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Utility Seeks Clarity On Costs Authorized To Be Included In Bypassable SOS Admin.

June 4, 2025

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Copyright 2025 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com

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Pepco in the District of Columbia has sought clarification from the D.C. PSC concerning which Community Renewable Energy Facilities (CREF) costs may be included in the bypassable SOS administrative charge

Pepco said that, in 2024, the Commission appeared to draw a distinction between Operation and Maintenance (O&M) expenses for CREF, which could be flowed through the SOS Administrative Charge, and CREF capital expenses, which may be recovered from CREF Subscribers.

However, Pepco said that, in a recent order, the PSC directed that certain CREF IT costs could not be recovered through the SOS Administrative Charge even though Pepco said that those costs are O&M and not capital costs

The PSC recently ordered that, "The Commission will not allow the $405,215.15 of IT costs in the SOS administrative charge. These costs relate to implementing and developing a system for CREFs. These costs should not be recovered through the SOS administrative charge. Pepco may recover these implementation costs 'solely through a rate assessment of the subscribers' as prescribed in D.C. Code § 34-1522. Thus, if deemed appropriate, recovery of these costs will be determined in Pepco’s next base rate case."

However, Pepco said that, "The 'IT costs' referenced in the Order are not capital costs but rather O&M costs intended to refine the Company’s billing process and management of the CREF program. Additionally, these costs are not related to the 'implementation' of the CREF program."

Pepco said that, under the 2024 order, it appeared that these costs were eligible for inclusion in the SOS Admin. charge, because the costs were incremental O&M costs, not capital costs, but the PSC's recent order treats the costs as related to "implementing" the CREF, and thus ineligible for SOS Admin. Charge inclusion

Pepco said, "Pepco respectfully requests additional clarity on how the Commission delineates costs that are appropriate for inclusion in the SOS Administrative Charge from costs that are required to be assessed to Subscribers under D.C. Code § 34-1522, so that the Company can properly allocate its CREF-related costs going forward."

To the extent the costs can not be included in the SOS Admin. charge, Pepco requested that the PSC confirm how Pepco may recover such costs (as well as the means for recovering the CREF capital costs previously excluded from the SOS Admin. Charge)

"Pepco asks for this guidance because it will be more efficient to determine the method up-front rather than litigate it in a base rate case," Pepco said

Pepco suggested that a work group address this issue as needed

FC 1017

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