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Initial Decision Would Dismiss Pennsylvania Utility's Attempts To Allow Non-Commodity Services To Be Billed On Utility Consolidated Bill (Including Services From Utility's Selected Vendor)
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An initial decision from two Pennsylvania PUC ALJs would dismiss, without prejudice, an application from Columbia Gas of Pennsylvania, Inc. for an affiliated interest agreement that was filed as part of Columbia Gas' intent to enter into a Billing Agreement with Pivotal Home Solutions, LLC, which would allow for charges for Pivotal’s warranty service plans and products & services to be included on Columbia Gas of Pennsylvania customers’ utility bills
The ALJs would close another proceeding, an old rate case, in which Columbia had filed to allow all third parties, subject to conditions, to include non-commodity costs on Columbia's utility bills (on-bill billing). Columbia had filed a letter in such docket, several years after an initial compliance filing, stating that Columbia would comply with non-discrimination provisions by providing all third parties (including retail suppliers) with on-bill billing for non-commodity services, rather than eliminating all on-bill billing for all non-commodity services from all parties, as had been Columbia's original means of complying with the non-discrimination directive
See full background on the proceedings in our prior stories here:
• Affiliated interest agreement proceeding, as a step needed to facilitate Pivotal's billing on Columbia bills
• Rate case proceeding in which letter allowing on-billing by all third parties was filed
Among other things, consumer advocates had objected to the manner in which Columbia sought to re-introduce on-bill billing for third parties' non-commodity services
As previously reported, the PUC in an order in a rate case filed in 2018 had found that Columbia's offering of on-bill non-commodity billing service to only selected vendors was discriminatory. Columbia chose to comply with the anti-discrimination provision by ceasing allowing any third-party to bill non-commodity services on its bill (including its previously selected vendors), rather than complying by opening bill access to all third parties on an equal basis
However, some six years after making the election to comply by ending on-bill billing, Columbia, in a letter styled as a compliance filing, informed the PUC that Columbia would comply with the anti-discrimination provision by opening on-bill billing to all third parties, subject to conditions (described in our prior story linked above)
Consumer advocates argued that Columbia could not choose to re-institute on-bill billing, after its prior termination, through a mere "compliance" filing, and argued that Columbia had not met the requirements for an application for such re-introduction to be considered by the PUC
In the initial decision, the ALJs agreed, and further found Columbia's related affiliated interest agreement (AIA), to facilitate Pivotal's billing on Columbia bills, to be procedurally deficient
Notably, with the ALJs proposing to dismiss the AIA case, and close the old rate case, based on procedural issues, the ALJs would make no findings as to the merits of on-bill billing for non-commodity services, or any proposed terms governing such
Specifically, the ALJs would conclude that Columbia's affiliated interest agreement filing is improper because it does not conform to the Commission’s regulations and the information required for applications or similar sought relief
The ALJs would conclude, "Given the novel issues raised in Columbia’s newly proposed on-bill billing
program, Columbia must file a formal request with the Commission to implement the
new program. This must be done through either a Petition or an Application under the
unique circumstances presented in this proceeding. Columbia’s filing does not meet the
criteria pursuant to Sections 5.11, 5.12 and 5.41 of the Commission’s regulations."
The ALJs would conclude that, "To re-institute any on-bill billing program and to seek relief from the Commission
regarding the proposed affiliated interest agreement, Columbia is required to file a
petition pursuant to Section 5.41 or other appropriate pleading."
"Columbia could have
simply addressed these matters in a proper pleading before the Commission, instead of
filing facially inadequate letters at Docket Nos. G-2025-3056022 and R-2018-2647577," the ALJs said
The ALJs further said, "based upon the insufficient and vague unverified initial filing by the
Company at Docket No. G-2025-3056022, the specific claims and basis for the claims
being advanced by Columbia, as well as the factual and legal basis to support such
claims, are unclear. Accordingly, the parties are unable to prepare a defense to the claims
advanced by the Company and the filing by the Company provides no notice to the public
or Columbia’s customers. As such, a hearing in this matter is not appropriate and is not
in the public interest. Therefore, the merits of the filings will not be addressed in this
decision."
The ALJs would dismiss the affiliated interest agreement proceeding without prejudice
Concerning the old rate case in which Columbia filed [in a June 30, 2025 Letter] to update its means of compliance by re-introducing on-bill billing, the ALJs said, "It is unreasonable to conclude that the Commission’s orders in the 2018
Rate Case permit or invite a subsequent compliance filing, nearly seven years later, and
that would disrupt a long-resolved proceeding."
The ALJs said, "The June 30, 2025 Letter [from Columbia], which contains
scant details about the mechanics of a newly proposed on-bill billing program is not a
'compliance filing' and will be stricken from Docket No. R-2018-2647577."
The ALJs would dismiss Columbia's June 30, 2025 on-bill billing letter filed in Docket No. R-2018-2647577, and would further strike from the record Columbia's June 30, 2025 Letter filed in Docket No. R-2018-2647577 in which Columbia had proposed to re-institute on-bill billing
The ALJs would close the rate case at Docket No. R-2018-2647577.
The initial decision may be appealed to the Commission prior to becoming final
G-2025-3056022, R-2018-2647577
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March 19, 2026
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Copyright 2026 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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