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The Public Utilities Commission of the District of Columbia is requesting information from the utilities on the number of residential purchase of receivable (POR) customers and the number of residential POR customers with uncollectable accounts. 

From Staff Request to Pepco: 

[ *** ] “Pepco recommends excluding late payment revenues from the POR discount rate calculation. These revenues should be used to cover the costs Pepco incurs in pursuing past-due and uncollectible balances and should not be used to reduce the discount rates charged to suppliers. Alternatively, if late payment revenues are retained in the calculation, Pepco recommends adding an administrative adder to more accurately reflect the costs associated with administering the program and collecting overdue balances.”

1. Please provide an illustrative example of how exclusion of the late payment revenues from the discount rate calculation would work, using CY 2023 POR data from Pepco 2024 POR filing. (A complete response must show the calculation of the discount rate as well as how the excluded late payment revenues are applied to reduce the uncollectible balance for the applicable year). 
2. (i) Please explain and confirm whether Pepco’s proposal to exclude late payments revenues from the discount rate would result in suppliers paying for the risk of uncollectible at the front-end as compared to the back-end when the uncollectibles are carried forward to future periods. (ii) If not, please explain how increasing the discount rate by eliminating late payment revenues (which would increase supplier upfront costs) and then applying the same late payments to the uncollectible balance (which would reduce future discount rates) helps improve the POR program.
3. (i) Please confirm whether Pepco’s proposal includes tracking the excluded late payments to ensure that they are used to reduce uncollectibles balances on a dollar-for-dollar basis. (ii) If not, please clarify Pepco’s proposal regarding how the late payments would be applied to the uncollectible balances going forward and how the reconciliation would work.
4. Please provide an itemized list describing the administrative costs that Pepco’s envisions should be included in the administrative adder it proposes in lieu of eliminating the late payment revenues from the calculation of the discount rate. 
5. Please quantify on an incremental basis (for the POR program) the cost associated with each of the items listed in question 1(d) above for CY 2024. [ *** ] 

“Pepco acknowledges that pandemic-related arrearages and disconnection moratoria may have contributed to elevated bad debt levels during earlier periods. However, RESA’s statement of the causes of the high arrearages does not comport with current data. Specifically, as of August2025, data indicate that the persistent year-over-year increase in write-offs continues and could be a result of other contributing factors that may include broader economic conditions and supplier practices.”

2022. For Residential POR customers, please provide a list of Third-Party Suppliers (TPS) enrolled in the POR program including: 1) the number of Residential POR customers and 2) the number of Residential POR customers with uncollectable accounts for each Third-Party Supplier for CY 2024, CY2023 and CY 2022. [ *** ] 
2023. For Non-Residential POR customers, please provide a list of Third-Party Suppliers (TPS) enrolled in the POR program including: 1) the number of Non-residential POR customers and 2) the number of Non-residential POR customers with uncollectable accounts for each Third-Party Supplier for CY 2024, CY2023 and CY 2022. [ *** ] 

“Pepco acknowledges the intent behind WGL and RESA’s recommendations and does not oppose the concept of lengthening the recovery period for under-collections. However, Pepco emphasizes that any extended recovery timeline must include appropriate compensation for carrying costs because currently, Pepco is only compensated for unrecovered balance within each specific year, with interest calculation resetting annually.”

1. Please provide an illustrative example using actual data that shows the step-by-step calculation of a multi-year amortization approach, showing the discount rate, the uncollectible balances, the annual amortization amount and the compensation for carrying costs. 
2. What does Pepco propose as a reasonable and appropriate carrying cost for the uncollected balance if the amortization approach is adopted by the Commission?

From Staff Request to Washington Gas Light: 

[ *** ] (a) The Commission designed the WGL and PEPCO POR programs to be self-contained with all revenues and expenses contained therein. Witness Tuoriniemi’s direct testimony in FC 1180 describes the removal of all POR expenses and revenues (including late payment fees) in Adjustment 7D. Please explain how including late fees as an offset to bad debt expense in the POR discount rate double counts those revenues. 

(b) If this is not WGL’s position, please explain the Company’s position in detail. [ *** ] 

“If the Commission is inclined to continue with the POR program, it could consider lengthening the period over which the Company recovers its current under-collection. Approximately 45% of the total proposed discount rate is related to prior period underrecoveries. If uncollectibles remain steady or decline, lengthening the period over which the current under-recovery is paid, the proposed discount rate could be somewhat mitigated. However, if uncollectable rates climb or there are fewer billed commodity sales than anticipated, lengthening the period over which the under-collection is paid may serve to exacerbate the problem.”

(a) Please provide an illustrative example using actual data that shows the step-bystep calculation of a multi-year amortization approach, showing the discount rate, the uncollectible balances, the annual amortization amount and the compensation for carrying costs. 

(b) What does WGL propose would be a reasonable carrying costs for uncollected balance if the amortization approach is adopted by the Commission. 

(c) Over what period of time does WGL propose for the amortization. 

(d) If the uncollectible rate does not decrease or increases from its current level, would Pepco continue to recommend amortization of the uncollectible balance. [ *** ] 

For Residential POR customers, please provide a list of Third-Party Suppliers (TPS) enrolled in the POR Program including: 1) number of Residential POR customers and 2) number of Residential POR customers with uncollectable accounts for each Third-Party Supplier for CY 2024, CY2023 and CY 2022. 

For Non-residential POR customers, please provide a list of Third-Party Supplier (TPS) enrolled in the POR Program including: 1) Number of Non-residential POR customers and 2) Number of Non-residential POR customers with uncollectable accounts for each ThirdParty Supplier for CY 2024, CY2023 and CY 2022.

Staff Request to Pepco (11/20/2025)
Staff Request to Washington Gas Light (11/20/2025)
PEPPOR-2025-01 (03/27/2025)
WGPOR-2025-01 (04/15/2025)
(Purchase Of Receivables)