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Maryland Utilities Ask PSC To Pause Retail Market Review, Citing Implementation Activities Under Reform Law SB1
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The Maryland Joint Utilities (indicated below) have asked the Maryland PSC to hold in abeyance the PSC's review of retail market issues and proposed reforms under the PSC's proceeding Public Conference 60
The Joint Utilities noted the recent passage of SB1, which includes a variety of retail market reforms
See details on SB1 here
While the PSC's PC60 proceeding had been examining several issues addressed by SB 1, the PSC proceeding also included various proposals not enacted by SB 1, including an extension of residential consumer protections to small C&I customers. See details on the proposals here
The Joint Utilities noted that SB 1 bars electric and gas companies from purchasing the residential accounts receivable from retail suppliers for supply agreements entered into or renewed on or after January 1, 2025.
"While this prohibition may not appear terribly complex on its face, multiple complex issues will have to be addressed by the Commission and stakeholders before the Maryland Joint Utilities can even begin to make the numerous resource intensive and costly changes that will need to be made to their customer care and billing systems (and potentially other processes and systems as well) in order to convert from a process of purchasing receivables for residential customers to an alternative methodology," the Joint Utilities said
The Joint Utilities said that such issues include, but are not limited to:
• the interpretation of Sections 8 and 9 of SB 1 [*editor's note: Section 8 generally applies the price limits to contracts entered into or renewed on or after January 1, 2025; Section 9 generally applies other provisions of the law on a prospective basis after December 31, 2024];
• the potential need to maintain multiple payment methodologies for the processing of customer receivables (e.g., POR for retail supply agreements entered into before January 1, 2025; POR for commercial customers; an alternative payment logic for residential retail supply agreements entered into or renewed on or after January 1, 2025; and POR associated with Community Choice Aggregation);
• determining how the Maryland Joint Utilities will know which accounts receivables are related to retail supply agreements entered into before January 1, 2025;
• whether to extend the prohibition of POR to commercial customers to eliminate multiple payment methodologies;
• the impact to the commercial POR discount rates from elimination of residential POR;
• the applicability of energy assistance payments and other bill credits;
• payment arrangement plans;
• budget billing;
• the cost responsibility between the utility customers and retail suppliers for making system and process modifications to comply with Senate Bill 1; and
• ensuring sufficient time for stakeholders to effectively communicate and explain changes to impacted parties.
The Joint Utilities noted that SB 1 goes beyond eliminating residential POR, and listed other new requirements which utilities and/or other stakeholders may need to implement, including restrictions on the prices and terms of energy supply offers, and requiring a new monthly report to the PSC by the "billing entity" for residential customers
"Therefore, the Maryland Joint Utilities recommend that PC 60 be held in abeyance so that interested stakeholders, as well as the Commission, can focus on implementing SB 1," the Joint Utilities said
The Maryland Joint Utilities also recommended that a new proceeding or proceedings be convened "as soon as possible" to address the new requirements of SB 1.
"While the prohibition against residential POR is not effective until January 1, 2025 -- a timeline which will be extremely difficult to meet under the best of circumstances -- the remaining provisions become effective on July 1, 2024, leaving little time for the multitude of decisions to be made, processes to be developed and changes to be implemented," the Joint Utilities said
The Joint Utilities include Baltimore Gas and Electric Company, Delmarva Power and Light Company, The Potomac Edison Company, Potomac Electric Power Company, Southern Maryland Electric Cooperative, Inc., and Washington Gas Light Company
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Raise Potential Of Eliminating Non-Residential POR
Ask That PSC Launch Proceeding To Address SB1 Implementation
May 31, 2024
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Reporting by Paul Ring • ring@energychoicematters.com
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