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PSC staff and OPC clash over payment-posting vs. pro rata mechanics in UCB rulemaking
Summary
Office of People's Counsel urged that payment posting must ensure payments first cover utility charges that can lead to termination, while PSC staff said the order allows negotiation of pro rata arrangements and cautioned OPC's language read the order too broadly. Commissioners asked staff to consolidate language and preserve options pending review.
Office of People's Counsel (OPC) and PSC staff debated how partial customer payments should be posted when utilities or suppliers use utility consolidated billing (UCB).
OPC's representative read language into the record asking that when a payment-posting sequence is used, "any customer payment shall first be applied to utility charges and arrearages for which service may be terminated before being applied to competitive supplier charges and arrearages." OPC argued that prioritizing amounts that could result in termination reflects the Commission's order and protects customers from being disconnected for utility arrears.
Staff strongly opposed OPC's broader reading of the order. Staff said the Commission's Order No. 91463 and its footnote 66 leave room for negotiation and that the order did not require application to all utility charges. "There is a footnote 66. And that footnote says that utilities and suppliers are free to negotiate a pro rata UCB," staff said, warning that OPC's reading would disadvantage suppliers and likely discourage participation in alternative billing arrangements.
RISA and other stakeholders recommended distinguishing residential and nonresidential service in the regulatory text: apply prorate or commission‑approved payment posting to residential accounts, while nonresidential UCB rules would remain distinct. RISA also suggested payment-posting implementation details be handled in tariffs, not in the regulation itself.
The Commission did not adopt either side's final language at the session. Commissioners asked staff to consolidate the competing redlines and to return with a single draft that preserves available options and clarifies where payment-posting mechanics belong (tariff vs. regulation).
