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Utilities File Justification For Hard End Date Of Billing Adjustments Under Legacy POR Program
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Pepco and Delmarva in Maryland have, as directed by the Maryland PSC, offered greater justification for the utilities' proposal to establish an end date at which time the EDCs will cease accepting billing adjustments under their terminated residential purchase of receivables programs
Pepco and Delmarva were unique among the Maryland utilities in that, for billing adjustments such as cancels/rebills, Pepco and Delmarva do not have capability to use the original POR discount rate that had been applicable when the charges were originally incurred. Pepco and Delmarva received PSC approval to use the current discount rate for any cancels/rebills (in this case, the discount rate effective as of the end of residential POR on December 31, 2025)
However, Pepco and Delmarva also sought to limit the time by which any cancels/rebills and similar billing adjustments would be billed by the EDCs under UCB, for receivables related to service prior to the Dec. 31, 2025 end of residential POR. The utilities proposed that the EDCs cease such UCB for residential billing adjustments effective December 31, 2026. Any adjustments after such time would need to be billed by the retail supplier directly, Pepco and Delmarva had proposed
The PSC directed Pepco and Delmarva to further support this proposed December 31, 2026 end date for residential POR billing adjustments under UCB, as the PSC excluded approval of this provision from a recent order addressing legacy POR issues
Pepco and Delmarva said that the December 31, 2026 end date for legacy residential POR-related billing adjustments, "is based on the need to manage increasing financial and operational risk."
Pepco and Delmarva expressed an, "underlying concern associated with accepting supplier charges [for legacy POR] indefinitely, particularly when charges are submitted well after consumption has occurred."
Pepco and Delmarva said, "From an operational standpoint, when customer usage data is transmitted to a supplier, suppliers have four business days to submit their charges for inclusion on the customer’s bill. However, the Companies do not have a firm 'bill close window' that automatically prevents charges from being accepted after the billing process has concluded. As long as the customer account remains active, supplier charges can be submitted and will be accepted and billed, even if they are received outside the standard billing cycle. Additionally, suppliers can also initiate corrections to their original charges, and those charges will be accepted at any time. This open-ended acceptance creates increasing exposure over time."
Pepco and Delmarva said, "While the POR discount rate is designed to cover expected uncollectibles based on historical norms, it was not designed to account for unlimited delays between usage, billing, and charge submission. Consequently, continuing to accept supplier charges indefinitely may distort uncollectible assumptions and shift incremental credit risk to non-shopping customers."
"Establishing a clear cutoff date -- such as December 31, 2026 -- provides regulatory certainty, aligns supplier billing activity with reasonable timing expectations, and appropriately balances supplier flexibility with customer and system protections. A date-certain approach also creates consistent incentives for suppliers to submit charges in a timely manner, while allowing sufficient transition time for suppliers to adjust internal processes," Pepco and Delmarva said
PC65, PC 65
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May 20, 2026
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Reporting by Paul Ring • ring@energychoicematters.com
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