Staff Files Comments on Proposed System-Wide Reliability Standards Report

Staff filed comments responding to the “Annual Electric System Planning (‘ESP’) Technical Conference, the Phase III Status Report (‘Status Report’) filed by the ESP Work Group Leader, and the [electric utilities’] Proposed System-Wide Reliability Standards for 2028–2031”.

Among other things Staff:

(1) said that the conference and status report reinforce its “view that Maryland is presently transitioning from utility distribution-planning processes that remain principally grounded in traditional engineering practices toward the broader, integrated planning framework contemplated by [COMAR] 20.50.15,” and recommended Maryland PSC “recognize the 2026 Annual ESP Updates as baseline transitional filings”;

(2) said it “has identified meaningful progress made by all four [investor-owned utilities (IOUs)], including the incorporation into their ESP processes of enhanced localized forecasting capabilities, greater documentation of system planning methodologies and constraints, increased consideration of distributed energy resources (‘DERs’) and non-wires solutions (‘NWS’), and initial implementation of the planning metrics and policy goal reporting contemplated by COMAR 20.50.15”;

(3) “recommends that future ESP filings establish a traceable relationship between an identified grid need and the proposed solution” and “distinguishing among conceptual planning solutions, internally approved projects, and projects incorporated into a utility’s capital program”;

(4) “does not recommend that the [utilities] be required to select an NWS for every distribution-system constraint, or that [PSC] should presume that a distributed solution is preferable to conventional infrastructure,” recommending instead that “Where an identified system need is screened for NWS, future ESP filings should identify the system need, whether it qualified for screening, the point in the process when the screening for alternatives was performed, the alternatives evaluated, the technical and economic criteria applied, and the rationale supporting the selected solution”;

(5) recommends Maryland PSC “maintain a distinction between hosting capacity analysis and traditional distribution capacity planning,” but “continues to believe that information developed through hosting capacity and interconnection analyses can appropriately inform particular ESP planning functions”;

(6) said that the status report “confirms that no quantifiable hosting capacity metric has yet been adopted and identifies disagreement concerning whether hosting capacity is presently a ‘gap’ that has not yet been addressed, or is instead partially addressed through existing maps and Uniform Planning Disclosures (‘UPDs’),” recommending MDPSC direct the utilities “identify in their Preliminary ESPs specific, technically appropriate planning uses of the hosting capacity information already available to the utilities, while allowing the ESP Work Group to continue developing standardized ESP-level hosting capacity metrics and methodologies”;

(7) recommends MDPSC use the ESP Work Group Leader’s Revised Transition Proposal “as a framework for establishing near-term expectations, rather than adopting it wholesale as a finalized regulatory framework”;

(8) recommends each utility “be required to include in its Preliminary ESP representative project or planning examples that demonstrate… progression through the following planning stages”: (i) planning input; (ii) identification of grid need; (iii) alternatives considered; (iv) technical/economic evaluation of alternatives; (v) selected solution and rationale; (vi) anticipated benefits; and (vii) “demonstration of applicability to State policy goals”;

(9) recommends utilities “representative examples should also be required to include reliability- or resilience-driven investments, where practicable, and should identify DER, NWS, hosting capacity, operational, and conventional infrastructure alternatives where those alternatives were reasonably applicable to the identified need”;

(10) recommends “specific SAIFI and SAIDI standards… for calendar years 2028 through 2031” for each IOU;

(11) “recommends that the [ESP] Work Group evaluate whether survey timing can reasonably be coordinated with the ESP cycle” and “develop standardized core customer survey themes and rating scales,” noting that the status report “identifies unresolved issues concerning survey neutrality, educational content, question design, and whether surveys should constitute or supplement stakeholder engagement”;

(12) “supports retaining [MDPSC’s] interim Short-List as the foundation for the future evolution of the ESP process, while continuing to allow the Work Group to develop metrics that address gaps identified” in the status report, such as “hosting capacity, reliability, resilience, load and demand management, and NWS”; and

(13) recommends IOU implementation roadmaps for transitioning to the Preliminary ESP identify: (i) “planning capabilities and methodologies currently utilized”; (ii) “methodologies, data sets, and analytical capabilities under development”; (iii) “planning functions affected by those capabilities”; (iv) “organizational responsibilities within the utility”; (v) “expected implementation milestones for the utility”; (vi) “areas where the utility is dependent on Work Group determinations, [MDPSC] guidance, or other… proceedings”; and (vii) “the filing cycle in which each planning capability is expected to become operational.”