Maryland Energy Storage Docket - Topic Categorization Framework

Executive Summary

This framework organizes 79 sub-topics from public comments into 8 Primary Topics. This structure balances specificity with manageability, allowing effective filtering while maintaining clear thematic boundaries.

Primary Topic Definitions & Sub-Topic Assignments

1. PROCUREMENT & CONTRACTING MECHANISMS

Definition: All aspects of how energy storage projects are solicited, selected, and contracted, including procurement design, timelines, evaluation criteria, and contract structures.

Sub-topics (22):

• Procurement Mechanisms

• Prioritizing Programs Over RFPs in Early Market Stages

• Support for a Short-Term Competitive Solicitation with Conditions and Redirecting Unused MWs

• "Preference for simple, proven long-term contracting (Full Tolling)"

• Financing rationale and comparison of incentive designs (full toll vs. partial toll vs. fixed incentive)

• Role of competitive developers versus utilities and Clearway's experience supporting recommendations

• A Tariffed Grid Services Program to Stimulate the Market

• "Procurement scale, timeline, and sub-allocation for meeting Maryland storage targets"

• Financial compensation mechanism and contract design to enable financeability

• Procurement evaluation design: include price and non‑price factors

• Program administration options and solicitation governance

• Competitive Procurement Modeled on the State's OREC Program and a Level Playing Field

• Limit Procurement to New PJM-Accredited (Incremental) Capacity

• Contract Structure: Prefer 15–20 Year Terms and Include Partial or Full Tolling Options

• "Minimize Ratepayer Risk by Awarding Only Advanced, Well-Understood Projects"

• Procurement Timing Should Look Beyond the First Target Year (2028) and Accept Offers for Later CODs

• "Phased Procurement Approach, Targets, and Implementation Timeline"

• "Cost Recovery, Tolling Agreement Structures, and Customer Protections"

• RFQ Pre-Qualification Before Procurement to Prevent Speculation and Improve Outcomes

• Leveraging the Existing Community Solar (CSEG) Program and CPCN Queue to Reduce Costs and Accelerate Deployment

• Procedural critique of Exelon Utilities‑SEIA instant filing and docket conformity

• Proposed Timeline and Implementation Steps

2. OWNERSHIP, DISPATCH & MARKET PARTICIPATION

Definition: Questions about who owns, controls, and operates energy storage assets, including utility vs. third-party ownership, dispatch rights, optimization authority, and wholesale market participation.

Sub-topics (10):

• Third-Party vs. Utility-Owned Ownership Structure

• Maximizing ratepayer benefits via 3rd-party optimization and scheduling

• Critique of Utility Dispatch Rights (UDR) and Recommendation for Third-Party Dispatch/Competitive Contracts

• "Administration, Conflict-of-Interest Avoidance, and Practical Implementation Recommendations"

• "Emphasis on Developer Certainty, Market Participation, and Ratepayer Benefits"

• Misalignment of Utility Incentives and Capital Bias; Proposal for Performance-Based Incentives

• Support for Utility Ownership and the Role of Utilities in Energy Storage

• Preference for Front-of-the-Meter Transmission-Connected Storage

• The Unique Characteristics and System Benefits of Third‑Party FTM Distribution‑Connected Storage

• Long‑Term Vision and Design Principles

3. INTERCONNECTION & GRID INTEGRATION

Definition: Technical and procedural aspects of connecting storage to the grid, including interconnection processes, costs, timelines, grid services, system benefits, and distribution/transmission integration.

Sub-topics (10):

• Importance of a Transparent and Efficient Interconnection Process

• Interconnection Process and Cost Certainty

• Transparent and Efficient Interconnection Process

• Concerns Over Dedicated Distribution Feeders

• Grid Services Programs and Their Benefits

• Energy Storage Use Cases and Benefits to the Distribution and Transmission Systems

• Valuation and Integration Tools: LVDER and DERMS to Optimize DER Deployment

• Interconnection Process for Standalone Storage and Solar Paired with Storage

• Valuation of Long-Duration and Multi-Day Storage

• Barriers to Investment in LDES and MDS

4. REGULATORY PROCESS & COMPLIANCE

Definition: Administrative procedures, regulatory requirements, exemptions, permitting, siting, stakeholder engagement mandates, and legislative/commission actions related to energy storage development.

Sub-topics (15):

• Project Exemptions

• Stakeholder Engagement

• Call for Legislative Action on CPCN Process

• Regulatory Clarity and Efficiency

• Site Control Requirements

• Stakeholder Engagement Requirements

• Permitting Challenges and Recommendations

• Project Maturity & Site Control

• "Ambiguity in the phrase ""application to begin construction"""

• Scope of Exemptions and Waivers—Include Electric Utilities Beyond MESP Applicants/Registrants

• Integration with the CPCN Process and Avoiding Duplicate Engagement/siting Reviews

• Clarify Stakeholder Engagement and Participation Requirements (COMAR §20.50.14.08)

• "Editorial Corrections, Section Numbering, and Specific Drafting Fixes"

• Permitting and Local Approvals: Addressing County-Level Gaps and SB 931 Implementation

• Recommendations for Commission Action (both instances)

5. CUSTOMER PROGRAMS & RATE DESIGN

Definition: Behind-the-meter storage programs, retail rate structures, utility tariffs, customer-facing impacts, and distributed energy resource programs targeting end-use customers.

Sub-topics (7):

• Behind-the-Meter (BTM) Energy Storage Programs

• Utility Tariffs and Rate Structures

• Retail Rate Design and Requirement for Utility Tariffs for ESS

• "Customer-Facing Impacts: Cost-Effectiveness, Integration with Solar, and Practical Barriers"

• Risk Allocation and Consumer Protection Concerns

• Prematurity — DRIVE Act Pilots Should Be the Launchpad

• Insufficient Detail in the Exelon Utilities' Proposal

6. ENVIRONMENTAL & EQUITY CONSIDERATIONS

Definition: Environmental justice, greenhouse gas emissions impacts, equity considerations, emissions reduction requirements, and co-optimization for environmental benefits.

Sub-topics (6):

• Equity and Environmental Justice Considerations

• Evidence and Risk That Energy Storage Can Increase GHG Emissions

• Recommendation that MESI Programs Include an Emissions Reduction Requirement

• Practical Approach to Implementing an Emissions Reduction Program Requirement

• Opportunities for Emissions Reduction Without Direct Incentive Payments (Co‑optimization)

• GMP Case Study and the Changed Market Context

7. POLICY FRAMEWORK & STRATEGIC PLANNING

Definition: Overarching policy recommendations, strategic frameworks, long-term planning, needs assessments, and recommendations for program design that span multiple technical areas.

Sub-topics (7):

• Recommendations for Policy Framework

• Collaboration and Future Development

• Need for Additional Analysis and Program Design

• Developer Readiness and Market Supply (RFI Findings)

• Importance of Cost Recovery Mechanisms

• Impact of Political and Economic Factors

• "Trade, Tariffs, Federal Tax Policy and Market Uncertainty — Mitigating Cost Risk to Ratepayers"

8. PRIORITIZING PROGRAMS OVER RFPS IN EARLY MARKET STAGES

Definition: This appears twice in the source data (lines 13 and 52). Recommend treating as one sub-topic under Primary Topic 1 (Procurement).

Note: This is a duplicate entry. It should be consolidated into a single sub-topic under "Procurement & Contracting Mechanisms."

Summary Statistics

Categorization Principles Applied

1. Functional Coherence: Sub-topics grouped by their primary functional relationship (e.g., all procurement-related items together)

2. Stakeholder Perspective: Topics organized to align with how different stakeholders (developers, utilities, regulators, customers) would naturally search for information

3. Actionability: Primary Topics structured to support decision-making processes (e.g., separate categories for regulatory compliance vs. technical integration)

4. Minimal Overlap: Clear boundaries between Primary Topics to avoid ambiguity in classification

5. Balanced Distribution: While not perfectly equal, distribution ranges from 6-22 sub-topics per Primary Topic, maintaining manageability

Implementation Recommendations

For Filtering & Analysis:

• Use Primary Topics as first-level filters in stakeholder dashboards

• Allow multi-select filtering when comments span multiple Primary Topics

• Create sub-topic dropdowns within each Primary Topic for granular analysis

For Reporting:

• Group comments by Primary Topic for executive summaries

• Use sub-topics for detailed technical analysis

• Track comment frequency by both Primary and Sub-Topic levels

For Stakeholder Engagement:

• Organize working groups around Primary Topics

• Use sub-topics to create focused discussion agendas

• Map stakeholder concerns to specific Primary-Sub-Topic combinations

Alternative Categorization Considerations

If 8 Primary Topics proves too granular, the framework could be consolidated to 5 Super-Categories:

1. Project Development & Procurement (combining Topics 1 & 2)

2. Technical & Grid Integration (Topic 3)

3. Regulatory & Administrative (Topic 4)

4. Customer & Rate Programs (Topic 5)

5. Policy, Environment & Equity (combining Topics 6 & 7)

However, the 8-topic structure is recommended as it provides better specificity for filtering while remaining manageable.