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Maryland Public Service Commission (MD PSC) Staff files additional comments on topic of battery energy storage systems:

“ {***} The Staff of the Public Service Commission files these Additional Comments regarding battery energy storage systems (“BESS”) for consideration by the Commission.

Survey of Public Service Company Property for Potential Energy Storage Facility Sites. 

Recently enacted Public Utilities (“PU”) § 7-216.1 which required the Commission to establish the Maryland Energy Storage Program (“MESP”).3 The statute requires the deployment of new energy storage devices4 in the State, with the MESP reaching a minimum of 3,000 MW of energy storage, or the maximum cost-effective amount of energy storage, by the end of delivery year 2033. The statute requires the Commission to establish targets with the goal of achieving: (i) 750 megawatts of cumulative energy storage capacity by the end of delivery year 2027; (ii) 1,500 megawatts of cumulative energy storage capacity by the end of delivery year 2030; and (iii) 3,000 megawatts of cumulative energy storage capacity by the end of delivery year 2033. To meet these goals, the statute provides that the Commission under the MESP may require investor-owned utility companies to install energy storage devices,5 and may require “any other mechanism or policy that the Commission determines is appropriate to achieve the goal of a robust, cost-effective energy storage system in the State.” 6 Under the later statutory provision, it is possible that the Commission could direct electric companies to install new BESS with some of the provisions of PU § 7-216.1 relaxed or perhaps using a “standard design” and “standard capacity” BESS 7 to reduce cost. 

In addition, it is possible that additional legislation may be proposed and enacted during the current legislative session requiring investor-owned utilities or perhaps some rural electric cooperatives to take actions to increase resource adequacy, which may include the installation of new energy storage devices.

To provide some preliminary information that might reduce the time needed to consider options, Staff recommends that the investor-owned utilities and the Southern Maryland Electric Cooperative8 be directed to survey currently owned real property to identify locations sufficiently large enough where a BESS could be installed. The survey would also identify electric facilities such as switchgear or substations near these locations that may support the installation of BESS. The results of the survey would be reported to the Commission within an appropriate amount of time, such as within three months. This list of locations on electric company-owned property would provide a ready resource for Staff, the Commission, private market actors, and utilities if needed in the future.

Battery Energy Storage Systems Sited on Federal Property or Military Installation. 

The federal government and military may have need for BESS facilities for backup power supply for critical facilities and operations. To reduce the administrative burden for any new BESS installations sited on federal government property or within the defined boundaries of a military installation, Staff recommends that the Commission use its authority under PU § 7-216.1(c)(4)(iv) to adopt a “policy that the Commission determines is appropriate to achieve the goal of a robust, cost-effective energy storage system in the State” and waive all requirements for the approval of any BESS that is sited on federal property or within a military installation, including any requirement to show the cost-effectiveness of the BESS, with the exception of the interconnection to the distribution system, compliance with safety and environmental standards, and any routine reporting requirements for BESS installations under the MESP. BESS installations located on federal property or military installations solely used to provide backup power services for critical services may but are not required to participate in providing demand reduction and other grid services. Any mandatory review of the decisions by federal or military authorities regarding the siting of a BESS on federal or military property, its mode of operation, or its cost-effectiveness would be inconsistent with the Supremacy Clause of the U.S. Constitution. 9 A general waiver of any unnecessary approval requirements for any BESS that is located on federal government property or within the defined boundaries of a military installation would eliminate any uncertainty regarding the approval process of new BESS facilities on federal property and military installations. 

This suggested policy would not apply to any BESS located on federal property or at a military installation that voluntarily participates in the MESP.

Reducing or Eliminating Cost-Effectiveness Requirements for BESS Installations in PJM Zones with Excessive High Summer Afternoon Congestion Costs or Excessive Summer Daytime Peak Loads. 

If the Commission determines that it should promote or accelerate the installation of new BESS in specific PJM zones with excessive high summer afternoon congestion costs or excessive summer daytime peak loads (which leads to higher customer prices in electricity auctions for these zones), the Commission could use its authority under PU § 7-216.1(c)(4)(iv) to adopt a “policy that the Commission determines is appropriate to achieve the goal of a robust, cost-effective energy 9 Article VI, Clause 2, of the Constitution of the United States. This is essentially a conflicts-of law rule specifying that certain federal acts take priority over any state acts that conflict with federal law. 5 storage system in the State” and adopt a policy that temporarily reduces, waives,10 or eliminates any cost-effectiveness reviews or requirements for the siting of new BESS located within these designated zones. The Commission could also temporarily reduce or eliminate any other requirement that restricts or delays the siting or construction of BESS facilities in the PJM zones of concern. To eliminate the need for any certificates of public convenience or necessity, the capacity of these BESS facilities would be limited to no more than 2 MW. This temporary policy would remain in effect until either a specified amount of new BESS capacity has been installed or the summer afternoon congestion costs or daytime peak loads have been reduced to an acceptable level. Such a policy may allow more new BESS facilities to be installed in more locations on the distribution system in the designated PJM zone, leading to a faster buildout of energy storage in these PJM zones.”{***}

(ML# 315025)

https://webpscxb.psc.state.md.us/DMS/official-filings  (01/17/2025)
See all filed comments at docket link below including joint Exelon comments.

PC66
Battery Energy Storage Systems – Resource Adequacy Technical Conference – Administrative