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PSC work group recommends TRACE method for GHG goals; DHCD and stakeholders clash over target interpretation
Summary
Staff and utilities proposed converting statutory MWh targets into lifecycle GHG goals using a TRACE methodology and agreed to statutory minimums for 2027–2029; advocates urged a longer‑lived measure adjustment to favor durable measures, and DHCD said its statute requires a trajectory interpretation rather than an annual fixed target, prompting requests for more analysis.
Staff presented the future programming work group's recommendation to translate previously expressed megawatt‑hour goals into lifecycle greenhouse‑gas reduction goals using a TRACE methodology that combines baseline savings, estimated useful life (EUL) of measures and marginal emissions intensity.
The work group reached consensus on using statutory minimums for the 2027–2029 cycle given current high energy costs to ratepayers, but could not agree on a longer‑lived measure adjustment. Advocates and some consumer advocates urged the Commission to apply an adjustment to increase weight for longer‑lived measures — such as electrification and deep retrofit measures — arguing this better aligns program incentives with climate goals. "We propose a longer lived measure adjustment ... to encourage longer‑lived savings and more profound GHG reduction methods," said Jim Gravatt (Maryland Energy Efficiency Advocates).
Utilities and staff cautioned that an ad‑hoc EUL adjustment would raise program costs and administrative complexity and that the proposed goal framework already reflects a materially higher portfolio EUL than prior cycles. BGE and PHI asked the Commission to issue a framework order before Jan. 1, 2026 (with PIM and evaluation baselines finalized by Feb. 1) so utilities could plan portfolios for the next cycle without mid‑cycle uncertainty.
A distinct but related disagreement concerned Department of Housing and Community Development (DHCD) goals. DHCD representatives said statutory language imposes a trajectory requirement, not an annual mandated target; advocates and OPC countered that the statute, read with related provisions and legislative history, should be interpreted to require an annual trajectory to achieve 0.9% GHG reductions after 2027. DHCD requested the opportunity to file a short written response to recent filings and stressed resource implications if a differing interpretation were adopted.
The Commission asked parties to submit additional analyses (cost, rate impact, and interpretation briefs) and signaled it will weigh ratepayer impacts alongside environmental objectives when setting final goals and assumptions for program planning.
