We are proud to present this third and final assessment of Governor Larry Hogan’s administration, reviewing his environmental legacy between 2015 and 2021. We are grateful to our partners throughout the state for contributing to this report.

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Governor Hogan’s time in office has been marked by extraordinary events. It began with the unnecessary death of a young man, Freddie Gray, that sparked an overdue examination of police policies in Baltimore and ended with a pandemic that created havoc around the world. In the middle was a federal administration that challenged every political norm.

Also unfolding over the past seven years has been the existential threat of the climate crisis and the urgent need for aggressive action from every level of government.

Maryland has more than 3,000 miles of shoreline and 265,000 acres of land less than five feet above sea level, making tackling climate change a matter of survival for many of the state’s most vulnerable communities, especially those of color and low wealth.

While Governor Hogan took positive actions, his leadership was inconsistent and he failed to adequately staff environmental compliance offices. He made strong statements committing to climate policy and the Chesapeake Bay that too often were followed by weak actions.

The full scope of Governor Hogan’s environmental record over the last seven years is mixed.

This report assesses four key areas:

  • Transportation
  • Energy Policy
  • Land and Water Protection
  • Environmental Justice

For the first three, we provide a table of key actions taken by the Hogan administration and a grade. We assessed Environmental Justice by reviewing each of the key actions taken and noting those that have significant equity implications.

As the Hogan administration draws to its conclusion, we especially lament that the administration’s record reveals a lack of commitment to the bold steps that are needed to position Maryland as a national leader in addressing climate change and environmental injustices.

The administration’s inability or reluctance to take concerted, strategic action to respond to the climate crisis far outweighs its accomplishments.

Maryland LCV urges our elected officials to provide bold, courageous leadership in environmental policy throughout Maryland and put the state on a much-needed course to a clean Bay, environmental justice, and necessary climate action.

Nearly all the actions evaluated in this report have implications for Maryland communities that suffer disproportionately from the effects of pollution and climate change. On the whole, the Hogan administration’s record on environmental justice, especially with regard to public transit, and clean and renewable energy, is inadequate.

On the whole, the Hogan administration’s record on environmental justice, especially with regard to public transit, and clean and renewable
energy, is inadequate.

Maryland’s Commission on Environmental Justice and Sustainable Communities (CEJSC) has met infrequently and been slow in both reaching out and  responding to the communities it is meant to serve. Efforts to re-invigorate the Commission and work with advocates in the 2021 legislative session to make
improvements to the Commission and add the Climate Justice team to the Maryland Commission on Climate Change mark encouraging steps, but more substantive efforts must be made before true progress is achieved.

Looking broadly at air quality measures that affect environmental justice communities, the administration’s record has improved over the course of Governor Hogan’s two terms. Having initially made the decision to weaken nitrogen oxide (NOx) emissions from waste-to-energy facilities, Maryland Department of the Environment (MDE) more recently set stringent limits and improved regulations on natural gas transportation and storage. The administration also publicly supported removing waste-to-energy as a qualifying source for renewable energy credits under the state’s Renewable Portfolio Standard in its proposed “Clean and Renewable Energy Standard,” although it did not support this action when presented with a stand-alone bill.

On the Eastern Shore, MDE responded to pleas to address air quality from communities surrounding the large Concentrated Animal Feeding Operations (CAFOs). Although it did not promote measures to reduce the source of the air pollution, MDE did install air monitors to capture data on ammonia emissions from poultry farms. While there are still concerns around the usability and transparency of data and the process surrounding these monitors, this is an important step forward, particularly if the data collected is used to inform pollution reduction measures.

One of the most important actions relating to the health of citizens and the Chesapeake Bay is the administration’s appeal of a court ruling that would require that it regulates poultry ammonia emissions as part of its Clean Water Act mandate. MDE’s annual enforcement and compliance reports document a significant decline in enforcement, further exacerbating the cuts made by previous administrations. Lack of enforcement allows for the perpetuation of structural disparities of pollution impacts on low-wealth communities and communities of color.

Governor Hogan’s record on transportation funding and policies clearly illustrates a lack of commitment to climate solutions from the transportation sector, the leading
source of greenhouse gas emissions in Maryland. During his tenure, Governor Hogan and his Department of Transportation have prioritized highway expansion, especially in rural Maryland, and actively starved public transit of funding and support.

Governor Hogan did provide limited support for the Purple line. However, his decision to unilaterally cancel the Baltimore Red Line after a decade of community input and planning reinforced the racial disparities evident in the Governor’s transportation policies. Cancellation of the Red Line disproportionately hurt residents of the poorest parts of Baltimore City, the majority of whom are Black. In addition to rejecting nearly a billion dollars in federal funding earmarked for the Red Line, Governor Hogan continued to hurt Baltimore by distributing the lion’s share of the state funds earmarked for the Red Line to nearly every other jurisdiction in the State. The reorganizing of the Maryland Transit Administration (MTA) bus system with the intent to improve public transit in the city was an inconsequential action when combined with the significant reduction in funding to support the MTA. As a result, Maryland’s public transit system is one of the least reliable in the country according to the Federal Transit Administration3.

During his tenure, Governor Hogan and his Department of Transportation have prioritized highway expansion, especially in rural Maryland, and actively
starved public transit of funding and support.

The Governor’s 2021 veto of a law mandating minimal funding to achieve “state of good repair” for public transportation indicates a disregard for the needs of the students, seniors, healthcare workers, and others who rely exclusively on public transit. The veto also hurts Western Maryland, which counted on funding for a study to expand MARC Rail to serve its communities, which was part of the bill. The lack of investment in Maryland’s public transportation systems in communities of need stands in direct contrast with the Governor’s public support of permanent funding for Washington Metropolitan Area Transit Authority (WMATA). Sustainable, comprehensive investment in public transportation is essential from an environmental perspective in Maryland, and particularly important for our urban and underserved communities.

The Governor’s decision in May of 2021 to reduce the scope of beltway expansion was an improvement, but it should be seen in part as a triumph of dedicated advocates and media coverage rather than a significant change in policy by the Governor, and the current plan for the expansion is still problematic4.

Governor Hogan’s actions in support of electric vehicle tax credits, to advance the state’s goal of 300,000 electric cars by 2030, are appreciated, as was his dedication of funds for electric school buses. While positive, these initiatives will require significantly more investment to make a meaningful difference.

The Hogan administration has been vague about its support for clean energy, and overall progress has been disappointingly slow.

The context of transitioning Maryland away from fossil fuels to a clean energy economy is another area where the Hogan administration’s inconsistency towards climate action is pronounced. The Governor has taken significant steps and made strong statements of support for climate action. At other times, the Hogan administration has seemed ambivalent about its support for clean energy, and overall progress has been disappointingly slow.

Governor Hogan opposed a fracking ban in 2017 and made decisions to expand fracked gas infrastructure in years following. However, at the “eleventh hour” of the Maryland General Assembly, he ultimately supported the 2017 ban on fracking. The Governor joined other members of the Board of Public Works and blocked the Potomac Pipeline expansion through Western Maryland, which was a positive action. Unfortunately, this significant energy policy step was
followed by his support of an expansion of existing pipeline infrastructure of the Del-Mar Energy Pathway Project that would run through the Eastern Shore. This inconsistent approach to climate policy was further evident when he vetoed the Clean Energy Jobs Act in 2016. However, three years later the Governor allowed an expansion of the program to go into law without his signature, but with sharp criticism for the legislation.

In 2020 and again in 2021, the Hogan administration offered the Clean and Renewable Energy Standard (CARES) bill. The 2020 bill promised a path to 100 percent clean energy, but with problematic provisions that prevented support by the environmental community. The 2021 version of the bill corrected many of those concerns but, unfortunately, the bill was introduced three weeks after the filing deadline, ensuring that it would not be considered during the legislative
session. In both 2020 and 2021, the Hogan administration’s attempts to build legislative or community support for a 100 percent clean energy policy were lackluster.

The Hogan administration has been vague about its support for clean energy, and overall progress has been disappointingly slow.

Notably, Governor Hogan has strongly supported the development of wind projects off the Ocean City coast, one of the most important opportunities for renewable energy in Maryland. He has used his platform to sign Maryland onto alliances and regional agreements and the Maryland Energy Administration (MEA) has actively intervened in the independent Public Service Commission approval process for offshore wind projects.

Public statements from a governor, such as those by Governor Hogan regarding expansion of offshore wind energy, are important. They can help drive public
support of and financial investment in a project, like the grant through MEA that demonstrates significant investment from the state to support job training
and capital upgrades to the offshore wind industry.19

Actions taken during Governor Hogan’s first term weakened carbon emission regulations. In recent years, however, the administration’s clean energy actions have generally been positive and provided defense against weakening federal standards. This was especially true in 2020 with stronger methane regulations and a resumed stakeholder process for setting methane limits for municipal solid waste landfills. The administration deserves credit for these actions, which were
made under the direction of Secretary of the Environment Ben Grumbles and reported by both the 2030 Greenhouse Gas Reduction Plan and the Maryland Commission on Climate Change.

Land and Water Protection

Governor Hogan’s record on funding land preservation and open space is excellent. However, the Governor’s record on water policy is mixed.

Governor Hogan’s record on funding land preservation and open space is excellent. He has, for example, supported full funding of Program Open Space every  year he has been in office and consistently honored that commitment, despite the temptations presented by the 2020 Coronavirus pandemic and the economic devastation caused by a once-in-a-generation health crisis.

The Governor’s record on water policy is mixed. He has been a supporter of the Bay Restoration Fund and, as chairman of the regional Chesapeake Bay Executive Council, helped to advocate for full federal funding of the Chesapeake Bay Program when the Trump administration proposed significant cuts. However, the Governor has consistently opposed legislation to support science-based oyster fisheries management and sanctuaries, which are vital not only to the health of the Bay but also to the economic strength of the communities who rely on a vibrant oyster population.

A 2021 independent forest audit of Maryland Department of Natural Resources (DNR) showed widespread mismanagement of the Forest Conservation Act. In addition, the Hogan administration’s early attempts to find solutions to the complicated Conowingo Dam quandary deteriorated into a deeply flawed settlement agreement with Exelon. As Maryland’s leader, Governor Hogan designs the state budget that is related to resources, capacity, and staffing of different agencies and, ultimately, enforcement of established laws and regulations and any new executive orders.

Although he inherited departments with chronic understaffing, the Department of Legislative Services (DLS) analysis showed chronic staffing shortages across state agencies throughout the Hogan administration. Most notably, Maryland Department of Environment (MDE) was one of the agencies with the highest levels of chronic understaffing.

This has contributed to low numbers of enforcement actions against polluters, which disproportionately impacts lower-wealth communities and communities of color.

Fighting Climate Change: Energy PolicyB-
Fighting Climate Change: TransportationD
Environmental JusticeD
Land & Water ProtectionC

While he made strong statements committing to climate policy,  Governor Hogan and his administration has not adequately addressed the challenges posed by climate change. Maryland’s elected officials must do more to meaningfully combat the climate crisis and protect our environmental health.

Tell Governor Hogan that you value Maryland’s air, land, water, and people and urge him to boldly address the climate crisis.

Footnotes and References to the Report