Legal Bulletins

Maryland just took several steps to speed up clean energy deployment.

In Order No. 91984 (PC 73), released today, the MD PSC targets interconnection and permitting bottlenecks so solar and storage can reach COD in time to capture expiring federal incentives put at risk by the One Big Beautiful Bill Act.

Key takeaways for developers and investors:

• SOID and interconnection can now move in parallel (through 2027)
  Community solar projects no longer need a Subscriber Organization ID before applying for interconnection, which had been a significant development bottleneck. Developers can file both together, cutting months off early-stage timelines. SOID is still required to join the program, just not to finish studies.
   
• Utilities on the clock for interconnection performance
  The PSC is clearly frustrated with missed COMAR timelines and is demanding detailed filings on causes and fixes, especially for front-of-the-meter community solar. Interconnection delays are now framed as a compliance issue, not just customer service.
   
• Quarterly interconnection reporting through 2027
  Queue data moves from annual to quarterly, giving a clearer, near-real-time view of backlogs and setting the stage for more transparent, public-facing queue information.
   
• Parallel construction is explicitly encouraged
  Utilities are expected to allow developers to build project facilities while system upgrades are built, rather than forcing everything to be sequential. The PSC signals it may mandate parallel construction if progress lags.
   
• “Minor design changes” are now clearly treated as minor
  Many tweaks qualify as “minor equipment modifications” and shouldn’t trigger full restudies if they don’t materially affect safety or reliability (e.g., downsizing capacity, like-for-like replacements, or certain inverter swaps that don’t increase export). Developers gain flexibility to right-size or optimize without losing queue position.
   
• Flexible interconnection (limited export, storage controls) is not optional
  Utilities must actively offer and clearly advertise options like limited-export and net-export studies, which are critical for solar + storage projects trying to avoid costly upgrades by capping export.
   
• Working groups get marching orders on deeper reforms
  More complex issues, such as upgrade cost-sharing, invoicing timelines, Level 4 flexibility, and DG-CPCN implementation, are pushed to the interconnection, net metering, and DG-CPCN work groups, with a request for fast proposals, including possible emergency rules.

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

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