Legal Bulletins

Maryland’s utilities have filed their initial distribution-connected BESS plans with the PSC in Case No. 9715. For developers tracking opportunities:

• BGE: Plan 1 targets 29 MW now (of 87 MW total) using three ownership/operational models with at least 30% third-party participation; Plan 1 assets are expected to be operational by Nov 1, 2027. 
   
• Pepco and Delmarva Power Light (DPL): Propose 10.5 MW (Pepco) and 4 MW (DPL); if approved, they intend to issue an RFP and evaluate on cost-effectiveness, site readiness, safety/cyber, developer experience, and more, with an aim to be operational by Nov 1, 2027. 
   
• Potomac Edison: Initial plan for 6.5 MW (within a 19.5 MW allocation) with ≥30% third-party ownership; proposes bilateral PPAs where the utility sells energy into PJM during agreed dispatch events and passes LMP energy payments to the developer. 

Note: Some proposals focus on peak reduction and market value stacking rather than near-term non-wires solutions, given timeline constraints.

Industry comments are due to the PSC by January 2, 2026, with a legislative style hearing occurring January 8, 2026. If your team is considering comments, sites, or procurement strategy, I’m standing by to help.

For more information or questions, contact David W. Beugelmans.

David W. Beugelmans 
410-576-4104 • dbeugelmans@gfrlaw.com