Virginia natural gas: eight distributors

Eight distributors, and one of them appears twice

The Commission's own list of regulated gas companies carries eight names, not the five that circulate in summaries: Appalachian Natural Gas Distribution, Atmos Energy, Columbia Gas of Virginia, Roanoke Gas, Shenandoah Gas Division of Washington Gas Light, Southwestern Virginia Gas, Virginia Natural Gas and Washington Gas Light itself. Washington Gas appears twice because the Shenandoah division carries its own service area around Winchester while the parent company serves Northern Virginia under the same Virginia tariff series. The Commission's territory map also shows municipal systems that it does not regulate as distributors, which is why a building can sit inside a gas map and still sit outside any choice programme.

• Eight SCC-regulated distributors, listed individually by the Commission, plus municipal systems outside its rate jurisdiction.
• Washington Gas Light and its Shenandoah Gas Division are separate entries, and the division's rates sit in the same Virginia tariff book.
• Territory is decided by mains, not by county lines: the Commission's map is a guide and the utility confirms the address.

The statute authorises a plan, not a market

Va. Code 56-235.8 does not deregulate gas supply. It authorises each gas utility to offer retail supply choice by filing an implementation plan, which the Commission must accept for filing within thirty days and then approve or disapprove within 120 days, extendable by order for up to sixty more. If the Commission does not act inside that window the plan is deemed approved. The section is written for customers who are not eligible for transportation service under tariffs already in effect, which is the detail that explains the whole architecture: Virginia's large industrials had transportation before the plan route existed, and the plan extends supply choice to the customers who did not.

• Thirty days to accept the filing, 120 days to decide, sixty more by order, and deemed approval if the Commission stays silent.
• A plan must carry unbundled firm and interruptible rates, open-access terms comparable to the utility's own transportation, and a code of conduct between utility and suppliers.
• No plan could take effect before 1 July 2000, which dates the framework to the state's restructuring decade.

The programme carries a cancellation clause

Subsection E of the same statute lets the Commission terminate a utility's retail choice programme on application of at least 25 per cent of that utility's choice customers, or of 500 choice customers, whichever number is smaller, on the utility's own application, or on the Commission's own motion. The remedy is an orderly return of those customers to the utility's sales service. A supplier agreement can therefore outlive the programme it was written for, and the statute anticipates it: the utility is given the opportunity to reacquire upstream transportation and storage capacity to serve the returning load, so the end of a programme is a capacity event as well as a commercial one.

• The trigger is a fraction of participants or an absolute count, whichever is lower, not a finding about the whole market.
• Termination returns customers to utility sales service rather than leaving them without a supplier.
• The utility may reacquire pipeline and storage capacity, which is where a returning load's cost actually reappears.

Licensing splits at small commercial

The licence duty in subsection F attaches to selling gas to the residential and small commercial customers of a utility that has an approved plan. The Commission issues that licence within forty-five days of a qualified application, requires the applicant to show it can serve essential-human-needs customers, and states that a licensee is not a public utility and is not rate-regulated as one, though the Commission may still police its terms and conditions. Large commercial and industrial accounts reached through transportation are governed by the utility's tariff instead: Columbia's supplier schedule requires a licence under the retail access rules at 20 VAC 5-312-40, a signed supplier agreement in the Commission-approved form, and financial assurance.

• The 20 VAC 5-312-40 application asks for ownership, affiliates, any affiliate relationship with a Virginia distribution company, and internal controls against information sharing.
• Washington Gas's Rate 9 supplier schedule in its Virginia tariff is backed by a standby letter of credit, performance bond or guaranty.
• Ask for the licence number and the assurance instrument, not a supplier's assurance that it is licensed.

Schedules decide eligibility, and each utility draws its own lines

Washington Gas separates sales from delivery: Rate 2 for commercial and industrial service, Rate 5 for large commercial and industrial, with 2A and 5A as the matching delivery schedules for a customer bringing its own gas. Columbia's small general schedules run in bands of 0 to 208.9 Dth, 209.0 to 626.6 Dth, and above 626.6 Dth a year, with a transportation mirror for each, while its large general schedules split at 20,888 Dth a month on an election that binds for twelve months and needs thirty days' notice before the anniversary to change. Virginia Natural Gas puts firm delivery on Schedules 6 and 7 and interruptible delivery on Schedule 9, whose volume bands are written in Mcf a year while its rates are per Ccf.

• Columbia also defines a customer group for aggregation at 100 customers or 10,000 Dth of annual demand, which is the threshold a multi-site portfolio has to clear.
• Columbia's transportation schedules require a daily demand meter with electronic measurement or automatic meter reading and telemetering equipment at the service location.
• VNG's interruptible delivery schedule prices a commodity charge against the alternate fuel the site can actually burn, which presumes the site has one.

Three units on one state's bills

A Virginia gas quote and a Virginia gas bill need not be denominated the same way. Washington Gas prices distribution and its purchased gas charge per therm, in declining blocks that step at 125 and 875 therms and then at the large-use tiers on Rate 5. Columbia's tariff is written in Dth and says plainly that therm rates are the Dth rate divided by ten. Virginia Natural Gas bills in Ccf. Roanoke Gas prices in therm blocks, and its industrial firm schedules carry a demand charge measured in therms rather than in kilowatts. Ccf is a volume, therm and Dth are energy, and the conversion between them depends on the heating value the utility applies to the meter.

• A Dth is ten therms by definition; a Ccf is a hundred cubic feet and its therm content is not fixed.
• Ask the supplier which unit its price is quoted in and which factor it used to convert.
• Compare a quote to the bill's own units before comparing it to anything else.

What to establish before signing

Six things decide whether a Virginia gas contract behaves the way the sales call implied. First, the distributor and the exact schedule at the service address, because the schedule is what carries eligibility. Second, whether the class is transport-eligible and what the utility wants as proof, which for Columbia means telemetering and for VNG's interruptible delivery schedule means an alternate fuel. Third, the supplier's licence and the assurance instrument behind it. Fourth, whether the bill is consolidated or dual, since the choice page for each utility describes both. Fifth, who carries balancing and imbalance charges when nominations miss. Sixth, that the programme itself can be terminated, so the contract's term and its protection are different questions.

• Get the schedule letter or number in writing before the supplier prices the account.
• Ask what happens to unused or over-delivered gas at the end of a billing month.
• Keep the utility's own confirmation of the enrolment, not only the supplier's welcome letter.

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