Attorneys General of the District of Columbia, Delaware, and Maryland
July 5, 2019
Via Email
PJM Search Committee
c/o Neil H. Smith
2750 Monroe Blvd
Audubon, PA 19403-2497
neil.smith@pjm.com
Re: PJM President and Chief Executive Officer Search
Dear Search Committee:
The undersigned Attorneys General of the District of Columbia, Delaware, and Maryland
appreciate the opportunity to comment on the skills and background the next President and Chief
Executive Officer of PJM (“President”) should bring to the office. We write to urge the Search
Committee for the new President to select a President who will be an enthusiastic partner in states
and localities’ efforts to address climate change, protect consumers, and promote green economic
development. Our states have adopted ambitious clean energy goals and programs including
renewable portfolio standards. It is essential that PJM’s President embraces the changes to the
energy sector needed to make these programs successful.
Climate change is already harming our states, localities, and residents. Flooding, extreme
heat, and severe storms damage property and infrastructure, and threaten human health. The Fourth
National Climate Assessment concludes that the: “evidence of human-caused climate change is
overwhelming and continues to strengthen, that the impacts of climate change are intensifying
across the country, and that climate-related threats to Americans’ physical, social, and economic
well-being are rising.”1 Our most vulnerable residents—particularly in low-income communities
and communities of color—bear a disproportionate share of these threats including increased
asthma attacks and dislocation associated with climate change.
Our states are leading the way to avoid the worst effects of climate change by transforming
the energy sector to promote clean energy and shift away from fossil fuel. The Fourth National
Climate Assessment finds that by shifting from our current high-emissions scenario to a lowemissions scenario, “[b]y the end of this century, thousands of American lives could be saved and
hundreds of billions of dollars in health-related economic benefits gained each year.” For this
reason, our states have adopted ambitious, but achievable, clean energy goals and programs. For
                                                            
1

U.S. Global Change Research Program, Impacts, Risks, and Adaptation in the United States:
Fourth National Climate Assessment, Volume II, at 36 (D.R. Reidmiller et al. eds., 2018)
available at https://nca2018.globalchange.gov/.

 example, the District of Columbia’s renewable portfolio standard requires 100 percent tier one2
renewable energy by 2032 and the District has committed to reducing District carbon emissions
50 percent below 2006 levels by 2032 and 100 percent by 2050.3 Delaware’s renewable portfolio
standard requires 25 percent renewable energy by 2025, with at least 3.5 percent from solar by
2025, and Delaware’s Cabinet Committee on Climate and Resiliency set a goal of reducing
Delaware’s greenhouse gas emissions 30 percent below 2008 levels by 2030.4 Just this past term,
the General Assembly of Maryland recommitted to a clean energy economy by increasing the
state’s renewable energy portfolio standard to require 50 percent of all retail electricity sold within
the state to come from renewable sources by 2030.5
PJM’s new President should purposely engage with states, localities, and stakeholders to
achieve this transformational change. The President should have the leadership skills and creativity
to drive innovations in PJM’s markets, operations, and planning functions to support the necessary
shift to clean energy. PJM’s President should also have the economic and policy background to
understand that state clean energy preferences are not out-of-market distortions to PJM interstate
markets, but instead are important market corrections. These policies address pressing
environmental externalities and will modernize our state economies, creating jobs as well as
environmental benefits. The President should understand and respect states’ essential role and
authority under the Federal Power Act in shaping the mix of generation resources offered to their
consumers. An innovative leader of PJM could ensure that our region benefits from clean energy,
mitigates the worst of climate change, and modernizes our energy economy. We look forward to
collaborating with this leader and PJM in achieving these benefits.
Sincerely,

_______________________________________________________

Karl A. Racine
Attorney General for the District of Columbia

                                                            
2

 District of Columbia Code § 34–1431(15).

3

District of Columbia Code § 34–1432(c)(25); Sustainable DC, at 7,
http://www.sustainabledc.org/wp-content/uploads/2017/02/Web-Ready-File-2.6.17.pdf.
4
26 Del. C. § 354(a); Climate Framework for Delaware, at 12, available at
http://www.dnrec.delaware.gov/energy/Documents/The%20Climate%20Framework%20for%20
Delaware%20PDF.pdf. 
5
Clean Energy Jobs Act, 2019 Md. Laws Ch. 757 (S.B. 516) (to be codified at Md. Code Pub.
Util. §7-703).
2
 

 _______________________________________________________

Kathleen Jennings
Delaware Attorney General

________________________________________________________

Brian E. Frosh
Maryland Attorney General

3