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PSC Staff Proposes Compliance Mechanism For New Statutory Disclosures Required From Retail Suppliers
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Staff of the Maryland PSC have proposed recommended mechanisms for retail energy suppliers to comply with various new disclosure and posting requirements under 2024's SB1
PUA § 7-315(c)(1) mandates that the PSC require residential energy retailers to post on the retailer’s website, in "clear and unambiguous language", the terms and conditions of the residential services and products sold by the retailer
Notably, the term residential energy retailer includes:
(i) an electricity supplier that supplies electricity to residential retail electric customers;
(ii) a gas supplier that supplies gas to residential retail gas customers;
(iii) an energy salesperson; and
(iv) an energy vendor.
Furthermore, Staff noted that an existing requirement in PUA § 7-507(j) requires that an electricity supplier (a definition which includes brokers) shall post on the internet information that is readily understandable about its services and rates for small commercial and residential electric customers. While § 7-507(j) only references electric suppliers, Staff said that, when read in conjunction with PUA § 7-604(b)(2), § 7-507(j), "may be applicable to natural gas suppliers as well".
To comply with the new and existing PUA provisions, Staff recommended that the Commission could allow residential energy retailers to post on their websites the existing "Contract Summary" already required by COMAR 20.53.07.08.B and 20.59.07.08.B, for each currently available offer.
PUA § 7-315(c)(2) requires a residential energy retailer to post an environmental disclosure on its website for the residential services and products sold by the retailer, which Staff again noted is similar to an existing obligation under PUA § 7-505(b)(4)
For electricity suppliers, Staff said that allowing suppliers to use the PJM Residual and System Mix fuel mix and emissions reports, as currently allowed, could be used for compliance with the new PUA § 7-315(c)(2)
Staff noted, however, that using a PJM emissions report is not viable for natural gas suppliers
Staff suggested that, for the retail natural gas emissions disclosure requirement, a similar 'off the shelf' generic report could be developed that suppliers could use
"[A]s most natural gas suppliers have virtually identical emissions, the Commission could issue a generic environmental disclosure for each natural gas supplier to use. While the actual emissions would be affected by the manner in which the customer uses natural gas, the supplier would generally have no knowledge of how the customer uses natural gas," Staff said
Specifically, to satisfy PUA § 7-315(c)(2)'s emissions disclosure requirement for suppliers serving residential customers with gas supply, Staff recommends that the PSC use an EPA-approved form attached to Staff's April 14 comments in proceeding PC 68.
Staff's proposed generic gas emissions disclosure would generally use data from the EPA posting on page 6 of this link (TABLE 1.4-2)
PC68, PC 68
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April 14, 2025
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Copyright 2025 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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