The Death of the Forward Test Year: How Maryland’s New Rate Mechanics are Rewriting Utility Government Relations
For nearly a decade, regulated utility government affairs teams operating in Annapolis and along St. Paul Street relied on a reliable playbook. You argued for decarbonization mandates, filed multi-year rate plans (MRPs) built on projected capital expenditures, embedded forward test years into your dockets, and relied on the Public Service Commission (PSC) to approve ratemaking structures that kept return on equity (ROE) predictable for investors.
That playbook is officially dead.
With the passage of the Utility RELIEF Act and a series of landmark orders from the PSC—including Case No. 9849 (Washington Gas), Case No. 9888 (c), and Pepco’s recent docket adjustments—the statutory framework under the Public Utilities Article (PUA) has fundamentally shifted. What used to be a technical ratemaking debate in hearing rooms has transformed into a high-stakes legislative weapon.
For Vice Presidents of Government Relations and Lead Regulatory Counsel at Maryland’s investor-owned utilities, water systems, and telecom networks, this isn't just a policy pivot—it’s an operational reset for how you justify budget, pitch your C-suite, and deliver regulatory wins.
