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OPC Seeks Specific Language Codifying Order Which OPC Interprets As Requiring That Utility Charges Will Be Paid Before Retail Supplier Charges Under Utility Consolidated Billing
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The Maryland Office of People's Counsel has requested that the PSC include, in a rule concerning post-POR billing for residential customers, a prior PSC finding which OPC argues provides that, under any payment hierarchy, all regulated utility charges which "may" result in termination shall be paid before any retail supplier charges
As first reported by EnergyChoiceMatters.com, Maryland PSC Staff have proposed updates to the electric and natural gas billing rules to, among other things, provide that utilities are not required to offer residential utility consolidated billing, and that, if offered, residential UCB may provide for either the proration of customer payments between the utility and retail supplier, or a payment posting sequence (waterfall) for customer payments.
OPC argues that the PSC, in directing the rulemaking, established that, "any customer payments shall first be applied to
utility charges and arrearages for which service may be terminated".
OPC cited the following language from the PSC's prior order: "Pursuant to COMAR 20.53.07.06A, '... a utility may not terminate service for failure of a customer to pay supplier charges.' Therefore, absent POR, under dual billing or non-POR UCB a utility may only terminate service for failure to pay regulated utility charges. This hierarchy of payments therefore reflects what most customers would expect -- that payments will first apply to those charges that will result in terminations if unpaid." [emphasis added]
Notably, the PSC's language says that payments should be applied first to charges that "will" result in termination if unpaid. Typically, non-payment of new (non-arrears) utility charges on a bill does not immediately result in the customer being subject to a termination order if the new (non-arrears) amount is unpaid (i.e. non-payment of new charges must be for consecutive bills before termination becomes an option for utilities for those charges)
However, OPC seeks to require that all regulated charges, which "may" result in termination if unpaid, shall be paid prior to any retail supplier charges
OPC, "recommends adding language to COMAR specifically
requiring any payment posting sequence to prioritize utility charges and arrearages that
may result in service termination before applying payments to supplier charges and
arrearages. Doing so would ensure that the regulations fully implement the Commission's
directive and provide clear guidance to utilities, suppliers, and customers."
OPC's proposed language provides that, "When utilizing a payment posting sequence a utility shall
prioritize the payment of charges that may result in service termination under
COMAR 20.53.07.06, such that any customer payments shall first be applied to
utility charges and arrearages for which service may be terminated before being
applied to competitive supplier charges and arrearages."
In separately filed comments, Montgomery County, Maryland sought to revise Staff's proposed rule such that a utility would still be required to offer residential UCB with POR to Montgomery County's proposed opt-out aggregation
RM 96, RM96
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June 8, 2026
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Copyright 2026 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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