The OPC CONNECTION – August 2020
A Note from Your People’s Counsel
It’s Complicated…That’s Why OPC is Your Utility Lawyer
Over my 30-plus years at OPC, I’ve witnessed numerous changes in the utility industry. The issues have changed and technologies have changed. Nonetheless, OPC’s aggressive advocacy for DC consumers has not changed, even during these devastating times of COVID-19. And another thing that has not changed is my guiding principle that consumers must have a place at the table whenever a utility seeks to raise their rates. OPC strives to empower consumers to let their voices be heard during the ratemaking process
Pepco’s pending application asking the Public Service Commission to approve a massive rate increase and dramatically change the way rates are set, is no exception. How can you claim your place at the table? Join a PSC virtual community hearing on Tuesday, September 29, at 2 p.m. OPC has been keeping consumers apprised of this proceeding through fact sheets, presentations at virtual community meetings, and social media.
Rate cases are very complex, and involve the review of mounds of technical accounting and economic data supplied by the utility. It’s OPC’s responsibility to read the fine print so you don’t have to do it. As your utility lawyer, OPC will meet the challenge, despite the fact that this case has been impacted by an unprecedented global pandemic, and marred by a maze of twists and turns, including major errors by Pepco.
Utilities are obligated to provide transparent and accurate data when they attempt to justify rate hikes. If not, consumers literally pay the price. OPC fights to keep this from happening.
See our FAQ here, contact OPC at (202) 727-3071 or firstname.lastname@example.org if you’d like to learn more about the Pepco case, and save the date for the September 29 community hearing.
DC Water Bills on the Rise
Want to learn about #Here2HelpDC? Here is your opportunity to find out how four District agencies charged with serving DC utility consumers are making residents and businesses aware of energy and money-saving initiatives that will help soften the negative impacts of the COVID-19 pandemic.
Join representatives from OPC, the Public Service Commission, the District Department of Energy & Environment, and the DC Sustainable Energy Utility on a live webinar on Wednesday, September 9, 12:30 to 1:30 p.m.
Learn about consumer protections, payment assistance programs and energy-saving initiatives available to District electric, natural gas, water and local phone consumers. Register here to attend. Also, check out this article about #Here2HelpDC.
DC Water Bills on the Rise
Washington Gas Light has proposed a $35.2 million rate increase. Should the Commission approve this request, the average residential gas bill would go up by almost $13 per month, beginning January 2021.
OPC contends the proposal is excessive and would not clearly advance the District’s climate action goals. Moreover, an increase of this magnitude would further exacerbate the energy burden consumers are coping with during the COVID-19 pandemic.
OPC goes on the record against WGL’s plan in testimony filed before the Public Service Commission on August 14. Just over $9 million of the increases stem from the company’s PROJECTpipes accelerated gas pipeline replacement program despite lackluster performance and uneven benefits for consumers.
After thorough review of WGL’s 1,600 page application, OPC has determined that the rate hike proposal is not in the public interest. Washington Gas has until September 14 to file rebuttal testimony to respond to OPC’s conclusions. Read more here.
Earlier this month, OPC presented testimony on behalf of water consumers at a DC Water public hearing on expected rate changes. OPC urged DC Water to take a measured approach in its pending rate adjustment to reflect the negative economic impacts and uncertainty resulting from the COVID-19 pandemic.
DC Water’s rate adjustment proposal will be effective October 1, 2020 for fiscal year 2021, and October 1, 2021 for fiscal year 2022. Based on our careful review of DC Water’s plans, OPC has made a set of recommendations, including urging DC Water to postpone the fiscal year 2022 rate plan until after the FY 2022 financial planning process concludes in 2021. See other recommendations and the full testimony here.
For the average residential customer, plans call for a rate increase of 6.6% for FY 2021 and 6.7% for FY 2022. To estimate the impact of the proposed changes to your water bill, see the following tools:
Rate Comparison Tool:
Impervious Area Calculator:
OPC will continue to keep consumers up-to-date on these issues. You are invited to share any concerns with your rates with OPC at (202) 727-3071 or email@example.com.
Need Help With your Water & Energy Bills? Apply Now!
With everyone staying home during the pandemic, your bills may be higher than you can handle. OPC wants to make sure you are aware of bill payment assistance residents can still apply for.
DC Water Emergency Bill assistance is slated to end January 22, 2021. The Low-Income Energy Assistance Program and utility discounts are available year-round.
If a resident applies and is approved on September 30th, they will receive an FY 20 benefit. If a resident applies and is approved on October 1st, they will receive an FY 21 benefit. The same resident can apply on September 30th and again on October 1st and receive two separate benefits.
Mayor Muriel Bowser and the DC Council authorized funds in May to provide emergency relief for unpaid DC Water bills during the coronavirus public health emergency.
DC Water ratepayers can apply through the Department of Energy and Environment for assistance to pay outstanding water bills from the fund established for the Clean Rivers Impervious Area Charge (CRIAC). You also can apply for ongoing monthly CRIAC discounts.
DOEE will review and approve the applications, and DC Water will directly apply the credits to the customer’s bill.
DOEE also assists income-eligible households with heating and cooling energy costs through the Low Income Home Energy Assistance Program (LIHEAP). Apply at: https://doee.dc.gov/liheap.
You also can contact OPC for more information at (202) 727-3071 or by email at firstname.lastname@example.org.
The Office of the People’s Counsel is always excited to welcome new members to the OPC Team. In July, Sarah Kogel-Smucker came aboard as our new Environmental and Climate Attorney. Sarah is breaking ground as the first staffer in OPC’s new Climate Action Division. Sarah’s has dedicated her career to public interest environmental and climate change advocacy
The native New Yorker ventured out of the “Big Apple” to attend Grinnell College in the small town of Grinnell, Iowa. There, she received a Bachelor’s Degree in Philosophy, and later obtained a JD from Boston College Law School.
Back home in New York City, Sarah worked for nearly 10 years at that NY Law Department’s Environmental Division. She focused on climate resiliency and helped develop and implement New York’s postHurricane Sandy rebuilding plan.
She is proud to have had stints at environmental nonprofit organizations where she lobbied for improvements in New York State’s preservation of open space and the clean-up of toxic waste sites.
Sarah moved to the District in May 2018, and before joining OPC, was with the DC Office of the Attorney General. At OAG, she worked on opposing federal rollbacks and advancing local solutions related to clean energy, climate change litigation and rulemaking.
OPC has a long history of environmental advocacy and Sarah looks forward to building on it. She will work in conjunction with other OPC divisions to help the District meet its clean energy and climate action goals and ensure consumers reap the benefits.
Sarah spends her down time hiking with the family, reading, and watching television. She’s now waiting patiently to safely resume traveling.
OPC is advocating for consumers in the following cases:
Formal Case No. 1154: Washington Gas Light’s Application for Approval of PROJECTpipes 2 Plan
PROJECTpipes is WGL’s 40-year accelerated pipeline replacement program. The first phase of the program is completed, and the company is now requesting the PSC to approve its application to begin the second phase of the project.
On August 6, 2020, OPC and Interveners filed a Joint Stipulation to Admission of Select Documents and Submission. In an effort to further streamline and make the hearing on this matter more efficient, OPC and the interveners stipulate to the admission of certain documents without the need to lay any foundation, subject to any motions to strike.
The Office of the People’s Counsel for the District of Columbia’s Investigation of Practices of Third-Party Suppliers. In 2019, OPC began conducting a study examining the energy bill impact, quality of services, and viability of Third-Party Suppliers and requested anonymized data from the utilities in connection with this purpose. A dispute arose over OPC’s statutory authority to collect this information.
On August 10, OPC filed Motion for Leave to Reply and Reply to WGL’s response to OPC’s motion to compel WGL to provide the requested information and reply to RESA’s comments.
RM40-2020-01-M Chapter 40 – Small Generator Interconnection Rules and Formal Case No. 1050 – The Investigation of the Implementation of Interconnection Standards in the District of Columbia
On August 14, OPC filed Reply Comments Regarding Notice of Proposed Rulemaking, in response to comments filed by Pepco. OPC’s filing is meant to aid the Commission, interested parties and stakeholders to meet the challenges of developing, in a cost-effective manner: (1) a better interconnection process to assist in the proliferation of CREF projects throughout the District that will strengthen the resiliency and reliability of the District’s energy delivery system, (2) allow optimal utilization of all viable DER options, and (3) afford all District ratepayers and consumers access to the benefits of sustainable energy options.
Formal Case No. 1162: Washington Gas Light’s Application for Authority to Increase Existing Rates
On August 17, OPC filed Direct Testimony and Exhibits to make corrections to and replace the testimony and exhibits filed on August 14, 2020, which inadvertently were filed as confidential and the confidential testimony filed as public, and therefore had confidential data that was inadvertently not redacted.
During the COVID-19 crisis, OPC welcomes the opportunity to speak at your Advisory Neighborhood Commission, civic association or community group meeting. We can give updates on utility issues and tell how we are continuing to serve during the pandemic. Call (202) 727-3071 if your group would like our staff to “zoom in.”
People’s Counsel Sandra Mattavous-Frye (bottom row left) welcomes Ward 2 Councilmember Brooke Pinto (top row left) and shares how OPC partners with DC Council offices to serve consumers.
Deputy People’s Counsel Karen Sistrunk testifies on behalf of DC Water consumers at the July 30th DC Council hearing on three pieces of legislation related to water and sewer services. See the testimony here.
OPC’s Doxie McCoy attends the National Associations of Black and Hispanics Journalists’ Virtual National Convention to learn and share best practices related to social media and traditional media tools to expand public affairs outreach
The People’s Counsel and OPC staff update leaders of the Washington Interfaith Network/WIN on the proposed Pepco and Washington Gas rate increases and discuss other pressing utility issues.