Acadia Center staff look ahead to 5 key areas of focus in 2023.

Potential Impacts of Grid Modernization Advisory Council in Massachusetts Already Taking Shape

Creation of the Council

On August 11, Massachusetts Governor Charlie Baker signed comprehensive climate legislation that will help boost offshore wind, adoption of electric vehicles, and building decarbonization. Among the many pieces of this extensive legislation was a requirement to develop of a Grid Modernization Advisory Council (Council). As part of this provision, electric distribution companies would be required to develop grid modernization plans and submit them to the Council. Acadia Center is hopeful that this Council will ensure that utility grid modernization plans are regularly updated, maximize benefits delivered to ratepayers, and provide for greater stakeholder input and public participation. Even before its members have been appointed, we are already seeing the impact of this new entity.

Grid Modernization Dockets, DPU 21-80 through 21-82

On Wednesday, December 2, the Department of Public Utilities (Department) issued a ruling in DPU Dockets 21-80 through 21-82, grid modernization proceedings for Eversource, National Grid, and Unitil. These proceedings required the companies to submit updated grid modernization plans, as well as plans to achieve full-scale deployment of advanced metering infrastructure. The companies submitted separate plans that included a ten-year grid modernization vision, a five-year strategic plan, and a four-year investment plan covering 2022-2025.

Acadia Center generally supported the implementation of these plans, but argued for some changes. We were concerned that 1) the proposed timelines for implementing time-varying rates (TVR) were far too slow; 2) by using an opt-in approach to TVR, the companies’ assumed customer participation rates were significantly lower than would be optimal to deliver the maximum possible benefits to customers; 3) the AMI plans did not propose specific AMI deployment performance metrics; 4) the plans either made passing mention or no mention of equity or environmental justice; and 5) the companies did not prioritize data access for customers and third-party vendors.

Acadia Center had some success in the proceeding, achieving some direct wins, such as the Department asking the companies to include a uniform statewide approach to evaluating equity of preauthorized grid modernization investments. However, a number of requests were left up in the air, thanks to the development of the new Grid Modernization Advisory Council.

The Department evaluated grid modernization performance metrics proposed by the companies and found some of them wanting, specifically the grid-facing and AMI performance metrics. They found that “additional work [was] needed in collaboration with the parties to develop performance metrics that appropriately track the quantitative benefits associated with grid-facing and customer-facing investments, and progress toward grid modernization objectives.” The Department also acknowledged several stakeholders’ arguments about the timeline for TVR and directed the companies to work with stakeholders “to identify AMI meter deployment strategies that may expedite and maximize the availability of TVR products to customers during the AMI deployment period.” The companies must now convene a stakeholder process to settle a number of outstanding issues, including the two above. This stakeholder process will convene at the soon-to-be-created Grid Modernization Advisory Council, where there will now be significantly increased transparency, deliberation, and stakeholder participation and input.

Grid Modernization Advisory Council Impacts in Other Dockets

We have also seen the impact of the coming Grid Modernization Advisory Council in other dockets. DPU 20-75-C was a long-winding docket assessing electric distribution companies’ optimal solutions for long-term planning for the interconnection of distributed generation facilities. Unfortunately, despite significant time and work invested by stakeholders and the Department, the Department opted to close its investigation in light of the creation of the new Council. While Acadia Center is concerned by the seemingly wasted time and effort in that docket, the long and overwrought process highlighted the need for reforms that will hopefully be provided by the Council.

Similarly, in DPU 22-22, an Eversource rate docket, the Department declined to move ahead with several pieces, including an electrification framework and revised peak periods, noting that certain factors would have to be settled at the newly created Council.

Acadia Center is hopeful that this coming Council will result in comprehensive and state-of-the-art grid modernization plans and a transparent and open stakeholder process to address these important issues.


For more information:

Kyle Murray,,  617-742-0054 ext. 106

Mass. DPU Continues Fossil Fuel-Dominant Business-As-Usual

Earlier in December, the Massachusetts Department of Public Utilities (DPU) approved a petition by Eversource Energy to supply new gas service in the Town of Douglas, MA (DPU Docket No. 22-107). The town had initially requested gas supply as part of an economic development project and stated that gas service was a prerequisite before commercial and industrial customers would bring operations to the town. Douglas does not currently receive gas service, so to meet anticipated customer demand, Eversource must build new gas distribution infrastructure.

The DPU rejected arguments by Acadia Center and others that building brand new gas infrastructure is at odds with the Massachusetts’ climate goals and is not in the public interest. The Massachusetts 2050 Decarbonization Roadmap makes clear that to meet the state’s greenhouse gas emission reduction requirements, we must move rapidly away from fossil fuels towards clean and non-emitting alternatives.

Although the Douglas case involves a relatively small project, multiplying many small projects like this one will keep Massachusetts dependent on expensive fossil fuel infrastructure, rather than on a pathway of reducing emissions and ensuring a clean, equitable energy system for all residents.

And while the Douglas case and the DPU’s approval are not unusual, the proceeding is an important example of why Massachusetts must reform utility regulation and how a lack of reform will continue to result in business-as-usual outcomes that work in the interest of the fossil fuel industry.

Acadia Center’s RESPECT proposal seeks avoid these business-as-usual outcomes by reforming how long-term distribution planning is done. RESPECT proposes two key reforms to break down planning silos planning and reduce the financial conflicts of interest inherent to utility planning today. First, states should conduct comprehensive and independent energy system planning that incorporates more meaningful stakeholder input. Second, states should create neutral, statewide Planning Entities that can facilitate long-term planning and separate the entity that does the planning from the entity that owns the infrastructure and therefore has a financial stake in the outcome of the planning decisions.

The Douglas case can help us see how RESPECT reforms would lead to better outcomes. In its request to the DPU, Eversource included a short letter from National Grid (the electricity provider in Douglas) which explained that providing an all-electric solution—an option that would be much more aligned with the state’s climate goals—would require system upgrades that would take two to five years to complete.

Stakeholders, including the Attorney General’s Office, questioned the information provided by National Grid and expressed concerns that the underlying data and analysis was not made public. When asked about specifics of the electrification study that National Grid conducted, Eversource claimed that it “has no information to impart on the electric distribution service requirements” because it “is not the electric distribution service provider for the Town of Douglas.” (DPU 22-107, AG-1-5).

RESPECT attempts to break down exactly these types of planning silos. Under business-as-usual, in which gas and electric utilities are not required to fully coordinate on long-term planning efforts, problems like a two-to-five-year time horizon for electrification upgrades will not become apparent until a utility requests approval for new fossil infrastructure. By that time, as we’ve seen with Douglas, it will be easy for a utility to claim that electrification upgrades will take too long, and because the town need gas service now, the DPU should approve the new fossil infrastructure.

Successful implementation of RESPECT reforms would help to avoid scenarios where fossil fuel interests continue to win out over cleaner alternatives. RESPECT reforms would also enable greater transparency and access for stakeholders that are traditionally excluded from the planning process and would ensure that long-term planning prioritizes equity, environmental justice, and greenhouse gas emission reductions in addition to safety and reliability.

Acadia Center is working to implement utility planning reforms in Massachusetts through legislation and is hopeful that such reforms can help stakeholders, regulators, and utilities reimagine what is possible for the Commonwealth’s energy future.


For more information: 

Kyle Murray,,  617-742-0054 ext. 106 

Oliver Tully,, 860.246.7121 ext. 202

Acadia Center’s Impact in Eversource’s Rate Docket, DPU 22-22

On Wednesday, December 2, the Department of Public Utilities issued a ruling in DPU Docket 22-22, allowing Eversource to increase base distribution rates for electric service and approving a proposed Performance-Based Ratemaking (PBR) plan with a few changes championed by Acadia Center and other intervenors. 

During the process and in its brief, Acadia Center argued that Eversource’s PBR plan should be approved, though with several significant alterations. Below represents Eversource’s petition, what Acadia Center asked for in modifications, and what was approved by the Department. 

Negative X Factor – Rejected 

Eversource: A productivity factor is an accounting tool that attempts to measure the difference in the expected growth rates of an electric utility’s productivity compared to the overall economy. Eversource’s last rate case in 2018 resulted in the DPU approving, for the first time in the country, a negative productivity factor, which added over $135M in automatic rate hikes with no strings attached over the last 4 years. As part of this year’s rate case, Eversource again sought a negative productivity factor, -1.45 percent. The company initially claimed that without the negative X-factor, the company would need to come in for rate cases more often than once every 5 years, driving up transaction costs. 

Acadia Center:  As we did in the last rate case, Acadia Center asked the Department to reject the use of a negative X-factor, noting that Eversource’s proposed solution did nothing to address the underlying problem that the utility was becoming less productive every year. We noted that Eversource has received annual revenue increases under this plan of between 2.97% and 3.55%, totaling $135 million, and that a negative X-factor is unprecedented in the United States outside of Massachusetts. Acadia Center contends that a negative X-factor can result in an increase in revenues for the utility without creating a real incentive to improve performance overall or to deliver better outcomes for customers. 

DPU: The Department got rid of the negative X-factor – in a way. It approved an X-factor of zero, as Eversource relented to in rebuttal testimony, despite them stating in the same testimony that an X-factor set at zero would result in an unworkable PBR plan. As part of this compromise, the DPU approved other factors that will be advantageous to Eversource. 

Length of PBR Term – Shortened 

Eversource: After its 2018-2023 PBR plan, Eversource sought a ten-year investment plan, arguing that it would give them enough time to achieve its goals and to provide certainty needed to follow through with medium- and long-term strategic business decisions.  

Acadia Center: Acadia Center asked the Department to approve a five-year PBR plan, as had been approved by the Department in the past, particularly in situations where a company is expected to undergo substantial capital investments. Additionally, given the fast changing nature of energy, the assumptions that all parties make today are unlikely to be true in 10 years, and it is better for all to be able to revisit these issues in 5 years. 

DPU: The Department appeared to agree with Acadia Center’s arguments, ruling for a five-year term instead of ten. The Department noted that the substantial capital investments that Eversource is planning on undertaking, such as critical infrastructure projects and other investments necessary to comply with legislative and administration policy initiatives, were more in line with a five-year term. It determined that a five-year term would allow for the resources and flexibility necessary for Eversource to adjust its operations and investments efficiently, and, in turn, best ensure ratepayer benefits of increased operational efficiencies and improved service, and the opportunity for avoided administrative costs. The DPU also said Eversource could file a request to continue the PBR plan for another five years when this one ends. 

Return on Equity (ROE) – Lowered 

Eversource: An ROE represents the cap on what a utility can try to earn on its investments. Eversource sought an ROE of 10.5 percent, claiming it was needed to cover a revenue deficiency of $89 million. 

Acadia Center: Acadia Center noted that a 10.5 percent ROE would be wildly out of step with ROE’s approved in the region for utilities in similar situation and asked the Department to approve no higher than a 9.25 percent ROE.  

DPU: The DPU, for a number of complex reasons, chose to effectively split the difference and approve an ROE of 9.8 percent. They noted that this was within a reasonable range of rates that would preserve Eversource’s financial integrity, would allow it to attract capital on reasonable terms and for the proper discharge of its public duties, and would be comparable to earnings of companies of similar risk. In approving an ROE of 9.8%, not only did the DPU approve an ROE lower than what was requested, it approved an ROE that was lower than Eversource’s current ROE of 10%.

Stakeholder Engagement – Required  

Acadia Center also advocated for better stakeholder processes and input going forward, noting deficiencies in the process in this docket and with PBR metrics. The DPU also noted deficiencies in the proposed PBR metrics and ordered refinements to be conducted through an inclusive stakeholder process over the course of the PBR plan. The Department then set out specifics for that stakeholder process, such as requiring reports on the number of stakeholder meetings held and lists of stakeholders that participate. Acadia Center thinks that the forthcoming Grid Modernization Advisory Council, a stakeholder body established by the 2022 climate bill to provide to grid modernization and planning like what the EEAC has done for efficiency, might be a good venue to handle development of the metrics for PBR, as well as grid modernization. 

For more information: 

Kyle Murray,,  617-742-0054 ext. 106 

Massachusetts Clean Heat Commission Report Delivers a Bold Vision for a Decarbonized Future

The much-anticipated Massachusetts Clean Heat Commission (CHC) report dropped yesterday and was a breath of fresh air. Despite the Commission’s composition with fossil fuel and business-focused Commissioners outnumbering consumer and environmental advocates, they have delivered a strong proposal for real progress on decarbonization. Acadia Center staff are thrilled to engage with the incoming administration on how to implement the recommendations of this report and excited for the potential impact on the Commonwealth and the clean energy future we strive to achieve.

Among the best parts:

  • Finally Saying the Future is Electric: Despite not mentioning the DPU 20-80 “Future of Gas” docket or the gas utility business model at all, the report directly identifies that “[t]he Commonwealth’s long-term building decarbonization strategy requires transitioning customers from existing pipeline gas infrastructure to electric infrastructure and, where appropriate given technical and financial feasibility, networked geothermal districts.”
  • Identifying the Need for Joint Energy System Planning: The CHC proposes that the Governor and Legislature direct the DPU and DOER to conduct statewide joint energy system planning across Massachusetts’ gas and electric utilities and municipal gas and electric companies and in conjunction with key stakeholders and communities. In other words, “agencies, go do RESPECT – Acadia Center’s framework to modernize energy planning.”
  • Embedding Equity, Engagement, and Representation in Decision-Making: Centering equity, engagement, and representation in all aspects of our Commonwealth’s building decarbonization principles and practices is critical to ensuring that no ratepayer is left behind. The report recommends that these core principles inform the design of all programs and policies. Acadia Center wholeheartedly agrees.
  • Focusing on Institutional Coordination and Alignment: As Acadia Center has been arguing across the region for years, our climate goals are only as strong as the agencies empowered (or not) to implement them. Without buy-in from every entity across our state government, we will not be able to achieve our net zero requirements. The CHC’s recommendation for cross-cutting coordination will be critical to the Commonwealth’s success.
  • Ending Investment in New Gas Infrastructure: The report echoes what Acadia Center and other climate champions have been highlighting about natural gas infrastructure in a bold and powerful statement. “Investments that would support new or increased natural gas infrastructure or capacity should instead be deployed to advance measures that help support the net zero future.”
  • Considering New Ideas Like a Clean Heat Standard: Although details on the specifics of the proposed Clean Heat Standard (CHS) remain sparse, if properly designed, the CHS could serve as another valuable policy tool for cost-effectively electrifying and improving the efficiency of buildings in the Commonwealth without driving up costs to electric ratepayers. The details of how biofuels and hydrogen are treated in the CHS will be of critical importance and Acadia Center is looking forward to engaging on this topic as the details of the CHS get fleshed out.
  • Being More Realistic About the Decarbonization Potential of Alternative Fuels: Unlike the DPU 20-80 “Future of Gas” analysis – that completely ignored lifecycle emissions from biofuels – the CHC is clear about the need for a science-based, full lifecycle analysis of various biofuels to determine their carbon intensity. This is an essential step for determining whether supporting the use of specific biofuels in buildings via policy makes sense. The report also highlights that alternative fuels are “…not a long-term solution for most of Massachusetts’ building stock.”
  • Creating One-Stop Shopping for Climate-Positive Projects: Acadia Center agrees that Mass Save could use some reforms and that the whole suite of building decarbonization programs should get pulled together under an umbrella that provides a single point of contact for consumers. But the devil is in the details on the Building Decarbonization Clearinghouse, and we would hate to lose the transparency and stakeholder leadership brought about through the Massachusetts Energy Efficiency Advisory Council (EEAC). We are excited to get to work on this issue further and have a lot to say about it.
  • Expanding Building Benchmarking: Acadia Center has supported DOER’s work to expand building labeling and energy scorecards for years and continues to think it is one of the best ways to demonstrate the value of decarbonized buildings to owners and renters. The CHC’s recommendation to expand existing energy labeling programs to cover buildings under 20,000 feet is critical for driving rapid deployment of energy efficiency in residential and smaller commercial buildings.
  • Funding the Transition with New Resources: The CHC recognizes that ratepayer funds, payments from regulated suppliers, and market-based funds may not be enough to finance the decarbonization of buildings that we need. Although the discussion of using taxpayer funds focuses on effective use of federal funds, rather than opening the state coffers, we appreciate the willingness of the Commission to think creatively about how we’re going to pay for this. The Climate Bank, too, has the potential to inject needed finance dollars into this cause.
  • Creating Strategies for Decarbonizing the Affordable Housing Sector: Creating strategies for decarbonizing affordable housing represents an incredible opportunity for the next administration…or a potential for major failure if not properly centered. We simply cannot afford to leave our LMI households and environmental justice (EJ) populations behind, and the CHC astutely recognizes that fact.
  • Additional Ideas Worthy of Merit:
    o Workforce Training and Education
    o Research and Development
    o Public Outreach and Awareness
    o Expanding Green Communities and Leading by Example
    o Electric Operating Cost Reductions

Though this report represents exactly the kind of bold thinking necessary to drive Massachusetts toward its decarbonization requirements, some difficult questions are omitted, and others require additional detail. Acadia Center will tackle those in a separate piece.

Overall, the Massachusetts Commission on Clean Heat produced a visionary set of recommendations that show impressive foresight. Members of the Commission should be proud of their work, and we laud the administration for its dedication and output under an extremely tight deadline.


For more information:
Kyle Murray
Senior Advocate and Massachusetts Program Director
617-742-0054 ext. 106


Solving the Winter Energy Problem with Acadia Center

Year after year, the operator of New England’s electric grid, ISO-New England (ISO-NE), announces a risk of blackouts during the winter. New Englanders are stuck in a Groundhog Day scenario, asking: if this threat to the region’s electric grid happens every year, why hasn’t it been fixed by now? At a recent webinar for the Acadia Center community, our staff took on these vital questions.

Melissa Birchard, Acadia Center’s Director of Clean Energy & Grid Transition, explained how ISO-New England operates the region’s power grid and electricity markets. ISO-NE, with the backing of the federal government, has the power to institute measures like rolling blackouts to keep the electricity system safe during the winter. Although rolling blackouts would only occur if winter weather were to be unusually severe and prolonged, state utilities have been asked to plan for this possibility.

The region’s overreliance on natural gas is the root cause of these problems. New England has increased its use of natural gas to generate electricity by a massive amount in the last 20 years. New England relies on natural gas for over 50% of its fuel mix each year, which is risky both because an overreliance on any one fuel creates a liability and because natural gas is not produced locally in New England and is, therefore, more difficult to have on hand and subject to price spikes. Because natural gas is a fossil fuel, it also contributes to extreme weather, perpetuating the risk of blackouts. Our targets for climate health all involve eliminating the use of fossil fuels like natural gas now and in the coming years.

In the winter, natural gas is in high demand not only in New England, but around the country and the globe. It’s this increased demand that threatens rolling blackouts and that causes consumer bills to rise, as gas supplies are preferentially delivered to utilities to provide heat, rather than merchant generators to keep the lights on. This winter has added challenges due to Russia’s war in Ukraine, restricting global imports from a major global supplier of natural gas. In addition, supply chain issues due to the pandemic and climate change are elevating risks. These factors have made prices skyrocket and the chance of blackouts rise.

Acadia Center’s answer to this problem, which we detailed in a recent explainer written with our partners, is clean energy. Clean energy provides solutions for near-, medium- and long-term problems.

These solutions include:

  • Resource Diversity – Stopping the overreliance on gas.
  • Demand Management – Managing consumer demand in smart and strategic ways. This can include using residential solar and batteries to support the electric grid, automatically adjusting lighting and device charging, or delaying energy intensive processes in industrial facilities to help lighten the load on the grid during key stretches of time.
  • Bringing online clean, renewable energy – Resources like offshore wind are strong in the winter and healthy for our planet.
  • Energy storage – Saving energy for the times of highest demand, in short, medium, and long duration.

To implement these solutions, we need to scale up clean energy and transmission lines for newly generated clean energy to travel across the region. We also need to get behind new technologies and modern energy markets. Many of these solutions need to be driven by the New England states and ISO-New England working together.

Amy Boyd, Vice President, Climate & Clean Energy Policy, detailed some solutions consumers can implement in the near term. The biggest thing consumers can do is make sure their homes are as energy efficient as possible and shop around to get off fossil fuels. Alternatives like community choice aggregation offer more options and often come in at a lower cost than traditional utility bills due to greater diversity and added renewable energy. Community solar can also be a great way to participate in clean energy located in your community, even if you can’t add solar panels to your own roof.

It’s important to remember that rising energy costs and the risk of blackouts can disproportionately affect renters, lower income people, non-English speakers, and environmental justice populations. These communities are most likely to live in homes that are not weatherized or connected to green energy, meaning they are on average 25% less efficient, cost five times more to heat, and create 50% of greenhouse gas emissions The winter energy problem is a threat to everyone but presents even more serious concerns for these communities, so we need green solutions to help these communities that need it most.

You can watch the webinar any time to hear more about this topic, find more  for consumers looking to lower energy bills, and hear Amy and Melissa answer questions from the audience. This webinar was made possible by the Acadia Center donor community, and we’re so grateful for the support. If you’d like to join Acadia Center in the fight for the clean energy system of the future, please donate here.




Heat Pumps in Real Life – Part 2

If you’ve been hanging around Acadia Center’s blogs for very long, you’ve heard about how air source heat pumps work by moving heat, rather than generating it – so they can be 3-4 times as efficient as gas, and how “a heat pump is probably the biggest thing that consumers can to do help fight the climate crisis.” You might have even seen my colleague Ben Butterworth’s multiple photos in the Boston Globe as the face of heat pumps, or read about the lessons I learned back in May when investing in seven mini-splits to electrify my 1880s house.

But have you heard that under the Inflation Reduction Act, starting in 2023, heat pumps will be eligible for rebates and tax credits of up to $8,000, in addition to the rebates already in place from state programs like MassSave?

Here’s what I’ve learned from living with my heat pumps through one of the warmest summers in Boston, and into a fall that’s been both cooler than usual and repeatedly hit 70 degrees in November.

Power Cool: Even though this August was the hottest on record, my heat pumps kept my family comfortable and well air conditioned. Last year, we had one AC unit and a ton of fans to see us through August, and it was miserable. We spent too much time and money at the movie theater, mall, water parks, and other desperate ways to keep cool. This year, we happily spent our days at home in comfort. My daughter even discovered a “power cool” setting that sounded like a jet engine but felt amazing as it rapidly cooled her room. We did use 38% more electricity in August than the year prior but were easily 100% more comfortable, and spent roughly the same, once you factor in the movies and water parks. Although my home isn’t a good candidate for solar, I’m going to look into a community solar program, to be able to reduce our bills for next summer.

Dehumidification settings matter: My son’s asthma was flaring up late this summer and his room smelled even funkier than you’d expect for a 9-year old’s bedroom. I had a mold inspector come check things out. He didn’t find any mold but did find that the humidity levels in most of the house were 68-72%. Way too high. After some frustration, I dug into the settings on my heat pumps and discovered that the dehumidification mode (rather than the auto-cool setting I originally chose) resulted in a much lower humidity home with a much cooler feel. Better idea all around! So, watch out for humidity weirdness and play with settings. You may be surprised by what you find. Also run a full dehumidification cycle when you’re switching from cooling mode to heating season to make sure that you clear out all the moisture and prevent mold in the air handlers.

Keep it Clean: Although my instruction manuals said that I should clean the air filters monthly (and other filters periodically), I have only done it twice in the 6 months the heat pumps have been part of our family. Both times, though, there has been a lot more dust than I predicted. These things really are filtering the air! It’s important to keep the filters clean to maximize air flow, reduce the amount of energy they need to expend, and keep your air quality high. I’m going to put an alert on my calendar to make it more of a habit. I’d also encourage folks to install indoor units where they can reach them for maintenance – 10 feet into the air (like two of mine are) isn’t a great spot unless you love hanging out on ladders.

Shoulder season: I have been loving the flexibility that my heat pumps offer to heat up one room at a time or turn them on just enough to take the chill out of the air. With our radiators, it’s all or nothing and that first burst of heating inevitably wakes up my kids with all the banging. Especially on these days when it’s cold in the morning, but lovely by mid-day, I appreciate having the option to micro-adjust the temperature in my office or bedroom while leaving the rest of the house to float (because it also holds its temperature well after upgrading our insulation). And on the surprise 70-degree days, it’s nice to just turn the units off and not deal with residual heat like we would have with the radiators. As climate change makes our weather weirder, I’m glad to have equipment that can handle extremes in both directions and change up quickly.

Be a New Englander, Wear the Sweater: The first few days I tried to switch to heating mode, my heat pumps would run for a few minutes, then pause seemingly mid-cycle and show me an icon like a water droplet on top of a snowflake. This error message wasn’t included in any of the instruction manuals, and after some googling, I determined that it means that the outdoor temperature and humidity levels aren’t different enough from the indoor temp I’ve requested. In other words, my heat pump was telling me to suck it up and put on a sweater. It was right. Indeed, on the days when the temperature fell further, the error went away, and the unit started cranking out toasty warm air. I also remembered to lock closed all my windows, and that helped immensely, too.

The Financials: I got my full rebate from MassSave two months after it was submitted by my vendor. I’ve heard that it’s taking longer than in recent months because there’s been such a flurry of activity and rebate requests. Stay patient and keep checking the online tracker to see what’s happening. As I mentioned, my summer electric usage was 20-38% higher than last year (but we got a lot more AC out of the deal), but my fall usage has been within 15% of what it was. My gas use, however, was down 77% for the month of October. The biggest portion of my gas bills is now the $10 a month customer charge – indicating that once I get an induction stove and heat pump water heater, I can save even more by ditching gas entirely.

The Bottom Line: For me, the investment in heat pumps was more about comfort and doing what we could to decarbonize than it was about saving money. We have not saved much from the summer, but that’s to be expected with so much added air conditioning. I am excited to see how much we’ll save this winter! Check out the MassSave heating comparison calculator if you want to see the potential savings for your home. This year, I’m even looking forward to snow, so we can really see how the heat pumps fare and hope to make it through the winter without turning on our backup system. I’ll let you know in the spring!





Why Keeping Hydrogen Out of Easily Electrifiable Sectors Matters

Is hydrogen a clean energy source?

It depends. Hydrogen does not release greenhouse gas emissions when it is used, so, similar to electricity, what really matters from a climate perspective is how the hydrogen is produced. That can range from very dirty to very clean. The vast majority of hydrogen used today is made from natural gas and produces a lot of greenhouse gas (GHG) emissions. Hydrogen produced in this manner is often referred to as “gray hydrogen.” There are also methods of producing “green hydrogen,” most notably by using renewable electricity to break water into hydrogen and oxygen through a process known as electrolysis. But, regardless of how hydrogen is produced, emerging research has found that – just like natural gas – hydrogen that leaks directly into the atmosphere is damaging to the climate.

What is hydrogen’s current role in our economy?

Today, hydrogen is used in industrial processes like oil refining and fertilizer production. In recent years, there has been expanded focus on the potential for using hydrogen to help decarbonize other sectors of the economy including power generation, transportation, and the natural gas distribution system. The question of whether to blend hydrogen into the natural gas distribution system to reduce the overall GHG emissions associated with using natural gas has been a particular hot button issue across the country, and particularly in the northeast.

Why is hydrogen suddenly a hot topic in the Northeast?

Many of the gas utilities in the Northeast have proposed hydrogen blending as a core strategy in their decarbonization plans and some are actively pursuing hydrogen blending pilot projects. The appropriate use of hydrogen was a key point of debate in the Massachusetts Future of Gas docket and four northeastern states (New York, New Jersey, Connecticut, and Massachusetts) have partnered to pursue a portion of the $8 billion of funding available through the Department of Energy to create a “regional hydrogen hub.”  Hydrogen is a central point of discussion in the currently underway updates to Connecticut’s Comprehensive Energy Strategy and Connecticut recently formed a Hydrogen Task Force to study hydrogen’s role in the state’s economy and energy infrastructure. Hydrogen will also undoubtedly be a focal point in Rhode Island’s own “Future of Gas” docket that recently kicked off.

What are the key problems and limitations associated with hydrogen?

Even if hydrogen is “green” (i.e., produced with 100% renewable electricity), it still faces a number of issues and limitations. Perhaps most importantly, most experts agree that hydrogen can only safely replace 7% of the total energy flowing through the gas distribution system, dramatically limiting any potential climate benefit of hydrogen blending. We still need to decarbonize  the other 93%. How? Gas companies have proposed replacing the remaining natural gas with so called “renewable natural gas” which is extremely problematic.

Additionally, the process of producing green hydrogen is inefficient and requires a huge amount of renewable electricity. As a result, for most sectors of the economy, it makes more sense to use clean electricity to “directly electrify” those sectors, rather than adding the inefficient middle step of converting that clean electricity to hydrogen. For example, using clean electricity to run a heat pump for heating a home is about five times more efficient and significantly more cost effective than using that same clean electricity to produce green hydrogen, blend that hydrogen into the gas system, and then burn that hydrogen in a boiler.

Because green hydrogen requires so much clean electricity to produce, producing green hydrogen at scale would require a ton of land to site the wind turbines and solar panels. We simply will not have enough land to produce green hydrogen at the scale necessary to decarbonize the whole economy. The limited green hydrogen we will have should be allocated to the sectors of the economy that are hardest to electrify, like aviation, shipping, and certain industrial processes. It is critical to use this limited resource strategically, and not waste it in sectors of the economy that are relatively easy to electrify, like building heating and passenger vehicle transportation.

Are there safety concerns associated with hydrogen?

Hydrogen does present unique safety challenges. It is the smallest molecule in the universe and is prone to leaks, highly combustible, and burns with a nearly invisible flame. So, while hydrogen is relatively safe in an industrial facility where trained professionals can constantly monitor the equipment, it does pose significant safety risk when you consider scenarios like people burning hydrogen in a furnace at their home.

What are the alternatives to hydrogen and why should we use them?

It is going to depend on the sector. As mentioned before, there are sectors of the economy that are exceedingly difficult to electrify such as shipping, aviation, certain industrial end uses, and chemical production. We are almost certainly going to need some amount of green hydrogen to decarbonize these sectors, but for many parts of the economy the main alternative is direct electrification using technologies like heat pumps and electric vehicles. For cars and home heating in particular, direct electrification is the superior alternative from basically any angle you can think of: Cost, efficiency, safety, and overall practicality.

Why should people be concerned about the gas company proposals to blend in hydrogen?

Direct electrification of homes using heat pumps and electric water heaters is a more cost-effective and safer means to decarbonize homes and save consumers money. Allowing gas utilities to blend hydrogen into the gas distribution system is a short-sighted decision that will only marginally reduce greenhouse gas emissions, cost ratepayers money, and distract from the more practical solution of electrification.

How do Acadia Center’s CLEAN-E and Beyond Gas Initiatives address these concerns?

Acadia Center is actively engaged in discussions around hydrogen in various forums  in Massachusetts, Connecticut, and Rhode Island. Acadia Center is leveraging our technical expertise related to hydrogen and our analytical capabilities to question modeling assumptions through independent quantitative analysis, develop detailed public comments, present to state agencies, and educate partners. Acadia Center is also a member of the Connecticut Clean Energy Task Force Hydrogen Uses Working Group. Throughout all these processes, Acadia Center is providing technical analysis and research to demonstrate the limitations of using hydrogen in the gas distribution system and the benefits of electrification paired with energy efficiency.

How can people act on this and push for renewable, efficient sources of energy?

There are a few ways for people to get involved. You can write a letter or call your congressperson and advocate for hydrogen to be left out of the easy-to-electrify sectors like home heating and light-duty transportation. Additionally, weatherizing and electrifying one’s home with heat pumps and electric water heaters would lower demand for natural gas. The Inflation Reduction Act has made weatherizing our homes far more affordable, and you can learn more about that here.


For more information:
Ben Butterworth, Director of Climate, Energy, and Equity Analysis,, 617-742-0054  ext. 111

The Third RGGI Program Review Should Advance Equitable Investments and Climate Goals

The Regional Greenhouse Gas Initiative (RGGI) is a market-based, cap-and-invest greenhouse gas reduction effort among the states of Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont, and Virginia. RGGI has been a pioneer of climate policy since its founding in 2009, generating $5.6 billion in proceeds for participating states over the last 13 years. 

Every five years or so, RGGI undergoes a program review, giving the participating states the opportunity to consider the program’s performance and make various changes including the equitable disbursement of the program’s proceeds. RGGI’s third Program Review is happening now and will last through 2023. In addition to securing effective greenhouse gas emissions reduction targets, Acadia Center is advocating that the current review process focuses on returning proceeds to the environmental justice (EJ) communities that host a major share of fossil fuel infrastructure but that have not received a proportionate share of clean infrastructure benefits. Together with EJ organizations and other partners across the RGGI footprint, we are also spotlighting improvements needed to RGGI’s market-based mechanisms to provide both greater resilience to the program and optimize emission reductions. 

Ensuring Equitable Investment 

The RGGI Memorandum of Understanding (MOU) is the framework for all states to participate in RGGI, signed by the governors of each participating state. However, the MOU does not impose any requirement for the states to guarantee the equitable investment of the monetary proceeds from the emissions auctions operated under the cap and trade program, which aims to stabilize and reduce emissions while remaining consistent with overall economic growth and a safe and reliable electric power supply. Most of the participating states lack procedures to ensure RGGI-funded investments deliver meaningful and proportional benefits to overburdened and underserved communities. Many states invest RGGI proceeds into clean energy projects that, while effective in reducing climate pollution, fail to address inequities that are a legacy of dirty energy as well as inequities that continue to arise as part and parcel of the clean energy transition. In other cases, RGGI funds have been used to fill state budget gaps, addressing neither climate nor justice imperatives. 

During the second RGGI Program Review in 2017, Acadia Center, environmental justice organizations, and many other partners from across the region submitted comments to RGGI1 calling on the RGGI states to require investments of RGGI auction proceeds in environmental justice communities. It has been five years since those comments were submitted, yet the RGGI program still requires no commitment from participating states to invest proceeds equitably. Since the time of these comments in the second Program Review, programs across the US have committed to environmental and energy justice including California’s 35% minimum from cap-and-invest, the federal Justice40 framework, New York’s 40% commitment from Climate Leadership and Community Protection Act (Climate Act) and New Jersey’s new EJ law. But the equitable investment of auction proceeds accrued from RGGI remains a glaring work in progress for the RGGI program and should be the priority for improvement in the third Program Review.   

Soliciting and Incorporating Input from Environmental Justice Communities 

The Program Review offers another important chance for the RGGI states to make a detailed assessment of how RGGI funds are being invested in communities and work to make those investments more equitable, both through RGGI itself and through accompanying state laws. As an initial matter, RGGI must offer ample opportunity for public comment throughout the Program Review while reaching out to capture the input of key communities. The second Program Review offered a range of opportunities for participation from residents, community-based organizations, and environmental justice advocates. It is even more important for the third Program Review to incorporate the voices of communities, both through public comment opportunities and concerted community outreach. The updated Program Review timeline contemplates ongoing engagement with communities on environmental justice and equity in fall 2022, continuing through fall 2023. This outreach and engagement should be tailored to increase the understanding of the program’s achievements to date while addressing the full scope of concerns that environmental justice communities may have about the market-based cap-and-invest program, including its impacts, its mechanisms, and how its proceeds are spent. RGGI should work to increase participation by scheduling meetings at multiple times of the day, involving an interpreter in public hearings to alleviate language barriers, and translating materials into multiple languages. Additionally, the RGGI program must focus presentations on the EJ impacts of RGGI to date and investigate potential solutions, as well as make provisions to track comments and suggestions from communities of color and environmental justice communities on program changes. 

Tackling Emissions Reductions with Reforms to the Cost Containment Reserve (CCR), Price Floor, and Emissions Containment Reserve (ECR)  

To limit emissions from the electric power sector, RGGI sets an annual carbon dioxide emissions cap from all RGGI states. More recently, participating states have set individual, ever-more aggressive emission reduction targets to decarbonize the electricity sector. By 2050, most participating states will be striving for net-zero emissions. RGGI’s regional cap and market mechanisms have yet to reflect these targets. The RGGI cap and market mechanisms need to be restructured to assist states in achieving their ambitious state-level targets for decarbonization of the power generation sector.  

RGGI’s market mechanisms are outlined by the Model Rule, a set of prescribed rules that serves as the framework for the CO2 Budget Trading Program in each RGGI state. The Model Rule has undergone recurrent revisions since it was first created, and mechanisms such as the Cost Containment Reserve (CCR), Price Floor, and Emissions Containment Reserve (ECR) should be highlighted for further reform for as part of the third Program Review. 

RGGI’s Cost Containment Reserve (CCR) is a mechanism that provides the market with a ceiling price. This means that when the price of emissions allowances in an auction carried out by RGGI is equal to the CCR price, RGGI will release additional emission allowances into the market. In practice, when the trigger price for the CCR is low, the CCR can become a mechanism for polluting facilities to avoid aggressive emission reductions. The CRR has been triggered three times in RGGI’s history and the last auction that triggered the CCR was in December 2021. However, the last three auctions have narrowly avoided the CCR trigger by only a few cents, highlighting the potential future significance the CCR has in dictating the volume of emissions allowances that are released. Acadia Center advocates substantially raising the CCR trigger price, as doing so would be a step towards reducing the power sector GHG emissions in line with state-level emissions reduction targets.   

Similarly, the RGGI Model Rule sets a price floor for allowance auctions, which is the minimum price for an allowance. In 2022, the Price Floor is $2.44 per ton, with a 2.5% rate of increase each year. In RGGI’s 57 auctions since 2009, the Price Floor had only been reached 10 times with the last time being almost 10 years ago, in December of 2012. RGGI should increase the Price Floor and establish a more ambitious rate of increase closely aligned with market prices in the most recent years’ auctions. This reform will ensure that prices will stay more consistent and RGGI states will still have the proceeds necessary to encourage stable investments in renewable electricity and energy efficiency, to grow these resources and contribute to overall decarbonization. 

Since January of 2021, RGGI has implemented an Emissions Containment Reserve (ECR), a mechanism to withhold up to 10 percent of emission allowances when the market price falls below the trigger price. However, it is essential to ensure that states can make use of this mechanism in an equitable and fair manner. Acadia Center recommends that RGGI increase the ECR trigger price to reflect the aggressive emission reductions the states need to achieve. The ECR trigger price, which is currently $6.42 per ton, will only rise to $11 in 2030, a figure far below this year’s average market price. For the past three auctions, the ECR price has been twice the market price and therefore has been rendered almost irrelevant, failing to reduce emissions as designed. 

In its advocacy with the RGGI states and with RGGI, Inc., Acadia Center works with a coalition of environmental justice organizations, community-based groups, environmental and energy policy organizations, and other partners from across the RGGI footprint. Our shared objectives are to achieve more ambitious emissions cap goals, improvements in air quality – especially in overburdened and underserved communities – and a commitment from all participating states to ensure equitable investment of RGGI proceeds in environmental justice communities. We are also currently working to update our 2019 report entitled “The Regional Greenhouse Gas Initiative: Ten Years in Review” to include information on RGGI’s successes and opportunities from 2019 to the present. Please speak to your state energy leaders about how RGGI can better serve you and your communities – and stay tuned to the Acadia Center website for more information.  

For More Information: 

Paola Moncada Tamayo, Policy Analyst,, 860-246-7121 x204
Joy Yakie, Manager, Environmental Justice & Outreach,, 617-742-0054 x110 


Connecticut Explores Performance-Based Regulation for the State’s Utilities

In August 2020, Tropical Storm Isaias left more than 1 million customers in Connecticut without power. For many customers, it took nearly a week to restore power.

Partly in response to the storm, state legislators passed the “Take Back Our Grid” Act (PA 20-5). The bill required the state’s investor-owned electric utilities, Eversource and United Illuminating, to provide credits back to customers for the delayed storm response. It also required the Public Utilities Regulatory Authority (PURA) to open a proceeding to explore and implement a new framework for how the state should regulate its investor-owned utilities.

While Tropical Storm Isaias may have been a catalyst, adopting a new approach to utility regulation—specifically Performance-Based Regulation (PBR)—has been a nation-wide conversation for years. Performance-Based Regulation includes a broad set of policy tools that regulators can use to tie utility revenues more directly to improved performance, helping to overcome outdated financial incentives.

PURA’s PBR proceeding is a key opportunity to help make utilities work better for customers.

What would it mean to improve utility performance through PBR? Regulators could, for example, require utilities to track the number of customers enrolled in time-varying rates, which have been shown to help reduce both costs and greenhouse gas emissions. Often, tracking data in scorecards leads to improved performance based simply on the pressure of public comparisons to peer companies. But if regulators felt that there was sufficient data and experience to set specific performance targets for the metric being tracked, here enrollment in time-varying rates, they could then impose either rewards or penalties (or both) according to how performance changed over time.

PURA’s PBR proceeding began in earnest in March 2022. The process is expected to last well into 2023, and possibly 2024. While this is a long proceeding, it is critical to make sure that regulators take the time to consider all potential solutions.

Acadia Center has been working closely with other advocacy groups in Connecticut, including Vote Solar, Conservation Law Foundation, and Save the Sound, to raise awareness about the proceeding and to ensure that the proceeding incorporates a broad set of interests and perspectives.

While PURA and stakeholders will figure out many details over the coming months, PURA’s overarching goals for any PBR framework in Connecticut are to 1) enhance electric distribution company performance; 2) advance public policy; 3) improve customer empowerment and satisfaction; and 4) ensure reasonable, affordable, and equitable rates.

So far, PURA has held three stakeholder workshops, each with an accompanying working paper from PURA staff to gather specific feedback from stakeholders. While later stages of the proceeding will explore performance metrics and potential rewards and penalties in more detail, the process so far has helped stakeholders develop a better sense of which regulatory tools in Connecticut are working and which are not.

As the proceeding continues, Acadia Center will work to ensure that a broad set of voices are heard and to make sure that any new regulatory tools support key public policy goals and prioritize customers.

For more information, including Acadia Center reports and an introductory webinar on PBR that Acadia Center co-hosted with Vote Solar, Conservation Law Foundation, Save the Sound, see: