Maryland

In early July, the PSC approved utility tariffs reflecting a majority of new requirements for the permanent community solar program. Discussions around additional changes are continuing, including on how to treat projects that fall short of the 40% income-qualified subscription threshold, path to participation for master-metered facilities, and compensating subscriptions on time-of-use rates. In addition, each utility will have to add tariff language capturing the process for banking unsubscribed energy. Legislation from May required that utilities implement systems to do so by July 1, 2025, which was a quick turnaround given the complexity associated with banking credits in each month and continuously tracking the relevant deadlines for applying each batch against subscriber bills. Thus far, the utilities have offered different processes for tracking unsubscribed credits and varying timelines for eventually creating automated systems to do so.

Governor Moore signed the Renewable Energy Certainty Act into law on May 20, 2025, which included uniform siting standards to streamline solar development across the state. The legislation also updated the unsubscribed energy rules for community solar projects. Instead of immediately being compensated for unsubscribed energy at avoided cost, community solar projects will now be able to bank that energy and redistribute the credits to subscribers at any point within a year; if that energy rolls over for the full year, then it’s paid out at avoided cost. The utilities, solar companies, and PSC staff are working on implementation details already. The PSC also formally approved consolidated billing regulations on April 30 so we will see a new chapter in the Maryland Register later this summer.

In response to the November hearing on consolidated billing – where Solstice testified in support of streamlined net crediting – the PSC issued an order on February 10, 2025 confirming that Maryland’s program will mirror net crediting in New York. This is a huge win for community solar owners and subscribers. We will continue working with the utilities via the Net Metering Working Group to get draft regulations filed by March 31. At the legislature, we’re watching SB 931 which would enable year-long banking of unsubscribed credits and introduce the option for local governments to offer automatic enrollment on projects.

In December, permanent program regulations for phase 1 were published in the Maryland Register. The second phase – focused on billing – is still ongoing. At a PSC hearing in late November, Solstice testified in support of an efficient and reliable consolidated billing mechanism. The debate in Baltimore focused on two paths forward: the net crediting system established in New York versus the consolidated billing approach in Illinois. After several hours of discussion, the Commission came a long way in understanding the benefits of New York’s model and we expect to see a decision this month.

In late November, the PSC is set to hold a hearing that will inform the mechanics of net crediting in Maryland. Solstice will join a group of community solar representatives in Baltimore to advocate for a program that guarantees savings to all customers and creates predictable collections for project owners. The permanent program legislation required that utilities implement consolidated billing with “protocols for purchase of receivables or net crediting.” Despite the specificity in the statute – and an initial understanding that Maryland would mirror New York’s program – utility representatives have now spent months advocating for a billing and remittance model similar to the complicated system in Illinois.

As reported in our last newsletter, community solar companies and utilities in MD have reached an impasse in negotiations on how net crediting (consolidated billing) should be set up. As of late October, PSC Staff delivered a petition for guidance from the Commission, which outlines all the existing context and arguments. After reviewing the petition, the Commission will open up a two-week comment period and then make a decision on how net crediting in MD will work. Otherwise, the net metering working group continues to host discussions about other regulatory issues that need to be finalized, including development of the self-attestation form for streamlining income verification.