Legal Bulletins

In a recent public comment notice, the Maryland Public Service Commission kicked off a new effort under the Renewable Energy Certainty Act (RECA): a Generation Procurement Models Study focused on strengthening resource adequacy.

The Study will examine alternative procurement models for in-state generation, including utility-owned projects, power purchase agreements, utility–supplier partnerships (like tolling arrangements), and a potential generation capacity credit (GCC) framework. The goal is to add at least 100 MW of PJM-accredited capacity in Maryland, expedite project approvals and interconnections, and prioritize options with little or no impact on customer bills.

The Commission is now requesting stakeholder comments on key design elements (qualification, bidding rules, selection criteria, contract terms), how similar models perform in other jurisdictions, and how PJM capacity, energy, and ancillary market participation should be evaluated. Comments are due January 23, 2026 via the PSC’s e-file system, referencing “PC 66.”

If you work in generation development in Maryland or the PJM region, this is a meaningful opportunity to help shape the next generation of resource adequacy policy.

For more information or questions, contact David W. Beugelmans.

David W. Beugelmans 
410-576-4104 • dbeugelmans@gfrlaw.com