Request for Comments RECA Generation Procurement Models Study (PC66)
December 11, 2025
I. BACKGROUND
During the 2025 Session of the Maryland General Assembly, the Public Utilities – Generating Stations–Generation and Siting Act (“Renewable Energy Certainty Act” or “RECA”) was passed. Among other matters, RECA requires the Public Service Commission of Maryland (“Commission”) to conduct a Generation Procurement Models Study (“Study”) to establish a process by which the Commission may establish power purchase agreements, partnerships between electric companies and electricity suppliers, or other procurement models for electricity generation projects (i.e., collectively referred to as “procurement models”).
The process established shall include a method for determining whether any of the procurement models specified will contribute to resource adequacy by increasing by 100 megawatts or more the electricity supply in the State that is accredited by PJM Interconnection, LLC (“PJM”).
Additionally, the process established requires that the Commission’s certificate of public convenience and necessity procedures, government agencies’ review processes, and electric companies’ processes be modified to connect the generation stations through expedited timelines.
Finally, on or before December 1, 2026, the Commission is required to report on the results of the Study to the Governor and the General Assembly in accordance with § 2-1257 of the State Government Article.
II. PROPOSED STUDY APPROACH
The proposed study approach includes a “multi-criteria decision analysis” to analyze and evaluate multiple options against a diverse set of criteria to provide a framework for incorporating various factors and stakeholder feedback. The proposed study’s approach also includes “least regrets planning” where options are considered and prioritized that would entail the least regret by projecting into the future and considering the consequences of each model on future Maryland resource adequacy and customer rates. The proposed study’s approach also envisions a stakeholder feedback collection process culminating in a Technical Conference convened by the Commission later in 2026.
Finally, the proposed study’s approach requires that, at a minimum, the following generation procurement models shall be evaluated against a “business as usual” (“BAU”) base case model which is defined as the current PJM Base Residual Auction (“BRA”) Model4 for securing generation without using any additional generation procurement models in Maryland:
- partnerships where an electric generation developer constructs a generating station for an electric company that becomes utility-owned, rate-based Generation;
- partnerships where electric companies enter into purchased power agreements (“PPAs”) for in-state generation with electricity suppliers;
- partnerships between electric companies and electricity suppliers such as, but not necessarily limited to, tolling agreements;
- a model where the Commission establishes generation capacity credits (“GCCs”)for generation solicited by the State of Maryland from generation developers using tolling agreements or other methods and requires that each electricity supplier purchase these credits in proportion to the electricity supplier’s capacity obligation; and
- any other promising industry generation procurement methods [.] that have merit.
The Commission is currently seeking technical consulting services to perform the Study in an RFP solicitation that is currently in progress.
III. REQUEST FOR COMMENTS
In order to meet the deadlines established by the General Assembly for the RECA Study, the Commission is requesting feedback now in advance of securing a consultant. The Commission requests comments regarding the use of generation procurement models and key procurement model design elements including qualification, bidding rules, selection criteria, and contract terms, among other factors that should be considered in this analysis or as an output of the study. Comments are also requested on the effectiveness of procurement models currently in use in other jurisdictions and if the types of generation potentially procured in Maryland through this process have specific technology factors that should be considered. Comments are also requested
regarding how participation in PJM capacity, energy and ancillary markets should be evaluated and credited for generation procured through this process.
Any party wishing to submit comments in response to this Notice shall e-file using the Commission’s e-File system by January 23, 2026. Comments should be addressed to Andrew S. Johnston, Executive Secretary, Maryland Public Service Commission, William Donald Schaefer Tower, St. Paul Street, 16th Floor, Baltimore, Maryland 21202, and reference “PC 66” in the subject line.
By Direction of the Commission,
Andrew S. Johnston
Executive Secretary