Investigations

Natural gas leaks along Washington Gas’s aging distribution system remain a critical issue for the District of Columbia. Gas leaks present serious threats to safety and affect the reliability of natural gas service. Because methane emissions contribute to climate change, gas leakage from pipes also impedes the District of Columbia’s ability to achieve its climate goals. The Public Service Commission (Commission) and various stakeholders are considering advanced leak detection (ALD) technology to better address this problem. ALD technology refers to new tools that can be employed to detect gas leaks. The hope is that such technology can facilitate more effective and efficient leak detection, which could help repair Washington Gas’s distribution system.

Accordingly, on December 11, 2020, the Commission ordered the creation of the Advanced Leak Detection Pilot Program (ALD Pilot) and directed Washington Gas to administer the program over three years, authorizing a budget of $1.4 million. Through the ALD Pilot, Washington Gas is to utilize ALD technology to identify gas leaks within its distribution system. Based on the results of the ALD Pilot, the Commission has indicated that ALD technology could applied on a larger scale and become a long-term tool. The results of the program will undoubtedly influence the cost of natural gas service moving forward for ratepayers.

The Office of the People’s Counsel (OPC) has concerns as to Washington Gas’s implementation of the ALD Pilot. Washington Gas abruptly switched the kind of ALD technology it originally proposed using. Initially, WGL proposed using mobile ALD technology where the system is vehicle mounted; however, Washington Gas later contracted for services with Satelytics Inc., a company that uses satellite imaging to locate gas leaks. OPC has concerns about the effectiveness of this technology in an urban setting where pipes are located underground beneath concrete and other infrastructure. There is no clear indication why WGL chose to make this switch. In contrast, vehicle mounted ALD technology is used successfully in many urban settings.

In response to concerns raised by OPC and other stakeholders, the Public Service Commission held a technical conference to further examine the ALD Pilot on April 14, 2022, with OPC in attendance. Questions about the efficacy of the program remain, and a second conference is already tentatively scheduled in May.

OPC remains committed to ensuring that appropriate technologies are considered and reasonable metrics are used in measuring the program’s success. Choosing unproven and ineffective methods would defeat the purpose of employing ALD technology and drive-up costs, creating an unfair burden on ratepayers.

OPC Asks FERC to Revise Treatment of Certain Utility Expenses Recently OPC filed comments asking the Federal Energy Regulatory Commission (FERC) to update guidelines regarding the types of expenses that utilities can require consumers to pay for as part of their electric bill. OPC’s comments were part of a FERC inquiry into updating decades old accounting rules in light of the evolving commercial and regulatory landscape, new technology, and changes in the way lobbying and other industry activities are conducted. For example, OPC asked FERC to shift the burden for demonstrating that certain expenses are justified to the utility rather than consumers, who often don’t have the same level of information. OPC believes that FERC should take a particularly critical eye toward industry trade association and civic and political related expenses if a clear consumer benefit cannot be demonstrated. OPC also asked FERC to strengthen accounting and transparency rules, so that FERC, ratepayers, and their advocates can more easily determine what expenses are correctly the responsibility of consumers. While OPC believes that utilities should be able to recover expenses related to providing reliable and affordable service, consumers should not be on the hook for expenses that benefit utility shareholders rather than utility customers.

WGL construction complaints –Wards 2, 3 & 6

Background: In September of this year, OPC began receiving complaints about Washington Gas’s construction projects in Foggy Bottom (Ward 2), Cleveland Park (Ward 3) and Capitol Hill (Ward 6). The construction work involves moving natural gas meters from inside of residences to outside locations and digging up the sidewalks.

Issue: The residents’ primary complaint is that the quality of WG’s construction is substandard, aesthetically unpleasing and, in some cases, causes issues with access to their homes. Further, this issue is complicated by the fact that both areas are historic districts. As such, WG’s must comply with a strict set of construction mandates.

OPC actions: OPC has conducted a site visit and met with the residents. Additionally, OPC had a meeting with WG’s regulatory and construction officials where the issues were explained in detail and an action plan was set in place to address the issues and to avoid future problems. OPC has also contacted the District’s Department of Transportation to understand how that agency implements its rules with respect to historically designated portions of the city.

Next steps: OPC will follow up with each of the community leaders in each ward to ensure the issues are addressed and will work with WGL to ensure an effective communications plan is in place to inform consumers about future construction projects.

Tyler House Apartments — 1200 North Capitol St NW

Background: In 2014 through 2015, the owner of the Tyler House Apartments began a project in which all of the units were renovated. During the renovation, a number of the residents were moved from one unit to another.

Issue: A number of the residents have experienced billing issues related to their Washington Gas accounts as a result of their relocation within the building. OPC also identified a number of meter installations in the Tyler House that should be inspected by the Commission to ensure they are safe.

OPC’s actions: OPC has met with the Tyler House Tenant association and individual residents and reviewed their billing issues. OPC has successfully resolved a number of the tenants’ bills, but others remain unresolved. OPC has drafted a petition requesting the Commission inspect the natural gas meter installations at the Tyler House which will be submitted to the PSC.

Next steps: OPC will meet with WGL officials to resolve the remaining complaints. If the meeting does not resolve the complaints, OPC will file a formal consumer complaint before the PSC on behalf of the remaining tenants. Additionally, OPC will file a petition requesting the Commission inspect the meter installations.

OPC Protects consumers from unscrupulous natural gas providers

In the early part of 2013, OPC began receiving complaints about a number of natural gas providers who were engaging in practices that resulted in consumers being deceived into contracts that resulted in excessive bills. In April 2013, the Office filed a Petition for an Investigation into the business practices of alternative energy suppliers in the District of Columbia.

In May 2013, the Commission granted OPC’s Petition and opened an investigation into the business practices of all alternative energy suppliers and opened an Investigation into the Business and Solicitation Practices of Starion Energy. Over the next several months, several consumers filed written testimony describing their interactions with alternative energy suppliers and the resulting harms.

The case ended in a settlement agreement whereby Starion agreed to recalculate all of the complaints’ bills using an agreed upon process. Additionally, Starion will work with OPC to design and implement materials that will better inform consumers of contract terms and conditions. Starion also agreed to provide $100,000 to the Greater Washington Urban League which used the money to provide energy assistance to low-income consumers.

This case highlights OPC’s commitment to support a competitive energy environment while ensuring consumers’ ability to participate in the market by making informed choices and be free from abuses.

Reliability—Electrical Power Outages Throughout the City

Issue: Through its advocacy, OPC has learned that there have been numerous non-weather related electric outages throughout the city.

OPC actions: OPC has analyzed numerous outage reports filed by Pepco with the Commission to see if there are any trends to be addressed. From July 2015 – January 1, 2016, OPC has learned that there have been 223 outages across all eight wards. The predominate reason for the outages is equipment failure.

Next steps: OPC is in the process of developing a petition requesting the Commission to investigate the best means for Pepco to address these non-weather related outages.

Jetu Apartments meter conversion

Background: The Jetu Apartments is a series of apartment buildings located at 869 21st St NE. Currently, the apartment buildings are master-metered which means there is a single meter on each building that records consumption for the entire building. The building owner pays the electric bill and includes the cost in the rents paid by the residents. The owners have decided to convert the building from a master-metered building to an individually-metered building. Therefore, each resident will have a meter recording their consumption and the residents will pay their energy bills directly to Pepco. The owners have agreed to reduce the amount of the residents’ rent by an amount to reflect their anticipated monthly usage of electricity.

OPC’s actions: OPC met with members of the tenant association and, pursuant to its request, provided the Office of Tenant Advocate with technical assistance in developing a counter-proposal to the building owner’s initial rent reduction amount. OPC’s calculation was more favorable to consumers than the building owner’s proposal. The building owner accepted the tenants counter-proposal based on OPC’s calculation. OPC held a series of meetings with members of the tenant association and recognized the need for consumer education on how the tenants will be affected by the meter conversion and what they could do to minimize any adverse effects.

Next steps: OPC has developed a tenant education plan for the 400 plus consumers in the Jetu Apartments about how to be an informed energy consumer, i.e., how to read a bill, how to use energy efficiently, and how to resolve complaints. OPC and Pepco are coordinating an education and outreach effort for the residents of the Jetu Apartments. The initial education and outreach meeting will likely take place in December. OPC has also reached out to the Office of the Tenant Advocate with the hopes of developing a plan involving both agencies to effectively address the conversion issue.