Utility Advisor

Petition · To the Maryland Public Service Commission and Maryland's utilities

Give Maryland a summer protection season

From Nov 1 to Mar 31, a Maryland utility cannot shut off a home for nonpayment without first certifying to the Commission that doing so is not a threat to life or health. Summer has no season like it. We ask the Maryland Public Service Commission and Maryland's electric and gas utilities for a Jun 1 to Sep 30 protection period that mirrors the winter rule, a final decision on the proposed 120-hour summer extreme weather period, and protections that follow the heat index, not just the air temperature.

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What we are asking for

Treat a Maryland July the way the rules already treat a Maryland January

Jun 1 to Sep 30

A summer season that mirrors the winter rule

From Nov 1 through Mar 31, a utility must file an affidavit with the Commission at least 24 hours before terminating residential gas or electric service for nonpayment, certifying that the termination is not a threat to life or health. Apply the same affidavit requirement from Jun 1 through Sep 30.

120 hours

Finalize the summer extreme weather period

The Commission has proposed, in rulemaking RM 86 (Case No. 9745), a 120-hour summer extreme weather period tied to a 95°F forecast. Finish the rulemaking and put the 120-hour window in the rules, so protection lasts through a heat wave instead of one day of it.

Heat index

Measure the heat people actually feel

Maryland summers are humid. A day that stays under 95°F on the thermometer can still carry a dangerous heat index. Tie the protection to the heat index the National Weather Service publishes, not to air temperature alone.

Why it matters

Today's summer rule is one forecast day at a time

Maryland's rules do protect households on the hottest days: a utility may not terminate electric service on a day the forecast is 95°F or higher. But that is the whole summer rule. If the forecast the next morning is 94°F, the shut-off can go ahead, with the same balance, the same household and the same heat wave still underway.

Winter is treated differently. From Nov 1 through Mar 31 the utility has to certify to the Commission, in advance, that cutting off a home is not a threat to life or health. That season exists because cold kills. Heat is the deadliest weather in the United States by the National Weather Service's count, and it gets no season at all.

A summer shut-off takes several things away at once: the air conditioning, the fans, the refrigerator that holds insulin and other medication, and the medical devices that run on the outlet. For an older adult, a baby or someone with a heart or lung condition, that is not an inconvenience. It is the emergency.

The Commission has already proposed a 120-hour summer extreme weather period. Finishing that work, adding a season to match winter's, and measuring heat the way the body feels it would close the gap.

What the rules say today

Nov 1 through Mar 31: no residential termination for nonpayment without an affidavit to the Commission. Summer: no electric termination on a day the forecast is 95°F or higher. There is no summer season.

Maryland PSC rules, COMAR 20.31.03. The 120-hour summer extreme weather period is proposed in rulemaking RM 86, Case No. 9745, and is not yet final.

What already exists, and where it falls short

Today's rule next to the ask

Today

Season
Nov 1 to Mar 31: an affidavit to the Commission at least 24 hours before any residential termination for nonpayment. No comparable summer season.
Extreme days
No electric termination on a day the forecast is 95°F or higher. On the next cooler day the termination can proceed.
Measure
Air temperature in the forecast.
Status
A 120-hour summer extreme weather period has been proposed and is not yet in the rules.

The ask

Season
Jun 1 to Sep 30: the same affidavit requirement before any residential termination for nonpayment.
Extreme days
A 120-hour protected window once a 95°F forecast triggers it, so protection lasts through the heat wave.
Measure
Heat index, which accounts for humidity.
Status
Finalize RM 86 so the summer period is written into COMAR, not left as a proposal.
Who is asking

Utility Advisor Inc

A Maryland 501(c)(3) nonprofit. We run the Critical Medical Needs Program under contract with the Maryland Department of Human Services, have processed more than 1,000 CMNP applications and have helped secure more than $20 million in assistance for Maryland households. In 2026 the Department honored us with the Vulnerable Population Expert Award. Every summer our phone line hears from households holding a shut-off notice in a heat wave. This petition is what we would change.

1,000+

CMNP applications

$20M+

In assistance secured

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