By Spencer James, HighGround Exchange · Updated · Sources & methods
One distributor, and a licence the Commission issues
Natural gas reaches a District business through a single distribution company. Washington Gas Light Company owns the mains and holds the delivery monopoly, and the Public Service Commission of the District of Columbia regulates it and licenses the companies that compete to sell the commodity flowing through those mains. The licensing regime is statutory rather than discretionary: the Retail Natural Gas Supplier Licensing and Consumer Protection Act of 2004, effective 16 March 2005, sits at D.C. Official Code 34-1671.01 and following, and the Commission implements it in Chapter 47 of Title 15 of the District of Columbia Municipal Regulations. Section 4700.3 closes the door on selling before authorisation. No person may present itself as a natural gas supplier, perform the duties of one, accept deposits or prepayments from retail customers, or contract or arrange contracts for retail customers before the Commission grants the licence. The practical reading for a buyer is that a District gas agreement should be with a company the Commission has licensed, because that is the only class of company the Commission can investigate, sanction, suspend or order to refund.
- Washington Gas Light Company is the gas distributor for the District of Columbia, and gas delivery is its monopoly.
- The Commission licenses competitive gas suppliers under the Retail Natural Gas Supplier Licensing and Consumer Protection Act of 2004.
- The implementing rules are Chapter 47 of Title 15 of the District of Columbia Municipal Regulations.
- Section 4700.3 bars soliciting, contracting or collecting deposits before a licence is issued.
- A licence is what gives the Commission jurisdiction to sanction a supplier or order a refund.
- Competitive supply depends on the service address, the meter and the utility territory; municipal utilities, cooperatives and some jurisdictions have no choice at all.
What a District licence application has to contain
The Commission publishes what it needs, and one item on that list is worth reading closely before signing anything. Section 4701.2 requires an applicant to show proof of technical and managerial competence; proof of compliance with the Federal Energy Regulatory Commission and with any transmission or pipeline company it intends to use; a sworn verification of compliance with federal and District environmental law; proof of financial integrity; proof of compliance with the bonding rules in sections 4704 and 4705; registration with the District's Department of Licensing and Consumer Protection and its Office of Tax and Revenue; a sworn verification of tax compliance; a sworn verification that it complies with the 2004 Act and the Commission's orders; its website address; a regulatory contact and a customer-service contact; and any trade name it will use. It must also file a sample copy of every natural gas supply customer contract it will offer, fixed or variable, together with a sample bill, and only brokers and aggregators are exempt from that requirement. That last line is the consumer-protection core of the chapter: the agreement itself is an exhibit the regulator has seen. A buyer handed an agreement that differs materially from the general offering is looking at something that was not filed as a sample.
- The application requires proof of technical and managerial competence, financial integrity and compliance with the bonding rules.
- An applicant must show compliance with the Federal Energy Regulatory Commission and with the pipeline or transmission company it will use.
- It must be registered with the Department of Licensing and Consumer Protection and the Office of Tax and Revenue, and verify tax compliance.
- A sample of every fixed or variable supply contract, plus a sample bill, must be filed; brokers and aggregators are exempt from that item.
- Because the contract is a filed exhibit, a materially non-standard agreement is worth questioning.
The clock the chapter runs on, in both directions
Chapter 47 sets response times for the regulator and notice duties for the licensee, and both matter to a business trying to understand who it is dealing with. The Commission reviews an application for completeness within fifteen days of receiving it. If something is missing it issues a deficiency letter, and the applicant has ten days to answer or the application is dismissed without prejudice, which leaves it free to refile. Once an application is complete, the Commission reviews it and issues an order approving or denying within fifteen days. The licence does not expire on a calendar date: section 4702.7 makes it valid until the Commission revokes it or the licensee surrenders it, subject to review every five years. Two further duties sit on a company already licensed. One that has not yet begun serving District customers must file notice with the Commission three business days before it starts soliciting or marketing, and every door-to-door representative has to present photo identification, with the licensee keeping a record of each representative and its photo identification available to the Commission on request. Before serving a first customer, the licensee must file the estimated start date and an affidavit that its sales, marketing and regulatory personnel, including contractors and vendors acting on its behalf, have been trained on Chapters 3 and 47 of Title 15.
- Completeness is reviewed within fifteen days; a deficiency letter gives ten days to cure or the application is dismissed without prejudice.
- A complete application draws an order within fifteen days.
- A licence stays valid until revoked or surrendered, with review every five years.
- A licensee new to the District gives three business days' notice before soliciting, and door-to-door representatives must show photo identification.
- A start-date filing and a training affidavit cover the sales, marketing and regulatory staff, including contractors and vendors.
- Leaving the market requires written notice to the Commission and to customers at least sixty days ahead.
Every class may choose, and what the switching data shows
Universal eligibility is what separates the District from most gas markets covered on this site. Washington Gas states that all customers in Washington, D.C. are eligible for the Customer Choice Program, and that every competitive supplier selling gas there must be licensed by the Commission. The utility's own participation table, updated on 1 September 2026, shows how much of each class has acted. Commercial accounts ran at 3,990 of 13,143, three in ten. Household accounts, the class this site does not write for, sat at 14,866 of 149,258, about one in ten. Interruptible accounts stood at 104 of 104, which is the whole class, and that is what a class built around accepting curtailment looks like: those sites were already in a negotiated relationship over their load. The District total was 18,960 accounts. The figure a commercial buyer should sit with is the commercial one, because seven in ten accounts of that class had not moved, which means a supplier pricing a District proposal is competing against a default the utility buys month by month and passes through at cost. The note on the utility's table also matters: the commercial figures include commercial and industrial accounts and group metered apartments, so the class is broader than a single meter at a single premises.
- Washington Gas states that all District customers are eligible for the Customer Choice Program.
- Every competitive gas supplier selling in the District must be licensed by the Commission.
- Commercial accounts were 3,990 of 13,143 participating, about three in ten.
- The commercial class includes commercial and industrial accounts and group metered apartments.
- Interruptible accounts were fully participating at 104 of 104, and the District total was 18,960.
What a supplier pays the utility, and what an offer has to cover
A competitive gas offer is not priced in a vacuum, because the supplier uses the utility's system to reach the meter and pays for that use. Washington Gas bills third-party suppliers a Balancing Charge, in place since April 2001, which recovers a portion of the company's capacity and peaking-operation costs, with storage billed to suppliers separately. The utility's own filings put District suppliers on Rate Schedule 5, with Maryland and Virginia on their own schedules, and it publishes purchased gas costs and balancing charges by jurisdiction and by month. The commodity works differently on the two sides of the choice. The utility is a pass-through, and says so: as a regulated utility it charges customers the same price it pays for the gas supply, buying monthly to serve firm customers, so its commodity cost moves with the market and the published cost-of-gas table is the record of that movement. A licensed supplier sets its own price and carries its own risk, which is the whole reason a competitive offer can be worth taking. That difference is what makes the arithmetic worth doing on the account's own numbers: split twelve months of therms into the heating season and the rest, work out what share of annual volume falls in the cold months, and then ask what each structure does to that share.
- Suppliers pay the utility's Balancing Charge, in place since April 2001, which recovers part of its capacity and peaking costs.
- Storage is billed to suppliers separately from the balancing charge.
- District suppliers sit on Rate Schedule 5, and the utility publishes purchased gas costs and balancing charges monthly by jurisdiction.
- Washington Gas charges customers what it pays for supply and buys monthly, so its commodity cost moves each month.
- Split twelve months of therms into heating and non-heating volume before weighing a fixed structure against an indexed one.
Why the utility's own supply affiliate has to compete on equal terms
Washington Gas belongs to a corporate family that also sells gas in the District, and the Commission has written a code of conduct around exactly that. WGL Energy Services appears on the utility's own list of companies licensed by the Commission to participate in the Customer Choice Program, so the distributor and one of its would-be competitors share a parent. Chapter 39 of Title 15 of the District of Columbia Municipal Regulations, the Affiliate Transactions Code of Conduct, published in 2011 and amended in 2020, governs the relationship. Section 3901.5 forbids the utility to give preferential treatment to an affiliate or to an affiliate's customers, and requires it to treat similarly situated suppliers the same way. Section 3902.1 prohibits joint marketing and joint advertising, and lets an affiliate's material into the billing envelope only within a general promotion of supplier choice where the same space is offered to every competitor on the same terms. Section 3902.3 bars sales leads to an affiliate. Section 3902.4 requires an affiliate's marketing to disclose that it is not the utility, that the Commission does not set its prices, and that buying from it is not a condition of utility service. Section 3902.5 requires separate premises. Section 3902.6 stops the utility from asking a customer to consent to having account information passed to a licensed affiliate at all. Sections 3903.1 and 3903.3 allow customer-specific information to move only on written consent, and require anything shared with an affiliate to be published contemporaneously to every non-affiliated supplier. The rest of the chapter keeps the money apart: an annual cost allocation manual filed within four months of the fiscal year end, an independent limited-engagement review every two years, a prohibition on loans and guarantees to affiliates, and written notice to the Commission within five business days if more than five per cent of the utility's earnings moves to its parent company. For a buyer the point is not that the affiliate is a poor counterparty. It is that the District has already written the rules that stop the distributor tilting the field, and the Commission is where a breach would be raised.
- WGL Energy Services, a company in the utility's corporate family, is licensed to sell gas in the District.
- 15 DCMR Chapter 39 is the Affiliate Transactions Code of Conduct, published in 2011 and amended in 2020.
- Section 3901.5 requires similarly situated suppliers to be treated alike and bars preferential treatment for an affiliate.
- Joint marketing is prohibited, and an affiliate's billing-envelope material requires equal access for all competitors.
- Customer-specific information needs written consent, and anything shared with an affiliate must be published to other suppliers at the same time.
The mains programme, the surcharge and the pilot that lets a site leave
The delivery half of a District gas bill carries a programme with a contested history, and it is worth knowing because that cost cannot be shopped. Washington Gas's accelerated mains replacement work began in 2014 as PROJECT pipes. Phase 1 ran from June 2014 through December 2020, Phase 2 was approved in 2021 and the Commission extended it to run through 16 June 2026, and by 31 December 2023 the first two phases had replaced 38.1 miles of mains and 8,497 services. The extension alone was expected to add roughly 8.72 miles of main and 2,628 service lines. A third phase proposed in 2023 was rejected in June 2024 because it did not align with the District's climate policy, and the company returned with a restructured plan, the District Strategic Accelerated Facilities Enhancement plan, filed in September 2024 in Formal Case No. 1179. The Commission approved a modified version on 4 March 2026: it cut the proposed budget by roughly thirty per cent, capped spending in each year with no carry-over of unused funds, required the company to absorb a first tranche of cost before any surcharge recovery begins, and made it justify replacement against alternatives rather than replace pipe merely because it is old, scoring risk instead. The approved framework runs from July 2026 to June 2029. That is not where the case rests. At a technical conference on 28 April 2026 the company presented its model results and a proposed first-year project list, and at the request of the Office of the People's Counsel, the District government and the Sierra Club the Commission agreed to reconsider its approval and paused the rollout that had been due to begin on 1 July 2026. A pre-hearing conference followed on 15 June 2026 and a second, two-day evidentiary hearing on 27-28 July 2026, after a first hearing on 9 December 2025. What matters to a buyer during that pause is what still appears on the bill: the Commission states that the cost of approved replacement work is currently recovered under PROJECT pipes Phase 2 through a surcharge it reviews and adjusts, so the line item does not disappear while the successor framework is settled, and the docket in Formal Case No. 1179 is where the current status sits. The plan also carries a Customer Choice Pilot: a customer whose service line is scheduled for replacement receives advance notice and the option to disconnect gas service permanently instead. Two related proceedings remain open, Formal Case 1187 on integrated gas distribution system planning and Formal Case 1178 on the company's leak detection and repair practices.
- PROJECT pipes began in 2014: Phase 1 ran June 2014 to December 2020, and Phase 2 was extended to run through 16 June 2026.
- By 31 December 2023 the first two phases had replaced 38.1 miles of mains and 8,497 services.
- Phase 3 was rejected in June 2024 for not aligning with the District's climate policy.
- The restructured District SAFE Plan was filed in September 2024 in Formal Case No. 1179 and approved as modified on 4 March 2026, over a July 2026 to June 2029 window.
- The Commission agreed to reconsider at a 28 April 2026 technical conference, paused the 1 July 2026 rollout, and held a second two-day evidentiary hearing on 27-28 July 2026.
- During the pause the Commission states approved replacement cost is still recovered under PROJECT pipes Phase 2 through a surcharge it reviews.
- A Customer Choice Pilot gives advance notice and a permanent-disconnect option to a customer whose line is due for replacement.
Submetered premises, and who is actually buying the gas
A District business whose suite is not individually metered is buying gas from the landlord rather than from the utility or a licensed supplier, and the District is one of the few jurisdictions with a written rule for it. Chapter 44 of Title 15 of the District of Columbia Municipal Regulations sets the standards for submetering and energy allocation equipment. Section 4400.2 permits an owner of a building not individually metered for each nonresidential rental unit to install that equipment in order to allocate both consumption and the demand and customer charges the utility or the supplier bills the building. Section 4401.3 requires a written agreement for the purchase of electricity or natural gas before anything is delivered, and it can be part of the lease; once an owner submeters, it is bound to supply every tenant. Section 4401.2 requires the lease to say plainly that the unit uses the equipment, that bills follow its readings, and that disputes about the amount and the equipment's accuracy sit between tenant and owner. The term worth reading before signing is section 4401.12: an owner may not charge the tenant more than the cost per kilowatt-hour, cubic foot or therm, plus the applicable demand and customer charges and taxes, that the utility and the supplier charge the building, with only the administrative and billing charges the chapter permits added. Installation is a regulated event in its own right, with notice to the Commission's Office of Engineering at least ninety days beforehand and written notification within thirty days of completion, and gas submeters must meet the ANSI B109 series, ASME and American Gas Association measurement standards. Building owners are also treated as public utilities for the purpose of bringing a complaint, which is the route open to a tenant if the pass-through does not match the rule.
- A suite that is not individually metered is supplied gas by its landlord rather than by the utility or a competitive supplier.
- 15 DCMR Chapter 44 governs submetering and energy allocation equipment in the District.
- The lease must state that the unit is submetered, that bills follow the equipment's readings, and that accuracy disputes sit between tenant and owner.
- Section 4401.12 bars an owner from charging more than the utility's and supplier's own cost plus permitted administrative and billing charges.
- Installation needs notice to the Commission's Office of Engineering ninety days ahead and again within thirty days of completion.
PUT THE OPTIONS SIDE BY SIDE
Your comparison checklist
| What a District gas account is deciding | How the District handles it | Where the answer comes from |
|---|---|---|
| Whether a supplier may sell to the account | Every competitive gas supplier must hold a licence the Commission issues, and selling before it issues is prohibited | 15 DCMR Chapter 47 and the Commission's supplier application route |
| What the supplier has already shown the regulator | Technical and managerial competence, financial integrity, bonding, tax registration, and a filed sample of its fixed or variable contracts | 15 DCMR 4701.2 application requirements |
| How much of the market has moved | Commercial accounts ran about three in ten participating, household accounts about one in ten, and interruptible accounts entirely | Washington Gas customer choice participation table |
| What a supplier pays to reach the meter | A Balancing Charge recovering part of the utility's capacity and peaking costs, with storage billed separately | Utility's published balancing charges and supplier rate schedule |
| Whether the utility may favour its own affiliate | No: a written code of conduct bars preferential treatment, joint marketing, sales leads and account information sharing | 15 DCMR Chapter 39 affiliate transactions code of conduct |
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Common questions
Further reading
Provider and official resources for the relevant service categories. Product availability and terms must be confirmed for your request.
Washington Gas -- Customer Choice programme: eligibility, licensed suppliers, participation by class and the Balancing Charge ↗Public Service Commission of the District of Columbia -- becoming a competitive supplier and the licensing requirement ↗Public Service Commission of the District of Columbia -- retail choice for electricity and natural gas, and the Consumer Bill of Rights ↗Public Service Commission of the District of Columbia -- Washington Gas pipeline replacement programme and the District SAFE Plan ↗15 DCMR Chapter 47 -- Licensure of Natural Gas Suppliers (compiled, updated 18 July 2024) ↗15 DCMR Chapter 39 -- Affiliate Transactions Code of Conduct (compiled) ↗15 DCMR Chapter 44 -- Submetering and Energy Allocation (compiled) ↗