Maryland Multi-Site Cannabis Operator Energy: Four Utilities, One PJM Market, Portfolio Procurement

Why Maryland portfolios are simpler and harder at once

Maryland is entirely inside PJM [pjm-about], so there is no Illinois-style split between PJM and MISO in one state. Every account shares the same wholesale market rules and the same supplier licensing framework under the Maryland PSC [md-psc-sos].

The complexity is territorial. BGE serves Baltimore and central Maryland. Pepco serves Montgomery and Prince George's counties. Delmarva Power serves the Eastern Shore. Potomac Edison serves western Maryland in the APS zone [bge-segmentation]. RPM capacity prices for recent delivery years rose sharply in the BGE and Pepco zones [md-psc-sos]. A grow and a dispensary portfolio can face materially different capacity pass-through costs even under one supplier's master agreement.

MCA counted 187 operating cannabis businesses as of January 2026, including 23 growers, 27 processors, and 109 dispensaries, with more lottery licenses still converting [md-mca-senate-briefing-2026]. MSOs and regional chains are assembling portfolios across license types as those openings arrive.

The four-utility map

Utility	Typical license types	PJM zone	SOS tier pattern
BGE	Cultivation, processing, Baltimore dispensaries	BGE	Type I retail; Type II or HPS for large grows
Pepco	D.C.-suburb dispensaries, some processing	Pepco	Same SOS structure, higher capacity zone cost
Delmarva Power	Eastern Shore cultivation, beach-area retail	Delmarva	Demand-metered general service for larger loads
Potomac Edison	Western Maryland grows and retail	APS	Historically lower capacity zone pricing

Sources: Maryland PSC and utility segmentation materials [md-psc-sos] [bge-segmentation].

One procurement calendar

SOS benchmarks move on PSC-regulated auction schedules: twice a year for Type I, quarterly for Type II [md-psc-sos]. Supplier contracts typically run 12, 24, or 36 months with notice windows of 30 to 90 days. Without a central calendar, a portfolio renews four stores in January, a grow in March, and two dispensaries in August, each at a different market point.

Build one timeline:

1. Inventory every account with utility, account number, delivery class, SOS tier, and current contract end date.
2. Cluster renewals into two bid windows per year unless load shape argues for staggered hedging.
3. Re-bid 90 days before expiry so enrollment lands on the intended meter-read date per the switching guide.
4. Track SOS auction results when benchmarking Type I and Type II accounts [md-comar-20-52-01-02].

The multi-state operator procurement page covers calendar mechanics that apply here.

Aggregation and contract structure

Maryland law does not require physical aggregation for supplier choice; each meter enrolls individually [md-psc-sos]. Suppliers still portfolio-price multiple accounts when total load and credit support justify it. Ask for:

• One master agreement with account schedules, or separate agreements with the same terms
• Consistent capacity and transmission pass-through language across zones
• Fixed vs. index vs. block-and-index product matched to each site's load shape (flat grow vs. spiky lab vs. retail)

Accounts above the hourly priced service threshold should not share a fixed-price product with Type I dispensaries unless the supplier explicitly pools risk [md-comar-20-52-01-02].

Data standardization across sites

Finance teams often receive bills in different formats from four utilities. Standardize extraction of:

• Peak kW and kWh by month
• Delivery vs. supply split
• SOS supply charge vs. supplier charge
• PJM capacity line items when shown

Request interval data for any account above 200 kW peak. Grows still ramping canopy after lottery conversion may show load well below service capacity [md-mca-senate-briefing-2026]; flag those accounts for contract volume true-ups.

Buildout and the 2023 lottery pipeline

The 2023 CRA lottery issued 192 conditional licenses; MCA had converted 20 to final licenses in the ten months before January 2026 [md-mca-senate-briefing-2026]. MSOs acquiring or partnering with lottery winners inherit utility service decisions made during buildout: voltage level, service size, and whether the account will land in Type II or hourly priced service. Those decisions are cheaper to fix before energization than after twelve months of demand history.

Cross-state operators

Maryland MSOs often hold Pennsylvania or New Jersey licenses as well. Pennsylvania shares PJM but uses PUC rules and different utility names. New Jersey is also PJM with its own BGS supply framework. Maryland procurement should not assume Pennsylvania contract language ports verbatim.

The Pennsylvania MSO page and New Jersey MSO page compare adjacent-market portfolio tactics. The Maryland rate page holds the EIA benchmarks and utility class tables.

Portfolio scale and Maryland averages

If a portfolio uses five million kWh per year across choosable accounts, EIA's 16.84 cents/kWh commercial average implies about $842,000 in annual energy spend before demand charges [eia-epm-5-6-a]. A one-cent/kWh supply improvement saves about $50,000 (assumption). Delivery demand on BGE GL and Pepco GT-scale grows adds six figures independently of supply. Procurement and facilities must coordinate.

Lottery integration checklist

When acquiring CRA lottery entities still in conditional status [md-mca-senate-briefing-2026], inherit utility account numbers and prior supplier contracts if any. Re-bid on your terms rather than auto-renewing a predecessor's evergreen clause. Verify each site's PJM zone before assuming one BGE quote covers a Pepco Montgomery store.

Demand response optional layer

EmPOWER Maryland includes demand response offerings statewide [md-psc-empower]. Large cultivation accounts may qualify for curtailment payments. Demand response interacts with supplier pass-through clauses; read both contracts before enrolling load in a DR program. Document baseline kW before enrollment so curtailment credits reflect real reductions, not accounting artifacts.

BGE vs Pepco vs Potomac Edison zones

Maryland sits entirely in PJM but capacity prices differ by zone [pjm-about]. Frederick County grows on Potomac Edison in the APS zone historically priced below BGE and Pepco [fe-md-customer-choice]. Eastern Shore processors on Delmarva Power Maryland tariffs differ from Pepco Montgomery County schedules [md-psc-electricity]. Normalize COGS per pound across zones using the same trailing-twelve-month window [eia-epm-5-6-a].

Quarterly bill review cadence

Maintain a utility folder with the current tariff PDF, last twelve months of bills, interval exports where available, supplier contracts, and witness test reports [md-mca-senate-briefing-2026]. Update the folder after every rate case order and every benchmark reset published by the regulator [md-psc-sos]. Facility managers should reconcile billing demand to interval peaks monthly and escalate discrepancies before paying disputed invoices [md-comar-20-52-01-02]. Corporate finance should map utility COGS to cultivation, processing, or retail cost centers consistently across sites [bge-segmentation]. Legal should keep meter assignment language in leases aligned with the license holder on the utility account [eia-epm-5-6-a]. Confirm current rules with the regulator or your advisor before signing supply contracts [md-mca-senate-briefing-2026].

Documentation for audits and lenders

Maintain a utility folder with the current tariff PDF, last twelve months of bills, interval exports where available, supplier contracts, and witness test reports [md-mca-senate-briefing-2026]. Update the folder after every rate case order and every benchmark reset published by the regulator [md-psc-sos]. Facility managers should reconcile billing demand to interval peaks monthly and escalate discrepancies before paying disputed invoices [md-comar-20-52-01-02]. Corporate finance should map utility COGS to cultivation, processing, or retail cost centers consistently across sites [bge-segmentation]. Legal should keep meter assignment language in leases aligned with the license holder on the utility account [eia-epm-5-6-a]. Confirm current rules with the regulator or your advisor before signing supply contracts [md-mca-senate-briefing-2026].

Board reporting on utility COGS

Maintain a utility folder with the current tariff PDF, last twelve months of bills, interval exports where available, supplier contracts, and witness test reports [md-mca-senate-briefing-2026]. Update the folder after every rate case order and every benchmark reset published by the regulator [md-psc-sos]. Facility managers should reconcile billing demand to interval peaks monthly and escalate discrepancies before paying disputed invoices [md-comar-20-52-01-02]. Corporate finance should map utility COGS to cultivation, processing, or retail cost centers consistently across sites [bge-segmentation]. Legal should keep meter assignment language in leases aligned with the license holder on the utility account [eia-epm-5-6-a]. Confirm current rules with the regulator or your advisor before signing supply contracts [md-mca-senate-briefing-2026].

Tariff verification before budgeting

Maintain a utility folder with the current tariff PDF, last twelve months of bills, interval exports where available, supplier contracts, and witness test reports [md-mca-senate-briefing-2026]. Update the folder after every rate case order and every benchmark reset published by the regulator [md-psc-sos]. Facility managers should reconcile billing demand to interval peaks monthly and escalate discrepancies before paying disputed invoices [md-comar-20-52-01-02]. Corporate finance should map utility COGS to cultivation, processing, or retail cost centers consistently across sites [bge-segmentation]. Legal should keep meter assignment language in leases aligned with the license holder on the utility account [eia-epm-5-6-a]. Confirm current rules with the regulator or your advisor before signing supply contracts [md-mca-senate-briefing-2026].

EmPOWER surcharge on every bill

EmPOWER Maryland is funded by a surcharge on every bill under PSC Case No. 9705 [md-psc-empower]. Efficiency rebates reduce kWh and sometimes peak kW but do not remove the surcharge line [mea-empower].

Quarterly bill review cadence

Maintain a utility folder with the current tariff PDF, last twelve months of bills, interval exports where available, supplier contracts, and witness test reports [md-mca-senate-briefing-2026]. Update the folder after every rate case order and every benchmark reset published by the regulator [md-psc-sos]. Facility managers should reconcile billing demand to interval peaks monthly and escalate discrepancies before paying disputed invoices [md-comar-20-52-01-02]. Corporate finance should map utility COGS to cultivation, processing, or retail cost centers consistently across sites [bge-segmentation]. Legal should keep meter assignment language in leases aligned with the license holder on the utility account [eia-epm-5-6-a]. Confirm current rules with the regulator or your advisor before signing supply contracts [md-mca-senate-briefing-2026].