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Retail Suppliers Propose Text Revision That Would Fix Broad Draft Rule Language That, Absent Change, Would Include C&I Customers In Rules Meant For Residential Customers
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Retail energy suppliers in Maryland have proposed changes to draft green power rules issued by Staff of the Maryland PSC, with one of the suppliers' changes ostensibly meant to address, as previously noted by EnergyChoiceMatters.com, the potential that the draft language could be read as applying certain new requirements to all green power plans, not only those marketed to residential customers as directed under SB1
As previously reported, SB 1 only allows retail suppliers to sell "green power" to residential customers at either: 1) a price set by the PSC generically, or 2) a price established through a company-specific petition from a retail supplier
Under SB1, "green power" is defined as, "energy sources or renewable energy credits that are marketed as clean, green, eco–friendly, environmentally friendly or responsible, carbon–free, renewable, 100% renewable, 100% wind, 100% hydro, 100% solar, 100% emission–free, or similar claims." [Public Utilities Article § 7-707(a)]
In brief, Staff's draft language to implement these SB 1 provisions requires that retail suppliers shall retire in PJM GATS one REC per each MWh marketed as green power, "as defined in Public Utilities Article § 7-707(a), Annotated Code of Maryland." No language in Staff's draft would limit this requirement to residential customers.
Because the SB1 definition of green power under § 7-707(a) (quoted above) is not limited to residential customers or residential sales, and because Staff narrowly defined green power as defined in § 7-707(a), and not § 7-707, generally, (where other subsections of § 7-707 are limited to applying to residential customers, but not the (a) definition itself), Staff's draft could be read as requiring that all products which are marketed as "green power" (including products using similar green terms noted in the green power definition above) -- including C&I sales -- must have RECs retired in GATS.
For those C&I plans which are marketed using terms meeting the definition of "green power", the GATS requirement would limit retail suppliers to using RECs from only certain states, because GATS only allows retirement of RECs from PJM states, or imported RECs if the RECs meet certain criteria (see a full discussion of these limits on RECs which may be retired through GATS in ECM's prior story here).
Such a GATS requirement would, for example, prohibit retail suppliers from describing a product for C&I customers that is backed by national (non-GATS) RECs as being, among other things, "clean", "green", "renewable", "100% renewable", "100% wind", "100% solar", or "carbon–free".
While SB1 was intended to prevent the use of such marketing terms for residential electricity plans which did not meet specific renewable content & source requirements, SB1 did not extend this prohibition to C&I plans (and, in fact, SB1's sponsors took great pains in the bill's debate to emphasize that nothing in the non-residential choice market was changing).
While the commenting retail suppliers do not describe the rationale for their proposed change in a narrative discussion, a group of retail suppliers has proposed revisions to Staff's draft language to confirm that the GATS retirement requirement does not apply to C&I sales (except as is currently required for RPS compliance or voluntary plans which use specific RPS terms, such as a plan marketed as, "having characteristics of a Tier 1 renewable source or a Tier 2 renewable source.")
Specifically, the Retail Energy Supply Association, NRG Energy, and CleanChoice Energy jointly propose to add the qualifier "residential customers" to the relevant language in Staff's draft provisions concerning GATS retirement.
With the suppliers' changes, the proposed rule would now read, "A supplier shall retire, in a PJM Environmental Information Services, Inc. Generation Attribute Tracking System reserve subaccount accessible by the Commission, one renewable energy credit for each megawatt-hour (MWh) of retail sales to residential customers of electricity marketed as 'green power' as defined in Public Utilities Article § 7-707(a), Annotated Code of Maryland."
Rulemaking RM 84
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October 15, 2024
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Copyright 2024 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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