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Comments Filed Re: PSC’s Energy Storage Working Group Report

Category: Maryland

On September 3-4, parties filed comments the Maryland Energy Storage Program Working Group (MESPWG).

Office of Staff Counsel – “The Phase II Final Report represents substantial progress toward development of a long-term framework for facilitating deployment of distribution-connected energy storage resources in Maryland. In particular, the Final Report proposes a Grid Services Framework (“GSF”) under which electric companies may develop GSTs to compensate qualifying energy storage resources for measurable grid services; a Deployment Incentive Framework (“DIF”) intended to address remaining financial barriers to otherwise beneficial storage deployment; and principles for developing appropriate charging-rate treatment for front-of-the-meter distribution-connected (“FTM-D”) energy storage resources.

Staff generally supports the conceptual structure presented in the Final Report and believes the proposed framework provides a reasonable foundation for further implementation of Phase II. The proposed structure appropriately distinguishes among: (1) compensation for measurable grid value provided by energy storage resources; (2) rates associated with the costs imposed by energy storage resources when charging from the distribution system; and (3) deployment incentives intended to address financial gaps or other deployment objectives that remain after available revenues and project benefits are considered.17 The Program Design Study similarly explains that the GST is intended to compensate specific, measurable storage behaviors that create quantifiable system benefits not otherwise monetized by the project owner, rather than operate as a general storage subsidy. Staff believes maintaining these distinctions will be important as the Commission considers implementation of Phase II. Staff does not believe acceptance of the proposed frameworks should constitute approval of the specific illustrative compensation values, event parameters, financial assumptions, or tariff designs evaluated in the supporting studies. The analyses supporting the Final Report provide a useful structure for evaluating these matters, but implementation will require consideration of utility-specific system conditions, updated market information, applicable charging rates, resource characteristics, and demonstrated ratepayer value. Accordingly, Staff recommends that the Commission generally accept the GSF, DIF, and charging-rate principles presented in the Final Report as frameworks for further implementation while establishing certain minimum principles necessary to guide subsequent electric company proposals.”

See all comments at main docket link here.

As reported previously, on September 2, 2026 the Maryland Energy Storage Program Working Group (MESPWG) filed a reply response to Joint Storage Parties (JSP).

MESPWG: (1) objected that: (i) “The MESP was launched on June 24, 2025 with Order No. 91705”; and (ii) the language of the Energy Storage Program Act (ESPA) plainly indicates “competitive energy storage procurements are required in the MESP, but grid services tariffs and deployment incentives are not a mandatory requirement”; and (2) “while the MESP was launched with energy storage procurements first, the MESP Work Group has provided recommendations for tools to facilitate a transition pathway option in its Phase II Final Report.”

Comments on MESP Work Group Phase II Final Report due by 9/4/26.

Previously on August 28, 2026 Joint Storage Parties (JSP) filed a letter regarding implementation of MESP.

Among other things, JSP: (1) sought to “highlight the need for, and importance of, establishing an implementation schedule,” given that “While HB 910 (2023) required that an energy storage program be established no later than July 1, 2025, as of August 2026, the energy storage industry has no line of sight on when the program may launch”; (2) requested MDPSC “establish clear implementation deadlines for utility filings related to”: (i) Grid Services Tariffs; (ii) Charging tariffs; (iii) Associated cost recovery mechanisms; and (iv) “Any supporting administrative processes necessary to launch the program”; (3) encouraged MDPSC “to establish deployment incentives that support achievement of the near-term storage deployment goals,” noting that “These incentives can be established in parallel with — and, for some elements, ahead of — the implementation schedule” recommended; and (4) urged MDPSC to “establish an enrollment pathway as soon as practicable, so that developers can begin investing in the State with confidence.”