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Md. OPC Petitions PSC for Modifications to Price to Compare Info
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February
11, 2011
The Maryland Office of People's Counsel has petitioned the Maryland PSC for an order clarifying the PSC's earlier order on the Price to Compare, and directing the Pepco, Delmarva, and Allegheny Power to correct what OPC alleged is "erroneous" SOS information on each utility's website (Case 9228).
As only noted in Matters (6/25), the PSC in a June 2010 order modified the Price to Compare information to include the following: 1) Actual pricing for the current SOS period (including base generation, transmission, and reconciliation); 2) Actual SOS pricing for the next SOS period (when known) and statement of the date beyond which SOS pricing is not known; and 3) A weighted average blend of the two most recently known SOS period prices to develop a yearly average.
Although there remains some confusion based on the PSC's language (suggesting the information applies to "all" SOS classes), these requirements were essentially only required for residential and Type I customers.
OPC alleged that that the information found on customers' bills and some of the utilities' websites, "contain inaccurate and outdated information."
Specifically, OPC alleged that a January 21, 2011 Pepco bill only listed the SOS price through May 31, 2011, even though the SOS price for the June 1, 2011 through September 30, 2011 period was known at that time and should have been listed as well. Additionally, the weighted average used on this bill reflected the weighted average through May 31, 2011, rather than September 30, 2011, which OPC argues should have been used.
"A historical weighted average price is useless and misleading to customers," OPC
said. Of course, while OPC meant this as applying to using a prior SOS period price
in the weighted average price, it also rings true for the weighted average OPC wishes
to be used (current SOS and immediately known forward SOS), because, except at the
very start of the pricing period, the static SOS rates for the current period become
"historic," and are of little value in projecting forward rates, which is the inherent
problem in attempting to create some sort of 12-
Because SOS pricing has been decreasing with each successive RFP under current market conditions, using older SOS rates in the weighted average results in a higher Price to Compare.
OPC alleged that bills from Allegheny and Delmarva contained the same deficiencies. OPC also alleged that each of the three utilities' websites contained the same deficiencies in listing Price to Compare information.
It should be noted that for Allegheny, some of its mass market SOS rates were not filed in tariffs until late January 2011 (due to its unique procurement schedule), and it does not appear that the tariffs containing these new rates have been approved by the PSC yet, and therefore unclear if it would be appropriate to use these rates in updated Price to Compare information.
For Delmarva and Pepco, new mass market SOS rates for the summer 2011 period were filed in early November, but the associated tariffs were not approved until December 3.
It's also an interesting aside that Baltimore Gas & Electric, which has posted updated
Price to Compare information online using the new summer 2011 rates, and is using
this info in its bills, actually hasn't filed the new SOS rates in a tariff with
the Commission, which caused some confusion for Matters when the new rates appeared
online but were not formalized in a tariff (BGE had said that due to service not
starting until June 1, the updated tariffs would be filed with a future change in
SOS prices, perhaps when non-
OPC recommended that the PSC establish specific deadlines for the updating of Price to Compare information once the new rates are known after an RFP. OPC suggested that utilities be required to file updated SOS tariff sheets within 1 week of an RFP result being approved, and, at the same time, be required to update their website with the new Price to Compare information; however, with such information labeled as "tentative" since, although the tariffs will have been filed, they will not have yet been approved by the PSC.
Within 2 days of the PSC approving the new SOS tariff sheets, utilities should be required to start using the new information on bills and update their websites to indicate the prices are no longer tentative, OPC said.
However, OPC conceded that even under this proposed schedule, there are quirks. Most
notably, under the schedule for the April RFP process, the new non-
OPC recommended using the forward non-
Of course, this discussion also ignores the fact that while base generation rates
for SOS are known according to a fixed schedule, transmission and reconciliation
rates do not change on a fixed schedule, and are typically either not known for months
beyond the next two to three months (for the reconciliation component) or, for transmission
rates, are "known" in so far as the current rates continue to apply in perpetuity
until a new tariff filing to replace them, but this tariff filing can occur at any
time as the FERC-
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