Retail Supplier Seeks Clarification Of Otherwise "Challenging", "Burdensome" Proposed Rule

In comments on a proposed rule, WGL Energy Services, Inc. asked the District of Columbia PSC to clarify proposed new RPS reporting requirements for retail electric suppliers

As only reported by EnergyChoiceMatters.com, the proposed rules, in addressing the grandfathering of existing contracts from recently adopted higher RPS requirements, provide that, for Compliance Years 2019, 2020, and 2021, suppliers shall include the number of the energy supply contracts that were executed prior to March 22, 2019, the effective date of the CleanEnergy DC Omnibus Amendment Act of 2018 (CleanEnergy Act), and the following information regarding such contracts:

(1) The length of each such energy supply contract

(2) The amount of electricity sold pursuant to each such energy supply contract for the Compliance Year that is the subject of the compliance report being filed and an estimate of the amount of electricity to be sold pursuant to each such energy supply contract for each Compliance Year through 2021. However, no estimates shall be required for inclusion in the compliance report for Compliance Year 2021

WGL Energy sought clarity on points (1) and (2) with respect to reporting each individual specific contract

WGL Energy noted that, with respect to prior similar grandfathering, retail suppliers currently provide such information in aggregate.

WGL Energy said that, "A single, one-time estimate of 2020-2021 annual electricity sales for contracts executed between October 6, 2016 and March 22, 2019 would satisfy the intent of the CleanEnergy DC Omnibus Amendment Act of 2018."

"With thousands of customers under contract in the District, creating reports with this level of detail would be challenging and unduly burdensome," WGL Energy said

"WGL Energy finds that point (1) is not necessary to meet the purpose of the Clean Energy Act and should be removed from the NOPR, and point (2) be rewritten as a one-time reporting obligation of the 2019 Annual RPS Compliance Report," WGL Energy said

RM29-2019-01-M-1