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More Utilities Seek To Assume Additional Non-Market PJM Costs, Remove Responsibility From SOS Suppliers
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All of the Maryland investor-owned electric utilities, including BGE, Pepco, Delmarva and Potomac Edison, propose to, under their full requirements contracts for SOS, transfer responsibility for PJM Billing Line Item 1935 to the utility, relieving the wholesale SOS supplier from the Billing Line Item 1935 obligation
Billing Line Item 1935 is the billing code for the federal Department of Energy’s 202C emergency order under Section 202(c) of the Federal Power Act
This proposal is being recommended by the state's SOS procurement improvement process (PIP) work group, as a consensus proposal
A report on the PIP notes that this proposal "essentially" makes costs for PJM Billing Line Item 1935 a pass-through item
The PIP group in their filing did not address treatment of Billing Line Item 1935 for non-SOS suppliers (retail suppliers)
The PIP group also proposed as a consensus proposal
two modifications to the credit standards in the SOS RFP for companies issuing Letters of Credit or other financial assurance on behalf of SOS bidders.
The first change is to require the issuer to be a U.S. commercial bank or a foreign bank with a U.S. branch and a Credit Rating of at least A from S&P or A2 from Moody’s and at least $10 Billion in Assets. The new language also specifies a more descriptive S&P credit rating in the event that a senior unsecured rating is unavailable.
In addition, new language is being added to the Acceptable LOC Form (RFP Appendix 6 for Bid Assurance and FSA Exhibit C for Performance Assurance), which specifies updated Beneficiary details and electronic presentment language in section (2) of LOC. There is also a minor revision to the last paragraph of the LOCs aligning this paragraph with the presentation language in section (2), the work group said
"The revisions to the language regarding the issuers of an LOC or other assurance would likely reduce the pool of acceptable issuers, but will probably not cause any reduction in the number of bidders in Maryland’s SOS bidding," a report from the PIP group said
The PIP group reported that there have been no objections to the proposed credit changes
The PIP group also proposed to continue to retain the ability to use a capacity proxy price in the SOS procurements if needed, though the group noted that PJM is currently back on schedule for capacity procurements, and a CPP is not anticipated to be needed during the SOS RFPs which are subject to the PIP's proposed 2026-2027 bidding process
Case 9056, 9064
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August 24, 2026
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Copyright 2026 EnergyChoiceMatters.com
Reporting by Paul Ring • ring@energychoicematters.com
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