Harsh Realities Confront Maryland and Its Bold Climate Plans

Maryland state agencies have rolled out a suite of ambitious climate action plans for 2025, aiming to slash emissions and propel the state toward a clean energy future. But the road ahead is riddled with financial uncertainties and operational ambiguities.

Gov. Wes Moore signed an executive order last June that required state agencies to submit their climate action plans by Nov. 1 and also created a subcabinet on climate, led by Serena McIlwain, secretary of the Maryland Department of Environment (MDE). As chair of the subcabinet, McIlwain will report annually to Moore on Maryland’s progress on its climate targets and implementation of agencies’ plans.

Last month, MDE unveiled climate action plans prepared by 25 state agencies, outlining more than 100 priority actions to lower emissions, pave the way to a fossil free economy and do so equitably, reflecting Moore’s “whole-of-government” approach to climate action. 

“We don’t have to choose between a green economy and a growing economy—we can, and we must, build both at the same time,” Moore said at the unveiling of the plans last month. 

McIlwain said the plans were an “unprecedented effort to focus on climate change as one government.” 

Taken together, the plans target multiple sectors ranging from energy and transportation to buildings and natural resources. They share common themes: emissions reduction, reliance on federal funding and a need for additional resources and staffing, while reflecting each agency’s specific expertise.

Agencies Lay Out Ambitious Targets

In its plan, the MDE lays out a regulatory approach, prioritizing key initiatives to curb climate pollution.

Its priorities include adopting a zero-emission heating equipment standard by the end of 2025, requiring zero on-site emissions for new space- and water-heating equipment. The agency is simultaneously developing a clean heat standard that will require natural gas and heating fuel distributors to reduce greenhouse gas emissions.

MDE will also focus on reducing transportation-related emissions under its Advanced Clean Fleets program, which requires owners of covered truck and bus fleets to invest more in purchasing zero-emission vehicles. The agency intends to lay groundwork for implementing the Advanced Clean Cars II program, the Advanced Clean Trucks Act of 2023 and the Zero-Emission School Bus Initiative, each targeting a specific class of vehicle to accelerate the shift to zero-emission vehicles.

The MDE’s other priorities for 2025 include a more stringent energy performance standard for buildings, including a modification to include Energy Use Intensity (EUI) standards in 2027. EUI is an indicator of a building’s energy performance. 

A maneuver backed by House Speaker Adrienne Jones at the end of last year’s legislative session delayed enforcement of EUI standards that would have required building owners to meet efficiency targets, face fines for non-compliance and begin reporting direct emissions data annually starting in 2025.

The MDE also plans to propose modifications to the Regional Greenhouse Gas Initiative, a multi-state cap-and-trade program that limits carbon emissions from power plants and reinvests revenue into clean energy and efficiency programs. MDE wants to tighten emission caps on all power plants run on fossil fuels across the participating jurisdictions while expanding regulatory oversight on transportation and industrial sectors. 

Renewable and alternative energy infrastructure is one of the major priorities for the Department of Natural Resources (DNR). It plans to install solar panels on approximately 220 acres of parking areas it owns and is exploring innovative strategies like agrivoltaics—using the same land for solar and agriculture—and integrating pollinator habitats under solar arrays.

The department is also prioritizing carbon sequestration, aiming to plant 5 million trees by 2031 under the Tree Solutions Now Act, with 500,000 of those trees going in underserved areas. Other initiatives include advancing climate-smart forestry, enhancing forest productivity and exploring so-called “blue carbon” strategies to capture carbon in coastal ecosystems.

The Maryland Energy Administration’s approach revolves around incentivizing clean energy adoption and educating consumers. In 2025, it plans to deliver six programs totaling $70 million to benefit underserved and overburdened communities. These include the commercial solar grant program, community solar program, community electric vehicle supply equipment equity program and solar energy equity program. They are all designed to mobilize solar and energy efficiency resources and reduce greenhouse gas emissions in vulnerable communities.

The MEA also plans to launch a public information campaign and expand its Clean Buildings Hub, designed to encourage building owners to reduce energy use and onsite emissions. 

The Maryland Department of Transportation’s plan uses a multi-sector approach that aims to reduce emissions through infrastructure projects, vehicle electrification and minimizing congestion. MDOT’s priorities for the year include the continued rollout of the Zero Emission Vehicle Infrastructure Plan, expanding EV charging networks under the National Electric Vehicle Infrastructure program and setting reduction targets for annual greenhouse gas emissions and vehicle miles traveled.

MDOT also plans to implement its 2023 Carbon Reduction Strategy, invest in transit projects like the Red Line in Baltimore City and the Purple Line in Montgomery and Prince George’s counties and advance climate resilience through the Transportation Resilience Improvement Plan, with a strong emphasis on equity and environmental concerns.

The Department of Agriculture plans to enroll 100,000 acres in its program for encouraging conservation practices. Priorities include scaling up agroforestry, implementing climate-smart farming methods like cover crops and nutrient management and reducing methane emissions through enhanced manure management and anaerobic digestion. 

Its plan also emphasizes protecting working lands with permanent easements under the Maryland Agricultural Land Preservation Foundation, particularly in vulnerable areas like the Eastern Shore, which are threatened by saltwater intrusion and rising seas. 

Operational Gaps and Shortcomings

Despite an impressive slate of proposed climate actions, the execution of many initiatives partially rely on federal grants, which have become uncertain under the Trump presidency. 

A recurring theme across the plans is workforce strain. Most state agencies, particularly MDOT and the Department of Agriculture, emphasize the need for additional staff to meet climate targets but fail to lay out recruitment timelines or specific investments in workforce development. The MDE and DNR also mention staffing needs, particularly in data management and monitoring for emissions reporting and climate resilience projects, in their plans.

Accountability is another missing link. For example, the Zero-Emission Heating Equipment Standard and clean heat standard rely heavily on stakeholder engagement and model rules. But what happens if stakeholders don’t agree or the process gets delayed is unclear. Similarly, while the MDE proposes modification to the regional cap-and-trade program, whether partner jurisdictions will agree is outside Maryland’s control.

In written comments, Jay Apperson, deputy director for the MDE’s office of communications, said the agency “started meeting with stakeholders to get input on the Clean Heat Rules in the fall of 2024” and intends to propose a zero-emission heating equipment standard and a clean heat standard reporting rule this summer. 

Of the cap-and-trade program, Apperson said, “Maryland and the other states will propose changes to our individual regulations after the states agree on a shared path forward under the regional process, not before.” He added that Maryland is advancing clean energy legislation to ensure that “our electricity supply continues to get cleaner in concert with, but not dependent upon agreement with other states.” 

Timelines add to the list of challenges. The zero-emission heating equipment standard, listed among the MDE’s 2025 priority, is supposed to be adopted by this fall, leaving little time for stakeholder input, rule drafting and public hearings. 

Getting all schools statewide to transition to electric buses by the year end is another aggressive goal. Many school districts have already asked for waivers, citing insufficient infrastructure and funding. These tight timelines could lead to hasty decisions or deficient implementation.

Agencies have made a noticeable effort to integrate environmental justice and equity concerns in their working plans. But there is a lack of specific actions and mechanisms for delivering measurable outcomes and evaluating their effectiveness. Most environmental justice benefits are dependent on federal grants and any gap in funding for programs targeting vulnerable populations could hinder equitable climate solutions.

There’s also no major public awareness campaign. While switching to electric cars, upgrading heating systems or recycling food waste will require public buy-in, the agencies have not included a robust strategy for engaging the public or addressing pushback against these changes.

Interagency coordination is crucial for departments to work collaboratively to drive down emissions and implement lower carbon energy solutions. It’s not clear how that will be managed, though, which risks fragmented efforts.

While the climate subcabinet is tasked with coordinating efforts across agencies, it lacks authority to hold them accountable for meeting their targets. MDE’s Apperson said that under Moore’s executive order, “state agencies must report on their progress to the Governor’s Subcabinet on Climate, led by the Maryland Department of the Environment.” He did not comment on whether the MDE has authority to perform oversight beyond receiving progress reports. 

Still, interagency coordination has grown under the Moore administration, said Evan Isaacson, senior attorney and director of research for the nonprofit group Chesapeake Legal Alliance. The state now has a chief resilience officer and a chief sustainability officer, he said, and Moore “resurrected the concept of Bay subcabinet coordination in 2023” before establishing the climate subcabinet.

Worthy Effort With Room For Improvement, Advocates Say

Advocates and academics welcomed the agency’s climate action plans as an important step forward but added that the real test lies in implementation. 

Kim Coble, executive director for the Maryland League of Conservation Voters, praised the Moore administration for getting the agencies to draw up their climate implementation plans. That should allow them to work collaboratively to achieve the climate targets, she said. 

Coble said that whether federal funding will continue under the Trump administration is a “significant concern and the trajectory of fully implementing existing federal and state programs is going to change a lot if we lose that money.” While she was glad to see Maryland agencies stepping up their efforts to combat climate change, it was just as important to lay down metrics to measure progress to track implementation, regulatory actions and funding needed to achieve the goals outlined in these plans. 

“If the federal funding isn’t there, and it’s likely that some of it is going away, then it will be essential for Maryland to identify new revenue strategies to fund its climate commitments.”

— Josh Tulkin, Sierra Club Maryland director

She said she expects the Maryland legislature to play its part and come up with ways to fund the state’s climate priorities. But she cautioned that residents must be part of the priority-setting effort.

“For environmental justice work to be effective, it has to be community-driven and led by community engagement. Did anyone in the governor’s office ask impacted communities about the actions they would like these agencies to take?” Coble asked. 

Josh Tulkin, director of the Sierra Club’s Maryland chapter, said publishing agencies’ climate plans brought transparency to the government’s approach toward climate and the environment. “But it wasn’t particularly easy to piece them all together and capture how each of these plans adds up to the state’s [climate] plan,” he said. “I think that’s an area for improvement.” 

He said the agencies’ plans clearly showed that achieving Maryland’s climate goals will have huge public benefits and will require upfront funding beyond the state’s current levels. “If the federal funding isn’t there, and it’s likely that some of it is going away, then it will be essential for Maryland to identify new revenue strategies to fund its climate commitments,” he said. 

Tulkin said the next significant test is whether the state sets up clear lines of accountability and reporting on the agencies’ climate implementation plans. 

Isaacson, with Chesapeake Legal Alliance, said there was a need for an honest assessment to determine which investments would make more sense in view of the state’s budget shortfall, the uncertain future of federal funds and the role that rising demand from data centers will play in the state’s trajectory on greenhouse gas emissions. 

“If there was such an assessment of the decision points that would truly bend the curve in light of these challenges, that would get us from these large and comprehensive plans to a short and prioritized list of action items,” Isaacson said.