Utility Revises Supplier Coordination Tariff, Includes New Billing Option

Updates Tariff's Purchase Of Receivables Provision

Utility To Include In Tariff Requirement For Retail Suppliers To Notify Utility Of Door-to-Door Marketing Zip Codes

May 4, 2020

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Choptank Electric Cooperative has filed with the Maryland PSC revisions to its retail electric supplier coordination tariff

Among other things, Choptank stated in its filing that the tariff, last changed in 2001, has been updated to reflect current COMAR requirements.

Choptank said that its revisions are similar to the other Maryland electric utilities’ Supplier Coordination tariffs. "However, certain sections are unique to Choptank. To promote efficiency and transparency, Choptank and PSC Staff have been in discussions for several weeks regarding this tariff. This includes informal data requests and a conference call," Choptank said

"As a result of preliminary discussions with Staff, the following rationale for specific changes is provided," Choptank said

Among other things, Choptank said revisions to the tariff reflect Choptank’s settlement process, "which will differ from other utilities."

"Choptank has a wholesale power contract with Old Dominion Electric Cooperative and does not directly purchase energy from the PJM market. Additionally, Delmarva Power owns the transmission meters at the substations; because of that, actual system loads will not be available for the purposes of Day After Settlement (Settlement A)," Choptank said

Among other changes in the tariff is new language to reflect the COMAR requirement that suppliers notify the utility of door-to-door marketing

The revised tariff states that suppliers shall, "Provide the Cooperative notification regarding door-to-door activity no later than the morning of the day the sales and marketing activities begin. The notification shall include the Electricity Supplier’s name, the beginning and ending date(s) of marketing activities, and zip code(s)."

While this tariff language, including the requirement to include zip codes, is used in supplier tariffs by other utilities in Maryland, the actual COMAR requirement does not make mention of zip codes. COMAR 20.53.08.07 states that the supplier shall provide to the utility nonproprietary information that caused the supplier to file a door-to-door notice with the PSC, with the PSC notification required to include, among other things, "a general description of the geographical area," (but with no mention of zip codes)

The tariff revisions also reflect an update to the billing options reflected in the current tariff, which currently only lists utility consolidated billing

The revisions add dual billing as an option for suppliers

Utility consolidated is still limited to rate ready billing

Furthermore, the revisions modify the current purchase of receivables language in the tariff

The current tariff merely states that, "The Cooperative and the Electricity Supplier may separately negotiate for the purchase of receivables under mutually agreeable terms and conditions." It also provides that, "If the Cooperative fails to bill the Electricity Supplier's charges in a timely fashion and in accordance with this Tariff and the Commission's requirements, the Cooperative will purchase the receivables from the Electricity Supplier."

In contrast, the revised tariff provides that, "When an Electricity Supplier elects to use Cooperative Consolidated Billing, the Cooperative will purchase the Electricity Supplier’s receivables pursuant to Commission rules and regulations and any other provisions of this Tariff."

"All electricity charges resulting from the Supplier provision of Competitive Power Supply for Customers billed using Cooperative Consolidated Billing will be purchased. The Cooperative will not purchase receivables associated with non-commodity charges or Early Termination Fees," the revised tariff states

The revised tariff does not make note of a discount rate, if any, or calculation

COMAR 20.53.05.06 requires that, under any POR used by a "utility", supplier receivables "shall be purchased with full and timely cost recovery for the utility under terms and conditions approved by the Commission."

"Utility" in this section of COMAR is defined as an electric company as defined in Public Utility Companies Article, §1-101, Annotated Code of Maryland, which is defined as, "a person who physically transmits or distributes electricity in the State to a retail electric customer."

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