operating a dual POR and non-POR billing system would be costly and time consuming to implement, given the different consumer protections and shut-off procedures that would presumably apply to the separate customer groups. Id. In their comments, Equitable, Dominion Peoples, OSBA, NFG and UGI also address the discount rate offered for accounts receivables. All of these comments reference the fact that the differences between NGSs customer bases could warrant differences in the discount rate between marketers within a POR program. Further, both EAP and NFG state that there is an inconsistency in the proposed regulation regarding the potential discount at which an NGDC will purchase receivables from an NGS. NFG at pp. 14-15. p. 6. In particular, both commenters note that Comments EAP Comments, section 62.224(a)(3) references a standardized discount while section 62.224(a)(4) states that the NGDC will establish a negotiated discount on a case-by-case basis. NFG Id. states that these two concepts are incompatible because either there is a discount that covers the various costs or there is a negotiated discount. NFG asserts that the Id. NGDC should be permitted to calculate a discount rate based on its experience with uncollectibles in its service territory and the Commission should then approve that rate. Id. In comments, the OCA and PECO state that the NGDC should be allowed to offer discounts so as to recover the NGS uncollectible expenses and the implementation, operating, administrative, and incremental costs associated with the POR. NFG further states that the regulation should provide for a factor” component “risk to the discount rate established by the NGDC. NFG explains that in any area of Id. business, companies who purchase accounts receivable do not do so at a dollar-for-dollar basis. Rather, a discount is always applied to the risk the purchasing entity takes with respect to uncollectibles. NFG further explains that among the risks an NGDC would take in implementing a POR program are the risk of uncollectible accounts and the
operating a dual POR and non-POR billing system would be costly and time consuming to implement, given the different consumer protections and shut-off procedures that would presumably apply to the separate customer groups. Id. In their comments, Equitable, Dominion Peoples, OSBA, NFG and UGI also address the discount rate offered for accounts receivables. All of these comments reference the fact that the differences between NGSs customer bases could warrant differences in the discount rate between marketers within a POR program. Further, both EAP and NFG state that there is an inconsistency in the proposed regulation regarding the potential discount at which an NGDC will purchase receivables from an NGS. NFG Comments at pp. 14-15. EAP Comments, p. 6. In particular, both commenters note that section 62.224(a)(3) references a standardized discount while section 62.224(a)(4) states that the NGDC will establish a negotiated discount on a case-by-case basis. Id. NFG states that these two concepts are incompatible because either there is a discount that covers the various costs or there is a negotiated discount. Id. NFG asserts that the NGDC should be permitted to calculate a discount rate based on its experience with uncollectibles in its service territory and the Commission should then approve that rate. Id. In comments, the OCA and PECO state that the NGDC should be allowed to offer discounts so as to recover the NGS uncollectible expenses and the implementation, operating, administrative, and incremental costs associated with the POR. NFG further states that the regulation should provide for a “risk factor” component to the discount rate established by the NGDC. Id. NFG explains that in any area of business, companies who purchase accounts receivable do not do so at a dollar-for-dollar basis. Rather, a discount is always applied to the risk the purchasing entity takes with respect to uncollectibles. NFG further explains that among the risks an NGDC would take in implementing a POR program are the risk of uncollectible accounts and the
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