The University of Maryland, Baltimore County asked the Public Service Commission on Oct. 15 to waive penalties totaling roughly $8,036,526 that Baltimore Gas and Electric Co. assessed after UMBC failed to fully interrupt gas use during a Jan. 20–23, 2025 system interruption called by BGE. The commission took the petition under advisement after hearing staff analysis, intervenor comments and testimony from UMBC and BGE representatives.

Staff recommended the commission deny the requested waiver. Alden Mancah, appearing for staff, told commissioners that BGE called an interruption from 10 a.m. on Jan. 20 through 10 a.m. on Jan. 23, 2025, under the utility's Interruptible Large Volume Service tariff; the tariff requires customers to cease gas use within six hours of notice. Because UMBC did not fully interrupt, BGE assessed a commodity penalty of $96,049 and an excessive-use penalty of $7,940,477. Staff reported that UMBC used gas for 68 of the 72 hours of the interruption, reduced average usage from about 500 therms per hour to about 200 therms per hour, and that engineering review found separate issues on each of the central-plant boilers contributing to noncompliance. On that basis, staff recommended the commission not waive the penalties.

Representatives from UMBC disputed some staff conclusions and said the university made multiple, documented efforts to prepare for and respond to the interruption. John Zaire, assistant vice president for facilities management, testified that UMBC had passed an interruption test on Nov. 19, 2024, had conducted preventive maintenance and commissioning work with the boiler manufacturer and third-party commissioning agents in early January, and that the campus experienced an "unprecedented series of unforeseen breakdowns" across multiple boilers during the interruption. UMBC said it reduced gas use to about 40% of typical levels during the event and remained in regular contact with BGE. UMBC provided commissioners additional documentation during the meeting, including maintenance records, commissioning reports and a spending list of improvements and spare parts.

Baltimore Gas and Electric, represented by Joel Michel, told the commission BGE can provide information on what triggers interruption notices (typically system conditions such as weather-driven forecasts) and noted the company regards the commodity portion of the assessed penalty as unrecoverable costs it incurred. The company's representative also said BGE can, in extreme cases, physically curtail service to interruptible customers, though that is a complex last-resort action.

The Office of People's Counsel and staff noted that, while UMBC's interruption program yields savings for the university and the state (UMBC estimated $16 million saved over 23 years), the tariff's penalty and waiver provisions are designed to preserve system reliability and to avoid shifting risk to other customers. OPC agreed staff had thoroughly reviewed the statutory waiver criteria and highlighted that UMBC used gas during most of the event (68 of 72 hours).

Commissioners questioned UMBC about preventive maintenance, the sequence of boiler failures, the volume of gas consumed during the event and whether the university is exploring switching to firm service. UMBC said it is pursuing multiple remedial projects (UMBC described approximately $6 million in planned investments and cited $121,986 already spent on parts and maintenance), that it is arranging for a temporary skid-mounted boiler as an interim measure, and that larger pump procurement and tube replacement projects are underway with multi-month lead times.

The commission did not rule at the meeting and took the matter under advisement to allow staff and other parties to review the additional materials provided by UMBC and to prepare any updated comments. Staff indicated it would review the submitted documents and could file updated comments.