Pa. PUC Staff Opposes POR at Philadelphia Gas Works Absent "Thorough Investigation" of PGW Finances

The Pennsylvania PUC's Bureau of Investigation and Enforcement (I&E) has recommended that the PUC reject a stipulation among PGW and retail suppliers to enhance choice at PGW, and said that Purchase of Receivables should not be implemented at PGW at this time (R-2008-2073938).

As only reported by Matters, the stipulation among suppliers and PGW would implement various retail choice billing and education enhancements (see 11/30). Education measures include bi-annual mailings on choice, and discussion of choice by PGW call center representatives with new delivery service applicants. Billing enhancements include changes to PGW's billing system to support different supplier rate offerings and the implementation of rate ready consolidated billing.

Additionally, the stipulation calls for PGW work towards the completion of a settlement agreement with the Purchase of Receivable collaborative participants by January 2012. The stipulation does not address POR itself.

I&E said that it, "opposes the establishment of a Purchase of Receivables program until a thorough investigation of the financial condition of PGW is completed."

"The submitted stipulation offers no evidentiary support for the establishment of a POR program by PGW," I&E added.

"By way of further explanation, I&E opines that the offered document cannot be used as a vehicle to establish a Purchase of Receivables ('POR') program. This joint stipulation represents the opinions of a limited number of parties and attempts to move the agreement away from the parameters of the April 13, 2011 Secretarial Letter ... Instead, the agreement is offered to promote a limited agenda without sufficient evidentiary support. The intent of the Secretarial Letter was not to establish a POR at this point," I&E said.

"A thorough evaluation of the financial condition of PGW is necessary to determine whether a POR is in the public interest. The genesis of the collaborative was an emergency rate relief proceeding. To suggest that a POR of any design is appropriate at this stage without a thorough investigation is ill founded," I&E said.

Apart from its objection to POR, I&E urged rejection of the stipulation due to the lack of evidentiary support.

"This failure to provide relevant evidence in support of the joint stipulation renders that submitted document insufficient to satisfy all applicable legal standards," I&E said.