GUAM PUBLIC UTILTIES COMMISSION DIRECT … public utilties commission docket no. 07-10 direct...

Exhibit JJC-1

GUAM PUBLIC UTILTIES COMMISSION

DOCKET NO. 07-10

DIRECT TESTIMONY OF

JOHN J. CRUZ

ON BEHALF OF

GUAM POWER AUTHORITY

Hagatna, Guam

October 04, 2007

Guam PowerAuthority Direct Testimony J. Cruz of 69

Guam Power Authority Direct Testimony J. Cruz of 69

Exhibit JJC-1

Guam Power Authority Direct Testimony J.J. Cruz Page 1

DIRECT TESTIMONY OF

JOHN J. CRUZ

Docket No. 07- ____

1. QUALIFICATIONS

1 Q. PLEASE STATE YOUR NAME AND BUSINESS ADDRESS. 2 A. My name is John J. Cruz. My business address is 1911 Route 16, Dededo, Guam 3

96912. 4 5 Q. BY WHOM AND IN WHAT CAPACITY ARE YOU EMPLOYED? 6 A. I am employed as the Manager of Strategic Planning & Operations Research at 7

the Guam Power Authority. 8 9 Q. WHAT ARE YOUR RESPONSIBILITIES? 10 A. I lead the Authority’s Business Strategy and Planning group. This includes 11

responsibilities in the areas of strategic planning, business planning, long range 12 transmission planning, integrated resource planning, information systems planning, 13 quality management planning, outsourcing business model development, engineering 14 analysis, financial analysis, load forecasting, demand-side management, resource 15 planning, information systems studies and project management, IPP and PMC contract 16 management support, engineering and business research, and general support for top tier 17 management. 18

19 Q. WHAT ARE YOUR RELEVANT QUALIFICATIONS? 20 A. I assisted in the evaluation of the bid for merchant banking services for Guam 21

Power Authority. My group manages the operating side of contracts associated with 22


Exhibit JJC-1

Guam Power Authority Direct Testimony J.J. Cruz 2

paygpa.com, the Authority’s Internet Payment Portal. It also acts as the project 1 management organization for the PAYGPA Project. 2

3 Q. PLEASE DESCRIBE YOUR EDUCATION, EXPERIENCE AND EMPLOYMENT 4

HISTORY. 5 A. My educational background includes a B.S. Electrical Engineering and B.A in 6

Mathematics from Gonzaga University with a minor in business. I am a registered 7 Professional Engineer in the discipline of Electrical Engineering on Guam. Prior to 8 joining the Guam Power Authority in 1991, I was employed at Hughes Aircraft Company 9 in the Modes Development Department of the Company’s Radar Systems Group. While 10 at Hughes Aircraft Company, I served as a Modes Leader on the B-2 for several radar 11 modes, supported several large combat aircraft proposals and special access projects, 12 performed low probability of intercept studies, developed analysis software for the 13 Magellan space mission, and developed designs and performance analysis for various 14 radar modes including sea surveillance, synthetic aperture array, ground moving target 15 indication, and weather avoidance among others. 16

While at Guam Power Authority, I held the positions of Communications 17 Engineer, System Planning Supervisor, Manager of Strategic Planning & Operations 18 Research, Acting Power System Control Center Manager, Acting Manager of 19 Engineering, and from time to time acted as Assistant General Manager of Operations. 20 My experience at Guam Power Authority includes systems integration and project 21 engineering for the Authority’s SCADA/EMS project (1991-1994), design and project 22 management of a fiber optic campus network at the Cabras-Piti Complex and the T&D 23 Dededo Complex (1998), Upgrade of the GPA WAN (2005-2007), functional 24 specifications for the Authority’s meteorological monitoring station project, design and 25 project engineering for GPA’s Fuel Switching System (1998-1999). Furthermore, I 26 initiated the idea for Performance Management Contracts at Guam Power Authority and 27 assisted in the development of the procurement documents and bid analysis for the first 28 and second Cabras 1&2 PMC, the Cabras 3&4 PMC, and the Transportation Privatization 29 attempt. 30


Exhibit JJC-1


While Manager of SPORD, I sponsored the following projects: Guam Power 1 Authority Strategic Plan, VOIP implementation, JDE Gap Analysis, Guam Power 2 Authority and Consolidated Commission on Utilities corporate web sites, PayGPA, the 3 Authority Exchange-Based Mail Service. 4

Principal author and editor for the Authority’s 1996 and 1999 Integrated Resource 5 Plan, the 1997 Long Range Transmission Plan, Quality Management Plan for Prudent 6 Fuel Use (2004), Quality Management Plan (QMP) for Cost-Effective Reduction of 7 Unaccounted for Energy (2005-2007), and Quality Management System for Ensuring 8 LEAC Plan Performance Goals (2005). 9

10 Q. HAVE YOU PREPARED AN EXHIBIT DETAILING YOUR RELEVANT 11

EXPERIENCE? 12 A. Yes. My resume is included as Exhibit JJC-1, Appendix A. 13 14 Q. HAVE YOU PREVIOUSLY TESTIFIED IN A PROCEEDING BEFORE THE 15

GUAM PUBLIC UTILITIES COMMISSION OR ANY OTHER UTILITY 16 REGULATORY AGENCY? 17

A. No, I have not testified previously before the Guam Public Utilities Commission 18 (GPUC). However, I have assisted GPA and its witnesses in developing testimony in 19 prior testimony filed before the GPUC. 20

21 2. PURPOSE AND METHODOLOGY 22

23 Q. WHAT IS THE PURPOSE OF YOUR TESTIMONY IN THIS PROCEEDING? 24 A. The purpose of my testimony is to demonstrate that the Authority’s proposed use 25

of convenience fees for this service is prudent, fair, and supported by industry practice. 26 As part of this demonstration, my testimony describes why and how the Authority 27 provides on-line payment service, the costs associated with this operation, the nature of 28 convenience fees, and the practice of charging such fees in the United States electric 29 utility industry. 30

31


Exhibit JJC-1


Q. WHAT ARE THE KEY ISSUES ADDRESSED BY YOUR TESTIMONY? 1 A. My testimony will address the following issues: 2

1. Why does the Authority provide an on-line bill payment service that accepts credit 3 cards for payments? 4

2. How does the Authority provide this service? 5 3. What are the costs the Authority incurs to provide these services? 6 4. What is a convenience fee and how is it used? 7 5. Is the use of convenience fees for use of credit cards prudent, fair, and supported by 8

industry practice? 9 6. Is the Authority’s petition to charge a $2.50 convenience per credit card transaction 10

consistent with the costs the Authority incurs to provide this service? 11 7. Other? 12

13 Q. WHAT METHODOLOGY DID YOU FOLLOW TO DEVELOP YOUR 14

TESTIMONY? 15 A. My approach to developing my testimony in this proceeding followed typical 16

procedures for an in-house expert. I drew from my base of experience in performing 17 research projects for other in-house clients, and analyzed information from a number of 18 sources relevant to the issues I am addressing in this proceeding. 19 More specifically, I reviewed the following types of documentation: 20 • Verisign transactional records 21 • Accounting information 22 • Internet based information sources 23 • Information from firms providing merchant banking services 24 • Guam Public Law. 25

Using my experience base and the information gathered and reviewed, I analyze 26 the data and extract meaningful information for this proceeding. 27

28 29 30 31 32


Exhibit JJC-1


Q. PLEASE OUTLINE THE REMAINING SECTIONS OF YOUR TESTIMONY. 1 A. Section 3 summarizes my recommendations. Section 4 reviews the nature of the 2

on-line payment service provided by GPA to customers. Section 5 explains the allocation 3 of FY 2008 costs to the on-line payment service. Section 6 compares the proposed 4 convenience fee with similar fees paid by electric utility customers in other jurisdictions. 5

6 3. RECOMMENDATIONS 7

8 Q. WHAT ARE THE MAJOR RECOMMENDATIONS THAT YOU DEVELOP IN 9

THIS TESTIMONY? 10 A. I recommend that the Authority charge a $2.50 convenience fee for each credit 11

card transaction. 12 13

4. NATURE OF GPA CREDIT CARD PAYMENT SERVICE TO CUSTOMERS 14 15

Q. DOES GUAM LAW MANDATE THE ACCEPTANCE OF CREDIT CARDS VIA 16 THE INTERNET? 17

A. Guam Public Law 28-51 adds Section 8123, “Acceptance of Payments, 18 Installation Applications and Service/Repair Requests Via The Internet” to Chapter 8, 19 Title 12 in the Guam Code Annotated. This section states the Guam Power Authority 20 shall “provide that the following services be made available via the internet: (1) 21 Acceptance payments via bank cards; (2) Application for installation of new and 22 additional services; and (3) Requests for service and repair.” 23

In general, a bank card refers to a plastic card issued by a bank, such as: 24

• ATM card, a plastic card only usable at an ATM. 25

• Credit card, a plastic card attached to a revolving credit line. 26

• Debit card, a plastic card linked to a bank account. 27 Therefore, Guam Public Law requires Guam Power Authority to accept payments via 28 credit card on the Internet. Exhibit JJC-1, Appendix B, contains the text from Guam 29 Public Law 28-51. The URL that publishes Guam Public Law 28-51 is 30 31


Exhibit JJC-1


http://www.guamlegislature.com/28th_Guam_Legislature/Public_Laws_28th/PL28-1 051.htm. 2

3 Q. ARE THE COSTS ASSOCIATED WITH ACCEPTING PAYMENTS VIA BANK 4

CARD A NEW COST NOT PREVIOUSLY ACCOUNTED FOR IN BASE 5 RATES? 6

A. Yes. The Government of Guam legally obligates GPA to provide this new service 7 to customers. GPA has not previously requested recovery in rates for the cost of 8 providing this service. 9

10 Q. DOES GUAM LAW ALLOW GPA TO LIMIT THE ACCEPTANCE OF CREDIT 11

CARDS VIA THE INTERNET TO ANY PARTICULAR CUSTOMER CLASS? 12 A. Guam Public Law 28-51 simply directs GPA to accept payments via bank card 13

over the Internet. It does not provide any guidance that can be used to exclude any 14 customer class from paying via bank card on the Internet. GPA allows any customer to 15 pay via credit card over the Internet but caps the payment amount that can be made in any 16 single month to $10,000. Furthermore, GPA only accepts VISA, MASTERCARD, and 17 ACH transactions via the Internet. 18

19 Q. WHAT IS GPA’S PAYGPA SERVICE? 20 A. GPA’s PayGPA service allows customers to view their current electric bills, 21

billing and payment history, and allows them to pay these bills via credit card or ACH 22 transaction over the Internet. 23

24 Q. WHAT IS THE UTILIZATION OF GPA’S PAYGPA SERVICE? 25 A. As of August 31, 2007, there are 4,424 registered users of GPA’s PayGPA 26

service. Each registered user may have access to several GPA accounts under the same 27 customer number. Not all registered users pay their bills via credit card each month. 28 Some use the PayGPA service primarily for information about their current and past bills 29 and payments. For the month of August 2007, the number of registered users grew over 30 the previous month by 218 to 4,206. The number of credit card transactions grew by 246 31


Exhibit JJC-1


over the previous month to 1989. The number of ACH transactions grew by 12 over the 1 prior month to 52. 2

Exhibit JJC – 1, Appendix C, shows that the number of registered users, monthly 3 credit card and monthly ACH transactions are growing. 4

5 Q. IS GPA’S PAYGPA INTERNET PAYMENT THE ONLY MEANS BY WHICH 6

CUSTOMERS MAY USE BANK CARDS TO MAKE ELECTRIC BILL 7 PAYMENTS? 8

A. No. There are several avenues to use bank cards to make GPA bill payments. 9 First, the Authority has recently signed a memorandum of understanding with a 10

third-party vendor to collect payments over the internet for GPA. Exhibit JJC- 1, 11 Appendix D, provides a copy of this agreement. This vendor may charge GPA customers 12 for this service. GPA does not receive nor does it collect any of this convenience charge. 13 Additionally, GPA does not incur bank card processing fees for these transactions. 14 Customers are free to use this service at their own risk. 15

Second, Citibank has a bill payment program using Citibank issued credit cards. 16 GPA participates in this program. (Exhibit JJC- 1, Appendix E) 17

Third, GPA customer service offices accept credit and debit cards. However, GPA 18 only accepts residential bill payments at its customer service offices. 19

20 5. ALLOCATION OF FY 2008 COSTS TO CUSTOMERS USING THE AUTHORITY’S 21

CREDIT CARD PAYMENT SERVICE 22 23 Q. WHAT IS GPA'S TOTAL COST THAT MUST BE ALLOCATED FOR FY 2008 24

TO SUPPORT ON-LINE PAYMENTS? 25 A. GPA's total budget to support on-line payment service for FY 2008 is $600,000. 26

(Exhibit RVW, Schedule TBD) 27 28 29 30 31


Exhibit JJC-1


1 Q. WHAT ARE GPA’S HISTORICAL COSTS TO SUPPORT CREDIT CARD 2

PAYMENTS? 3 A. Exhibit JJC – 1, Table 1, provides GPA's historical costs to support credit card 4

payments. 5 6

Table 1, Historical Costs to Support Credit Card Payments 7 TOTAL EXPENSE FOR PROJECT Implementation AMX International Installation/Configuration $0.00 AMX Insternational Ebill/Epay Licenses ~30,000 $0.00 Rackspace Server Setup $500.00 Rackspace Server Monthly for testing $15,582.92 Network Solutions paygpa.com domain registration $34.95 Total $16,117.87 Maintenance as of 8/31/07 Rackspace Server Rental 10 months 12/05-09/06 $10,300.00 Rackspace Server Rental 4 month 10/06-8/07 $14,080.00 RackspaceBandwidth overage/ New Firewall $2,875.96 Verisign certificate 1st year $1,146.00 Verisign certificate 2nd year renewal $1,545.00 Verisign certificate 3rd year renewal $795.00 AMX Support 1st year $4,928.00 Internet Connection 2% bandwidth utilization 12/05-1/07 $210.00 Network Solutions paygpa.com domain registration $99.95 Merchant Banking Services Transaction Charges 01/06-08/07 $370,760.18 Total Non-Labor O&M $406,740.09 Grand Total $422,857.96

8 9 Q. HOW ARE INTERNET CREDIT CARD PAYMENTS PROCESSED BY THE 10

AUTHORITY? 11 A. Figure 1, Credit Card Process Flow, illustrates how credit card payments are 12

processed. Figure 1 was provided by Authority’s Merchant Bank Service Provider. 13


Exhibit JJC-1


1 Figure 1, Credit Card Process Flow Diagram 2 3 Q. DOES GPA PAY A SINGLE RATE FOR THE PROCESSING OF CREDIT 4

CARDS? 5 A. No. There are many different kinds of credit cards issued by VISA and 6

MASTERCARD. Each has a different charge rate that is applied to payments received 7 using that card. 8

Web Payments/Credits are charged a discount rate. This discount rate is charged 9 to GPA for the acceptance and clearing of each payment. This discount rate is paid to the 10 Merchant Billing Services Provider. 11

This rate is either 2.35% (Qualified) or 3.85% (Non-qualified) for web payments. 12 The EXHIBIT JJC-1, Appendix F, [Non-Qualified Qualified Transaction 13 Literature.PDF], describes how credit cards are classified into Qualified to Non-Qualified 14 transactions. 15 1. All online payments are directly deposited in batches into GPA bank account. 16 2. The discount rate will later be debited from GPA’s bank account. 17 3. The discount rate for all payments debited immediately from GPA’s bank account is 18

2.35%, regardless if it is a Qualified or Non-Qualified transaction. 19


Exhibit JJC-1


4. The Non-qualified charge (3.85%) is invoiced later by the Merchant Banking Service 1 provider where an adjustment is made reflecting the portion of the 3.85% charges not 2 debited from GPA’s account. 3

4 Q. SINCE GPA DOES NOT PAY A SINGLE RATE FOR THE PROCESSING OF 5

CREDIT CARDS, HOW IS THE PER INTERNET TRANSACTION COST 6 CALCULATED? 7

A. The transaction cost for processing credit card payments over the internet is 8 calculated as the total credit card processing fee payments made to the Merchant Banking 9 Service divided by the total number of processed credit card transactions. It is not based 10 on the discount rate applied to each transaction. The total number of Internet transactions 11 from January 2006 to August 2007 is approximately 27,556 based on the Merchant 12 Billing Services invoices. The total payments made to the Merchant Banking Services 13 for processing internet credit card payments is $370,760.18. The average transaction cost 14 for processing internet credit card payments is approximately $13.45. 15

16 SINCE GPA DOES NOT PAY A SINGLE RATE FOR THE PROCESSING OF CREDIT 17

CARDS, HOW IS THE PER FACE-TO-FACE TRANSACTION COST 18 CALCULATED? 19

A. The transaction cost for processing face-to-face credit card payments is calculated 20 as the total credit card processing fee payments made to the Merchant Banking Service 21 divided by the total number of processed credit card transactions. It is not based on the 22 discount rate applied to each transaction. The total number of face-to-face transactions 23 from February 2006 to August 2007 is approximately 46,870 based on the Merchant 24 Billing Services invoices. The total face-to-face payments made to the Merchant 25 Banking Services for processing face-to-face credit card payments is $245,247.34. The 26 average transaction cost for processing face-to-face credit card payments is 27 approximately $5.23. 28

29 30 31


Exhibit JJC-1


6. PROPOSED GPA CONVENIENCE FEE 1 2

Q. WHAT IS A CONVENIENCE FEE AND HOW IS IT USED BY UTILITIES? 3 A. GPA is providing the convenience of credit card payments to the customer. 4

However, this convenience comes with a cost in the form of credit card processing fees 5 that are based on a percent of the customer payment. A convenience fee is a charge to the 6 customer for using this credit card payment service and is used to offset the added costs. 7

8 Q. WHAT RESOURCES DID GPA USE TO CONSIDER WHETHER CHARGING A 9

CONVENIENCE FEE IS CONSISTENT WITH UTILITY INDUSTRY 10 PRACTICE? 11

A. GPA used several sources to investigate the use of convenience fees by utilities in 12 the United States. These include: 13

14 1. A survey of information on the Internet and via email performed by GPA staff 15

(Exhibit JJC-1, Table 2) 16 2. The National Regulatory Research Institute (NRRI) paper “Survey to Determine if 17

States Have Rules or Laws Profiting or Curtailing the Charging of ‘Convenience 18 Fees’ for Customers Who Pay Utility Fees with Credit Cards” (Exhibit JJC-1, 19 Appendix G) 20

3. “Credit Card Acceptance: Driving Customers to Paperless Billing Among the 21 Challenges Facing Utility Organizations” by Dennis Smith, Vice President, Research 22 and Information Delivery, Chartwell Inc. found at the URL: 23 http://www.energypulse.net/centers/article/article_print.cfm?a_id=1403. (Exhibit 24 JJC-1, Appendix H) 25

26 27

28 29 30 31


Exhibit JJC-1


Table 2, GPA Convenience Fee Survey 1

2


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1


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1

2


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1

2 3

Q. IS CHARGING A CONVENIENCE FEE CONSISTENT WITH INDUSTRY 4 PRACTICE? 5

A. Yes. Charging a convenience fee is consistent with industry practice. Many 6 utilities outsource credit card payments to third-party vendors who charge the 7 convenience fee for the use of the service. Some utilities charge the convenience fee 8 directly. 9

10


Exhibit JJC-1


Q. WHAT IS THE INDUSTRY AVERAGE CONVENIENCE FEE AMOUNT? 1 A. The article by Dennis Smith (Exhibit JJC- 1, Appendix H) states: “The industry 2

average is more than $4 a transaction.” 3 4

8. CONCLUSIONS 5 6

Q. WHAT ARE YOUR CONCLUSIONS ON THE CENTRAL ISSUES ADDRESSED 7 IN YOUR TESTIMONY? 8

A. My conclusions are as follows: 9 1. The acceptance of bank cards via the Internet is mandated by Guam Public Law and 10

is a new expense not formerly anticipated for under base rates. 11 2. The average credit card processing cost per transaction for providing this service via 12

the Internet is $13.45. 13 3. The average credit card processing cost per transaction for providing this service 14

through customer services representatives is $5.23. 15 4. The average credit card processing cost per transaction for providing this service via 16

face-to-face and the Internet is $8.28. 17 5. The use of convenience fees for use of credit cards is prudent, fair, and supported by 18

industry practice. 19 6. The Authority’s petition to charge a $2.50 convenience per credit card transaction is 20

less than the costs the Authority incurs to provide this service. But as a matter of 21 policy, the Consolidated Commission on Utilities has chosen to use $2.50 as the 22 convenience fee for each credit card transaction. GPA expects that it will recover 23 only about $240,800 of its credit card processing costs through the convenience fee. 24

25 Q. DOES THAT CONCLUDE YOUR PREFILED TESTIMONY? 26 A. Yes, it does. 27 28


APPENDIX A

(RESUME FOR JOHN J. CRUZ)


Exhibit JJC-1


APPENDIX A 1 RESUME FOR JOHN J. CRUZ, P.E. 2

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Exhibit JJC-1


1


APPENDIX B

(PUBLIC LAW 28-51)


Exhibit JJC-1


APPENDIX B 1 GUAM PUBLIC LAW 28-51 2

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Exhibit JJC-1


1


APPENDIX C

(MONTHLY & DAILY CREDIT CARD TRANSACTON STATISTIC)


Exhibit JJC-1


APPENDIX C 1 MONTHLY AND DAILY CREDIT CARD TRANSACTION STATISTICS 2 3

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SCHS1SCHPSCHJ3SCHJ1SCHH5SCHH4SCHH1SCHHSCHG3SCHG1RRES

GPA RateSchedules

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3 4 5


APPENDIX D

(MEMORANDUM OF UNDERSTANDING BETWEEN GPA & MCB)


Exhibit JJC-1


APPENDIX D 1 MEMORANDUM OF UNDERSTANDING BETWEEN GPA AND MCB 2 (PAYGUAMBILLS) 3

4


APPENDIX E

(CITIBANK ONE BILL AGREEMENT & AMENDMENT ONE)


Exhibit JJC-1


APPENDIX E 1 CITIBANK ONE BILL AGREEMENT AND AMENDMENT ONE 2

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APPENDIX F

(NON-QUALIFIED, QUALIFIED TRANSACTION LITERATURE.PDF)


Exhibit JJC-1


APPENDIX F 1 NON-QUALIFIED QUALIFIED TRANSACTION LITERATURE.PDF 2

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APPENDIX G

(SURVEY FROM VARIOUS STATES)


Exhibit JJC-1


APPENDIX G 1 “SURVEY TO DETERMINE IF STATES HAVE RULES OR LAWS PROFITING OR 2 CURTAILING THE CHARGING OF ‘CONVENIENCE FEES’ FOR CUSTOMERS 3 WHO PAY UTILITY FEES WITH CREDIT CARDS” 4

5


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APPENDIX H

(ARTICLE FROM ENERGY PULSE ON

CREDIT CARD ACCEPTANCE)


Exhibit JJC-1


APPENDIX H 1 “CREDIT CARD ACCEPTANCE: DRIVING CUSTOMERS TO PAPERLESS BILLING 2 AMONG THE CHALLENGES FACING UTILITY ORGANIZATIONS” 3

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GUAM PUBLIC UTILTIES COMMISSION DIRECT … public utilties commission docket no. 07-10 direct...

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