2 Center Plaza, 1 th - Baltimore Gas and Electric · Public Service Commission of Maryland ......

September 1, 2016

Via Electronic Filing

David J. Collins, Executive Secretary

Public Service Commission of Maryland

William Donald Schaefer Tower

6 St. Paul Street, 16th

Floor

Baltimore, Maryland 21202-6805

Re: Rulemaking 56 – COMAR 20.62 – Community Solar Energy

Generation Systems

Compliance Plan of Baltimore Gas and Electric Company

Supplement No. 587 to P.S.C. Md. E-6: Rider 32 – Community Energy Pilot

Program and to Electricity Supplier Coordination Tariff

Dear Mr. Collins:

Attached for filing in the above-referenced case, please find the Compliance Plan and the

associated Community Solar Energy Pilot Program Rider of Baltimore Gas and Electric

Company (BGE), as required by the Code of Maryland Regulations 20.62.01.03.

BGE desires to be a partner in ensuring the success of the pilot so that customers might

benefit from community solar. As such, BGE was an active participant in a working group that

met on numerous occasions in an attempt to develop a model tariff. The working group

consisted of solar developers, utilities, Commission Staff, the Maryland Office of People’s

Counsel, and others. The working group was highly engaged; however, agreement could not be

reached on a single tariff. Over the course of developing the tariff and Compliance Plan

submitted today, BGE has identified issues that could impact customer satisfaction with the pilot

and ultimately its success. Thus, BGE submits this non-consensus Rider 32 for the

Commission’s consideration. If the Commission wishes to permit a comment period to enable

interested parties to comment on this filing, BGE would not object.

In order to comply with the statute and support competitive markets, BGE is placing a

dollar credit on the Subscriber’s bills, instead of a kilowatt hour (kWh) credit. Although the

regulations provide the option of a dollar or kWh credit, the only option available to BGE as a

Standard Offer Service (SOS) provider is the dollar credit. This is because Public Utilities

Article Section 7-306.2(d)(8) requires that the energy output of the facility be used as an offset to

BGE SOS. Since the kWh’s related to community solar are already dedicated to reducing the

BGE SOS obligation, those same kWh’s cannot then be used again to credit the customer’s bill.

The dollar credit is also preferable from the standpoint of the competitive markets. Third party

retail suppliers will be financially harmed if a kWh credit is implemented. A kWh credit will

Kimberly A. Curry Assistant General Counsel BGE Legal Department

2 Center Plaza, 12th Floor 110 West Fayette Street Baltimore, MD 21201

Telephone 410.470.1305 Fax 443.213.3206 www.bge.com [email protected]

http://www.bge.com/


September 1, 2016

Rulemaking 56

Page 1

Rulemaking No. 56 Compliance Plan of Baltimore Gas and Electric Company for the

Community Solar Regulations in Code of Maryland Regulations Section 20.62

Pursuant to the Code of Maryland Regulations (COMAR) Section 20.62.01.03A,

Baltimore Gas and Electric Company (BGE) submits this Compliance Plan detailing BGE’s

implementation of a Community Solar Pilot Program in its service territory. Attachment 1 to this

Compliance Plan are redlined and clean versions of a proposed Rider 32 – Community Energy

Pilot Program to the BGE Retail Electric Service Tariff. Rider 32 describes the process for

billing and crediting Subscribers to a Community Solar Energy Generating System (CSEGS) and

the procedures for a CSEGS to apply to participate in the Community Solar Pilot Program and to

apply for interconnection to the BGE system. In this Compliance Plan, BGE describes how it

will comply with the community solar regulations, its timeline for implementation, and how it

intends to recover its costs.

I. BGE ADMINISTRATION OF THE COMMUNITY SOLAR PILOT PROGRAM

Pilot Program Structure (COMAR 20.62.02.01)

Section A of COMAR 20.62.02.01 directs each electric company to establish a program

to accept and administer CSEGS projects for 3 years from the earlier of 1) the first date of the

application of Subscriber Organization to operate a CSEGS or 2) 6 months from the effective

date of this subtitle. BGE’s Rider 32 will become effective upon Commission approval, and

continue in effect for three years from that date. BGE shall continue to facilitate the operation of

Subscriber Organization that was established during the program for a period of 25 years after

the pilot program has ended.

Sections B and C require that an electric company apply credits and excess generation in

accordance with applicable tariffs and pay Subscriber Organizations in accordance with

applicable tariffs. BGE’s Rider 32 describes the process for these crediting and payment

mechanisms.

Program Generation Capacity (COMAR 20.62.02.02)

Section A specifies the statewide capacity limits and program category limits. Rider 32

contains procedures for managing capacity in the pilot program. If a pilot program application

exceeds the available program capacity or category and the application is otherwise complete,

the application shall be deferred to the next program year if space is available. Deferral of one

application does not preclude BGE from accepting a smaller pilot program application for that

program year received after the application that was rejected. BGE will assign a CSEGS

identification number and capacity in the pilot program queue will be reserved for the Subscriber

Organization’s specific CSEGS upon a complete and accepted pilot program application.


September 1, 2016

Rulemaking 56

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BGE will, in accordance with COMAR 20.62.02.02B, maintain a list of accepted projects

and total pilot program capacity in its service territory on the BGE website.

Number of Accounts Per Project (COMAR 20.62.02.03)

This provision limits the Subscriber Organization to 350 accounts per project and permits

an electric company to require a Subscriber Organization to maintain a minimum average

subscription size of 2kW. These requirements are stated in the attached Rider 32.

Subscription Credits (COMAR 20.62.02.04)

Section A requires a Subscriber Organization to provide the electric company with a

document indicating the proportion of the CSEGS output that will be applied to each

Subscriber’s bill, and to provide the electric company monthly Subscriber List updates. The

electric company will use the most recently updated Subscriber List to apply the credits. The

attached Rider 32 contains a list of data that BGE will require from the Subscriber Organization

in order meet Section A’s requirements. BGE will determine the credits to the accounts of the

Subscribers after receipt of the Subscriber Organization’s meter read. BGE reserves the right to

require the CSEGS to be moved to a bill cycle that enables BGE to facilitate efficient credit

calculation.

Section B directs the electric company to determine the amount of the kilowatt hour

(kWh) to be credited to each Subscriber by multiplying the Subscriber’s most recent generation

proportion by the metered output of the CSEGS. This statement is made in Rider 32.

Sections C and D authorize an electric company to apply a credit as a kWh credit or as a

dollar credit. If applied as a dollar credit, the electric company must apply a credit that is no less

than the value to the Subscriber, than had the credit been applied as a reduction in metered

kWh’s. As stated in proposed Rider 32, BGE will provide the credit as a dollar amount instead

of a kWh credit. Although the regulations provide the option of a dollar or kWh credit, the only

option available to BGE as a Standard Offer Service (BGE SOS) provider is the dollar credit.

This is because Public Utilities Article Section 7-306.2(d)(8) requires that the energy output of

the facility be used as an offset to BGE SOS. Since the kWh’s related to community solar are

already dedicated to reducing the BGE SOS obligation, those same kWh’s cannot then be used

again to credit the customer’s bill. The dollar credit is also preferable from the standpoint of the

competitive markets. Third party retail suppliers will be financially harmed if a kWh credit is

implemented. A kWh credit will result in a reduction of sales from the suppliers to their

participating customers. Alternatively, a dollar credit will insulate suppliers from the

participating customers’ relationship with the community solar facilities, and leave their sales

volumes unchanged.

The Subscriber will receive a monthly dollar credit on their bill that will be the equivalent

of their subscription percentage of the CSEGS’s monthly generation amount applied to all

energy charges on the Subscriber’s bill. If the Subscriber is with a third party supplier, the


September 1, 2016

Rulemaking 56

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monthly dollar credit on their bill will be the equivalent of their subscription allocation of the

CSEGS monthly generation amount applied to all energy charges. BGE proposes use of the

BGE SOS rate to calculate the credit for Subscribers who are enrolled with suppliers. BGE

proposes using the BGE SOS rate because currently there is no requirement, or electronic

standardized process, for a supplier to provide the rate information needed to calculate the credit.

Nor is there a means that permits BGE to receive the supplier rate in sufficient time to enable

BGE to calculate a credit to place on the Subscriber’s monthly bill. BGE recommends that the

Commission convene a working group, inclusive of third party suppliers, to develop a

standardized, electronic means for the Maryland utilities and suppliers to exchange this

information. BGE requests whatever waivers are needed to enable it to use the BGE SOS rate as

a proxy while a formalized process is developed. BGE provides as Attachment 2 to this

Compliance Plan revisions to the Electricity Supplier Coordination tariff that adds a new

subsection 2.13 that notes that the BGE Community Energy Pilot Program is available to

customers who are enrolled with a third party supplier and that all of the terms and conditions

associated with the Community Energy Pilot Program are described in Rider 32 – Community

Energy Pilot Program of BGE’s Retail Electric Service Tariff.1

BGE will maintain a record of the kWh’s applied to each Subscriber’s account for 3 years

(COMAR 20.62.02.04E). BGE will carry over the credit to the next month’s bill until the earlier

of the closure of the Subscriber’s account, or the Subscriber’s last meter reading prior to the

month of April.

Subscription Limitations (COMAR 20.62.02.05)

Proposed Rider 32 limits the Subscriber’s subscriptions to 200% of the Subscriber’s

annual usage. The Subscriber Organization will certify in the pilot program application that each

Subscriber’s total subscriptions will not exceed the 200% threshold.

Excess Generation (COMAR 20.62.02.07)

Thirty days after the April billing month, BGE will provide to the Subscriber a true-up

for excess generation. The excess generation will be credited to reasonably exclude the

distribution, transmission, and non-commodity portion of the Subscriber’s bill. BGE will

compare the Subscriber’s annual use to their subscription amount, or amounts, if the Subscriber

is enrolled with multiple Subscriber Organizations, either annually or only for the period of time

that the Subscriber has had subscriptions. If the subscription amount is higher than the actual

usage amount, BGE will credit any excess generation at the generation component of the BGE

SOS rate in effect at the time.

1 BGE also makes a non-substantive change to the Electricity Supplier Coordination Tariff to remove an outdated

reference to net metering aggregation as a pilot in Section 2.12.2, because BGE’s net metering aggregation program

has been a permanent program since March 2014.


September 1, 2016

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Under BGE’s proposal, throughout the year, the Subscriber’s monthly credit amount will

be capped at the full retail value of the lesser of his actual usage or subscription amount, with

any subscribed generation amount in excess of that actual usage rolling forward for use in future

months where actual usage is greater than the subscription amount, up to the annual true up. Put

another way, a Subscriber’s bill will not be permitted to reflect a negative amount. BGE

provides as Attachments 3-7 to this Compliance Plan examples of how the excess generation

calculation process will work. These examples show the bill impacts each month, over a 12

month May to April period, of Subscribers who have purchased subscriptions at 50%, 100%,

200% and 300% of their annual usage. The examples make the following assumptions:

The Subscriber’s monthly usage is 1000 kWh per month, for a total of 12,000 kWh over a

year period

The generation rate charged to the Subscriber in each month is the generation component

of the BGE SOS rate

The transmission rate charged to the Subscriber in each month is the transmission

component of the BGE SOS rate

The distribution rate charged to the Subscriber are the current BGE distribution rates

The Subscriber is a residential customer

Attachment 3 provides an example of a Subscriber who has purchased a subscription at

200% of their annual usage. This example shows that the Subscriber’s actual usage in month 1 is

1000 kWh. However, since the Subscriber has purchased a subscription that represents 200% of

their annual usage, the Subscriber could receive a full retail rate credit for 2000 kWh, which

would result in a negative bill. Under BGE’s proposed method, BGE will cap that Subscriber’s

credit at the full retail value of 1000 kWh, with the additional 1000 kWh rolling over to the next

month, and this Subscriber would only pay the fixed charge of $8.26 this month. In month 2, the

Subscriber’s actual usage is again at 1000 kWh, and the subscription amount is 2000 kWh. The

Subscriber’s credit again is capped at full retail value of 1000 kWh, with the remaining 1000

kWh rolling over to month 3. At the end of month 2, the Subscriber in this example would have

2000 kWh accumulated. After 12 months, this Subscriber would have 12,000 kWh in

accumulated excess generation. At the annual true-up for this example, BGE multiples the

excess generation by the generation component of the BGE SOS rate, which yields a credit of

$1,032.38.

Attachment 4 is an example at 100%. In this example, the Subscriber’s usage is 1000

kWh and his subscription amount is 1000 kWh. Because this Subscriber’s actual usage and

subscription are equal, this Subscriber will have no excess generation, and will only pay the

fixed charge of $8.26 in the true-up month. Attachment 5 is an example at 50%. In that

example, the subscription is 50% of the Subscriber’s usage. Under BGE’s proposal, since BGE

will cap the Subscriber’s credit at the full retail value of the lesser of his actual use or the

subscription amount, this Subscriber’s credit in month 1 is 500 kWh. This Subscriber will have


September 1, 2016

Rulemaking 56

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no excess generation. Attachment 6 is an example at 300%.2 With a monthly usage of 1000

kWh, the Subscriber should receive a credit based on 300% of their usage; however the

Subscriber’s credit is capped at the full retail value of 1000 kWh, with 2000 kWh rolling over to

the next month. At the end of a 12 month period, the Subscriber will have 24,000 kWh in excess

generation. However, Subscribers are only allowed to subscribe up to 200% of the annual base

line so at this time, the Subscriber will only receive credit for 12,000 kWh of excess generation.

Finally, Attachment 7 is a summary of the analysis of the excess generation calculations for the

differing subscription levels.

In light of these implications, BGE proposes to, in the enrollment letter and prior to the

true-up period, send communications to Subscribers, explaining how this process works.

Unsubscribed Energy (COMAR 20.62.02.09)

BGE will credit unsubscribed energy monthly to the Subscriber Organization at the net

hourly PJM locational marginal price in the BGE Zone. No retroactive corrections or changes

can be made to Subscriber information or allocation percentage.

Utility Cost Recovery (COMAR 20.62.02.09)

See Section II below for BGE’s proposed cost recovery mechanisms.

Pilot Project Application Process (COMAR 20.62.03.03) and Pilot Program Queue

(COMAR 20.62.03.04)

The Subscriber Organization must apply to the Commission in order to be granted entry

into the pilot. Once approved by the Commission, the Subscriber Organization must follow the

interconnection procedures in COMAR 20.50.09 and indicate a request to participate in the pilot

program. Once the interconnection agreement is executed by the Subscriber Organization, the

Subscriber Organization may then submit an application to the pilot program. Rider 32 describes

the documentation required in order for the CSEGS or Subscriber Organization to successfully

complete the application process and to maintain their position in the queue. A project may lose

its place in the queue if the Subscriber Organization does not complete any item required during

the application process. BGE will notify a Subscriber Organization prior to removal from the

queue. Of note, if a CSEGS or Subscriber Organization disputes with either BGE or the

Commission any aspect of BGE’s administration of the application process, BGE will not set

aside capacity for that CSEGS or Subscriber Organization while the investigation of the dispute

is pending.

2 A subscription of 300% is not permitted under COMAR 20.62.02.05. However, BGE includes this example to

show the impact if a Subscriber were to inadvertently enroll with a single or multiple Subscriber Organizations at a

level that is 3 times his or her annual use.


September 1, 2016

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BGE will maintain on its website daily updated information about the current status of its

pilot program in accordance with COMAR 20.62.03.04D.

II. IMPLEMENTATION TIMELINE

BGE will be ready to accept interconnection applications for CSEGS projects upon

Commission approval of the tariff.

III. COST RECOVERY

Supply portions of the credit provided to Subscribers will be recovered through Rider 8 to

the BGE Retail Electric Tariff. Incremental administrative costs will be recovered through Rider

10 to BGE’s Retail Electric Tariff. The distribution portion of the credits provided to

Subscribers will be treated as a reduction to the actual revenues collected in the calculation of the

Rider 25 monthly rate adjustment where applicable; all others distribution credits will be

recovered through base distribution rates.

ATTACHMENT 1

112 Electric – Retail - Baltimore Gas and Electric Company

P.S.C. Md. – E-6 (Suppl 587) Filed 09/01/16 – Effective 10/13/16

32. Reserved for Future UseCommunity Energy Pilot Program

Availability: This rider is applicable to all customer classes for 3 years from the earlier of 1) the first

date of the application of Subscriber Organization to operate a CSEGS or 2) 6 months from the effective

date of Code of Maryland Regulations 20.62. In addition to the requirements set herein, all participants in

this rider are subject to the regulations as stated in Code of Maryland Regulations 20.62. BGE shall

continue to facilitate the operation of Subscriber Organization that was established during the program for

a period of 25 years after the program has ended.

Definitions: In addition to the definitions provided in Code of Maryland Regulations 20.62, the

following definitions are used for the purposes of this rider.

Community Solar Energy Generating System (CSEGS): The physical solar energy generating

facility.

Subscriber Organization: The body responsible for maintaining Subscribers and providing the

list of Subscribers to the utility for billing. A Subscriber Organization must be a customer of any BGE

electric tariff schedule. The Subscriber Organization must be the name on the account for the CSEGS

with BGE and must have obtained a Subscriber Organization Number from the Maryland Public Service

Commission (PSC).

Subscriber: A Subscriber is a customer of any BGE electric tariff schedule that has subscribed

with a Subscriber Organization for a portion of the output produced by a CSEGS.

Subscriber: A Subscriber is a BGE Customer taking service on any electric Tariff Schedule being

billed the charges that would be assigned if the Subscriber were not participating in this pilot program. A

Subscriber may subscribe to more than one subscription from more than one Subscriber Organization and

may also participate in net-metering. A Subscriber may not subscribe for greater than 200% of their

annual baseline energy, including any net-metering, if applicable. The Subscriber will be allocated a bill

credit for a percentage of the monthly output of the CSEGS as provided to BGE by the Subscriber

Organization.

A Subscriber will receive a monthly dollar credit on their bill that will be the equivalent of their

subscription percentage of the CSEGS monthly generation amount applied to all energy charges on the

Subscriber’s Bill. If the Subscriber is with a third party supplier, the monthly dollar credit on their bill

will be the equivalent of their subscription allocation of the CSEGS monthly generation amount applied

to all energy charges and their third party supply rate, where available through a PSC approved

predefined and standardized electronic process across all Maryland utilities. If the third party supply rate

is unavailable, or the Subscriber has not chosen a third party supplier, the applicable BGE Standard Offer

Service Rate will be used. Supply portions of the credit provided to Subscribers will be recovered

through Rider 8. Incremental administrative costs will be recovered through Rider 10. The distribution

portion of the credits provided to Subscribers will be treated as a reduction to the actual revenues

collected in the calculation of the Rider 25 monthly rate adjustment where applicable; all other

distribution credits will be recovered through base distribution rates. Depending on timing of notification

from the Subscriber Organization of the Subscriber’s subscription amount, it may take up to two billing

cycles, or more, before a bill credit is applied to the Subscriber’s bill. Subscriptions may not take effect

retroactively.

Electric – Retail – Baltimore Gas and Electric Company 113

P.S.C. Md. – E-6 (Suppl.587) Filed 09/01/16 – Effective 10/13/16

(Continued on Next Page)

32. Community Energy Pilot Program - continued

On or before 30 days after the billing cycle that is complete immediately prior to the end of April

each year, BGE will apply to the bill of each eligible Subscriber a true up for any excess generation. The

Subscriber’s excess generation shall be credited to reasonably exclude the distribution, transmission, and

non-commodity portion of the Subscriber’s bill for the excess generation amount.

Subscriber Organization: Prior to applying for an Interconnection Agreement for this pilot program,

a Subscriber Organization must first be granted permission to participate in this pilot from the PSC and

have received a Subscriber Organization Identification Number. Once the Subscriber Organization has an

Identification Number, they must apply to BGE for an Interconnection Agreement under Code of

Maryland Regulations 20.50.09, indicating a request to participate in the Pilot Program. Interconnection

Applications will be processed in the order in which the completed Interconnection Applications are

received. A Subscriber Organization is responsible for all interconnection costs.

A CSEGS is subject to all tariff provisions applicable under the schedule they are placed. Tariff

Schedule and demand are determined based on the capacity of the CSEGS system. A CSEGS may not

exceed 2MW in AC rated capacity. A CSEGS of 500 kW or greater may not be located on the same or

contiguous parcel of property as another CSEGS of 500kW or greater owned by the same Subscriber

Organization or its affiliate. A CSEGS facility with a capacity greater than 1 MW will be placed on

Primary Service. Metering for a CSEGS will be divided into an input and an output channel. All usage on

the input channel will be billed in accordance with the applicable tariff schedule of the CSEGS. All

generation on the output channel will be used in the calculation of the Subscriber Credits. BGE reserves

the right to require the CSEGS facility to be moved to a bill cycle in order to facilitate efficient credit

calculation.

A Subscriber Organization must provide an executed Interconnection Agreement, in conjunction

with a Community Energy Pilot Application. Pilot Program Applications shall be processed in the order

in which they are received. BGE will notify the Subscriber Organization of receipt of the Pilot Program

Application and whether the Pilot Program Application is complete within 5 business days. A Subscriber

Organization receiving notice of an incomplete Pilot Program Application shall revise and resubmit

within 10 days of receiving the notice. If a Pilot Program Application exceeds the available program

capacity or category and is otherwise complete, the Pilot Program Application shall be deferred to the

next program year if cap space is available. Deferral of one Pilot Program Application does not preclude

the company from accepting a smaller Pilot Program Application received after the deferred Pilot

Program Application. Available pilot program capacity can be found on BGE.com. A CSEGS

Identification Number will be assigned and capacity in the pilot program queue will be reserved for the

Subscriber Organization’s specific CSEGS upon a complete and accepted Pilot Program Application. If a

CSEGS or Subscriber Organization raises a dispute with BGE or the Commission regarding the

processing of an Interconnection Application or a Pilot Program Application, BGE will not set aside

capacity for the CSEG during the pendency of the investigation of the dispute.





Pilot Program Applications will only be accepted in electronic format as defined by BGE. In

order to apply for capacity in an electric company’s pilot program queue, a Subscriber Organization shall

provide the following to the electric company upon Pilot Program Application:

An executed Interconnection Agreement

Proof of application for all applicable permits

Proof of site control:

o Evidence of property ownership;

o An executed lease agreement; or

o A signed option to purchase or lease.

Selection of one of the Following Project types, as defined in COMAR 20.62.02.02A(3):

o Small/Brownfield;

o Open; or

o Low to Moderate Income (LMI)

Amount of that Pilot Program capacity the project intends to take

If a project fails to begin operating within 12 months of submission of a completed application, it

shall be removed from the queue unless a $50 per kW deposit is paid to maintain its spot in the queue for

6 additional months. Projects in LMI category are exempt from queue deposits. A project may lose its

place in the queue if the Subscriber Organization does not complete any item required. BGE will notify a

Subscriber Organization prior to removal from the queue. A Subscriber Organization must maintain all

data and information as prescribed in the regulations as stated in Code of Maryland Regulations 20.62.

A Subscriber Organization shall maintain a minimum average subscription size of 2kW. The

number of Subscribers may not exceed 350 accounts per project. A Subscriber Organization will certify

in the Pilot Program Application that each Subscriber’s total subscriptions will not exceed the statutory

200% annual baseline energy usage eligibility threshold. The Subscriber Organization will certify in the

Pilot Program Application each Subscriber’s LMI eligibility, if relevant to the CSEGS project. The

Subscriber Organization will certify in the Pilot Program Application that each Subscriber authorizes the

utility to release that Subscriber’s account information as necessary.

A Subscriber Organization must provide BGE, following requirements set forth by BGE, with an

individual document for each CSEGS facility indicating the proportion of a CSEGS output that shall be

applied to each Subscriber’s bill at least monthly including:

CSEGS Identification Number

Applicable Month

Subscriber Organization Identification Number

Subscriber Organization Name

Subscriber name (per BGE account)

Each Subscriber’s Electric Choice ID

Percentage share of each Subscriber





Subscriber Organization monthly Subscriber List updates should clearly indicate which

Subscribers are new to the list. Non-compatible or incorrect information will be provided to the

Subscriber Organization. BGE will apply credits using the most recently updated Subscriber List at the

time of the credit calculation. Subscriptions associated with ineligible Subscribers (such as Subscribers

that are not BGE customers or have finalized their BGE accounts) will be treated as Unsubscribed

Energy. Unsubscribed Energy will be credited monthly to the Subscriber Organization at the net hourly

PJM locational marginal price (LMP) in the BGE Zone. No retroactive corrections or changes can be

made to Subscriber information or allocation percentage.



32. Community Energy Pilot Program

Availability: This rider is applicable to all customer classes for 3 years from the earlier of 1) the first

date of the application of Subscriber Organization to operate a CSEGS or 2) 6 months from the effective

date of Code of Maryland Regulations 20.62. In addition to the requirements set herein, all participants in

this rider are subject to the regulations as stated in Code of Maryland Regulations 20.62. BGE shall

continue to facilitate the operation of Subscriber Organization that was established during the program for

a period of 25 years after the program has ended.

Definitions: In addition to the definitions provided in Code of Maryland Regulations 20.62, the

following definitions are used for the purposes of this rider.

Community Solar Energy Generating System (CSEGS): The physical solar energy generating

facility.

Subscriber Organization: The body responsible for maintaining Subscribers and providing the

list of Subscribers to the utility for billing. A Subscriber Organization must be a customer of any BGE

electric tariff schedule. The Subscriber Organization must be the name on the account for the CSEGS

with BGE and must have obtained a Subscriber Organization Number from the Maryland Public Service

Commission (PSC).

Subscriber: A Subscriber is a customer of any BGE electric tariff schedule that has subscribed

with a Subscriber Organization for a portion of the output produced by a CSEGS.

Subscriber: A Subscriber is a BGE Customer taking service on any electric Tariff Schedule being

billed the charges that would be assigned if the Subscriber were not participating in this pilot program. A

Subscriber may subscribe to more than one subscription from more than one Subscriber Organization and

may also participate in net-metering. A Subscriber may not subscribe for greater than 200% of their

annual baseline energy, including any net-metering, if applicable. The Subscriber will be allocated a bill

credit for a percentage of the monthly output of the CSEGS as provided to BGE by the Subscriber

Organization.

A Subscriber will receive a monthly dollar credit on their bill that will be the equivalent of their

subscription percentage of the CSEGS monthly generation amount applied to all energy charges on the

Subscriber’s Bill. If the Subscriber is with a third party supplier, the monthly dollar credit on their bill

will be the equivalent of their subscription allocation of the CSEGS monthly generation amount applied

to all energy charges and their third party supply rate, where available through a PSC approved

predefined and standardized electronic process across all Maryland utilities. If the third party supply rate

is unavailable, or the Subscriber has not chosen a third party supplier, the applicable BGE Standard Offer

Service Rate will be used. Supply portions of the credit provided to Subscribers will be recovered

through Rider 8. Incremental administrative costs will be recovered through Rider 10. The distribution

portion of the credits provided to Subscribers will be treated as a reduction to the actual revenues

collected in the calculation of the Rider 25 monthly rate adjustment where applicable; all other

distribution credits will be recovered through base distribution rates. Depending on timing of notification

from the Subscriber Organization of the Subscriber’s subscription amount, it may take up to two billing

cycles, or more, before a bill credit is applied to the Subscriber’s bill. Subscriptions may not take effect

retroactively.





On or before 30 days after the billing cycle that is complete immediately prior to the end of April

each year, BGE will apply to the bill of each eligible Subscriber a true up for any excess generation. The

Subscriber’s excess generation shall be credited to reasonably exclude the distribution, transmission, and

non-commodity portion of the Subscriber’s bill for the excess generation amount.

Subscriber Organization: Prior to applying for an Interconnection Agreement for this pilot program,

a Subscriber Organization must first be granted permission to participate in this pilot from the PSC and

have received a Subscriber Organization Identification Number. Once the Subscriber Organization has an

Identification Number, they must apply to BGE for an Interconnection Agreement under Code of

Maryland Regulations 20.50.09, indicating a request to participate in the Pilot Program. Interconnection

Applications will be processed in the order in which the completed Interconnection Applications are

received. A Subscriber Organization is responsible for all interconnection costs.

A CSEGS is subject to all tariff provisions applicable under the schedule they are placed. Tariff

Schedule and demand are determined based on the capacity of the CSEGS system. A CSEGS may not

exceed 2MW in AC rated capacity. A CSEGS of 500 kW or greater may not be located on the same or

contiguous parcel of property as another CSEGS of 500kW or greater owned by the same Subscriber

Organization or its affiliate. A CSEGS facility with a capacity greater than 1 MW will be placed on

Primary Service. Metering for a CSEGS will be divided into an input and an output channel. All usage on

the input channel will be billed in accordance with the applicable tariff schedule of the CSEGS. All

generation on the output channel will be used in the calculation of the Subscriber Credits. BGE reserves

the right to require the CSEGS facility to be moved to a bill cycle in order to facilitate efficient credit

calculation.

A Subscriber Organization must provide an executed Interconnection Agreement, in conjunction

with a Community Energy Pilot Application. Pilot Program Applications shall be processed in the order

in which they are received. BGE will notify the Subscriber Organization of receipt of the Pilot Program

Application and whether the Pilot Program Application is complete within 5 business days. A Subscriber

Organization receiving notice of an incomplete Pilot Program Application shall revise and resubmit

within 10 days of receiving the notice. If a Pilot Program Application exceeds the available program

capacity or category and is otherwise complete, the Pilot Program Application shall be deferred to the

next program year if cap space is available. Deferral of one Pilot Program Application does not preclude

the company from accepting a smaller Pilot Program Application received after the deferred Pilot

Program Application. Available pilot program capacity can be found on BGE.com. A CSEGS

Identification Number will be assigned and capacity in the pilot program queue will be reserved for the

Subscriber Organization’s specific CSEGS upon a complete and accepted Pilot Program Application. If a

CSEGS or Subscriber Organization raises a dispute with BGE or the Commission regarding the

processing of an Interconnection Application or a Pilot Program Application, BGE will not set aside

capacity for the CSEG during the pendency of the investigation of the dispute.





Pilot Program Applications will only be accepted in electronic format as defined by BGE. In

order to apply for capacity in an electric company’s pilot program queue, a Subscriber Organization shall

provide the following to the electric company upon Pilot Program Application:

An executed Interconnection Agreement

Proof of application for all applicable permits

Proof of site control:

o Evidence of property ownership;

o An executed lease agreement; or

o A signed option to purchase or lease.

Selection of one of the Following Project types, as defined in COMAR 20.62.02.02A(3):

o Small/Brownfield;

o Open; or

o Low to Moderate Income (LMI)

Amount of that Pilot Program capacity the project intends to take

If a project fails to begin operating within 12 months of submission of a completed application, it

shall be removed from the queue unless a $50 per kW deposit is paid to maintain its spot in the queue for

6 additional months. Projects in LMI category are exempt from queue deposits. A project may lose its

place in the queue if the Subscriber Organization does not complete any item required. BGE will notify a

Subscriber Organization prior to removal from the queue. A Subscriber Organization must maintain all

data and information as prescribed in the regulations as stated in Code of Maryland Regulations 20.62.

A Subscriber Organization shall maintain a minimum average subscription size of 2kW. The

number of Subscribers may not exceed 350 accounts per project. A Subscriber Organization will certify

in the Pilot Program Application that each Subscriber’s total subscriptions will not exceed the statutory

200% annual baseline energy usage eligibility threshold. The Subscriber Organization will certify in the

Pilot Program Application each Subscriber’s LMI eligibility, if relevant to the CSEGS project. The

Subscriber Organization will certify in the Pilot Program Application that each Subscriber authorizes the

utility to release that Subscriber’s account information as necessary.

A Subscriber Organization must provide BGE, following requirements set forth by BGE, with an

individual document for each CSEGS facility indicating the proportion of a CSEGS output that shall be

applied to each Subscriber’s bill at least monthly including:

CSEGS Identification Number

Applicable Month

Subscriber Organization Identification Number

Subscriber Organization Name

Subscriber name (per BGE account)

Each Subscriber’s Electric Choice ID

Percentage share of each Subscriber





Subscriber Organization monthly Subscriber List updates should clearly indicate which

Subscribers are new to the list. Non-compatible or incorrect information will be provided to the

Subscriber Organization. BGE will apply credits using the most recently updated Subscriber List at the

time of the credit calculation. Subscriptions associated with ineligible Subscribers (such as Subscribers

that are not BGE customers or have finalized their BGE accounts) will be treated as Unsubscribed

Energy. Unsubscribed Energy will be credited monthly to the Subscriber Organization at the net hourly

PJM locational marginal price (LMP) in the BGE Zone. No retroactive corrections or changes can be

made to Subscriber information or allocation percentage.

ATTACHMENT 2

TABLE OF CONTENTS

1.0: DEFINITIONS/EXPLANATION OF ABBREVIATIONS .............................................................. 1

2.0: GENERAL TERMS AND CONDITIONS ...................................................................................... 4

2.1 Scope and Purpose ............................................................................................................ 4

2.2 Electricity Supplier’s Responsibilities to Customers ......................................................... 4

2.3 Tariff to Govern ................................................................................................................ 4

2.4 Recourse to the Commission ............................................................................................. 4

2.5 FERC Jurisdiction ............................................................................................................. 4

2.6 Electricity Supplier Obligations ........................................................................................ 4

2.7 Electricity Supplier and Company Obligations ................................................................. 5

2.8 Control Area Services and Obligations ............................................................................. 5

2.9 Communications and Data Exchange ................................................................................ 5

2.10 Record Retention ............................................................................................................... 5

2.11 Customer Lists .................................................................................................................. 5

2.12 Net Energy Metering ......................................................................................................... 6

2.13 Community Energy Pilot Program ……………………………………………………...7

3.0: UTILIZATION OF SCHEDULING COORDINATORS ................................................................. 7

3.1 Participation through a Scheduling Coordinator................................................................ 7

3.2 Designation of a Scheduling Coordinator .......................................................................... 7

3.3 Change of Scheduling Coordinator ................................................................................... 8

3.4 Load Scheduling through a Scheduling Coordinator ......................................................... 8

3.5 Primary Obligations of Electricity Supplier ...................................................................... 8

4.0: COMMENCEMENT AND TERMINATION OF COORDINATION SERVICES ......................... 9

4.1 Application Process to Company ...................................................................................... 9

4.2 Commencement of Coordination Services ...................................................................... 10

4.3 Notice of Electricity Supplier Discontinuance to the Company ...................................... 10

4.4 Termination of Coordination Services ............................................................................ 10

4.5 Effect of Termination ...................................................................................................... 10

4.6 Survival of Obligations ................................................................................................... 10

5.0: CREDITWORTHINESS ................................................................................................................ 11

5.1 Purpose and Intent ........................................................................................................... 11

5.2 Finding of Creditworthiness ............................................................................................ 11

5.3 Credit Amount ................................................................................................................. 11

5.4 Change in Financial Status .............................................................................................. 11

5.5 No Endorsement of Electricity Supplier .......................................................................... 11

6.0: NONCOMPLIANCE AND DEFAULT ......................................................................................... 11

6.1 Definition of Noncompliance .......................................................................................... 11

6.2 Events of Noncompliance ............................................................................................... 12

6.3 Supplier Default .............................................................................................................. 12 6.4 Cure and Default ............................................................................................................. 12

P.S.C. Md. – E-6 (Suppl. 501 587) Filed 02/27/12 09/01/16– Effective 04/01/1210/13/16

Baltimore Gas and Electric Company – Electric – Supplier 7

2.12.2 Net Metering Aggregation Pilot. Effective April 1, 2012 the Company’s Net Metering

Aggregation Pilot will be is available to Customers who are provided Competitive Power Supply

by an Electricity Supplier. All of the terms and conditions associated with the Net Metering

Aggregation Pilot as a r e described in Rider 18 – Net Energy Metering of BGE’S Retail

Electric Service Tariff. All Customers participating in the Net Metering Aggregation Pilot must be

served by the same Electricity Supplier, and use Dual Billing.

The Company will provide the Electricity Supplier meter read data for each aggregated account in

accordance with Section 12 of this Tariff. Within five business days after the Meter Read Date,

the Company will provide the Electricity Supplier with the following information about the

eligible customer-generator in a format agreed upon between the Company and Electricity

Supplier:

a) Account number – eligible “host” account

b) Account number(s) – aggregated accounts

c) Start meter reading date

d) Stop meter reading date

e) Start index

f) Stop index

g) kWh consumed or generated

If the aggregated group has accrued net excess generation for the 12 month period that ends with

the billing cycle that is complete immediately prior to the end of April of each year, then the

eligible “host” account of the aggregation group will be provided a net metering payment at the

Supplier Average Generation Rate provided by the Electricity Supplier of record as of March 31.

The net metering credit will be calculated for the entire group as outlined in Section 2.12.1 of this

Tariff. The total amount of the payment will be provided to the eligible “host account”.

2.13 Community Energy Pilot Program. The Community Energy Pilot Program is available to

Customers who are provided Competitive Power Supply by an Electricity Supplier. All of the terms

and conditions associated with the Community Energy Pilot Program are described in Rider 32 –

Community Energy Pilot Program of BGE’s Retail Electric Service Tariff.

3.0: UTILIZATION OF SCHEDULING COORDINATORS

3.1 Participation through a Scheduling Coordinator. An Electricity Supplier is responsible for

performing the responsibilities and obligations provided in this Tariff, but may elect to perform certain

functions through a Scheduling Coordinator. To the extent an Electricity Supplier so elects, it becomes a

Coordinated Electricity Supplier. A Coordinated Electricity Supplier may retain up to ten Scheduling

Coordinators with the Company at any time. More than 10 Scheduling Coordinators may be allowed if

mutually agreed upon by the Electricity Supplier and the Company. An Electricity Supplier may become

a Coordinated Electricity Supplier by entering into a business arrangement with another Electricity

Supplier or other entity that will act as a Scheduling Coordinator. A Coordinated Electricity Supplier

must enter into this business arrangement with a Scheduling Coordinator for all the Electricity Supplier’s

responsibilities, including installed capacity obligation, transmission obligation, import capability, load

forecasting, load scheduling, and reconciliation rights and responsibilities. The Scheduling Coordinator

is responsible for meeting all of the requirements of PJM that may be necessary in order to carry out its

responsibilities. All actions of the Scheduling Coordinator on behalf of the Electricity Supplier are

binding on, and attributable to, the Electricity Supplier, whether such actions were or were not authorized

by the Electricity Supplier.

3.2 Designation of a Scheduling Coordinator. For each Scheduling Coordinator designated, the

Electricity Supplier must provide the Company with a completed Scheduling Coordinator

Designation Form fully executed by both the Electricity Supplier and the Scheduling Coordinator.

The Scheduling Coordinator Designation Form is not intended to supplant or replace any agency

contract between the Electricity Supplier and a Scheduling Coordinator.

P.S.C. Md. – E-6 (Suppl. 501587) Filed 02/27/12 09/01/16– Effective 04/01/1210/13/16

ATTACHMENTS 3 - 7

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