Response and Recommendations to Maryland’s Climate Pathway Report
BALTIMORE, MD (July 5, 2023) – Maryland Climate Partners, a coalition of more than one hundred environmental, faith, consumer advocacy, and social justice organizations focused on ensuring equitable implementation of the Climate Solutions Now Act (CSNA), commends the Maryland Department of the Environment (MDE) on the recent release of its Maryland’s Climate Pathway report, produced in partnership with the University of Maryland Center for Global Sustainability.
The Pathway report shows that Maryland can achieve its ambitious climate goals and that doing so will bring health and economic benefit to Maryland.
The report, issued on June 30, outlines a path for the state to meet its emissions reductions targets of 60% by 2031 and net zero emissions by 2045 and proposes the basis for policies to meet the nation’s most ambitious short term climate goals.
Climate Partners members support the all-of-government and all-of-society approach reflected in the report and are committed to collaborating with MDE and other agencies and the historically disinvested communities throughout the state most harmed by environmental injustices to develop policies for the final plan that benefit all Marylanders.
After an initial review of the Pathway report, Maryland Climate Partners offer the following considerations. We also refer to our Preliminary Priorities we submitted to MDE during the public input process, which preceded the release of the Pathway report. We look forward to submitting additional policy measures and modeling measurements that address a full set of metrics in the state’s plan to ensure that it meets GHG targets in addition to equity and economic goals.
Environmental Justice & Equity
The Pathway report includes a narrative on and supplemental modeling of the health and environmental justice benefits of emissions reductions, which are vast and impactful.
We advise use of an equity lens when crafting final policies, to ensure options with even greater benefits for equity, health, and affordability are adopted. The health and environmental justice analyses included in the Pathway report are important elements and look at the impacts of the GHG emissions reductions themselves. Equity should also be in the initial considerations and framing for policy.
The Pathway report places a strong emphasis on mitigation of harm. MDE should ensure that the policies that it develops for its climate plan also take into account distribution of benefits.
As MDE formulates final policies in its plan to reach GHG emissions reductions, soliciting input from communities disproportionately affected by climate impacts, per the requirements in the Climate Solutions Now Act, will be essential to ensure a more equitable impact.
Clean Energy
The Pathway report includes a proposed 100% Clean Electricity Standard, which results in significant growth in clean energy and is a key policy for achieving the state’s goals.
Some of the assumptions built into the modeling need further examination and policy intervention to be realistically achievable. For example, full implementation of the Renewable Portfolio Standard would include 14.5% of Maryland’s electricity coming from solar energy, which the state is not currently positioned to meet.
The Pathway report estimates offshore wind will reach a capacity of 2.2 GW in 2035. With full implementation of the Promoting Offshore Wind Energy Resources (POWER) Act passed in 2023, we hope that number is higher. The POWER Act set a goal of 8.5 GW of offshore wind by 2035, and while not all of that may be operational by 2035, we anticipate it will be greater than 2.2 GW. MDE should consider the necessary policies we need to implement full deployment of OSW in the POWER Act.
The model that informs the Pathway report seems to include carbon capture and storage (CCS) technology in its definition of “clean energy.” We need clarification on this point and would not recommend that MDE move forward with CCS in its definition of clean energy.
Trash incineration
The model in the Pathway report predicts business as usual for trash incineration for energy.
The CSNA commits to focusing on environmental justice alongside climate reductions. Some of the recommendations in the Pathway report may seem "optimal" from a more economic standpoint but fail to account for critical environmental justice and health issues. Maryland must phase out trash incineration.
Building Electrification
The report provides important insight into the policies that need to be adopted to achieve substantial building emissions reductions and has proposed strong solutions to barriers, including investing in workforce development and increasing public awareness of financing resources.
Maryland should consider adopting clear building decarbonization goals with interim targets, including subgoals for how many residential and commercial buildings, as well as low- and moderate-income homes, need to be decarbonized to meet the state’s ambitious climate goals.
To achieve the building emissions reductions goals and ensure that low- and moderate-income Marylanders are not burdened with increasing long-term gas infrastructure costs, the state should create a gas transition strategy to ensure equity and affordability in the transition away from gas. As a first step, the state’s Public Service Commission should open a proceeding asking gas utilities to plan for a shift toward a highly electrified building sector.
Especially in homes, improvements to the energy efficiency, safety, and thermal regulation of the indoor environment offer important health and quality of life benefits that raise the necessity of this strategy. Reductions in energy burdens and improvements in home conditions are not highlighted by the models in the report but will greatly improve the lives of Maryland residents.
MDE should ensure the inclusion of a zero-emission appliance standard in its final recommendations.
Transportation
The report modeled critical transportation electrification policies, including the Advanced Clean Cars II, Advanced Clean Trucks, and Advanced Clean Fleets regulations. Additionally, the report included the scenario where 100% of all new bus sales are electric buses by 2025. MDE also acknowledges the vital role that reducing Vehicle Miles Traveled (VMT) plays in achieving the state’s climate targets. MDE cited policies that improve and expand public transit, biking, funding for complete streets, bike-share programs, e-bike rebates, mixed-use development, transit-oriented development, and parking reform among these strategies.
MDE should include the Heavy-Duty Omnibus regulation among its suite of vehicle electrification policies. While the report emphasized the importance of an equitable transition to electric vehicles it will be important to model more state policies that will make electric vehicles and infrastructure more accessible to communities of color, rural communities, low-wealth consumers, and people with disabilities.
The additional policies only yielded .67% VMT reductions between 2025 and 2030 and still resulted in annual average VMT growth of 1% between 2020 and 2030. MDE should set an explicit VMT target that reduces VMT 20% per capita below 2019 levels by 2030 and model policies that will help achieve this VMT reduction goal.Text here