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No Party Files Any New "Comprehensive Proposals" Allowing UCB To Continue Without POR In Maryland
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Neither the Maryland utilities nor retail suppliers filed any new "comprehensive proposals" that were to detail how retail energy suppliers could serve new or renewed residential customers under utility consolidated billing in Maryland without purchase of receivables (POR)
As previously reported, the PSC, in a "clarification" of a December 2024 order, had directed, "interested residential
suppliers and utilities to negotiate and submit comprehensive proposals detailing how a supplier
may: (1) enroll a new customer under a utility consolidated billing ('UCB') mechanism that
does not involve the utility purchase of supplier receivables; and (2) renew a customer under a UCB mechanism that does not involve the utility purchase
of supplier receivables."
The December 2024 order, which the clarification addressed, requires that dual billing, or supplier consolidated billing (if available), shall be the only method for new or renewed residential shopping customer billing, due to SB1's prohibition on residential POR
In response to the above-stated direction from the PSC's clarification, the joint utilities, consisting of Baltimore Gas and Electric, Potomac Electric Power Company, Delmarva Power & Light, Potomac Edison, Southern Maryland Electric Cooperative, and Washington Gas Light, stated that, "the Joint
Utilities point to their compliance plans that were filed in PC65 in August 2024 "
"[N]nothing
has meaningfully changed, and no new solutions have come from the negotiations to date," the joint utilities said
Generally, such utility compliance plans had stated that no mechanism to allow UCB without POR to continue, while also allowing grandfathered contracts to continue on POR, could be quickly implemented or be done in a cost effective manner. The plans did address a post-POR form of UCB to be in place after grandfathered POR ends (such as pro-ration, though current timelines may create a 6-month, or more, gap between the time grandfathered POR ends and a new UCB is in place)
The Joint Utilities alleged that, as convened by PSC Staff, meetings among the utilities and suppliers about non-POR UCB were held on January
22, February 5, and February 19, 2025 (ECM notes that only the February 19 meeting occurred after the PSC's Feb. 6 clarification order directing the filing of comprehensive plans to allow UCB without POR).
The utilities alleged, "The Joint Utilities all participated, as well as responded
in writing to multiple rounds of questions from both Staff and the suppliers in efforts to move
negotiations forward."
The utilities alleged, "However, the suppliers have failed to come to the table with any meaningful
insight or proposed solutions."
The joint utilities alleged that suppliers recently proposed a new approach, under which the UCB with POR mechanism would be in place for non-eligible customers, but that the POR program for these non-eligible customers would have a 100% discount rate
The joint utilities said, "The utilities responded in writing explaining a myriad of reasons that is not a viable solution."
The joint utilities said that suppliers' requests for rehearing or stay of the PSC's dual billing mandate, "are nothing more than a last-ditch attempt to delay and/or
avoid the inevitable."
As to the post-POR form of UCB, the joint utilities said that implementation, "will not be fast, and it certainly will not be cheap".
The Joint Utilities "firmly believe" that the risk of any significant costs for a non-POR form of UCB should not be with utility customers.
The joint utilities said, "The legislative mandate to end POR is non-negotiable; at this point the best use of the parties’ time would be spent attempting to go down a path towards a reasonable solution, which is believed to be dual billing."
The Retail Energy Supply Association and CleanChoice Energy, Inc. (the Supplier Coalition) said in comments that, "The Supplier Coalition made good faith efforts to bring the stakeholders together to discuss what a short-term (and potentially long-term) UCB solution might look like. We asked for a meeting with the utilities and sent five questions to the utilities in advance. We proposed a meeting between individuals of suppliers and the utilities fluent in EDI/XML so that the Supplier Coalition could better understand the utilities’ systems and the challenges they face in designing a UCB program. [ed. note: The Supplier Coalition said in a footnote to this sentence that: 'Members of the Supplier Coalition have operating systems and technology every bit as sophisticated, if not more so, than the utilities’ systems. We thought a meeting of subject matter experts would be a good idea. The utilities apparently disagreed.'] The goal was to work together to find an alternative to the utilities’ long-term UCB solution. In sum, the Supplier Coalition attempted to productively engage directly with the utilities, asked legitimate questions, and offered ideas in an effort to identify reasonable solutions -- all of which the utilities dismissed."
The Supplier Coalition said, "The hope for negotiations in response to the Clarification Order was to arrive upon a short-term UCB solution that would be cost efficient and faster to implement than the long-term solution. As the Supplier Coalition explained to the full working group, a short-term solution might not be ideal, but it would serve as the solution until all stakeholders, including the Commission, have a better understanding of the actual long-term market impact of SB1, including future supplier participation in the Maryland residential market."
The Supplier Coalition said, "The Supplier Coalition has been unable to reach an agreement with the utilities. Importantly, the Supplier Coalition has not objected to the elements of the UCB programs that the utilities are proposing in the working group for use over the long term. The Supplier Coalition does not have sufficient information, however, to opine on whether the long-term programs are being designed at 'least cost' or for prompt implementation. We have not heard anything that would address our concerns that the long-term UCB programs will not be implemented until well beyond January 1, 2026, the apparent 'end date' for UCB as set forth in Order No. 91463."
PC 65, PC65
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Implementing Non-POR UCB, "Will Not Be Fast [&] ... Certainly Will Not Be Cheap," Utilities Say, Arguing That Ratepayers Should Not Bear Significant Cost Risk
March 7, 2025
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Copyright 2025 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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