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From Response: 

[ *** ] the Maryland Energy Efficiency Advocates (“MEEA”) respectfully requests that the Commission direct that the utilities also include the following information in their revised 2025-2026 program plans for each program that is proposed to be added, modified, or included without changes from the original 2024-2026 Plan as filed:

1) Any evidence used by the utility to develop and support its costs and savings projections, including i) its own historic costs to achieve savings; ii) benchmarking against programs implemented by program administrators in other jurisdictions; iii) independent reports and/or analyses of expected costs to achieve savings;

2) A detailed explanation of how and why each program as proposed supports the State’s GHG reduction goals, and the extent to which alternative options were assessed;

3) A detailed explanation of the strategic importance of the program in advancing a market shift towards decarbonized energy systems in Maryland; and

4) A detailed explanation of the specific risks and the level of risk (high/medium/low) that the program might not achieve proposed savings within budgets, and potential mitigation strategies to address those risks.

MEEA strongly believes that the information listed above is vital to both the Commission and stakeholders’ ability to assess why the utilities revised specific aspects of the program plans or why the utilities chose not to revise aspects of their plans. Providing this information should not be burdensome to the utilities because this data and findings are necessary for the utility to determine whether and how to revise their plans before filing those plans with the Commission.

MEEA Request (ML# 310285) (06/17/2024)
9705 (06/07/2023)
(The 2024-2026 EmPOWER Maryland Program)