Alliance Comments to Maryland Public Service Commission Ask for Clarity in Proposed Regulation Affecting Small CHP and WHP Systems

The Alliance submitted comments to the Maryland Public Service Commission requesting clarity on a recently proposed regulation that would affect “small” (<2 MW) CHP systems. Historically, in Maryland, utilities have not been required (nor allowed) to monitor and control these smaller units. The proposed rule would now allow such monitoring, unless certain circumstances are met. Our comments seek to clarify the scope of the changes by asking a series of questions about clarifying terms and seeking more background information regarding this change. Ultimately, we recommend that the final regulation follow two principles: (1) That any new monitoring of CHP systems would come at no additional cost to the CHP site itself, but would be handled on the utility side; and (2) that any control of the CHP system would be done only in emergency situations unless a control plan was developed and approved by the site. Ensuring these two principles are met will prevent new barriers from being introduced as a result of the regulation changes.