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WGL: POR "Accommodated" In New D.C. Billing System, But Says Consideration Should Not Occur in Current Billing System Review

September 14, 2016

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Reporting by Paul Ring • ring@energychoicematters.com

Washing Gas Light told the District of Columbia PSC that, "implementation of a POR program in the District of Columbia can be more easily accommodated," in its new billing system, but said that a current docket reviewing the impacts of the new billing system on retail suppliers should not consider implementation of POR.

"While the functionality to implement a POR program has been built into the new SAP solution so that it will be easier to implement a POR program in the future than the initial implementation in Maryland, a number of issues must be decided by the Commission before a POR program can be implemented in the District of Columbia," WGL said

WGL noted specifically issues related to establishment of a discount rate, as well as the terms and conditions applicable to purchased receivables, such as the frequency and timing of remittances by the gas distribution company to suppliers, as needing to be resolved before POR implementation.

"Based on the Company's experience in Maryland, due to the rate and policy issues that must be resolved before a POR program can be implemented in the District of Columbia, the terms and conditions of a POR program could not be finalized within the existing timeframe before the Company's new SAP solution will be implemented. But even more importantly, Washington Gas is now well into its extensive testing of its new system ... Any change to the new system beyond remediation of faults discovered through the testing process -- and certainly the addition of a POR program in the District of Columbia would constitute a very substantial change to the system -- would require complete retesting of the entire system, causing substantial delay in the implementation date at significant additional cost," WGL said

"While the implementation of a POR program in the District of Columbia can be more easily accommodated in the new SAP solution, consideration of rate and other policy issues that must be decided before implementation of such a program should be considered in a separate proceeding, wholly separate from the Commission's investigation of the Company's new SAP solution in this proceeding," WGL said

"[W]hile Washington Gas does not oppose consideration, in an appropriate proceeding, of RESA's recommendations related to a purchase of receivables ('POR') program for competitive service providers ('CSPs') in the District of Columbia, Washington Gas strongly opposes consideration of such issues as part of this proceeding," WGL said

FC 1138

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