Maryland's New Executive Order Restructures Solar Project Review Process

Executive Summary

Maryland Governor Wes Moore signed an Executive Order on September 23, 2023, establishing a new statewide review framework for large solar projects — a move that directly targets permitting inefficiency, one of the most persistent bottlenecks facing solar developers in the Mid-Atlantic. The order signals the state's intent to accelerate renewable energy buildout by making the approval process more structured and predictable. Developers with shovel-ready or early-pipeline projects in Maryland stand to benefit most from reduced bureaucratic friction. Stakeholders operating under assumptions built around the old review structure will need to reorient quickly. The InfraSale takeaway: Maryland is becoming a more actionable market for solar infrastructure, and project timelines should be reassessed now.

What Happened

On September 23, 2023, Governor Wes Moore issued an Executive Order establishing a new statewide framework for the review of large solar energy projects in Maryland. The order introduces guidelines intended to clarify and restructure how large solar developments move through the state's approval process, addressing longstanding concerns about review timelines and procedural inconsistency.

The Executive Order targets large-scale solar specifically, suggesting the state is prioritizing utility-scale and commercial-scale development over smaller distributed generation. While the source does not detail the precise megawatt threshold that defines "large" under the new framework, the focus on this segment indicates a deliberate policy choice to accelerate the highest-capacity projects in the pipeline.

The order follows a pattern of executive action aimed at aligning Maryland's regulatory environment with its clean energy goals. Industry context: Maryland has set a target of 50% renewable energy by 2030 under its Renewable Portfolio Standard, and permitting reform is widely recognized as a prerequisite to meeting that target on time.

Source: Google Alert - Solar Energy

Why This Matters

Permitting delays are not a Maryland-specific problem — they are the defining constraint on solar deployment across the country. What makes this Executive Order notable is that it represents direct executive intervention, bypassing the slower pace of legislative reform. That speed of action matters to developers who have projects waiting in queue.

When a governor issues an EO to restructure review processes, it typically signals that the current framework was generating enough friction to warrant political attention. Assumption: the existing review process was producing unpredictable timelines, interagency coordination gaps, or both — common failure modes in states that layered renewable energy ambitions onto legacy permitting infrastructure not designed for volume.

The second-order effect is market signaling. Maryland just sent a message to the developer and investor community that the state is open for large solar business. That kind of clarity tends to attract capital and accelerate the conversion of optioned land into active project applications.

Power & Interconnection Impact

A streamlined permitting process on the state side can reduce the overall project development timeline, but interconnection remains a parallel — and often longer — critical path. Assumption: if state review timelines compress, developers will reach the interconnection application stage faster, which could increase near-term pressure on PJM's already congested interconnection queue in the Maryland footprint.

Reduced permitting uncertainty may make it easier for developers to execute Power Purchase Agreements (PPAs) earlier in the development cycle. Offtakers, particularly utilities and large commercial buyers, are more willing to commit when state-level approval risk is lower. This could unlock financing for projects that were previously stalled waiting for permitting clarity.

Industry context: Maryland sits in PJM territory, where interconnection queue reform is already underway at the federal level through FERC Order 2023. Faster state permitting combined with PJM's evolving cluster study process could meaningfully compress total development timelines for well-positioned projects.

Land, Zoning & Permitting Impact

The core value of the Executive Order is in the permitting layer. By establishing a new review framework, the state is creating a more defined procedural pathway — which reduces the risk of projects stalling due to interagency ambiguity or inconsistent standards across counties.

Assumption: the new framework may include clearer criteria for site suitability, which would help developers assess land parcels earlier in the prospecting process. If the state codifies what qualifies a site for large solar review, that information becomes a usable filter for landowners, developers, and brokers sourcing acreage in Maryland.

Zoning remains largely a county-level function in Maryland, so the Executive Order's reach into local land use decisions may be indirect. However, a statewide framework with clear guidelines can still influence county behavior by establishing expectations and reducing the surface area for local opposition to exploit procedural ambiguity.

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Developers should also consider how the new framework interacts with Maryland's agricultural land preservation programs, which have historically been a complicating factor for solar siting on farmland in the state. Assumption: the EO does not override those programs, but clearer state-level review standards may help developers navigate that interface more efficiently.

Investment Takeaway

Maryland's Executive Order shifts the risk-adjusted return profile for solar development in the state. Here is the read for capital allocators:

Pipeline projects accelerate. Developers with sites already under option or in early-stage development should expect faster movement through state review — model tighter timelines in your underwriting.
Maryland moves up the priority list. In a capital allocation exercise across Mid-Atlantic states, Maryland just improved its relative standing for solar deployment risk. Permitting clarity is a quantifiable de-risking event.
Early-stage land plays become more attractive. If review processes are more predictable, the gap between raw land and permitted project closes faster — that compression creates value for landowners and developers alike.
Interconnection exposure remains. State permitting reform does not fix PJM queue delays. Investors should not model interconnection timelines shortening in parallel without additional evidence.
Stakeholders tied to the old process need to adapt. Consultants, legal teams, and county liaisons whose value was navigating the previous review structure should expect their workflow to change.

InfraSale Market Angle

For solar developers active in Maryland, the Executive Order is a prompt to reopen project schedules that may have been padded to absorb permitting uncertainty. If the new framework delivers on its intent, contingency buffers built around state review delays can be reallocated or removed.

Landowners in Maryland with acreage suited for utility-scale solar should be aware that developer appetite in the state is likely to increase. More predictable permitting means more developers can justify committing to site control, which typically means better lease terms for landowners who move early.

Investors evaluating Maryland solar assets — whether development-stage projects or operating portfolios — should treat this EO as a positive data point in due diligence while maintaining scrutiny on interconnection queue position, local zoning status, and offtake structure.

Market Signal

Location: Maryland, USA
Primary Issue: New review framework for solar projects
Infrastructure Theme: permitting
Who Benefits: solar developers and investors
Who's at Risk: stakeholders relying on the previous review processes
InfraSale Takeaway: InfraSale users should evaluate project timelines and adjust strategies to align with the new permitting framework.

Take Action

Maryland's revised solar review framework is a concrete change in the development environment — not a proposal, not a study, an executed order. Developers and landowners with Maryland exposure should act on this now, before the market fully reprices the state's project risk. Post an interconnection-ready project for investor review.

FAQ

What does the new executive order mean for solar developers?

Governor Moore's Executive Order establishes a new, structured review process for large solar projects in Maryland, replacing what was a less defined procedural pathway. For developers, this means greater clarity on what the state expects at each stage of review, which translates to more reliable project scheduling and reduced approval risk.

How will the new framework affect project timelines?

Assumption: a more codified review process typically reduces the back-and-forth between developers and state agencies, compressing the time between application submission and approval. Developers should revisit their project schedules and model scenarios where state review time shortens meaningfully, while keeping interconnection and local permitting timelines unchanged until further evidence emerges.

Are there specific guidelines for land use under the EO?

The source does not specify the land use criteria introduced by the Executive Order. Assumption: the framework likely includes site suitability standards that inform what types of land are appropriate for large solar development, but developers should review the full text of the order and consult legal counsel to understand how those standards apply to specific parcels.

Does this executive order affect county-level zoning decisions?

Zoning authority in Maryland sits primarily at the county level, so the Executive Order does not override local zoning decisions. However, a clearer state framework can reduce the procedural ambiguity that county opponents sometimes use to slow or block projects, making the overall local approval environment more navigable.

How does this interact with Maryland's renewable energy targets?

Industry context: Maryland has a 50% renewable energy target by 2030 under its Renewable Portfolio Standard. Permitting reform through executive action is a practical lever for closing the gap between the state's installed solar capacity and what is needed to hit that target on schedule.