Acadia Center Comments in Response to Massachusetts Draft Non-gas Pipeline Alternatives (NPA) Framework

The Massachusetts Department of Public Utilities (DPU), through its order in D.P.U. 20-80, requested that the natural gas distribution companies engage with stakeholders to develop a non-gas pipeline alternatives (NPA) framework. NPAs are defined broadly to include decarbonization solutions including electrification, targeted energy efficiency, and demand response that can help to avoid traditional investments in the gas system. Going forward, gas companies will have to demonstrate that NPAs were adequately considered and found to be non-viable or cost prohibitive to receive full cost recovery. Through participation in the NPA Working Group and NPA Technical Subcommittee, Acadia Center has actively provided input over the last several months to inform the development of the NPA Framework and recently submitted comments in response to the Draft NPA Framework developed by the natural gas distribution companies in Massachusetts. The comments touch on a number of topics, including concerns that limitations associated with the proposed cost-benefit testing procedure may screen out too many promising NPA projects and how the relatively narrow scope of the NPA Framework highlights the need for more holistic, big-picture gas system planning to minimize the risk of future stranded gas system assets as the Commonwealth moves towards decarbonization of the built environment.