information exchange. This is how most other distribution utilities transmit information. BGE should be required as a condition of the merger to adopt the more choice-friendly operational capabilities of the other Applicant utilities and offer EDI for choice transactions," IGS testified.
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