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In an Order issued on May 11, 2026 the Commission addresses the three issues raised by the Net Metering Working Group.  The Commission’s decision related to each of these three issues are identified below:

Issue 1 Raised by the NEM Working Group: Concurrent Interconnection and Community Solar Subscriber Organization ID Application Processes

“The Commission approves Position 1. While this option would require an application for a SOID be made before an application for interconnection, the application for interconnection can follow as soon as practicable without the need to wait for Staff to issue the SOID. This option preserves the Commission’s intent that CSEGs should not have to wait—potentially for long periods of time—to obtain the SOID before they can apply for interconnection. The Commission finds it should not be burdensome for a CSEG to provide proof of an SOID application as part of the interconnection application. The Commission appreciates the NEM Working Group’s ideas for how to confirm an SOID application for purposes of an interconnection application and urges the NEM Working Group to adopt practical solutions.”

Issue 2 Considered by NEM Working Group: Whether Financial Deposits Related to the New Concurrent SOID and Interconnection Application Process are Recommended

“The Commission appreciates the NEM Working Group’s discussion of this issue and accepts the work group’s recommendation not to require financial deposits for concurrent applications for interconnection and an SOID.”

Issue 3 Considered by NEM Working Group: Site Control and Interconnection Queue Management – Cure Period

“The Commission has since reviewed the utilities’ responses16 and approves Position B. The Commission will apply the adopted emergency regulations prospectively, consistent with our practice and Maryland law. The Supreme Court of Maryland made clear in United Insurance Co. of America v. Maryland Insurance Administration that “statutes that operate retroactively are generally disfavored, and therefore, a statute is presumed to apply prospectively unless there is a ‘clear legislative intent to the contrary[.]’”17 The new site control requirement was included in the suite of emergency regulations adopted by the Commission on March 18, 2026. The requirement was adopted without modification. The Commission did not express a clear intent that the requirement should apply retroactively and thus necessitate a cure period for affected CSEG applications already in the utilities’ interconnection queue. Accordingly, the requirement for evidence of site control, as approved in RM 94, will take effect on the same effective date as the rest of the RM 94 emergency regulations. The Commission encourages those CSEGs projects already in the interconnection queue to work with the host utility to meet all required elements of interconnection as expeditiously as possible.”

The Commission also clarified that when the emergency regulations in Rulemaking No. RM94 go into effect they will be applied prospectively, negating the need for a cure period for interconnection applications filed in the meantime.