Developers and trade groups push transmission procurements, walk‑up distribution programs and long‑duration storage carve‑outs

Trade associations, community‑storage developers and long‑duration storage vendors used the PSC hearing to press complementary approaches to the utilities’ procurement concepts: more transmission procurements for large projects, tariff‑style “walk‑up” programs for distribution storage, and specific treatment for long‑duration batteries.

Why the proposals matter

Industry witnesses told commissioners that Maryland’s storage mandate will be easiest to meet if the state creates multiple entry points for investment. Transmission‑connected, utility‑scale projects provide large, rapid additions of capacity and can materially lower wholesale capacity bills, industry groups said. Distribution‑connected projects and behind‑the‑meter batteries provide different, local benefits — including capacity reduction at the customer or feeder level, deferred distribution upgrades, power quality and resilience for critical facilities.

Developers urged the PSC to design programs that let both kinds of projects compete on appropriate terms.

Front‑of‑meter transmission projects and long contracts

The Mid Atlantic Renewable Energy Coalition (MAREC) told the PSC that front‑of‑meter transmission‑connected storage should be the backbone of Maryland’s plan and urged the commission to allow flexibility beyond the Next Generation Energy Act minimums. Diane Cherry of MAREC asked the PSC to permit project design flexibility, longer commercial operation windows where needed and long‑term contracts to enable financing:

- MAREC recommended the PSC consider additional transmission procurement beyond the Act’s 1,600 MW (for example adding ~600 MW later in 2028) to provide an alternate route for projects that cannot meet earlier performance windows. - Industry witnesses urged offering long term contracts (witnesses suggested at least 15 years) and allowing bidders a choice between full tolling and partial tolling structures to attract competitive responses.

Long‑duration storage

Form Energy asked the PSC to explicitly include multi‑day storage in the initial procurements and proposed a dedicated small carve‑out (Form suggested about 75 megawatts) and procurement criteria that reward low dollars per megawatt‑hour of stored energy. Form emphasized that multi‑day storage is designed to deliver reliability during prolonged weather events and that its iron‑air approach has different lifetime and cost characteristics than short‑duration lithium‑ion batteries.

Distribution‑connected “walk‑up” programs, community storage and virtual power plants

Several participants urged the PSC not to rely solely on discrete RFPs for dozens or hundreds of small distribution projects.

- SEIA, 9 Dot Energy and community‑storage developers described “walk‑up” tariff or program models (similar to Connecticut and Massachusetts approaches and to New York’s value‑stack/VDER frameworks) that let projects enroll in a standing program once they meet eligibility and maturity criteria. They argued tariffs lower administrative overhead, improve project financeability and produce a steady pipeline of distributed resources. - 9 Dot Energy and Turning Point Energy promoted community energy storage — stand‑alone front‑of‑meter projects sized to serve local feeders and share benefits with nearby customers — as a distributed analog to community solar projects. - Solar and residential‑battery firms (Sunrun and Maryland Rooftop Solar Coalition) emphasized residential batteries and virtual power plants as a growing source of flexible capacity. Sunrun reported over 156,000 residential batteries in its book of business nationally, with roughly 20,000 currently enrolled in VPPs; they urged incentives and retail‑rate design that enable medically‑necessary and low‑income customers to participate.

Interconnection, permitting and equity

Developers pressed the PSC and utilities to clear interconnection and permitting barriers. Turning Point Energy highlighted that, unlike solar, few Maryland counties have explicit battery ordinances and that local permitting moratoria can delay projects. Multiple witnesses said improved interconnection procedures (device‑level metering, appropriate modeling of charging regimes to avoid artificially inflating interconnection costs) would unlock many more projects.

Trade‑offs and program design

Industry witnesses advised a portfolio approach: large transmission projects secured with stable long‑term contracts to attract capital; medium‑scale distribution projects supported through standing tariff programs and targeted RFPs for locational needs; and a pathway for behind‑the‑meter and residential VPPs through forthcoming DRIVE‑Act proposals and retail‑rate reforms.

Ending

Developers and industry associations presented program design recipes aimed at scaling storage along multiple pathways: large transmission procurements, tariff‑based distribution programs that let projects “walk up,” a dedicated multi‑day storage procurement track, and clearer interconnection and local permitting paths. They urged the PSC to approve short‑term steps while committing to a long‑term market design that keeps third‑party competition robust and shields customers from undue cost exposure.