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Grid Optimization Comments Filed

Dockets: 9665 ,Maryland
Category: Uncategorized
Related Categories: Electric, Grid Modernization, Maryland, Utility

Stakeholders filed comments, and utilities filed responses to questions, on MEA’s unified cost control and grid optimization regulatory strategy proposal filed on September 8, 2026.

Highlights from stakeholder comments are provided below.

OPC: (i) supports adoption without further workgroup discussion of MEA’s proposed “distributed energy resource (‘DER’) dispatch technology readiness index [DTRI] and the grid utilization metric”; (ii) said that “capabilities for active DER dispatch should not be a limiting factor that prevents consideration of non-wire solutions (‘NWS’) for deferring traditional upgrades”; (iii) raised “significant concerns with any future adoption of financial rewards through PIMs for satisfying metrics intended to demonstrate that a utility is efficiently using its existing assets or is prepared to use DER technologies and other alternatives to avoid infrastructure spending,” saying it “sees little justification for providing utilities with additional financial rewards for satisfying obligations they already have”; and (iv) supports MEA’s request for “a stronger [NWS] framework,” recommending MDPSC “establish now that, before a utility seeks recovery for a capacity-driven infrastructure investment, it must identify the underlying system constraint and demonstrate that feasible NWS were screened on a comparable basis.”

Joint Clean Energy Parties: (i) support MEA’s “interconnection-speed and flexible-interconnection metrics, which are properly directed to the IWG”; (ii) support MEA’s “grid utilization, 8760 constraint-analysis, non-wires solution (“NWS”) screening, and data-transparency proposals, which lay the foundation for cost-effective DER deployment”; (iii) recommend ensuring “that any performance-tracking or [PIM] framework is developed through a transparent stakeholder process, with DER and interconnection stakeholders directly involved in defining the underlying metrics, and is designed to reward utilities for advancing DER interconnections, deploying [NWS] via storage programs, and increasing grid utilization”; (iv) recommended advancing “a properly designed front-of-the-meter (‘FTM’) storage grid services tariff as the preferred vehicle for delivering” MEA’s requested NWS; (v) recommended requiring “multi-year distribution system planning to incorporate storage as a capital-deferral resource”; and (vi) recommended MDPSC “Consider cost-sharing between load and DER for proactive grid upgrade plans developed under the multi-year distribution system planning.”

Advanced Energy United: (i) said it supports MEA’s proposals of a comprehensive DER roadmap, “robust data sharing platform”, performance accountability framework, and grid utilization framework; (ii) said that while it “supports using performance metrics, and subsequently, [PIMs] to motivate utilities to achieve outcomes that may run counter to existing incentives… utilities should not be rewarded for achieving their core responsibilities… [and] even a well-designed PIM can, at best, mitigate (but not fully overcome) the existing bias towards capital expenditures without other ratemaking reforms”; (iii) recommended MDPSC consider grid modernization metrics of “Seasonal peak load as a share of available capacity,” “Energy delivered as a share of deliverable capacity,” “Current and voltage imbalance,” and “Equipment life and deferred replacement”; (iv) supports a broader performance-based ratemaking (PBR) framework, including, in addition to PIMs, “revenue decoupling, shared savings mechanisms… changes to the treatment of Capital Expenditures… Operational Expenditures… and new revenues for as a platform for integrating and coordinating third-party DERs”; and (v) recommended MDPSC “begin developing an NWS Screening and Evaluation Framework,” while noting that “financial treatment of NWSs will require careful consideration – and ideally be considered as part of a package of reforms that re-orient Maryland’s utilities around cost containment, affordability, and system optimization.”

Note that post-technical conference comments due by September 28, 2026.