Baltimore Gas & Electric proposes two‑year VPP pilot and TOU refinements under DRIVE Act

Baltimore Gas & Electric Co. (BGE) told the Maryland Public Service Commission at a DRIVE Act implementation hearing that it is seeking approval for a two‑year virtual power plant (VPP) pilot focused on residential customers and updated time‑of‑use (TOU) offerings.

BGE presented the VPP as a “software‑driven network of distributed resources” the company said could act “like a flexible power station” by aggregating customer‑side devices — batteries, solar‑plus‑storage and bidirectional electric vehicles — to reduce system peaks and provide other grid services. Amy Chandler, senior manager of transportation electrification and load management at BGE, said the utility’s proposal is “rooted in pay for performance.”

The company proposed a BYOD (bring‑your‑own‑device) approach, a flat pay‑for‑performance incentive of up to $100 per month per enrolled device and a two‑year pilot timeline intended to produce learnings for a future, larger program. Kevin Knight, load management manager, said the pilot would prioritize residential enrollments and aim to recruit existing devices rather than subsidize new hardware. Lynn Fiery, speaking for BGE on TOU, said the utility plans to streamline and strengthen customer signals in legacy TOU schedules and “double” residential TOU participation over time.

Why it matters: The DRIVE Act directs investor‑owned utilities to file proposals that advance customer aggregation, peak reduction and pilot testing of grid services. BGE sought authority to defer incremental implementation costs to a regulatory asset and recover them in a future base rate case, asking the commission to treat the deferred costs under the standard ratemaking framework. John Frane, BGE director of regulatory strategy and revenue policy, said the company was asking for “traditional cost recovery” and argued utilities cannot implement programs at scale without established recovery mechanisms.

Key details: BGE said its VPP pilot will (1) enroll residential customers with batteries, solar‑plus‑storage or bidirectional EVs; (2) use device nameplate and reasonable performance assumptions to calculate payments; (3) emphasize ease‑of‑use to reduce opt‑outs; and (4) collect device‑level and AMI data to measure performance. BGE also stated its pilot will allow export where interconnection and net‑metering terms permit and that the pilot design could be iterated and scaled into a permanent program.

Questions and concerns raised at the hearing included how the pilot will be targeted to locations where distribution upgrades could be deferred, whether differing incentives should be available by location, how aggregators or third‑party implementers will be selected, and why BGE did not include a specific low‑ and moderate‑income (LMI) incentive in its initial filing. Commissioner Suchman urged earlier, more active feeder‑level targeting, and BGE officials said they are coordinating with capacity planning teams and expect to test locational targeting in the pilot period.

Context and next steps: BGE’s filing aligns with the DRIVE Act’s objectives but drew requests from commissioners and intervenors for more granular commitments on locational targeting, LMI outreach and public reporting. Staff and other stakeholders asked for clear metrics and data access arrangements to permit independent verification of pilot performance. MEA representatives said the state’s energy office is open to using grant resources and other tools to amplify equitable participation.

BGE asked the commission to approve its pilot so it could proceed with RFPs, customer outreach and a program launch timeline intended to meet statutory reporting deadlines and feed learnings into future program design.