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PSC Hears Dispute On Whether Community Solar Credits Can Appear On Supplier Consolidated Billing
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At its administrative meeting today, the Maryland PSC heard from parties concerning whether a customer served under supplier consolidated billing (SCB) may also receive community solar credits under the customer's SCB bill
The PSC took the matter under advisement and did not issue an immediate ruling
The issue was brought before the PSC by Baltimore Gas & Electric, as working groups could not reach consensus on the questions: 1) whether House Bill
908 permits community solar customers to participate in SCB; and 2) if community solar
customers are permitted to participate in SCB, how their credits should be applied.
BGE argued that House Bill
908 requires the utility to handle community solar billing and crediting if so requested by the community solar provider, and does not contemplate this obligation being fulfilled by a retail supplier under SCB. While BGE was open to following Commission direction, BGE argued that there was inherent tension under statute between the House Bill
908 requirements imposed on EDCs with respect to community solar, and allowing community solar to be credited and billed under SCB
BGE further said, "incorporating community solar into SCB will require additional billing
system upgrades, which will result in increased SCB implementation costs."
"Finally, if
utilities are required to incorporate community solar into their SCB system upgrades, the
December 31, 2024, SCB implementation deadline will be jeopardized," BGE said
BGE further said, "If the Commission determines that community solar customers should be permitted
to participate in SCB, BGE will not be able to continue its method of applying community
solar credits unless BGE is permitted to retain all customer community solar credits as
opposed to sending said credits to suppliers. BGE’s billing system is not currently designed
to handle the complex electronic data interchange transactions that would be needed to
transmit credits to and receive credits from suppliers. BGE’s proposal of retaining customer
credits to be applied to utility charges is the least costly solution because it avoids the need
for additional system upgrades and additional delays in the implementation of SCB."
Commissioners asked BGE to provide supplemental information concerning the additional cost and implementation time if community solar is allowed to be billed and credited on SCB, including for a mechanism under which community solar credits are not solely applied to BGE's distribution charges
Generally, Staff, OPC, retail suppliers and community solar providers agreed that statute permits SCB customers to be billed and credited for community solar under SCB
Staff said that no statute, regulation, or PSC order provides that community solar
subscribers shall be precluded from enrollment in Supplier Consolidated Billing
OPC said, "(1) PUA § 7-306.2 does not prohibit community solar
customers from participating in SCB; and (2) BGE should apply community solar net
energy metering credits to the electric distribution charges on customer bills and should
send any unused credits to the SCB supplier to be applied toward electric charges
remaining on a customer’s supplier-consolidated bill. OPC therefore recommends that the
Commission reject BGE’s request to bar community solar subscribers from participating
in SCB and to direct BGE to apply the credits only to electric distribution charges and
transfer any unused credits for application to the remaining electric charges on a
customer’s supplier-consolidated bill."
In discussing the statutes, and BGE's observation that SCB is not mentioned in the community solar statute, Commissioner Michael Richard cited the existing competitive billing statute, and asked why the community solar statute should not be read in concert with existing statute providing for competitive billing.
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February 14, 2024
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Copyright 2010-23 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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