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PSC Again Rejects WGL Tariff to Impose Balancing Responsibility on Retail Suppliers
September 13, 2011
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The District of Columbia PSC has again rejected a series of changes to Washington Gas Light Rate Schedule No. 3 (Interruptible Sales Service), Rate Schedule No. 3A (Interruptible Delivery Service) and Rate Schedule No. 6 (Small Commercial Aggregation Pilot), finding that certain provisions remain unclear, are inconsistent with each other, or are not fully explained (GT97-3).
As only reported by Matters, WGL's changes are meant to, among other things, ensure that competitive service providers (CSPs) pay their "fair share" of interruptible balancing, by shifting the responsibility for balancing Interruptible Delivery Service Customer deliveries and consumption to the competitive supplier designated to manage the deliveries (see 2/22).
The revisions would establish various balancing charges and penalties, and implement a Daily Required Volume (DRV) for interruptible customers.
The revisions would also eliminate Rate Schedule No. 3 (Interruptible Sales Service), as WGL said that Rate Schedule No. 3A (Interruptible Delivery Service) is more advantageous to customers currently on Rate Schedule No. 3.
The PSC cited two concerns in particular for rejecting the filed tariffs, none of which dealt with the main thrust of the proposal to assign the balancing obligation to suppliers.
First, the Commission noted that Part F (Availability) of Rate Schedule No. 6 states that:
"If a customer decides to terminate service with its Supplier and that Supplier provides confirmation of its agreement to terminate its contract, such customer may remain under the Interruptible Distribution Delivery Service Rate Schedule for a period up to 3 months and will be charged the applicable firm rates for the volume provided by the Company. Customers will have a period of three (3) months to choose another Supplier or, depending on Company infrastructure capabilities and/or availability may be switched to Rate Schedule Nos. 2 or 3 until such time as the customer chooses another Supplier. If such customer wishes to be provided service by another Supplier, and that Supplier complies with the requirements of this Rate Schedule, said customer can initiate service effective with the subsequent meter read of the customer"
The PSC noted that WGL has proposed to phase out to Rate Schedule No. 3 (Interruptible Sales Service), and thus said it is unclear why the tariff would provide that customers would be moved to this schedule under the circumstances described above.
Additionally, the PSC said that Rate Schedule No. 3A (Interruptible Delivery Service), as proposed, provides that a customer may be switched to Rate Schedule No. 2 only.
"The proposed language suggests that an interruptible delivery service customer may have a little more flexibility when selecting a new supplier -- possibly indefinite -- if the customer were switched to Rate Schedule No. 2 (or 3). However, based on WGL's proposed revisions to Rate Schedule No. 3A, it appears that the Company does not intend to allow such customers to have an indefinite period of time to select a new alternative supplier, regardless of whether they were switched to Rate Schedule No. 2," the PSC noted, stating WGL must clarify these provisions.
Lastly, the PSC directed WGL to explain why Part F in Rate Schedule No. 6 is necessary, since it does not appear that Part F affects the manner in which WGL and an alternative supplier interact.
The PSC did not opine on the Office of People's Counsel's request in the case to increase the imbalance penalty for exceeding the 15 percent tolerance limit from $10/Dth to $12.50/Dth under normal operating conditions, and increase the penalty under operational flow order conditions from WGL's proposed $25/Dth to $35/Dth.
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