WGL Warns New Purchase Of Receivables Program May Be Delayed Absent Rule Change Concerning Enrollments/Drops

In comments to the District of Columbia PSC, Washington Gas Light has warned that its new Purchase of Receivables program for its D.C. service area may need to be delayed to the extent rules are not updated to be consistent with how enrollments and drops will be handled under the POR system

In an April 25 filing, WGL wrote, "By this filing, Washington Gas Light Company ('Washington Gas' or 'Company') hereby withdraws its Comments on the Notice of Third Proposed Rulemaking, filed in RM3-2014-01 on April 23, 2018, and submits this pleading in lieu of comments requesting approval of the Company's proposed revision to 15 DCMR §327.37. The Company is making this request to ensure that its proposed tariff revisions implementing the Purchase of Receivables ('POR') program, under consideration in Formal Case No. 1140, are consistent with the Public Service Commission of the District of Columbia's ('Commission') regulations governing the enrollment and dropping of competitive service providers ('CSP') operating in the District of Columbia under the POR program."

WGL said, "Under proposed Rule 327.37, currently under review in RM3-2014-01, once Washington Gas processes a customer enrollment from a CSP, the Company would be prohibited from accepting an enrollment from another CSP for a customer until the Company receives notice of termination of the customer's contract. Washington Gas recommends that this provision be revised. As the Company prepares to launch the POR program in the District of Columbia, customers should be given the flexibility to add and drop suppliers without having to wait until a CSP submits notice of termination of the customer's contract. The Company is currently testing POR implementation with automatic enrollments when requested by the customer. There is no technological barrier that would prohibit the Company from initiating a drop when another supplier enrolls the customer. Moreover, the tariff revisions under consideration in Formal Case No. 1140 provide for this automatic drop/enrollment process."

WGL said, "Furthermore, the process described in the currently proposed Rule 327.37, in RM3-2014-01, is inconsistent with the process Washington Gas follows in Maryland. COMAR 20.59.04.02(8) provides, 'The utility shall drop a customer from its current supplier when another supplier enrolls the customer.' Also, COMAR 20.59.04.02(A)(3) reads, 'Enrollments shall be processed on a first-in basis during any given month,' meaning enrollments will be processed upon a customer's request. Washington Gas seeks to follow the same process as it does in Maryland, such that when a customer is currently with a CSP he/she will be switched from that CSP with the 'new' enrollment, rather than waiting for the CSP to give notice of termination of the contract. This will enable enrollments via telephone or other technological means, which allows customers to timely switch CSPs at their request."

WGL said, "In the interest of administrative efficiency, and to ensure that customers receive service from their selected CSPs as early as possible, the Company requests that the Commission amend Rule 327.37 as follows, prior to POR implementation: The Natural Gas Utility shall drop a customer from its current supplier when another supplier enrolls the customer and shall process an electronic transaction for enrollment regardless of whether the customer is currently supplied by another supplier or by the utility. Enrollments shall be processed on a first-in basis during any given month."

WGL said, "For these reasons, Washington Gas respectfully requests that the Commission approve the proposed revision to Rule 327.37, as recommended herein, in advance of the launch of the POR program, to ensure consistency between the Company's tariff and the Commission's regulations."

"Without approval of consistent requirements in the tariff and regulation, implementation of the POR program may be delayed," WGL said