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From Maryland Joint Utilities Letter: 

[ *** ] the Maryland Joint Utilities recommend that the Commission hold Public Conference 60 (“PC 60”) in abeyance so that interested stakeholders, as well as the Commission, can focus on implementing SB 1, which will require significant time and effort.

In the Petition, MEAC recommended that the Commission solicit comments on the continuing appropriateness for Maryland utilities to purchase the receivables of retail suppliers (i.e., “purchase of receivables” or “POR”). In response to a request for comments, certain stakeholders urged the Commission to go beyond a review of POR and convene a public conference regarding reforms to retail choice in Maryland to protect residential and small commercial customers. On February 16, 2024, the Commission docketed PC 60 to consider potential retail energy market reforms to enhance the benefits of retail choice to consumers in Maryland. [ *** ] 

As noted above, SB 1 bars electric and gas companies from purchasing the residential accounts receivable from retail suppliers for supply agreements entered into or renewed on or after January 1, 2025. While this prohibition may not appear terribly complex on its face, multiple complex issues will have to be addressed by the Commission and stakeholders before the Maryland Joint Utilities can even begin to make the numerous resource intensive and costly changes that will need to be made to their customer care and billing systems (and potentially other processes and systems as well) in order to convert from a process of purchasing receivables for residential customers to an alternative methodology. Such issues include, but are not limited to:

• the interpretation of Sections 8 and 9 of SB 1; 
• the potential need to maintain multiple payment methodologies for the processing of customer receivables (e.g., POR for retail supply agreements entered into before January 1, 2025; POR for commercial customers; an alternative payment logic for residential retail supply agreements entered into or renewed on or after January 1, 2025; and POR associated with Community Choice Aggregation); 
• determining how the Maryland Joint Utilities will know which accounts receivables are related to retail supply agreements entered into before January 1, 2025; 
• whether to extend the prohibition of POR to commercial customers to eliminate multiple payment methodologies; 
• the impact to the commercial POR discount rates from elimination of residential POR;
  the applicability of energy assistance payments and other bill credits; 
• payment arrangement plans; 
• budget billing; 
• the cost responsibility between the utility customers and retail suppliers for making system and process modifications to comply with Senate Bill 1; and 
• ensuring sufficient time for stakeholders to effectively communicate and explain changes to impacted parties.

Furthermore, SB 1 is not limited to the elimination of POR for residential customers. Numerous additional requirements were adopted that will also require significant consideration and effort by the Commission, the Maryland Joint Utilities and other interested stakeholders, such as:

• requiring energy salespersons and energy vendors to be licensed by the Commission;
• requiring the licenses for energy suppliers, energy salespersons and energy vendors to be renewed every three years; 
• requiring the Commission to develop a training and educational program for energy suppliers, energy salespersons and energy vendors; 
• enacting numerous restrictions on the prices and terms of energy supply offers; 
• allowing a residential customer to be placed on a “do not transfer” list that indicates its intention to remain on Standard Offer Service and prohibits directed marketing; 
• requiring a new monthly report to the Commission by the “billing entity” for residential customers; 
• setting restrictions on the circumstances under which an electricity supplier can market electricity as “green power;” and 
• requiring the Commission to hold a proceeding to set the price of electricity marketed as “green power.”

Therefore, the Maryland Joint Utilities recommend that PC 60 be held in abeyance so that interested stakeholders, as well as the Commission, can focus on implementing SB 1. The Maryland Joint Utilities also recommend that a new proceeding or proceedings be convened as soon as possible to address the many new requirements of SB 1. While the prohibition against residential POR is not effective until January 1, 2025 – a timeline which will be extremely difficult to meet under the best of circumstances – the remaining provisions become effective on July 1, 2024, leaving little time for the multitude of decisions to be made, processes to be developed and changes to be implemented.

The Maryland Joint Utilities is comprised of Baltimore Gas and Electric Company, Delmarva Power and Light Company, The Potomac Edison Company, Potomac Electric Power Company, Southern Maryland Electric Cooperative, Inc., and Washington Gas Light Company.

Maryland Joint Utilities Comments (05/31/2024) 
PC60 (06/02/2023)
Maryland Energy Advocates Coalition’s Petition For Rulemaking