Kimberly A.

Curry
Senior Counsel

2 Center Plaza 110 W. Fayette Street Baltimore, Maryland 21201 410.470.1305 443.213.3206 Fax kimberly.a.curry@constellation.com

Via Electronic Filing April 27, 2012

David J. Collins, Executive Secretary Public Service Commission of Maryland William Donald Schaefer Tower 6 St. Paul Street, 16th Floor Baltimore, MD 21202 Re: Case No. 9208 Application of Baltimore Gas and Electric Company for Authorization to Deploy a Smart Grid Initiative and to Establish a Surcharge Mechanism for the Recovery of Cost Reply Comments of Baltimore Gas and Electric Company Dear Mr. Collins: Baltimore Gas and Electric Company (BGE) submits these reply comments to respond to the comments of Washington Gas Energy Services (WGES) regarding supplier access to demand response control functions and to clarify one statement reflected in the April 6, 2012 Comments of the Maryland Energy Administration (MEA) as it relates to BGEs smart grid initiative. In its comments, WGES restates the provision from Order No. 81637 that suppliers are to be given access to demand control functions that is equivalent to the electric companys own access to those functions. WGES Comments at 4, citing Order No. 81637. As BGE noted in this proceeding, it has significant concerns from a security standpoint regarding this provision, and believes that further guidance is needed as to how or whether this can be implemented. As stated in the Testimony of Michael Butts in Case No. 9208, giving third party suppliers control of BGE assets would introduce security risks. Effective cyber-security requires the application of encryption, authentication and key management services throughout the entire cyber-chain from the computer system that issues commands, through the communications network, to the intelligent endpoint device. By giving third party suppliers access to BGE physical assets, BGE would necessarily need to rely upon the security standards applied by the third party suppliers. Given that these cyber-systems are beyond BGEs control, BGE could not guarantee the security of these systems and, by extension, the security of the grid.

David J. Collins, Executive Secretary April 27, 2012 Page 2 That testimony further stated that independent third party control of demand response and load curtailment services could cause significant concerns for grid operators. Grid operators routinely monitor the loading of circuits and take mitigating actions if the loads reach engineering limits. If a third party supplier were able to turn-on and turn-off load without BGE authority and/or control, these operations could result in overloaded circuits and potential system outages. In MEAs comments, after acknowledging its concerns with offering an opt-out option, MEA noted that, if the Commission were to determine that opting-out was in the public interest, the Commission should consider approving the installation of an advanced meter with the wireless technology disengaged. See MEA Comments at 11. MEA further stated that a transmitter-off meter will enable a customer to view daily energy usage on an hourly basis and that the customer may participate in future dynamic pricing options and alternatives. This statement would not be true for BGEs smart grid project. For BGE, a transmitter-off meter would not have this capability; only customers with wireless-enabled meters will be able to retrieve interval data. Respectfully submitted, /s/ Kimberly A. Curry Kimberly A. Curry Enclosures KAC:jdb cc: Case No. 9208 Service List