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PSC Directs Utilities To Address Whether Automatic Switch Block May Be Implemented
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In an order adopting provisions for a statutorily required Do Not Transfer list process, the Maryland PSC has directed the utilities to provide updates concerning any implementation challenges and concerns related to adopting an automatic block (enrollment rejection) for any customer on the Do Not Transfer list
See background on the new Do Not Transfer lists in Maryland here
PSC Staff has reported that, for electricity, while the EDI working group has developed code for an automatic block of enrollments of customers on the Do Not Transfer list, Staff reported that the utilities have not yet implemented this EDI change absent PSC approval of the automatic enrollment blocks. Staff has described implementing an auto-block for Do Not Transfer list customers as "logical", but Staff did not specifically propose such implementation, noting that the automatic block mechanism was not discussed in detail in the Do Not Transfer list working group
The PSC directed the utilities to provide a two-week status update, and then monthly updates thereafter,
addressing any implementation challenges and concerns related to the implementation of
the automatic switch block code for customers on the Do Not Transfer list.
The PSC's order on the Do Not Transfer lists adopted consensus items from a work group without modification, and also addressed non-consensus items
Among the non-consensus items is the frequency with which utilities should update the Do Not Transfer lists.
Staff had proposed daily updates to the Do Not Transfer lists, but certain utilities favored weekly updates
The PSC adopted, at this time, weekly updates, but the PSC explicitly, "reserves the
right to evaluate whether additional data is needed and whether utilities should provide
daily updates."
The PSC ruled that the Do Not Transfer lists shall only include the customer’s name and
service address. The customer's billing address will not be included on the Do Not Transfer list.
Staff had proposed inclusion of the billing address on the Do Not Transfer list, as failure to include the billing address, if different from the service address, may still result in customers receiving marketing materials mailed by retail suppliers (the Do Not Transfer lists under Maryland law also function as a Do Not Market list). Several utilities had opposed including the billing address on the list, as some utilities consider the billing address personal information not needed to implement a Do Not Transfer request
With the PSC directing that the customer billing address shall not appear on the Do Not Transfer list, the PSC directed that utilities shall explain to customers -- during calls to the customer care center and
through other notices to customers -- that a Do Not Contact [sic] List enrollment should be made
separately for each service address.
The Commission directed the utilities to, within two weeks,
provide the Commission with a status update on their efforts to educate customers about
the Do Not Contact [sic] List, milestones, and an update on technology and software developed
for purposes of the List, including a description of the functionality of sharing the Do Not
Transfer List secure web portal electronically with retail suppliers, and proposed cost-recovery
mechanisms.
The PSC emphasized that, while utilities have a role in helping
to facilitate customer enrollment onto the Do Not Transfer lists and the maintenance of the Do Not Transfer lists, "the responsibility for
complying with the Do Not Transfer List rests with suppliers, their employees and their
contractor agents."
The Do Not Transfer List proceeding also addressed certain reporting obligations of billing entities under SB1, which includes retail suppliers engaged in dual billing of customers and suppliers using supplier consolidated billing
The PSC held that any reporting shall apply only to residential customer bills, consistent with SB1's stated purpose of not impacting the non-residential market, notwithstanding certain specific language in SB1 concerning the reporting of general service classes billing information
As part of their reporting per SB1, retail suppliers which bill customers must report the "total energy
distributed to retail supply customers". Staff had proposed that retail suppliers not be required to report this metric, as Staff interpreted "total energy
distributed to retail supply customers" as meaning all retail supply customers in the market, not only a specific supplier's own customers
The PSC disagreed with Staff's interpretation of "total energy
distributed to retail supply customers", and found that this required reporting from a supplier applies to only the supplier's own retail residential customers that are billed via SCB or dual billing, The PSC ordered that a supplier engaged in billing shall report the total energy
distributed to the supplier's residential retail supply customers
Suppliers submitting data on total
energy sales for SCB or dual billing customers are permitted to submit this information
confidentially
The PSC's order also addresses what default service rate should be used when the utilities -- and retail suppliers engaged in billing -- report comparisons of the retail supplier billed rates, versus the otherwise applicable default service rate, under SB1
Specifically, PUA § 7-510(g)(2)(vi) and § 7-604.2(e)(2)(vi) require the reporting of the
average SOS rate and default gas commodity average rate by the utilities. Staff initially recommended that the
Commission require utilities and suppliers to report this data based on the SOS and
default gas commodity rates retail choice customers would have paid in the preceding
month based on billing to customers in the prior month by date issued to customers
As stated by the PSC, BGE, Pepco and DPL disagreed with
this Staff recommendation, stating that the utilities' billing systems do not
possess the functionality to calculate what retail supply customers would have paid based
on the utility commodity rates at the time of usage.
Staff offered an alternative default service rate which may be used, under which billing entities, for compliance with PUA § 7-510(g)(2)(vi) and § 7-604.2(e)(2)(vi), may instead report the average SOS rate and default
gas commodity rate calculated based on the SOS and default gas commodity rates billed to
utility default service customers in the preceding month by date issued to customers.
The PSC adopted the use of Staff's original default service rate reporting proposal and the use of Staff's alternative.
Specifically, "The Commission adopts Staff’s original and alternative proposals and directs the
utilities, for UCB customers, and suppliers, for dual billed and SCB customers, to report
on the average SOS rate and the default gas commodity average rate, as required in PUA
§ 7-510(g)(2)(vi) and PUA 7-604.2(e)(vi), based on the SOS and default rates retail choice
customers would have paid in the preceding month based on billing to customers in the
prior month by date issued to customers. Alternatively, utilities may report the average
SOS rate and default gas commodity rate calculated based on the SOS and default gas
commodity rates billed to utility default service customers in the preceding month by date
issued to customers."
The PSC directed the utilities to indicate their reporting method
by explaining how the average SOS and default gas rates are calculated in their filings
PC 67
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May 7, 2025
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Copyright 2025 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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