Maryland Thermal Energy Network Pilots
Office of People’s Counsel | Maryland
In 2025, the Maryland Office of People’s Counsel (OPC), an independent state agency representing the interests of residential ratepayers, selected GEEG to evaluate the state’s first Thermal Energy Network pilot projects under the WARMTH Act. GEEG combined benchmarking, cost analysis, engineering review, and regulatory support to help OPC assess whether the proposed pilots would protect ratepayers while advancing the state’s clean energy goals.
Signed into law in May 2024, the WARMTH Act requires Maryland gas utilities with more than 75,000 customers to propose at least one thermal energy network pilot for approval by the Maryland Public Service Commission (PSC). Baltimore Gas and Electric Company and Washington Gas Light Company notified the PSC of their intent to develop pilot plans.
Drawing on GEEG’s work on the Eversource Thermal Network Pilot in Framingham, Massachusetts, the team began by benchmarking thermal energy network projects in other states. The analysis examined project costs, design challenges, and implementation approaches to establish reasonable expectations for project scale and cost. This provided OPC with important context for evaluating the potential ratepayer impacts of Maryland’s proposed pilots.
GEEG partnered with MaGrann Associates, a specialized energy engineering and green building firm, to conduct a comprehensive technical review of each pilot proposal. The review examined site selection criteria, proposed network technologies, and infrastructure requirements, and other key elements of project design.
A central focus of GEEG’s work was a rigorous cost and benefit-cost analysis. The team evaluated each utility’s cost projections under scenarios with and without federal funding support to assess potential ratepayer exposure. Using a cost per ton metric, GEEG compared Maryland’s proposed pilots with those in other states, creating an “apples-to-apples” framework that helped OPC and the Commission better understand the relative costs of each project. The PSC found this comparative approach particularly effective in highlighting areas where proposed costs were above market norms.
GEEG complemented its technical analysis with regulatory and stakeholder support, reviewing filed comments and stakeholder feedback and preparing detailed written comments on behalf of OPC. GEEG President Theo Love also provided expert testimony at a Maryland PSC hearing, helping to explain the economic considerations surrounding the proposed pilots and Maryland’s emerging thermal energy network market.
Through this engagement, GEEG helped OPC evaluate whether the proposed pilots were technically sound, cost-effective, and aligned with the interests of Maryland ratepayers. The work provided regulators with a stronger basis for comparing emerging thermal energy network proposals, evaluating potential ratepayer impacts, and identifying opportunities to improve project design before broader deployment.
