We take exception to your Sept. 8 editorial (“Our View: Bad weather doesn’t answer all CMP billing questions”), and question how you concluded that the Maine Public Utilities Commission and the Liberty Consulting Group are “CMP-friendly.”

Such a portrayal can only reflect incomplete knowledge or inaccurate understanding of the MPUC’s investigation of CMP’s metering and billing systems. The analysis, reports and day-to-day work of the MPUC staff and independent consultants are all matters of public record. To suggest that MPUC staff is biased couldn’t be further from the truth. In fact, it was our staff in the Customer Assistance Division who alerted us to problems with CMP meters and bills.

It’s also unfortunate that you present the OPA report and MPUC staff report as contradictory. In fact, the reports are complementary. Both conclude that there were an unacceptable number of billing errors that CMP has not addressed adequately and there remain unresolved high-usage complaints that must be addressed.

In short, here are the facts of the MPUC proceedings related to CMP.

The volume of complaints received by the MPUC triggered a formal investigation into CMP metering and billing in March 2018. The complaints involved high energy usage and billing errors.

Regarding high energy usage during the winter of 2017-2018, the independent Liberty audit examined approximately 4 million bills and found CMP’s metering and billing system was accurately capturing usage.


The Liberty audit also found that the vast majority of high bills during that winter could be explained by cold weather and an increase of 18 percent in the price of electricity supply through the standard offer.

To test this finding, the MPUC staff analyzed the billed usage of customers of Emera Maine during the same winter period. This analysis, which was suggested by counsel for the OPA, found that 13.8 percent of Emera Maine customers and 13.7 percent of CMP customers experienced high energy use.

Over 100,000 billing errors also occurred because of the poor implementation of CMP’s billing system. These errors are separate and discrete from the high energy usage observed during the winter of 2017-2018. Most of these errors have been addressed through the hard work of the MPUC staff. All of them must be resolved.

To be clear, the MPUC staff has never stated that the billing errors were attributed to cold temperatures, or that cold weather explains all high-usage complaints.

The MPUC’s Consumer Assistance Division is still working through 1,247 high-usage complaints. Both the MPUC staff and OPA have made recommendations to address these outstanding complaints through an independent review process to ensure they are resolved.

It’s unfortunate that your editorial was written without referring to any of this valid, verifiable information, most of which is contained in the staff’s bench analysis. Importantly, the MPUC staff also recommended a $6.5 million annual reduction in CMP’s earnings, as well as other remedial measures, because of its customer service failures. On balance there is no support for your suggestion that MPUC staff findings are “CMP-friendly.”  The MPUC remains objective and will follow the facts wherever they lead.

It is up to MPUC commissioners to judge all the evidence, and to accept, reject or amend the various proposals and analysis from those involved in these cases in making a final decision that is fair and in the public interest.

The MPUC cannot and will not prejudge decisions in any ongoing investigation or rate case of any utility. While our regulatory process may frustrate some who want immediate action, we follow a meticulous regulatory path laid out in Maine statutes. We will not rush to judgment in any case that comes before us. Our process protects both consumers and regulated utilities, and our record of impartiality and independence is well established.

We hope that in the future, your Editorial Board will more carefully examine the facts, follow the public proceedings and reach more informed opinions about a regulatory process that is transparent, exhaustive and meticulously fair.

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