Last month the Commission directed Staff to initiate a rulemaking docket to evaluate proposed state energy modernization. The rulemaking docket has now been opened for the purpose of exploring possible modifications to the Commission's energy rules, including the following subject areas:

*Renewable Energy Standard and Tariff rules,
*Electric Energy Efficiency Standards miles,
*Gas Utility Energy Efficiency Standards rules,
*Net Metering rules,
*Resource Planning and Procurement mules,
*Retail Electric Competition rules,
*Electric vehicles,
*Interconnection of distributed generation facilities,
*Blockchain technology,
*Technological developments in generation and delivery of energy,
*Forest bioenergy,
*Baseload security,
*Statutory Biennial Transmission Assessment, and
*Other energy-related topics.

The full text of the Memorandum on Rulemaking Docket is available on the NEM Website.

The Staff leader of the Competitive Markets and Customer Choice Work Group announced that the first meeting of Phase III will take place on September 24, 2018, from 10AM-2PM in BGE's Smart Energy Hall Room C at the BGE headquarters at 110 W. Fayette Street in Baltimore. Conference call capabilities will be made available for those unable to attend in person. A meeting agenda is forthcoming. However, the Staff leader suggested the meeting will include a debrief after the previous Commission rulemaking session as well as discussion of the Workgroup's current tasks and timelines for moving forward.

Issues referred to the Phase III workgroup during the last rulemaking session include revisions to the Commission's website; certain non-residential consumer protections; a proposal to require suppliers to provide consumers (for which the supplier has an email address) with an email notice of rate change; treatment of supplier budget billing in the rules and the availability of customer look-up tools/wallet enrollment. With respect to the look-up tool/wallet enrollment issue, the Commissioners requested the workgroup include: a well-developed supplier proposal; a utility implementation cost estimate; information on how the measures impact suppliers ability to do business and serve more consumers; lessons learned from implementation in other jurisdictions; and a review of how existing consumer protections apply to its use. The Commission also tasked the workgroup with examining ways to provide data access to Curtailment Service Providers and Energy Consultants without making these entities Commission-jurisdictional. Experience and examples from other states are to be considered in this regard.

Culminating its extensive review of grid modernization issues, the Commission released a PowerForward Roadmap. The Roadmap sets forth a policy to support grid strength and reliability as well as an open platform to facilitate innovation and consumer value. The Roadmap suggests that the utilities, "should work towards developing a cyber-physical platform consisting of uniform core components, so that the foundation for customer engagement and market participation in providing innovative products and services is set in the state. The goal of a uniform platform is to enable a variety of market opportunities, regardless of service territory, and to create efficiencies that can be passed along to customers either through the proliferation of a more diverse set of retail market offerings or through cost savings associated with the different types of products and services." The platform should provide standardized access to customer energy usage data (CEUD) for retail providers and other third parties as well as deployment of advanced customer metering.

The Roadmap suggests that, in general, behind the meter products and services should be the province of the competitive marketplace. "Assigning the opportunity for behind the meter customer applications to competitive forces, whether CRES providers, third-party technology or other trusted customer advisors, is consistent with traditional behind the meter limitations on regulatory jurisdiction. These competitors could include EDU affiliates with appropriate corporate separation safeguards to eliminate the possibility of competitive advantage." However, the Roadmap says that utility involvement in behind the meter products may be permissible to advance social policy goals. "There should be two such social policy justifications that would allow an EDU to participate in providing behind the meter customer applications: (i) in circumstances where there is social inequity in the deployment of customer applications; and (ii) in circumstances where the application is deemed crucial to advance the state, but the marketplace has not developed to allow for that application to be deployed competitively to customers—a necessity and timing nexus must exist for this second justification. Further, the Commission would provide due consideration, in very limited circumstances, to a request by an EDU to deploy for residential customers only, a behind the meter application of minimal invasion and cost that is deemed essential for residential customers to realize the benefits of grid architecture investments."

The Roadmap endorsed the implementation of Standard Service Offer time-of-use rates that utilize advanced meter data. "TOU rates should be designed or modified to incent customers to reduce consumption during peak periods and to engage customers in making informed decisions about their energy usage, regardless of whether customers are shopping for their electric supply or on the SSO rate."

The Roadmap recognizes the importance of data access to facilitating retail offerings. It discusses the creation of a Data and the Modern Grid Workgroup (DWG) to address data access issues associated with grid modernization that would be tasked with:
• Creating a protocol for data privacy protections.
• Allowing customers to obtain real-time, or near real-time, access to CEUD through the connection of qualified home area network (HAN) devices to the customer’s smart meter.
• Prescribing a uniform methodology across the utilities for third parties to obtain CEUD.

The full text of the PowerForward Roadmap is available on the NEM Website.