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MEA Files Comments On Renewable Energy Certainty Act Generation Procurement Models Study
The Maryland Energy Administration (“MEA”) files comments responding to the Maryland Public Service Commission’s (PSC’s) notice requesting comments on the Renewable Energy Certainty Act (“RECA”) Generation Procurement Models Study that was issued by the Commission on December 11, 2025.
MEA Comments state that “RECA appropriately recognizes that Maryland faces resource adequacy risk, while simultaneously requiring that any State action minimize customer rate impacts. This risk to the electric system’s ability to meet peak demand is driven by a mix of load growth, generator retirements, wholesale market volatility, and transmission constraints.”
Regarding Principles for Procurement Models MEA further states, [***] “MEA believes that the Commission should consistently apply the following principles discussed below across all procurement models evaluated in the Study.”
“Procurement models should demonstrably result in new capacity that would not otherwise be developed under the PJM capacity market, officially known as the Reliability Pricing Model (“RPM”). Models that merely shift ownership or contract structure without increasing net accredited capacity should not be credited toward RECA objectives.
In addition, the Study should evaluate how risks are allocated among all stakeholders, including developers, utilities, suppliers, and customers. Customer protection should be given priority, and procurement models should not socialize risks.
Further, all models should be assessed using a consistent rate-impact framework that includes sensitivity analyses for PJM capacity prices, fuel costs, and load growth uncertainty. It is important that the Maryland procurement model be compatible with PJM market constructs.
Models that distort PJM price signals or expose Maryland customers to double-payment risks should be avoided.” [***]
Previously on January 17, 2026 the joint utilities’ -Pepco, DPL and BG&E- filed an additional response to the request for comments structured as answers to questions posed in the Commission’s technical conference held on December 3, 2024.
In responding to the Commission’s question about
- “What Can The Commission Do To Encourage New Baseload Generation And What Should The Commission Do To Avoid Discouraging New Baseload Generation?”
The joint utilities’ responded, “[t]he Commission can encourage and not discourage baseload generation by creating a constructive regulatory environment with sufficient certainty for these types of investments. Building a power plant is a significant investment, made over time and with a long lifecycle. To make such a significant long-term investment, the baseload generation developers will need the security of knowing that the regulatory rules under which they are building the baseload generation will not change in a way that negatively impacts that investment. For example, for unregulated generation and regulated generation alike, any CPCN approval and the regulatory conditions under which that approval was given should not change. Regulatory certainty is even more critical for regulated generation as discussed below.”
Q: What Is the Joint Exelon Utilities’ Position on Regulated Generation?
“It is crucial that a utility is able to recover prudently incurred costs related to acquiring, constructing, owning, and operating regulated generation through rates in a manner that does not negatively impact its credit standing.”
“Regulated in-state generation can provide value in complementing new transmission investment to enable further delivery of generation supply from surrounding states, and supplementing the generation that serves Maryland through wholesale markets. Regulated generation would give Maryland greater control and assurances over the types of generation resources that serve our customers, including fuel source, location, capacity, planned life span, operational use, and many other elements.”
- “If the Commission Allowed Regulated Generation, Would That Discourage Market Solutions?”
The Joint utilities responded, “Commission support for regulated generation will not discourage market solutions, as history demonstrates. While PJM runs a capacity market and has done so since the mid-2000s, significant quantities of regulated generation have always existed in the PJM footprint. Amounting to more than 40 GW, or approximately a quarter of capacity in the region, this regulated generation is owned by vertically integrated and municipal utilities. This reality has not discouraged an enormous amount of generation development during the period in which the capacity market has been in place—which exceeds 50 GW of dispatchable resources and more than 70 GW of total generation58—not to mention the huge quantities of generating capability currently in the queue. While not all of this generation was developed on a purely merchant basis, the amount developed dispels the idea that the presence of regulated development stymies market solutions.”
Read all comments at docket link below.
PC66 (10/10/2024)
(Resource Adequacy)
