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1 Kimberly A. Curry Assistant General Counsel BGE Legal Department 2 Center Plaza, 12 th Floor 110 West Fayette Street Baltimore, MD Telephone Fax kimberly.a.curry@bge.com Via Electronic Filing September 1, 2016 David J. Collins, Executive Secretary Public Service Commission of Maryland William Donald Schaefer Tower 6 St. Paul Street, 16 th Floor Baltimore, Maryland Re: Rulemaking 56 COMAR 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 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 (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

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3 Compliance Plan of Baltimore Gas and Electric Company 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 Pursuant to the Code of Maryland Regulations (COMAR) Section A, 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 ) Section A of COMAR 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 ) 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.

4 Compliance Plan of Baltimore Gas and Electric Company September 1, 2016 Rulemaking 56 Page 2 BGE will, in accordance with COMAR B, 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 ) 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 ) 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 (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

5 Compliance Plan of Baltimore Gas and Electric Company September 1, 2016 Rulemaking 56 Page 3 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 E). 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 ) 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 ) 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 , because BGE s net metering aggregation program has been a permanent program since March 2014.

6 Compliance Plan of Baltimore Gas and Electric Company September 1, 2016 Rulemaking 56 Page 4 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, 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

7 Compliance Plan of Baltimore Gas and Electric Company September 1, 2016 Rulemaking 56 Page 5 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 ) 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 ) See Section II below for BGE s proposed cost recovery mechanisms. Pilot Project Application Process (COMAR ) and Pilot Program Queue (COMAR ) 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 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 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.

8 Compliance Plan of Baltimore Gas and Electric Company September 1, 2016 Rulemaking 56 Page 6 BGE will maintain on its website daily updated information about the current status of its pilot program in accordance with COMAR D. 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.

9 ATTACHMENT 1

10 112 Electric Retail - Baltimore Gas and Electric Company 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 In addition to the requirements set herein, all participants in this rider are subject to the regulations as stated in Code of Maryland Regulations 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. P.S.C. Md. E-6 (Suppl 587) Filed 09/01/16 Effective 10/13/16

11 Electric Retail Baltimore Gas and Electric Company 113 (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 , 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. (Continued on Next Page) P.S.C. Md. E-6 (Suppl.587) Filed 09/01/16 Effective 10/13/16

12 114 Electric Retail - Baltimore Gas and Electric Company 32. Community Energy Pilot Program - continued 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 A(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 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 (Continued on Next Page) P.S.C. Md. E-6 (Suppl 587) Filed 09/01/16 Effective 10/13/16

13 Electric Retail Baltimore Gas and Electric Company Community Energy Pilot Program - continued 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. P.S.C. Md. E-6 (Suppl.587) Filed 09/01/16 Effective 10/13/16

14 112 Electric Retail - Baltimore Gas and Electric Company 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 In addition to the requirements set herein, all participants in this rider are subject to the regulations as stated in Code of Maryland Regulations 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. P.S.C. Md. E-6 (Suppl 587) Filed 09/01/16 Effective 10/13/16

15 Electric Retail Baltimore Gas and Electric Company 113 (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 , 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. (Continued on Next Page) P.S.C. Md. E-6 (Suppl.587) Filed 09/01/16 Effective 10/13/16

16 114 Electric Retail - Baltimore Gas and Electric Company 32. Community Energy Pilot Program - continued 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 A(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 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 (Continued on Next Page) P.S.C. Md. E-6 (Suppl 587) Filed 09/01/16 Effective 10/13/16

17 Electric Retail Baltimore Gas and Electric Company Community Energy Pilot Program - continued 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. P.S.C. Md. E-6 (Suppl.587) Filed 09/01/16 Effective 10/13/16

18 ATTACHMENT 2

19 TABLE OF CONTENTS 1.0: DEFINITIONS/EXPLANATION OF ABBREVIATIONS : GENERAL TERMS AND CONDITIONS Scope and Purpose Electricity Supplier s Responsibilities to Customers Tariff to Govern Recourse to the Commission FERC Jurisdiction Electricity Supplier Obligations Electricity Supplier and Company Obligations Control Area Services and Obligations Communications and Data Exchange Record Retention Customer Lists Net Energy Metering Community Energy Pilot Program : UTILIZATION OF SCHEDULING COORDINATORS Participation through a Scheduling Coordinator Designation of a Scheduling Coordinator Change of Scheduling Coordinator Load Scheduling through a Scheduling Coordinator Primary Obligations of Electricity Supplier : COMMENCEMENT AND TERMINATION OF COORDINATION SERVICES Application Process to Company Commencement of Coordination Services Notice of Electricity Supplier Discontinuance to the Company Termination of Coordination Services Effect of Termination Survival of Obligations : CREDITWORTHINESS Purpose and Intent Finding of Creditworthiness Credit Amount Change in Financial Status No Endorsement of Electricity Supplier : NONCOMPLIANCE AND DEFAULT Definition of Noncompliance Events of Noncompliance Supplier Default Cure and Default P.S.C. Md. E-6 (Suppl ) Filed 02/27/12 09/01/16 Effective 04/01/1210/13/16

20 Baltimore Gas and Electric Company Electric Supplier 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 of this Tariff. The total amount of the payment will be provided to the eligible host account 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 ) Filed 02/27/12 09/01/16 Effective 04/01/1210/13/16

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