The Brandon Shores coal-fired power plant, based on Anne Arundel County, has been a major topic in the news and discussion item in Annapolis. Sierra Club has received several questions about its engagement with the plant owner, Talen Energy, and its role in different proceedings and processes. We’ve put together this memo as a primer on the subject.
Sierra Club believes we can achieve grid reliability while advancing Maryland’s clean energy and climate goals and protecting ratepayers, and it has actively advocated for strategies to move Maryland in that direction.
Sierra Club has been working for over 20 years in Maryland to ensure power plants are complying with environmental permits, encourage the growth of renewable energy, and facilitate transition and support for affected workers and communities.
Brandon Shores is a two-unit 1,282-megawatt (MW) coal-burning power plant in Anne Arundel County, Maryland. One unit has been operating since 1984, and the other since 1991. The plant is owned by Talen Energy.
PJM Interconnection, the grid operator and planner for a 13-state region, is the primary entity responsible for maintaining the reliability of the transmission system and planning upgrades so that the system adapts to changing circumstances.
2020
On November 10, 2020, Talen Energy publicly announced its plans to cease burning coal at Brandon Shores, Wagner, and a third power plant, noting that this was part of a Transformational Move Toward a Sustainable, ESG-Focused Future.
Sierra Club and members of the Stoney Beach Community, located next to Brandon Shores, issued a press release applauding the decision, noting that ceasing to burn coal would eliminate a significant source of sulfur dioxide pollution, coal dust, and noise affecting the nearby community. Joint statement.
According to the Clean Air Task Force’s 2010 “The Toll from Coal” study, Brandon Shores was causing 14 premature deaths and 145 asthma attacks annually.
Talen’s announcement followed a bi-laterial agreement reached between Sierra Club and Talen Energy whereby Talen agreed to announce plans to cease burning coal at Brandon Shores, Wagner, and a third coal plant by December 2025. The agreement does not prohibit Talen from converting the plant to run on oil instead of coal, and as part of that agreement Sierra Club agreed to not contest permits to repower Brandon Shores and Wagner to alternative fuels.
2021
Talen obtained most or all of the permits it needed to convert to oil and discussed these conversion plans with PJM. Sierra Club did not intervene in the CPCN process.
At the time, Talen Energy announced plans to convert to oil at their power plants and made both the State of Maryland and PJM aware of their plans.
For the next three years, all pertinent entities - the Maryland PSC, PJM and the Sierra Club - held this same understanding.
2023
In early 2023, Talen informed PJM that it was abandoning its plans to convert Brandon Shores to oil and decided to fully retire the plant, citing economic reasons for walking back their commitment from three years earlier.
When Talen notified PJM of Brandon Shores’ retirement in 2023, PJM determined that shutting down Brandon Shores would create transmission reliability issues and designed a set of transmission upgrades to address those issues. PJM did not study alternatives to the transmission solution, nor did it allow for a competitive process for the construction of the transmission, for which it has been criticized by the Maryland Public Service Commission, Office of People's Counsel, and others.
PJM projected that new transmission upgrades would take five years to complete, which leaves a three-year gap after Brandon Shores’ proposed deactivation date in 2025.
PJM moved to contract with Talen to keep Brandon Shores operating for another three years under a “reliability must run” (RMR) agreement. These agreements can be extremely costly for consumers.
Since RMR’s are voluntary, Talen has held significant power in setting the price at which Brandon Shores remains in operation and costs could end up being more expensive than introducing new generators to the grid. This cost would end up falling back on ratepayers.
Sierra Club joined Maryland Energy Administration, PSC, and others in criticizing PJM for not planning for the potential loss of Brandon Shores and Wagner.
2024
In the spring of 2024, Sierra Club alerted PJM and the Federal Energy Regulatory Commission (FERC), the federal agency that regulates PJM, that failing to include Brandon Shores and Wagner in the capacity market would have dire consequences for Maryland ratepayers. PJM ignored this warning.
As a result, PJM’s most recent capacity auction cleared at record high prices (a $14 billion total cost, compared to $2.2 billion in the prior auction). Analysis from the Maryland Office of People’s Counsel (OPC), the state’s ratepayer advocate, and others showed that a major contributor to these high prices was that the power generated by Brandon Shores and Wagner was not reflected in the auction.
Sierra Club and other environmental organizations filed a complaint against PJM at FERC on September 27, 2024, seeking to change these rules in order to save consumers billions of dollars each year by requiring PJM to include RMR units in its market. The FERC complaint was not focused on Brandon Shores or any particular RMR unit; it broadly addressed the deficiency of PJM’s rules about RMRs and the capacity market.
In its response to this broad complaint about PJM’s market, PJM singled out Sierra Club’s agreement with Talen, claiming it prevented Talen from operating Brandon Shores under an RMR. This is false. The agreement did not forbid Talen from operating Brandon Shores under an RMR. Under the agreement, Talen would not have faced any restrictions if it stopped burning coal at Brandon Shores, as Talen itself planned to do. But even if Talen had continued burning coal after December 31, 2025, Talen could have still operated Brandon Shores -- it just exposed itself to litigation risk if it were to violate any environmental laws at its coal plants.
Furthermore, there are other issues that could have prevented Brandon Shores from burning coal. In 2021, Talen was granted modification by MDE of its air and water discharge permits which are based on ceasing burning coal.
Additionally, Talen declined to bid Wagner into the capacity market, despite the plant not being subject to the agreement, because it does not currently burn coal.
2025
Regardless, Sierra Club and Talen amended the agreement in January 2025 to explicitly clarify that Talen can operate the plant pursuant to an RMR without facing any legal challenges from Sierra Club.
Sierra Club, Maryland OPC, PSC, Talen and other parties engaged in the FERC process establishing the RMR. In January 2025, a settlement was reached with some parties, including Sierra Club. The settlement ensures that these resources from Brandon Shores can participate in the PJM capacity auction, which will drive down capacity prices.
On January 27, Talen updated the operational costs to be nearly $145 million per year for Brandon Shores when operating under an RMR.