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PSC Preliminary Report Released Evaluating Alternative Generation Procurement Models
Comments Sought and Technical Conferences Scheduled
The Power Advisory LLC, filed the preliminary report for the Renewable Energy Certainty Act Generation Procurement Models Study (“Preliminary Report”). The Preliminary Report is submitted for stakeholder review and discussion in advance of the technical conference to be convened by the Maryland Public Service Commission.
In response to the preliminary report, the Maryland PSC on August 17th issued a notice for comments to be filed by Thursday, September 17, 2026. The Commission’s notice also announced technical conferences are scheduled as follows:
Tuesday, September 29, 2026, beginning at 10:00 a.m.;
Wednesday, September 30, 2026, beginning 10 minutes after the conclusion of the Administrative Meeting; and, if needed,
Thursday, October 1, 2026, beginning at 10:00 a.m
As background, the Renewable Energy Certainty Act (“RECA”) requires the Commission to study the advantages and disadvantages of alternative generation procurement models that could help Maryland achieve its resource adequacy objectives. The study establishes a methodology for determining whether the specified procurement models could increase accredited generation capacity in the State by at least 100 MW under PJM’s accreditation framework. The Commission retained Power Advisory to conduct the study and provide related consulting support.
From the Preliminary Report’s Executive Summary:
Background – This report presents Power Advisory’s proposed methodology and assumptions for evaluating alternative generation procurement models for Maryland, in response to the Public Service Commission’s request for an assessment of procurement approaches that supports the policy objectives of (1) Resource Adequacy, (2) Affordability, and (3) Speed to Market , while accounting for the evolving dynamics of the PJM wholesale electricity market.
Methodology – This study employs Multi -Criteria Decision Analysis (MCDA) to compare procurement models across a set of evaluation criteria: ( i) cost and rate impacts, (ii) risk and uncertainty, (iii) implementation, and (iv) efficacy , with weights adjusted to reflect different policy objectives. A Technology Mapping combines the MCDA results with technology -specific characteristics to identify procurement models best suited to bringing a specific technology to market. Finally, the Least Regrets Analysis tests the robustness of each model across policy objectives to identify approaches that limit downside risk as priorities and market conditions change.
Findings – The study finds that PPAs, Competitive Dialogue, and Index RECs (all sourced through competitive procurement processes) are the strongest and most robust procurement models across policy objectives, while technology -specific characteristics may support alternative models – e.g., Partial Tolling for dispatchable resources such as BESS and conventional gas.
Caveats – This report provides a high -level comparative assessment of procurement models and relies on qualitative judgement rather than detailed financing modeling. The focus is on evaluating procurement models, not generation technologies, and therefore does not attempt to identify the lowest cost generation technology. Project -specific implementation issues, such as interconnection feasibility, are outside the scope of this study as they depend on how a procurement is implemented, rather than the procurement model itself.
Procurement Model Performance: MCDA Summary
Affordability – Index REC, PPA, and Competitive Dialogue perform the best in terms of promoting affordability. This stems from the strong competitive tension from the competitive procurement process used to award PPAs and in Index REC processes.
PPA also benefits from the extensive experience with such processes, which reduces the perceived risks and associated risk premia embedded in the pricing offered by bidders. However, with a PPA, the buyer must be identified. A similar arrangement as employed for the transmission – connected energy storage procurement could be used, with an escrow administrator appointed. Additionally, a PPA will require that the buyer have significant financial capability as sellers will be concerned with the buyer’s creditworthiness.
An alternative is the Index REC . However, the Index REC will require the development of an administrative framework to administer contract settlement and payment, with an equivalent level of administrative effort.
Speed to Market – PPA , Index REC , and BRA perform best in terms of speed to market. o BRA is already being implemented with annual schedules for auctions and requires no additional administrative effort to implement. One caution with respect to BRA is its low efficacy score. Even though we allocated a 15% weight to efficacy for the speed to market objective, BRA’s favorable performance vis -à-vis other criteria outweighed the low efficacy score.
PPA and Index REC perform well based on relatively high scores across the majority of evaluation criterion.
Least Regrets Analysis – The least regrets analysis reinforces the MCDA results: PPA, Index REC , and Competitive Dialogue provide the most robust performance across policy objectives and the lowest downside exposure as priorities change. However, least regrets performance e does not imply that a single model should be applied to all technologies. Technology -specific characteristics may support a more specialized approach, such as Partial Tolls for dispatchable resources, where those structures better align with the particular procurement need.
