January 18, 2000

BY HAND
Mark W. Musser, Esq.
Secretary
New Jersey Board of Public Utilities
Two Gateway Center - 8th Floor
Newark, New Jersey 07102

Re:	I/M/O The Rate Unbundling Filings By Gas Public Utilities Pursuant To Section 10, Subsection A of the Electric Discount And Energy Competition Act of 1999-- Public Service Electric & Gas Company BPU Docket Nos. GX99030121 and GO99030122.

Dear Secretary Musser:

At the Board’s January 10, 2000 agenda meeting President Tate stated that, at its next regular meeting on January 19, 2000, the Board would discuss the establishment of process to expedite the implementation by Public Service Electric and Gas Company ("Public Service" or "Company") of (i) unbundled billing, and (ii) a consolidated billing option for third party suppliers. In the proposed Stipulation submitted by Public Service in this proceeding, the Company proposed to delay the implementation of unbundled billing until August 1, 2000 and to delay the offering of a consolidated billing option indefinitely, pending the implementation of Electronic Data Interchange ("EDI"). This letter is to provide the Ratepayer Advocate’s comments as to timeframes which should be established by the Board.

UNBUNDLED BILLING

As noted in comments previously filed by the Ratepayer Advocate, unbundled billing is a fundamental requirement of the Electric Discount and Energy Restructuring Act ("Act"). Section 10(a) of the Act specifically requires that the unbundled components of each utility’s gas rates be "separately identified and charged in its tariffs." Despite this specific statutory requirement, Public Service is proposing to delay both the filing of unbundled tariffs and the implementation of unbundled billing until August 1, 2000. None of the other three gas utilities has requested a similar delay.

In order to shop for a supplier, customer must have access to unbundled rate information, including their shopping credit or "price to compare." Public Service has not presented any testimony or other documentation that it is unable to meet this fundamental statutory requirement on a timely basis. All of the State’s electric utilities, including Public Service, include the "price to compare" on consumers’ electric bills, the other gas utilities have agreed to reflect unbundled billing information, including the "price to compare, on their customer bills. Public Service, the largest gas supplier in the State of New Jersey, should do the same.

Unbundled rate information, including the "price to compare," is essential to enable consumers, and especially smaller consumers, to shop for an alternative supplier. Public Service should not be exempted from its statutory obligation to provide this information on a timely basis. The Board should direct Public Service, like the other three gas utilities, to implement unbundled billing at the time the rates established in the Board’s rate unbundling order becomes effective.

CONSOLIDATED BILLING OPTION

Public Service is proposing an even longer delay before it offers third party suppliers the option of having the Company render a consolidated bill, containing both the utility and third-party supplier’s charges. According to the proposed Stipulation submitted by Public Service to the Board, it would not implement a consolidated billing option until an indefinite date after the implementation of EDI, which the Company "anticipates" will occur "late in 2000." Again, Public Service’s position is at odds with that of the other three natural gas utilities. New Jersey Natural Gas Company ("New Jersey Natural") and South Jersey Gas Company ("South Jersey") already provide a consolidated billing option, and Elizabethtown Gas Company ("Elizabethtown") had committed to do so by April 1, 2000.

Public Service apparently is not claiming that it could not provide consolidated bills before the end of the year, merely that it does not wish to do so before EDI is implemented. This is not a sufficient reason to allow Public Service to delay implementation of this option. Issuance of customer bills involves an expense for suppliers who wish to enter the New Jersey marketplace. If all suppliers who wish to service Public Service customers are required to issue their own, separate bills, this could diminish their ability to offer savings, and thus their willingness to enter the market, especially for smaller consumers. Public Service provides natural gas service to more consumers than the other three utilities combined. It should not be permitted to be the only utility which does not make consolidated billing available on a timely basis. The Company should be directed to implement a consolidated billing option as soon as possible, and no later than April 1, 2000.

CONCLUSION

For the above reasons, in addition to those stated in comments previously submitted by the Ratepayer Advocate, Public Service should be required to implement unbundled billing, and to offer a consolidated billing option, within the same time frames agreed to by the other three New Jersey gas utilities.

SHS/ww

 * Attachment not included