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Washington Gas Light, Pepco and RESA filed comments in response to the comments of the Office of People’s Counsel. 

Washington Gas Light’s comments state that “every statement made in the OPC comments regarding the relationship between the Company and its TPS affiliate, WGL Energy Services (“WGL Energy”), is incorrect or, at the very least, highly misleading.”

Their comments discuss the following issues:  

1. From Washington Gas Light’s comments: [ *** ] 
2. Washington Gas Share’s OPC’s Concerns About Harm To Low-Income And Limited-Income Households [ *** ] 
3. Washington Gas Does Not Give Preferential Treatment To Any Affiliate(S) Or Customers Of Affiliate(S) In Providing Regulated Services [ *** ] 
4. The Gas Costs Charged By Washington Gas Are Just And Reasonable [ *** ] 
5. WGL Energy Is Far From The Only Active TPS In The Natural Gas Market In The District Of Columbia [ *** ] 
6. WGL Energy’s Prices Compared To Washington Gas [ *** ] 
7. Washington Gas Is The Default Provider Of Natural Gas In The District [ *** ] 

Conclusion: Washington Gas appreciates the opportunity to provide its reply comments on the best way to address the issues facing the POR program. Washington Gas respectfully request that the Commission consider the reply comments herein and integrate them into any changes the Commission decides to make to the POR program. Further, Washington Gas respectfully asserts that the recommendation that the Commission initiate an investigation based on OPC’s baseless suggestion that any pricing difference between Washington Gas and WGL Energy is the result of nefarious activity should be rejected. Initiating an investigation based on suggestions of wrongdoing that are completely devoid of any merit would be a waste of Commission resources and is wholly unnecessary.

From Pepco’s Comments: 

[ *** ] 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. This approach does not account for cumulative unrecovered balances over time, and therefore, any prolonged recovery timeline must ensure that Pepco is made whole and does not incur financial losses as a result of deferred cost recovery. Pepco previously proposed amortizing substantial POR balances over a two-year period, but the Commission rejected this approach, citing concerns about delayed cost recovery and/or potential subsidization by Standard Offer Service (SOS) ratepayers. [ *** ] 

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 August 2025, data indicate that the persistent year-over-year increase in write-offs continues and could be a result of other. While the pandemic may have initiated certain trends, these trends in uncollectible expenses and write-offs have continued well beyond the pandemic. [ *** ] 

While Pepco understands the intent behind convening a formal working group, Pepco respectfully prefers to address recommendations and explore potential solutions through the current process in filings. It allows for the parties to consider other parties’ written positions in advance, which will allow the Company to carefully deliberate those positions to prepare a contemplative response. This approach is both more efficient and productive because it allows for focused and timely exchanges on specific issues. Pepco remains committed to constructive collaboration and any questions that may be posed by parties or the Commission.

Regarding RESA’s proposal to explore SCB, Pepco does not support its implementation in the District of Columbia. SCB has faced significant challenges in Maryland, where initial supplier interest has diminished significantly, and operational complexity has proven burdensome. SCB requires extensive data exchange between utilities and suppliers, and despite the fact that discussions began in 2017 in Maryland, implementation has been slow and costly. Exelon’s Maryland Utilities have invested over $24 million to date. 10 Given that supplier participation remains limited, Pepco is concerned that ratepayers may ultimately bear the financial burden of the program with only limited participation. Given these outcomes, Pepco does not believe SCB is a viable or cost-effective solution in the District of Columbia.

OPC noted in one of its responses that, in practice, bad debt accumulated through the POR Programs is ultimately recovered through future rate cases – placing an undue financial burden on consumers.11 This is not correct and has not been presented in any Pepco base rate cases. Pepco does not include bad debt expense associated with POR in base rates or through a base rate case. Instead, bad debt expense is deferred, and actual write-offs are recovered through the POR discount rate. This approach ensures that bad debt expense and associated write-offs attributable to POR are accounted for only within the POR mechanism.[ *** ] 

From RESA’s Comments: 

[ *** ] RESA respectfully urges the Commission to:

1. Preserve POR as a cornerstone of retail energy competition that and promotes choice. 
2. Reject OPC’s proposal to eliminate residential POR, which would harm District customers by reducing competitive supply options. 
3. Convene a stakeholder working group to identify the drivers of increased discount rates and propose durable, data-driven solutions. 
4. Maintain the non-residential POR program in its current form to ensure continued stability and access to competitive energy supply options for District businesses. [ *** ] 

WGL Comments (09/29/2025)
Pepco Comments (09/29/2025)
RESA Comments (09/29/2025)  
PEPPOR-2025-01 (03/17/2025)
(Purchase of Receivables)
WGPOR-2025-01-G (04/15/2025)
(Purchase Of Receivables)