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PSC Staff Seek Order Allowing Utilities To Drop Customers To Default Service If Retail Supplier Does Not Place Customers On Dual Billing
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Staff of the Maryland PSC recommended that the PSC issue an order authorizing the state's utilities to drop residential shopping customers to default service if the customer's supplier has not transitioned the customer to dual billing upon the end of utility consolidated billing with purchase of receivables on December 31, 2025
Staff noted that COMAR currently permits utilities to remove a customer from a current retail supplier due to the receipt of a switch request from another supplier, a drop request from the current supplier, or the request from a customer to return to SOS to the extent that the customer's supplier has not communicated such request to the utility
COMAR does not provide that utilities may drop customers to SOS outside of these circumstances
In light of the fact that residential UCB is ending on Dec. 31, 2025, and that the only billing available will be dual billing, Staff said as follows regarding allowing utilities to take action to drop any remaining UCB residential customers to SOS: "Staff agrees with the Joint Utilities that this is an issue requiring Commission action because there may be suppliers that fail to switch all or some of their residential retail customers to dual billing or fail to drop these customers to default service."
"If a supplier fails to initiate the drop to SOS or a switch to dual billing, the utility system will continue to bill any remaining accounts under the current UCB POR system, as utilities have not implemented system changes at this time. The proposed solution is to remove any remaining accounts from retail supplier service to prevent POR billing from happening. Staff recommends that the Commission issue an order that allows utilities to drop existing residential retail choice customers served under UCB/POR if the customer’s supplier fails to either drop the customer to default service or switch to dual billing," Staff said
Staff also proposed that the PSC waive any standard tariff limits on the number of drops to SOS that utilities are required to process at a given time
Staff said that the PSC should require the utilities to report on any residential customers who continue to be served under UCB after 12/31/25, with such info identified by supplier
Notably, Staff said that the prohibition on residential UCB service after December 31 applies to mixed meter scenarios
"[C]ustomers on a non-residential retail supply contract but on a residential utility tariff are residential customers for SB 1 and Order No. 91463 compliance purposes," Staff said
Staff also addressed other issues related to the end of residential UCB with POR
For cancel/rebills and delayed billing of pre-January 1, 2026 usage, Staff agreed with the Joint Utilities' approach to use the long-standing "like for like" process for cancel/rebills, meaning billed through the same method as originally billed, including POR where applicable. Additionally, the Joint Utilities state that delayed bills from bill periods prior to January 1, 2026 that are rendered to customers after January 1, 2026, will be billed under POR where applicable.
In support of this approach, Staff said that the December 31, 2025 effective date for the end of residential POR applies to when the supply was used, not when the supply appears on the customer’s bill (in other words, using POR during 2026 is appropriate for pre-2026 usage regardless of billing or re-billing date)
With regards to any continued POR due to re-billing or delayed billing, while several utilities can apply the original POR discount rate from the time of the original billing to the re-bill, Staff reported that Pepco and Delmarva are unable to do so with their current systems
Staff recommends that Pepco and Delmarva use the POR discount rates effective as of December 31, 2025 for any cancel/rebills
Notably, Pepco and Delmarva had said that, if there are any cancel/rebills after December 31, 2026, the supplier would need to bill the customer directly for those adjustments
However, Staff opposed this request
"Staff recommends against limiting the use of POR for residential cancel/rebills after December 31, 2026 because cancel/rebills for overbilling can occur beyond this period and would likely require the supplier to dual bill, which they may not have the ability to do," Staff said
PC 65, PC65
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December 1, 2025
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Reporting by Paul Ring • ring@energychoicematters.com
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