Implementation

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State law (Maryland Code, Environment Article, § 2-1205) requires MDE to develop plans, adopt regulations, and implement programs that reduce statewide GHG emissions to achieve the emissions reduction requirements of the state. MDE has broad authority to regulate air pollution, including GHG emissions, in Maryland. MDE and other agencies mentioned in this section will use existing statutory authority to implement the following regulatory and programmatic actions:

MDE

  1. Adopt a Zero-Emission Heating Equipment Standard - In 2024, MDE will initiate a rulemaking to propose a draft regulation by the end of 2024 and adopt a final regulation by the end of 2025. 

  2. Adopt a Clean Heat Standard - In 2024, MDE will initiate a rulemaking to propose a draft regulation by the end of 2024 and adopt a final regulation by the end of 2025.

  3. Modify the Regional Greenhouse Gas Initiative program - In 2024, MDE will work with the other RGGI states to establish a new regional cap. Maryland is currently advocating for the cap to be strengthened to be consistent with states’ 100% clean energy goals. MDE will also eliminate underutilized components of Maryland’s program under RGGI including offsets and the Limited Industrial Exemption Set Aside when it updates its CO2 Budget Trading Program regulation in 2024.

  4. Evaluate a Cap and Invest program - In 2024, MDE will explore how expanding Maryland’s current cap and invest program (RGGI) to cover additional sources could work. 

  5. ​Determine if Maryland should adopt the Advanced Clean Fleets regulation - In 2024, MDE will work with stakeholders and consultants to determine if adopting ACF would result in emissions reductions beyond those expected by Maryland’s adoption of the Advanced Clean Trucks regulation. 

MEA

  1. Determine a legal framework for a Clean Power Standard - In 2024, MEA will finalize a conceptual framework for the Clean Power Standard and determine if all or part of a CPS can be implemented through existing authority. 

  2. Determine if additional state action is needed to accelerate solar power deployment - In 2024, MEA will take the outcomes of the Task Force to Study Solar Incentives and take steps to overcome barriers to solar power deployment in Maryland. 

  3. Launch a consumer education campaign - With new funding or its regular budget, MEA will launch a public information campaign to promote consumer rebates and tax credits funded by federal and state investments.

  4. Expand the Climate Transition and Clean Energy Hub - With new funding, MEA will expand its capacity to provide technical support on building decarbonization projects to building owners.

  5. Provide new EVSE incentives - Once new funding is secured, MEA will begin providing point-of-sale rebates for purchasing EV supply equipment (EVSE) as described in this plan.

  6. Provide new building decarbonization incentives - Once new funding is secured, MEA will begin providing point-of-sale rebates for energy efficiency and electrification projects and distribute funding to MCEC to scale up green bank lending. 

  7. Provide new industrial, public infrastructure, and nature-based solutions incentives - Once new funding is secured, MEA will utilize and distribute funds to MDE, MCEC, DNR, MDA, and local governments for a wide range of emission reduction and sequestration projects in Maryland’s industrial, waste, agricultural, and forestry & land use sectors. 

MDOT

  1. Implement the ZEV Infrastructure Plan - In 2024, MDOT in consultation with partner agencies will implement round 1 of the NEVI Program to deploy charging along Maryland’s 23 EV Alternative Fuel Corridors.

  2. Implement the Maryland Transportation Plan - In 2024, MDOT will begin implementing the updated Maryland Transportation Plan including making investments in new infrastructure projects and programs that will reduce vehicle miles traveled and enhance transportation choices in the state.

  3. Provide new EV incentives - Once new funding is secured, MVA  will begin providing point-of-sale rebates for purchasing EVs as described in this plan.

PSC

  1. ​Initiate a gas system planning proceeding - In 2024, the PSC should initiate a proceeding to require natural gas utility companies to develop plans to achieve a structured transition to a net-zero emissions economy in Maryland.

Labor

  1. Expand workforce development programs - Building on existing programs, significant federal investments, such as the $23 million Good Jobs Challenge Grant for Maryland Works for Wind, and with additional new funding, the Department of Labor will expand investments in apprenticeship and workforce development programs for electricians, heat pump installers, and other jobs needed for the clean energy transition. 

DSCI

  1. Expand service-to-career pathways – Growth of the Maryland Climate Corps efforts through the Department of Service and Civic Innovation will increase the number of individuals who are exposed and prepared for green jobs of the future. 

All Agencies

  1. Apply for federal funding - Under the leadership and coordination of the Governor’s Federal Office, all agencies will apply for federal funding to implement actions that support the achievement of this plan. State agencies will work closely with local governments, nonprofits, and community-based organizations to ensure Maryland is competitive for federal climate action implementation funds and to build capacity for local-level implementation. State agencies will offer support to Maryland’s businesses and private sector to ensure they are competitive for historic federal investments.    

Legislative Actions

Fully implementing this plan will require action by the Maryland General Assembly. Maryland is fortunate to have policy experts in the legislature who are skilled at developing targeted legislation to address the complexity of the clean energy transition. Recommended legislative actions include:

  1. Develop New Funding Sources - In consultation with MDE, pass legislation to implement one or more of the new funding sources described in the funding section of the plan (see navigation bar).​

  2. Modify the Renewable Portfolio Standard - In consultation with MDE and MEA, pass legislation to modify the definitions of qualifying resources in the RPS to align with definitions of clean power resources under the forthcoming Clean Power Standard.

  3. Require new multifamily buildings to be EV-ready - In consultation with MEA, pass legislation requiring that the state’s EV-ready standards for new buildings be extended to include multifamily buildings. 

  4. Modify EmPOWER - In consultation with PSC, pass legislation establishing GHG reduction goals for electric and gas utility companies and require the utilities’ programs to facilitate beneficial electrification of fossil fuel heating equipment. 

  5. Modify the state’s ability to regulate GHG emissions from the manufacturing sector - In consultation with MDE, pass legislation that relaxes an existing prohibition on the state to require GHG emissions reductions from the state’s manufacturing sector. A recommendation to this effect is included in the 2023 Annual Report of the Maryland Commission on Climate Change. 

  6. Modify the state’s EV purchasing incentives - In consultation with MDE, MEA, and MVA, pass legislation that creates point-of-sale rebates for purchasing new and used EVs including base rebates available to most car buyers, bonus rebates for low and moderate income and high-mileage drivers, and authorize funding to provide technical assistance grants to owners of small fleets as described in this plan. ​​

Climate Pathway Stakeholder Input

Engaging stakeholders remains a priority throughout the development and implementation of Maryland's climate action plans. MDE actively sought robust public input to help shape Maryland's Climate Pollution Reduction Plan over an extensive six-month outreach period in 2023. Interested parties provided feedback through multiple channels, including online comment forms, letters, phone calls, and direct conversations with MDE staff at public events. The Maryland Commission on Climate Change was instrumental in providing input from its working groups, building on its long-standing engagement in previous emissions reduction efforts.

Between July and September 2023, MDE and UMD hosted a series of statewide public stakeholder meetings to present the Maryland’s Climate Pathway report and gather feedback. These sessions took place at Bowie State University, Hagerstown Community College, Salisbury University, Morgan State University, and the College of Southern Maryland. The team hosted two virtual sessions as well to maximize access for busy Marylanders who could not attend an in-person session.

Finally, MDE compiled all the feedback received through this extensive outreach into an outreach results webpage. Thousands of Marylanders provided comments at the outreach sessions or submitted written comments. Opportunities for public and organizational input will continue as legislation is introduced to implement the plan, as well as through the regulatory hearing processes. 

Executive Action Stakeholder Input

MDE's regulatory function occurs through a coordinated effort with the public and private sectors. The review process helps to ensure participation from stakeholders, other agencies, the general public, and other entities affected by regulations. Draft air regulations are also brought before the Air Quality Control Advisory Council for advice and recommendations.

Proposed regulations are published in the Maryland Register. Each listing describes how and when to submit comments and provides additional information including budget impacts on agencies, industries, and small businesses. Proposed regulations are subject to a public hearing after publication in the Register. Formal adoption of new regulations occurs only after a hearing is held and necessary changes are made. 

Legislative Action Stakeholder Input

As part of the legislative process, standing committees meet during the legislative session to receive testimony and take action on bills that are referred to the committee. Bill sponsors and citizens supporting or opposing the proposed legislation have an opportunity to provide input on a bill through oral and/or written testimony. Marylanders are encouraged to discuss policy matters with their elected representatives. 

CPRG: From Planning to Implementation 

While Maryland passed the CSNA in 2022, the federal government’s passage of the BIL in 2021 and the IRA in the same year provides a once-in-a-lifetime opportunity for Maryland to leverage the federal government’s funding and programs to spur state action. One such program is EPA’s Climate Pollution Reduction Grant (CPRG). MDE is the lead agency for Maryland’s CPRG Planning Grant and is working in close coordination with the Metropolitan Statistical Areas (MSA) within the state and the counties not covered by a CPRG MSA Planning Grant (Figure 16).

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Figure 16: Maryland CPRG Planning Areas.

Under the CPRG for Planning, MDE will expand its GHG emission reduction planning activities and deliverables to publish the following plans and reports required by EPA.

Maryland’
s Priority Climate Action Plan


A Priority Climate Action Plan (PCAP), due March 1, 2024, aims to identify near-term, high-priority, and implementation-ready measures to reduce climate pollution. The PCAP will prepare Maryland’s eligible entities to compete in the transformative federal funding from the BIL of 2021 and IRA of 2022, including the $4.6 billion EPA CPRG competition.

Maryland’s Comprehensive Climate Action Plan

A Comprehensive Climate Action Plan (CCAP) is due two years after the award of the planning grant. This plan will focus on all significant GHG sources/sinks and sectors present in Maryland and establish near-term and long-term emission reduction goals. Measures and strategies will be identified to achieve those goals, including recent changes in technologies and market forces, potential leveraging of other funding opportunities (e.g., under the IRA of 2022, BIL of 2021, or other sources), new program areas and opportunities for regional collaboration, or inclusion of analyses to estimate benefits including those flowing to low income and disadvantaged communities. The plan as a whole is required to include:

  • Maryland’s GHG inventory;

  • GHG emissions projections;

  • GHG reduction targets;

  • Quantified GHG reduction measures;

  • A benefits analysis for the full geographic scope and population of Maryland;

  • A low-income and disadvantaged communities benefit analysis;

  • A review of authority to implement;

  • A plan to leverage other federal funding; and

  • A workforce planning analysis.

Maryland’s Status Report

A status report is due at the end of the four-year planning grant period in the summer to fall of 2027. This report will include the implementation status of the quantified GHG reduction measures included in Maryland’s CCAP, along with any relevant updated analyses or projections supporting implementation and next steps and future budget/staffing needs to continue that implementation. MDE will deliver a series of GHG emission reduction plans and inventories with an increasing emphasis on implementation planning and tracking.

CPRG Stakeholder Engagement

MDE is committed to providing inclusive, accessible, and transparent public and stakeholder engagement processes to inform the development of upcoming CPRG plans and competitive implementation grants that may develop from these plans. MDE will lead three concurrent stakeholder engagement processes in the development of the PCAP, CCAP, and status report:

  1. Ongoing public and stakeholder engagement through existing climate-action and environmental justice commissions, task forces, and working groups with over 250 cross-sectoral members, with most groups meeting either monthly or quarterly. To ensure representatives of low-income and disadvantaged communities that may be affected by or benefit from plan development are included in the process, Maryland’s CPRG for Planning will align directly with best practices for engagement offered by MDE’s new Office of Environmental Justice and the Maryland Commission of Environmental Justice and Sustainable Communities (CEJSC). Ongoing monthly and quarterly meetings of these advisory groups are open to the public and materials from these meetings are available on the MDE website. 

  2. Public outreach to compile near-term, high-priority, implementation-ready projects from covered agencies, jurisdictions, and stakeholders to include in the PCAP. This process will include leveraging existing plans, or for counties without their own plans, MDE is leading the Maryland CPRG Local Support Program to facilitate the process of identifying qualifying projects. MDE launched a webpage for this effort which will include details, webinar links and recordings, and a comment submission form. 

  3. Environmental Justice Listening Sessions led by the MDE Secretary, MDE EJ Office Director, and MDE Secretary’s EJ Advisory Council. MDE is conducting listening sessions in communities with EJ concerns. MDE has and will continue to identify top communities with EJ concerns and will use the MDE EJ Screening Tool to develop a report on the key permitted facilities in the area, identify the communities' socioeconomic demographics, and review existing community feedback and concerns about permitted facilities. MDE will schedule and conduct listening sessions with citizens in the community to identify and discuss concerns and opportunities and key actions MDE and other state agencies can undertake to address inequities and ensure direct benefits to communities. Direct citizen feedback from these sessions will help to identify priorities for Maryland’s PCAP and inform methods for how to assess community benefits.

The CPRG for Planning will deliver the following benefits by driving climate pollution reduction planning into implementation and action: 

  • Tackle damaging climate pollution - while supporting the creation of good jobs and lowering energy costs for families.

  • Accelerate work to address environmental injustice - and empower community-driven solutions in overburdened neighborhoods. 

  • Deliver cleaner air - by reducing harmful air pollution in places where people live, work, play, and go to school. 

  • ​Ensure Maryland is competitive for federal implementation funds - from the BIL of 2021 and IRA of 2022. 

  • Drive successful local-level implementation - for high-priority GHG emission reduction programs and projects. 

Progress Tracking and Reporting

MDE bears an enormous responsibility to Maryland’s citizens following the publication of this plan to ensure that the state’s GHG reduction goals are fully achieved. Implementation and tracking of the policies and initiatives contained within will require both monitoring and annual reporting on status and success. Facilitated through such analyses, MDE will adopt a final plan that achieves net-zero statewide GHG emissions by 2045 on or before December 31, 2030. MDE will continue to analyze the success of these policies and initiatives through review and revision of the final plan on or before December 31, 2035.

Coordination among Maryland’s state agencies is essential to ensure proper implementation and function of the plan. State agencies, many of which have a prominent role in the implementation of the policies and initiatives in this plan, are required to report annually on the status of programs that support the state’s GHG reduction efforts or address climate change to the Maryland Commission on Climate Change. The law requires annual reports from the following Maryland state agencies:

  • The Department of the Environment

  • The Department of Agriculture

  • The Department of General Services

  • The Department of Housing and Community Development

  • The Department of Natural Resources

  • The Department of Planning

  • The Department of Transportation

  • The Maryland Energy Administration

  • The Maryland Insurance Administration

  • The Public Service Commission

  • The University of Maryland Center for Environmental Science

These annual reports must include program descriptions and objectives; implementation milestones and whether or not they have been met; enhancement opportunities; funding; challenges; estimated GHG reductions by program for the prior calendar year; and any other information that the agency considers relevant. Additionally, when reviewing planning, regulatory, and fiscal programs, each agency is required to identify and recommend actions to more fully integrate the consideration of Maryland’s GHG reduction goal and the impacts of climate change. Such considerations include sea level rise, storm surges and flooding, increased precipitation and temperature, and extreme weather events. Specific policies, planning, regulatory, and fiscal changes to existing programs that do not currently support Maryland’s GHG reduction efforts or address climate change must also be accounted for. 

In conjunction with the aforementioned annual report, MDE is required to include in the Maryland Commission on Climate Change’s Annual Report the status of the state’s efforts to mitigate the causes of, prepare for, and adapt to the consequences of climate change, including future plans and recommendations for legislation to be considered by the General Assembly as well as an accounting of state money spent on measures to reduce GHGs and co-pollutants and the percentage of funding that benefited disproportionately affected communities. 

If it becomes clear that Maryland could fall short of achieving an implementation milestone, such as the number of EVs registered, heat pumps installed, or homes weatherized, the GHG impact will be evaluated to help determine if other actions must be scaled up to make up for any shortfall to achieve an equivalent amount of GHG emissions reductions.