How Massachusetts Can Make this Decade Count: Acadia Center Weighs in on the Interim CECP
Overview
As the decade opens, Massachusetts is breaking new ground in climate policy with stronger, legally binding carbon emission targets and an ambitious 10-year plan that will set the course for a just, equitable, and decarbonized economy by 2030. These advances are the outcome of several years of focused advocacy, analysis, and stakeholder engagement. Acadia Center is pleased to have been a leader in this process through ACES coalition engagement, as an original member of the Implementation Advisory Committee, and by drafting and organizing comments on the Interim Clean Energy and Climate Plan (CECP) for 2030.
Overall, Acadia Center believes that the interim Clean Energy and Climate Plan (CECP) provides the Commonwealth and its stakeholders a solid basis upon which to advance climate policy. Acadia Center provided extensive detailed comments to the Plan, including several overarching points:
- With the passage of S.30 into law on March 26, 2021, Acadia Center recommends EEA update its Roadmap Modeling scenarios and issue a final 2030 CECP that accounts for the more stringent, science based 50% economy-wide target and the new statutory requirements related to all major carbon-emitting sectors; and
- Acadia Center urges EEA to refine the final CECP’s specificity regarding how the state will achieve the components of the plan. This should include: establishing the timing for each action in the plan, identifying the agency or department responsible for overseeing the action, estimating any additional funding necessary, and determining the need for additional statutory or regulatory authority to fully implement all actions in the plan.
The bulk of Acadia Center’s comments focused on buildings and energy supply. Acadia Center is committed to supporting the effective implementation of the final CECP for 2030 through engagement with the Executive Office for Energy and Environmental Affairs and other responsible agencies and the many interested and affected stakeholders seeking to ensure that Massachusetts reaches its 2030 climate goals and set the state on a path to reaching a net-zero economy.
Transforming our Buildings
As Massachusetts prepares to implement an unprecedented policy program to reach zero net emissions by 2050, the targets included in the interim CECP for the buildings sector are appropriately ambitious. Acadia Center commends the Commonwealth for recognizing the critical role that a decarbonized commercial and residential building stock will play in reducing overall emissions. Buildings account for nearly a third of the Commonwealth’s annual emissions, and rapid building electrification is the only reasonable way to eliminate these emissions.
Acadia Center presented a number of recommendations for the interim CECP’s approach to building electrification, including:
- The creation of a specific framework for electrifying one million homes and 300-400 million square feet of commercial real estate by 2030;
- The necessity of a regulatory or legislative target to ensure rapid progress and jump-start the marketplace for zero-emissions-ready technologies in buildings;
- Address Mass Save program’s design and cost-effectiveness accounting methods that may limit electrification;
- Prioritize weatherization, supported by strong education and awareness campaign and implemented through expanding workforce development and jobs;
- Use solid data to carefully track the progress of the deployment of the measures in buildings;
- Fully prepare for the challenges in electrifying and weatherizing older, substandard housing;
- Target improving housing in environmental justice communities and make it possible for renters to participate in weatherization and electrification programs; and
- Revisit electric rate design to ensure that electric rates reflect and support the Commonwealth’s electrification policy goals.
Transforming our Energy Supply
Similarly, Acadia Center reviewed the interim CECP’s plans to achieve the 2030 target through strategies aimed at the state’s Energy Supply. A successfully decarbonized electric grid will serve as the backbone to economy-wide decarbonization efforts in the building and transportation sectors. Acadia Center’s comments on the Energy Supply sector focused on the need to ensure continued progress in meeting the Commonwealth’s renewable energy procurement targets while ensuring proper siting and equitable outcomes. The comments also reinforced the need for significant reforms of both the regional market and the distribution-level system.
Acadia Center detailed its concerns regarding the interim CECP’s lack of commitment to further deployment of clean energy generation beyond what is already planned in anticipation of future market reforms. Those regional reform processes, particularly at the ISO-NE level, are likely to take years, and this should not be a justification to pause or curtail renewable generation procurements in the meantime.
Acadia Center’s comments presented a range of recommendations about Energy Supply, including:
- Expand solar power while protecting farmland and forests, incentivizing development on contaminated and brownfield sites, and providing stakeholders with clarity, predictability, and technical assistance to address siting challenges;
- Extend the applicability of the state’s climate and clean energy policies to include Municipal Light Plants;
- Require that future imported energy under the Global Warming Solutions Act (GWSA) be subject to stringent attribute accounting procedures and tracking systems;
- Explore using existing and possibly new transmission resources in a bi-directional method to employ existing Canadian hydropower as a form of pumped storage; and
- Exclude additional buildout of hydroelectric impoundment dams in Canada and elsewhere from eligibility in procurements and other clean energy policies.
Acadia Center-led Coalition Comments on the Future of Gas
Acadia Center was the lead author and coordinator of coalition comments focusing on the need for the CECP to address the use of natural gas in buildings. The Commonwealth continues to use gas in buildings for space heating water heating and other uses, contributing to more than 18% of the state’s emissions as of 2016. Yet gas companies continue to build new pipelines and solicit new customers, who install new gas equipment, which in turn increases emissions, damages public health, and locks in more stranded assets each year. Acadia Center and 37 co-signers urged the Commonwealth to add clarity to the goals of the CECP as they relate to gas, so future planning will take into account the Commonwealth’s targets. The specific recommendations include:
- Creating a cross sector infrastructure plan that addresses both the increase in demand for electricity through electrification and winding down of gas use in buildings;
- Retaining an independent consultant to support EEA’s capacity to address the public’s needs and as a counterbalance to the gas companies’ consultants engaged in the DPU’s inquiry into the future of gas companies;
- Focus on electrification rather than alternative fuels like hydrogen and renewable natural gas to reduce emissions in buildings;
- Require accurate accounting for methane leakage from the gas pipeline and distribution system
- Design the next Mass Save 3 year plan with the gas phase out in mind;
- Accurately and holistically account for the costs of the health impacts cause by maintaining or expanding gas infrastructure; and
- Provide realistic and well-publicized pathways away from gas for low-income and other marginalized households.
Other Joint Coalition Comments
Acadia Center contributed to and signed on to the following joint comments with a broad range of advocacy and activist groups on both transportation and environmental justice.
Transportation recommendations prioritized a multi-pronged approach to reducing transportation emissions, including tailpipe pollution that disproportionately harms marginalized communities and greater emphasis on public transit. These provisions include:
- Expanding public transit service and electrifying transit buses and trains;
- Ensuring equitable and timely investment through the Transportation and Climate Initiative Program;
- Increasing EV sales goals to 50% by 2030;
- Modifying EV rebate programs to accelerate deployment and expand access to electric mobility options;
- Accelerating the coordinated deployment of EV charging stations;
- Prioritizing electrification of cars, trucks, buses and private fleets in environmental justice (EJ) communities;
- Implementing strategies to reduce vehicle miles traveled (VMT); and
- Improving and expanding public transportation and biking and pedestrian infrastructure.
Environmental Justice recommendations focused on the need to center and prioritize justice, equity and worker rights in the CECP to address unequal burdens to impacted and vulnerable communities and avoid further harms to those communities as Massachusetts transitions toward a pollution-free economy. Among the many important recommendations are the following:
- Improve community engagement and EJ considerations in infrastructure siting
- Require diverse hiring and workforce development practices across all sectors to achieve quality jobs
- Not assume that any biogenic feedstocks are “zero emission” or “net zero”
- Prioritize investments in overburdened and underserved communities
- Address the environmental justice and low-income needs for public transit, EV incentives, electrification of public transit fleets and school buses, diesel phase out, alternative transportation modes
- Address heating fuel emissions from existing buildings, and provide funding and other support for LMI and EJ populations
- Focus Mass Save/Energy Efficiency programs on pre-electrification, weatherization, and electrification
- Remove MSW and woody biomass from eligibility in clean energy incentive programs
- Eliminate existing and ban future high heat waste facilities (MSW) and employ zero waste policies
- Preserve existing trees and plant new trees in urban areas
- Allocate funds and jobs for climate adaptation projects that benefit EJ populations
Contact for more information:
Deborah Donovan, Massachusetts Director
ddonovan@acadiacenter.org
617-742-0054 ext.103
New England Governors’ Energy Vision: Shifting Power on the Regional Electricity Grid
Acadia Center works at the forefront of the effort to move toward a just, equitable and climate-focused future for New England and the Northeast. Central to that shift is the urgent need to fundamentally reshape the system we rely on to deliver electricity over the regional grid. We must ensure the region has an electricity grid that can serve the needs of a fully electrified economy while rapidly evolving toward greater reliance on newer, cleaner, and more advanced energy technologies, including renewable generation powered by the wind and sun, energy storage, and flexible energy demand. The region must approach this transformation by putting the needs of customers at the center, especially the needs of those hose communities have borne a disproportionate economic burden of the detrimental impacts of energy, endured the damaging impacts of the fossil-fueled system and are at greatest risk when it comes to climate-driven disasters.
Today, the way the region’s electricity grid is planned and operates neglects to consider the climate crisis and environmental justice priorities while perpetuating our dependence on fossil fuels. That is largely because the grid is not currently managed to embrace viable clean energy technologies or consider the impacts of its decision on vulnerable communities. Over the last year, Acadia Center, states, and a multitude of stakeholders throughout the region have intensified their commitment to transform the electricity grid through reforms that will reduce the burdens the grid places on consumers and the planet and broaden the universe of stakeholders providing input into goals and priorities for the region. The outcome of these ongoing discussions will have far-reaching implications for achieving state climate policy goals and establishing a clear pathway toward a fully decarbonized economy.
Who’s got the power now?
The Independent System Operator of New England (ISO-NE) is a non-profit entity formed over 20 years ago to oversee the electricity grid that serves all six New England states. It manages the wholesale electricity market so there is sufficient electricity generation capacity to reliably and cost-effectively meet consumer demand at all times. When the ISO was created, electricity mostly came from centrally dispatched plants fueled by nuclear, hydropower, coal and oil, mostly owned and operated by for-profit corporations. Over the last two decades, the region’s energy needs have been increasing met through gas-fueled power plants as fracked gas became increasingly cheap and was perceived as lower-polluting than dirtier coal and oil.
There is one notable success story that demonstrates the meaningful benefits that state clean energy commitments provide to consumers and the climate. Investments in energy efficiency programs and solar energy have cut the region’s energy use by 15%, and continued expansions of efficiency and solar could result in as much as a 25% reduction, conferring significant savings and carbon reductions.
In many ways, ISO-NE’s decisions are stuck in this out-of-date world centered on fossil fuels. The status quo benefits the owners of today’s fleet of plants and is holding the region back from fully achieving a clean energy future. What’s more, the byzantine, exclusionary decision-making forums dominated by ISO staff, its board, and the powerful incumbent energy companies shut out the people most affected by the decisions that result.
What is needed?
Times have changed and our grid must change with it. Today, access to affordable, clean sources of electricity, and investing in efficiency and emerging technologies will enable us to transform the grid yet again into the grid of the future, one that equitably meets everyone’s needs as we face the climate crisis. And that means changing the mission of the entity that operates the grid to one that:
- Prioritizes attaining state policy goals for clean energy and climate emission reductions
- Supports the expansion of renewable energy resources, including community-based sources
- Ensures full consideration of the justice and equity implications of the grid’s impacts
- Makes decisions by accounting for all benefits (reducing carbon emissions) and costs (damaging public health and the climate)
Where’s it going? New England Governors’ Energy Vision of Regional Cooperation
In October 2020, the New England Governors released a Vision Statement expressing dissatisfaction with this status quo, and committing to fully transparent, publicly accessible regional discussion about three major areas of concern: wholesale energy market design; transmission infrastructure planning; and governance. After issuing their public commitment to regional cooperation in March 2019, the states have been frustrated with the slow progress and narrow scope of discussions happening behind closed doors between ISO leadership and members of NEPOOL, the regional stakeholder body. The Governors’ October Vision Statement describes in detail the states’ mutual concerns about the inability for the regional market to enable the states to meet their clean energy and climate goals in a timely and optimal way. Specifically, the statement:
- Lays out a set of minimum principles necessary to address the fundamental shortcomings of the energy market rules;
- Articulates the priorities for a significantly re-engineered transmission planning process; and
- Calls for an update of the ISO’s mission statement, governance structure, and mechanisms for stakeholder participation.
“A clean, affordable, and reliable regional electric grid – together with transparent decision-making processes and competitive market outcomes that fully support clean energy laws – is foundational to achieving our shared clean energy future… To achieve these goals, we need a decarbonized grid capable of supporting the accelerated adoption of more sustainable electric, heating, and transportation solutions for families and businesses.”
— Governors’ Statement on Electricity System Reform
The states committed to holding a series of public forums focusing on the three topics (wholesale energy market design, transmission infrastructure planning, and governance), and are seeking stakeholder input in the form of written comments. Overall, the Governors have set the stage for the region to reach resolution on a range of interrelated issues by putting state climate policy and stakeholder needs at the center of the process. Acadia Center strongly supports and presses for the commitment to reaching consensus solutions, understanding that politically durable progress must begin with states asserting themselves and taking control of the dialogue. Acadia Center and its coalition partners have attended three forums and have prepared comments on Market Design, Transmission Planning, and Governance issues. In Acadia Center’s comments, we have raised substantive policy reforms for consideration, including their implications for a just transition.
Thus far, calls for fundamental reforms have been met with strong resistance by the ISO and incumbent stakeholders that dominate the NEPOOL and ISO agendas. With the states opening the forums up to everyone, this process has the potential to bring about reforms that can bring the region an electricity system that is centered on the states’ climate commitments and protective of all the region’s residents. This process has the makings of a major paradigm shift.
What’s next? The Energy Vision Forum on Equity and Environmental Justice
While Acadia Center applauds the states for launching the Energy Vision initiative, we were concerned about the initial lack of focus on equity and environmental justice outcomes. It is essential that these values be considered when weighing the range of market design, transmission, and governance reforms. And that can only happen when the voices of front-line communities are part of the conversation from the beginning. After hearing about these concerns, the state organizers agreed to add a fourth forum focusing on environmental justice and equity.
On March 18, 2021, the states convened the fourth and final forum designed to be a dialogue between state policymakers and the public to address equity and environmental justice concerns. The virtual forum was free and presented in both English and Spanish. A recording of the session is located on the New England Energy Vision website as well as presentations by the speakers. Stakeholders can join the mailing list to hear about next steps by signing up here. In addition, stakeholders are invited to submit written comments regarding equity and environmental justice perspectives on the regional energy grid. Comments should be sent to Claire.Sickinger@ct.gov by April 29, 2021.
Conclusion
Acadia Center is working to ensure that New England has an electricity grid that can rapidly evolve toward greater reliance on cleaner, safer, and more affordable energy technologies, including renewable generation powered by the wind and sun, energy storage and flexible energy demand. The region’s governors have opened a dialogue on a range of interrelated issues by putting state climate policy and stakeholder needs at the center of the process. As the initiative progresses, Acadia Center will be pressing states to set and meet a high bar when it comes to delivering forward looking solutions that put equity and environmental justice concerns that their center. Acadia Center will work with allies to unlock the door to a clean energy future while pushing for greater accountability, transparency, fairness, and equity for the communities that bear the worst burdens of our fossil fueled electricity grid.
Additional Resources:
- Acadia Center remarks at the CT League of Conservation Voters 2021 Legislative Planning Summit
- Meeting recording [starting at minute 39]
- Acadia Center presentation at the Fix the Grid 101 webinar
- Meeting Recording, Access Passcode: Ncc?7.QH
- Massachusetts Attorney General’s office public education efforts such as the December 2020 Teach-In covering the regional markets and their role in transitioning to clean energy.
Advocating for an Ambitious and Equitable TCI Program in Connecticut: The Power of Coalitions
The Transportation and Climate Initiative (TCI) project continues to move forward in Connecticut with strong support from the Lamont Administration and many others, attesting to the strength of the TCI Coalition that Acadia Center has been working to build over the past two years. An important milestone occurred on March 8, 2021, when the Connecticut General Assembly’s Environment Committee held a public hearing on Senate Bill No. 884, a governor’s bill that would establish the TCI Program as state policy and require the Department of Energy and Environmental Protection (DEEP) to adopt implementing regulations. The hearing was well attended by numerous and wide-ranging supporters who countered misinformation provided by the fossil fuel industry, spoke to the benefits the TCI Program would bring to the state, and called on state leaders to adopt additional measures to ensure equitable outcomes. Following the hearing, Governor Ned Lamont, legislative leaders and Middletown officials held a press conference on March 17, 2021, to express their support for the program and to highlight the state’s first electric school bus—the type of investment that could be replicated across the state with TCI funds.
Acadia Center has led and coordinated the advocacy efforts of the Connecticut TCI Coalition since 2019. The TCI Coalition now includes over 50 environmental, transportation, labor, justice and energy policy advocacy groups and businesses. This broad group of stakeholders from across the state has been coordinating virtually over the last year, extending outreach, amplifying campaign messages, and meeting regularly with state agencies to communicate our shared vision.
The success of the legislative hearing is the result of months of preparation on the part of Acadia Center and our coalition partners, sharing regional data and studies with the coalition, and refining a coordinated message. The TCI Coalition coordinated and conveyed a positive narrative that addressed the many benefits of the TCI program, from cleaner air and achieving climate targets to transportation improvements that will help businesses and communities thrive. Testimony from Acadia Center and our allies also called on Connecticut to go above and beyond the terms of the regional agreement by strengthening equity provisions and dedicating more TCI-P funds for investment in the state’s overburdened and underserved communities. Early modeling projects that TCI could save Connecticut over $360 million in public health costs annually by 2032; if implemented equitably, most of those health benefits will occur in the communities hardest hit by transportation pollution.
Staff from the Connecticut Department of Energy and Environmental Protection (DEEP) and the Department of Transportation (DOT) responded to misinformation about the TCI-P. As in other states, members of the fossil fuel industry exaggerated the program’s costs, ignored its benefits, and offered no alternative to address the climate, public health, and transportation challenges facing Connecticut. Katie Dykes, Commissioner of the Connecticut DEEP, and the other representatives of the Lamont administration gave strong testimony. Commissioner Dykes noted: “This is an environmental program that will cap greenhouse gas emissions and require the oil industry to pay for the damage it is causing to public health and the climate … I believe that Connecticut, being a leader on addressing climate and air pollution, is going to provide significant benefits to our communities,” Dykes told members of the committee. “I am very confident that if we do move this program forward, that we will see more states joining.”
Senator Christine Cohen, Co-Chair of the Environment Committee, expanded on her testimony by publishing a pro-TCI op-ed in the Connecticut Post. “Turning climate change around is the challenge of our time, and we owe it to future generations to do all we can to mitigate its impacts. We need bold action. I look forward to doing my part, along with my colleagues in the legislature, to ensure that Connecticut enacts legislation to implement TCI.”
Amy McLean, Acadia Center Connecticut Director, testified that “Connecticut has an opportunity to deliver the clean air and improved transportation options that the state’s residents and businesses deserve. Chronic under-investment—both in marginalized communities and in alternatives to personal vehicles—has resulted in congested roads, inadequate public transit, and neighborhoods lacking access to economic opportunities. At the same time, the imported fossil fuels used to power vehicles remain Connecticut’s greatest contributor to climate change and a major source of the air pollution that disproportionately harms minority residents. It is time to end that toxic combination by passing Senate Bill 884 to advance a modern, equitable, and sustainable transportation future.”
Acadia Center and its TCI Coalition partners look forward to continuing their partnerships to support this program that will bring enormous benefits to all Connecticut residents. The Environment Committee is expected to vote on SB 884 by March 31st, and the conversation will continue from there. For more information on the next steps and how you can support an equitable and ambitious TCI-P in Connecticut, contact Amy McLean, Senior Policy Advocate and Connecticut Director at amclean@acadiacenter.org
A Clean Energy Future for Rhode Island
Acadia Center’s Goals in Rhode Island
Rhode Island offers a unique opportunity for clean energy action. With its small geographic size, high population density, and a single utility serving nearly all the state’s energy customers, Rhode Island is a model venue for the equitable, clean energy vision central to Acadia Center’s work. Known in history as the birthplace of the American industrial revolution, Rhode Island is poised, once again, to become a center for innovation and the birthplace of a clean energy revolution. Rhode Island is also particularly vulnerable to the worst effects of climate change given its 400 miles of shoreline and low-lying topography. Rhode Island has set a goal of reducing its greenhouse gas emissions 80% by 2050, but Acadia Center is pushing the state towards even more ambitious and meaningful targets through the Act on Climate 2021 bill (S. 78 / H. 5445), which aims for net-zero in 2050, and includes transparency, equity, and accountability provisions.
Landscape
Acadia Center played a significant role in some recent victories for clean energy in Rhode Island, including the following:
- 2017: Governor Raimondo announces a commitment to increase Rhode Island’s clean energy production 10-fold by 2020, moving from 100MW to 1000 MW.
- 2019: Regulators approve the 400MW Revolution Wind offshore wind contract.
- 2020: Rhode Island commits to generating 100% of its electricity from clean energy by 2030.
Yet Rhode Island still faces many hurdles to clean energy development, including some of the following:
- Low-income households and communities of color in Rhode Island are most affected by outdated systems, and climate-warming pollution, are often the last to benefit from solutions.
- Periodic efforts to terminate energy efficiency programs thwart additional progress.
- The state’s utility regulations do not appropriately weigh the health, economic, and environmental benefits of clean energy options against the risks of continued fossil fuel dependence.
- National Grid, the state’s monopoly utility, continues to push for natural gas expansion that is incompatible with the state meeting its current climate goals, much less the emissions reductions targets in line with the latest science.
Our Priority Issues
Acadia Center has built strong, lasting relationships with stakeholders throughout the Rhode Island climate community. Through these relationships and a holistic approach combining, data, advocacy and implementation, Acadia Center is well positioned to create change in Rhode Island.
Energy Efficiency: Rhode Island has been a leader in energy efficiency; since 2011, the state has scored within the top 5 states in the nation in energy efficiency, according to the yearly reports by the American Council for an Energy-Efficient Economy (ACEE). Acadia Center is proud of its role shaping the efficiency policies that led to this ranking and advancing the creation of a stakeholder energy efficiency council. We will continue to offer guidance and input to Rhode Island’s Energy Efficiency and Resource Management Council and press for heating electrification incentives to be included in energy efficiency programs, which will also help transition buildings away from fossil fuels.
Clean Power: Support additional procurements of large-scale renewables and work to align the regional grid operator with climate goals.
Transportation: Build upon Acadia Center’s leadership in the Rhode Island Mobility Innovation Working Group to help build a strategy for clean transportation policy.
Climate Planning: Ensure Rhode Island meets its goal to reduce GHG emissions 80% by 2050 through intermediate and specific targets, and work to pass the Rhode Island Act on Climate 2021 bill.
Utility Innovation: Reform the utility business model to put climate and consumers first and make sure the Public Utility Commission holds the utility accountable when exploring non-pipeline alternatives.
No Natural Gas: In addition to the work to switch to clean power sources, we continue to educate stakeholders and consumers about the dangers of natural gas. We will intervene where necessary to encourage options beyond new pipelines.
Spotlight on Aquidneck Island
Rhode Islanders on Aquidneck Island (Newport, Portsmouth, and Middletown) had a recent brush with danger in January 2019, when an operational failure of National Grid’s natural gas pipelines to Aquidneck Island forced a gas shutoff that left about 7,000 people in Newport County without heat in sub-freezing temperatures and forced them to evacuate their homes in the middle of the night. Since the gas accident, Acadia Center has been engaged in the community, pushing back against the utility’s narrative and proposed solutions set. Acadia Center presented information to the town councils demonstrating weatherization and heating electrification are viable and preferred alternatives to building more gas infrastructure. Following this engagement, two of the three towns on Aquidneck Island supported moratoriums on natural gas pipelines, including new gas connections, instead choosing what are known as “non-infrastructure solutions” to eliminate the need for additional natural gas capacity on the island and encourage replacing gas with electricity.
Although we collectively managed to get National Grid to commit to planning non-pipeline alternatives and studying gas reliability, Acadia Center will be tracking developments to ensure that the work is being done. We will continue evaluating the options put on the table and advocating for the best possible scenario, as the utility still has no financial incentive to stop pushing for new pipelines.
Contact us:
Hank Webster, Staff Attorney and Rhode Island Director
hwebster@acadiacenter.org
For Media Inquiries:
Nancy Benben, Director of Communications and External Engagement
nbenben@acadiacenter.org
617.742.0054 ext. 104
The Missing Piece of State Climate Goals: Public Utilities Reform
Acadia Center is shaping reforms to the statutory mandates that guide state agencies in order to enable those agencies to be stronger partners in meeting climate goals. By reforming directives, state agencies will be better positioned to address the climate crisis and to make decisions that work for all communities, both now and in the future.
States have committed to significant economy-wide cuts in greenhouse gas emissions by 2050. But despite these goals, states have not explicitly empowered the agencies that impact carbon emissions – such as Public Utilities Commissions (PUC) and Departments of Transportation – to prioritize climate, equity, and environmental justice, in their decision-making. To achieve our climate goals, government agencies should be empowered to prioritize climate change impacts and mitigation in their decisions.
The decisions that PUCs and other state agencies make in 2021 will create the building, transportation, and energy infrastructure of 2030, 2050, and beyond. But because of outdated mandates, agencies are limited in their ability to make decisions in line with state climate goals. Public Utility Commissions, for example, which regulate the rates and investment decisions of electric and gas utilities, are legislatively mandated to reduce the costs of energy, ensure reliable gas and electric service, and guarantee utilities the opportunity to earn a profit. PUCs cannot regulate utilities in alignment with state climate targets or make decisions that value reducing greenhouse gases.
The result of outdated mandates is that PUCs often fail to treat clean energy resources on a level playing field as fossil fuels, furthering a dependence on energy sources that are exacerbating the climate crisis and leading PUCs to undervalue the future costs and climate impacts of energy investments that lean heavily on fossil fuels.
Other state agencies make many decisions with long-term climate ramifications, including establishing building codes, setting land use policy, and approving transportation projects such as new highways and road construction. Without taking long-term climate risks into consideration, these types of decisions could reinforce existing systems and products that rely on carbon emissions and fail to make the changes that will be necessary as we transition to a more resilient, zero-carbon economy.
By updating agency mandates, we can allow regulators and other policymakers to make decisions that support greenhouse gas reductions and consider climate change impacts. This would minimize long-term costs from climate change that now fall outside the scope of the core responsibilities of many state agencies.
To put these reforms into action, Acadia Center is working with other organizations, such as the Environmental Priorities Coalition in Maine, to support legislation for reforming PUC and state agency mandates in order to put climate and energy justice front and center and to ensure that all agencies are committed to helping states reach their emissions reduction targets.
Progress is already underway in the Northeast. In Massachusetts, Bill S.9, the major climate bill that is back on Gov. Baker’s desk after his initial veto in January, adds greenhouse gas reductions and equity as core responsibilities for the Department of Public Utilities.
In Maine, state representatives will soon introduce a bill that Acadia Center spearheaded to add climate and equity responsibilities to the PUC’s mandate and to task other state agencies to align their decision-making with the state’s climate laws.
And in Connecticut, Acadia Center has put together a factsheet describing opportunities to reform the Public Utilities Regulatory Authority (PURA) and other state agencies, including amending the state’s Global Warming Solutions Act and modifying PURA’s statutory mandate directly.
Winter 2021 in Massachusetts – All Climate, All the Time
As the sun set on the last days of 2020, Massachusetts’ Executive Office of Energy and Environmental Affairs (EEA) published two key documents – the MA 2050 Decarbonization Roadmap report (plus its 6 technical appendices), which evaluated 8 different pathways towards more than 85% reductions in greenhouse gas emissions (GHGs) by 2050, and the Interim Clean Energy and Climate Plan for 2030, (“CECP”), which detailed the actions and policies that the Commonwealth proposed to employ to cut economy-wide GHG emissions by 45% from 1990 levels by 2030. Acadia Center has been hard at work reviewing the 2050 Roadmap, including determining what the “end dates” may be for the use of fossil fuels in Massachusetts, and is leading a coalition in writing comments on the CECP.
Less than a week after EEA released these long-awaited documents, the Massachusetts climate bill – legislation that Acadia Center and its partners had supported through the Senate, House, and conference committee process throughout 2020 – emerged from committee and passed both bodies in the waning hours of the 2019-2020 legislative session. The bill (S.2995) called for a net zero stretch code, 50% cuts in GHGs by 2030, reforms to the enabling statute of the Department of Public Utilities, and requirements that the energy efficiency plans achieve a GHG reductions goal and include the value of GHG reductions in cost-effectiveness calculations – three reforms at the heart of Acadia Center’s Next Generation Energy Efficiency strategy.
Governor Baker vetoed the bill on January 14th, citing, among other reasons, the expense of a net zero stretch code and a $6B incremental cost to achieve 50% emissions reductions by 2030, instead of the 45% planned for in the administration’s CECP.
Acadia Center debunked the Governor’s primary cited reasons for his initial veto in two blog posts. One demonstrated that a net zero stretch code is both a key provision of the administration’s own Clean Energy and Climate Plan for 2030 and an attainable threshold that many builders in Massachusetts are already meeting at little additional cost. The other concluded that the $6B price tag cited by Governor Baker as the additional cost of achieving S.2995’s requirement of 50% cuts in emissions by 2030, versus 45% in the Clean Energy and Climate Plan was likely off by orders of magnitude, based on the 2050 Roadmap.
The timing of the veto as one legislative session ended and another began made it impossible for the legislature to override the Governor’s veto. With the overwhelming support for the landmark bill, House and Senate leadership refiled an identical bill, S.9, which passed on January 28th with veto-proof margins. As one of the co-chairs of the Alliance for Clean Energy Solutions (ACES), Acadia Center brought together over twenty clean energy businesses and advocacy organizations to sign on to a letter urging Governor Baker to sign the bill and empower Massachusetts to address the climate crisis – as well as another letter thanking legislative leadership for quickly passing S.9.
Governor Baker’s second veto took the form of an amended version the bill, S.13. As of this publication, the legislature is still considering whether to adopt the proposed changes or override the veto directly. Acadia Center has been engaged in conversations with legislative leadership about positive changes requested by the Governor that strengthen environmental justice provisions and stringency of the base building code, and encouraging the legislature to reject other changes, such as making the “floor” levels for 2030 and 2040 interim greenhouse gas emissions limits into “ceilings” and preventing future administrations’ abilities to reduce greenhouse gas pollution faster.
Why Acadia Center wants to see the Climate Bill become law:
As written, S.9 will put into law the commitments made by the Baker Administration’s Clean Energy and Climate Plan for 2030 and beyond, setting Massachusetts on a path to reach net-zero emissions and avoid the worst impacts of climate change. It represents a sea change in Massachusetts’ approach to climate change. While current law enables climate targets to be seen simply as an aspirational goal that feels good, this legislation would require the state to make a real commitment and plan to reach net zero by 2050. It also:
- Includes vitally important provisions ensuring that front line communities and low-wage workers will benefit from the Commonwealth’s transition to a low-carbon economy;
- Gives the Department of Public Utility (DPU) the authority it needs to consider equity and climate in its decisions;
- Requires interim targets and all sectors of the economy to strive towards emissions reductions;
- Puts in place real protections for environmental justice communities; and
- Makes the Renewable Portfolio Standards (RPS) a true tool to add significant renewable power on the system.
These are just a few of the benefits, and why Acadia Center is advocating so strongly for this bill.
Image credit: Office of Governor Baker on Flickr
Weatherization: The Little Climate Action that Could
New England is full of drafty houses. Regionally, almost a third of housing units were built before 1940, and more than half were built before the 1970’s, when the first building energy codes were adopted. Anyone who lives in such a house knows how uncomfortable it can be, on a February day, to feel the cold outside air seeping in through cracks around the windows and under the baseboard.
Less well-known is just how much these drafts contribute to the region’s greenhouse gas emissions. Acadia Center analysis shows that heating equipment in the draftiest houses can emit more than six times the CO2 of the same size house built to the current building code.
Not only is it possible to increase comfort and reduce energy bills in these drafty homes while also slashing emissions—it’s easy. Tens of thousands of New England homes undergo weatherization treatment through energy efficiency programs every year.
How does weatherization work?
Imagine poking holes in the bottom of a plastic cup and holding it under the tap. The larger the holes, the faster the water needs to come out of the tap to keep the cup full. Heating your home is like that: the cup is your house, the water is heat energy, the tap is your heating equipment, and the holes are—well, holes. Tiny cracks all around the house can let in cold air from the outside, while gaps in insulation allow heat to move faster through walls, ceilings, and floors. In the summer, heat and humidity can sneak in just as fast as they sneak out in the winter.
Weatherization is a way to slow the movement of heat by sealing up cracks and adding or improving insulation. Blocking the pathways that heat uses to escape your house means that heating and air conditioning equipment doesn’t need to work as hard, which saves money and avoids emissions.
Wait, I don’t see any cracks.
Like water, heat can move through spaces that are hard to spot. Window frames, door thresholds, fireplaces, switch plates, duct supply and return grilles, recessed light fixtures, attic hatches, and the joists that sit atop foundation walls are all common sites for air leakage. Homes settle over time, which unavoidably creates small cracks in all manner of locations.
Yikes! What can I do about that?
There’s an energy efficiency program in every Northeast state that will cover a big part of the cost of weatherization. These programs are designed to make it easier for homes and businesses to be more energy efficient, which benefits everyone. Weatherization work is often completely free for income-eligible households. Here is a list of programs by state:
State | Residential | Income-Eligible |
Connecticut | Weatherization • All Rebates | Income-Based Offers |
Maine | Weatherization • All Rebates | Income-Based Offers |
Massachusetts | Weatherization • All Rebates | Income-Based Offers |
New Hampshire | Weatherization • All Rebates | Income-Based Offers |
New York | Weatherization • All Rebates | Income-Based Offers |
Rhode Island | Weatherization • All Rebates | Income-Based Offers |
Vermont | Weatherization • All Rebates | Income-Based Offers |
Is there anything I can do myself?
Hiring a weatherization contractor will save you the most money, but some weatherization measures are easy enough for homeowners to do on their own. For example, V-seal weather stripping can be applied to the tracks of double-hung windows or sliding doors. Foam tubing on exterior door thresholds is also effective and easy to install. Caulking can be useful for larger gaps around baseboard molding and in the framing around windows and doors. Some caulking products dry clear, making the seal invisible. Others are white but can be painted.
Other types of air sealing projects are better completed by a professional. These include any work done on or near something hot—the vent for a furnace or clothes dryer, for example. Some projects are also just too onerous for building owners to do by themselves. While it may be technically possible to seal and insulate an entire attic as a DIY project, it is perhaps not advisable—for safety reasons, because of the effort involved, and because small mistakes can affect the success of the project.
Why would I insulate my attic?
While air sealing stops the movement of warm air through cracks, insulation stops the movement of heat through building components. Older homes very often have little or no insulation.
Heat moves slower through insulation because it’s full of air pockets—that’s why six inches of pink fiberglass insulates better than a brick wall four feet thick. Aside from fiberglass, contractors also commonly insulate with blown-in cellulose. Made from ground-up newspaper treated with a flame retardant, cellulose can often be inserted into wall cavities from the outside by temporarily removing a piece of siding, drilling a small hole, and then capping the hole when the insulating is complete.
Together, insulation and air sealing can improve the comfort of your home while cutting emissions. And because strong incentives are available no matter where in the Northeast you live, the work often pays itself off in bill savings in three years or less.
So this can save me money?
Weatherization is one of the best ways to save money on utility bills. For an older home, insulation and air sealing can reduce bills by more than 50% and emissions by 60% or more. If your heating bill in a cold winter month costs more than $250, look into weatherization.
PowerHouse and Building Electrification: Fact vs. Fiction
Nearly a third of greenhouse gas emissions in the Northeast come from buildings, and most of these emissions result from burning fossil fuels on-site for space heating, water heating, and cooking. Electrifying these end uses with clean, efficient electric equipment—like air- and ground-source heat pumps—is a necessary part of any realistic state climate policy.
Yet the fossil fuel industry and its allies have invested heavily in sowing doubt about electrification. Acadia Center’s PowerHouse home energy simulator counters this misinformation with a detailed analysis of the real costs and benefits of eliminating fossil fuel use in homes.
Information Gaps
PowerHouse is designed to fill a gap in analysis and information available to the public, enabling Acadia Center and its partners to provide credible data to rebut arguments made by the opponents of electrification. The simulator evaluates residential energy needs using ACCA Manual J algorithms and ten years of hourly weather data for eight locations around the Northeast. This allows for an analysis of operating costs, peak demand impacts, demand management potential, and net emissions that is both detailed and state-specific, rather than relying on regional or national averages.
A key capability of the PowerHouse tool is to quantify the compounding benefits of delivering whole-home electrification and weatherization as a package for a variety of residential building types. Weatherization measures like insulation and air sealing can dramatically reduce both the up-front and operating costs of electrification for most homes. PowerHouse puts a dollar value on these savings.
PowerHouse counters common misconceptions about electrification, including:
- MYTH: Heat pumps cost too much! The simulator demonstrates that whole-home electrification and weatherization leads to an overall cost reduction, which can be even more substantial in the drafty, old homes where marginalized communities often live.
- MYTH: Electrification won’t actually reduce emissions! As the model clearly demonstrates, whole-home electrification can immediately reduce emissions by more than half—an impact that grows each year as the grid adds more renewable resources.
- MYTH: Electrification will blow up the grid! Peak demand impacts are an important factor, but concern about the grid is overblown due to unreasonably pessimistic expectations about heat pump performance.
- MYTH: Heat pumps don’t work in the cold! Currently available cold-climate heat pump models can meet a home’s full heating needs in temperatures well below zero. Thousands are installed in the Northeast every year.
Equity and Justice
Low- and moderate-income households, communities of color, and English-isolated households in the Northeast are more likely to live in older, less efficient housing units. They are also more likely to be renters with very little control over their energy use decisions. Extending the benefits of energy efficiency and electrification to these households will require a concerted and meaningful commitment of resources—something that can be understood perfectly well without a home energy model.
However, PowerHouse can help to make the case for investing in marginalized communities by demonstrating the energy burden that these households suffer. A drafty, old house or apartment can cost six times as much to heat in the winter than a new unit of the same size built to the current building code. Providing clear, accurate numbers about energy burden for state decision-makers and other stakeholders can help bring the issue home for people who might never have dealt with energy bills like this themselves.
Grid impacts
Electric grid impacts are a common area of concern when it comes to heat pumps. Understanding the relationship between equipment performance, weather, and the peaks and troughs of electric demand is critically important to the overall project of building electrification.
PowerHouse closely parses this relationship, accounting for building shell characteristics, heat pump capacity, and input power for each hour of the year—granularity that is not possible with existing home energy modeling software. In this way, it can help to develop strategies for achieving building electrification at scale, for both new construction and retrofits.
Acadia Center’s PowerHouse home energy simulator meets fossil fuel industry misinformation with clear, fact-based analysis that proves the benefits of building electrification. By arming Acadia Center and its partners with this fine-grained analytical capability, the models will give advocates an advantage over the army of consultants working with oil and gas companies to irresponsibly prolong the use of fossil fuels.
The $6 Billion Question: Reality-Checking Baker’s Claimed Cost of Extra Climate Protection
In the flurry of activity at the end of 2020, two landmark (though long-expected) climate visions were put forward by different branches of the Massachusetts government. One, offered by the Executive Office of Energy and Environmental Affairs and backed up by its comprehensive draft Clean Energy and Climate Plan for 2030, called for the state to reduce its greenhouse gas (GHG) emissions in the year 2030 by 45% compared to 1990 emissions. The other, a bill passed with overwhelming legislative support entitled “An Act creating a next-generation roadmap for Massachusetts climate policy”, called for a 50% reduction by 2030, instead of 45%, among many other positive provisions. On January 14th, Governor Baker vetoed the bill. But with the arrival of the 2021 session, the legislature passed the same bill again on January 28th, which the Governor must sign or veto by February 7th (although the large majorities in both bodies’ initial vote mean the legislature could override any veto).
Acadia Center has already debunked other claims in the Governor’s first veto. In his explanatory letter, the Governor claimed unlocking that extra 5% of GHG savings (the difference between 45% and 50%) would come with an extravagant cost: $6 billion more, to be exact. That figure, and how the Governor’s Office arrived at it, has touched off a number of conversations within the legislature and environmental advocacy community, because there has been little information revealed about where it came from.
Despite this, one can still infer valuable information from the Administration’s estimates for 2030. To explore this further, it is important to distinguish between an annual and a cumulative value. If, by 2030, Massachusetts reduced its annual emissions by 50%, the state would be emitting about 4.7 million metric tons[1] of GHGs less, annually, than if it only achieved a 45% reduction. Assuming those two reduction pathways gradually diverge between 2020 and 2030, that means – with a little help from high-school geometry – that the cumulative difference would be around 20-25 million metric tons. This is the triangular “wedge” of GHGs shown in the chart below, and this wedge, according to the Administration, is what costs $6 billion extra.
Now consider two important charts, included below, taken from December’s Massachusetts 2050 Decarbonization Roadmap reports, which contain the technical analyses that underpin policies set forth in the Clean Energy and Climate Plan, or CECP. These two charts show cost and emission differences between the study’s “All Options” scenario, which by 2030 attains GHG reductions of 47% compared to 1990[2], and its “Reference” scenario, which attains reductions closer to 15%. Reading the charts, it appears the “All Options” scenario cumulatively avoids about 150 million metric tons of GHGs and costs roughly $4.75 billion more than “Reference” by the year 2030.
To phrase it another way, the Roadmap analysis suggests that the average cost to get from 15% to 47% (and avoid about 150 million metric tons of emissions by 2030) is about $32 per metric ton avoided. This figure is also in line with a recent Applied Economics Clinic paper that explicitly calculated carbon “abatement costs” for Massachusetts. But the Baker Administration, in their justification for a more restrained 2030 target, says that to go from 45% to 50% could cost almost ten times that amount: $240-$300 per metric ton[3]. It is no surprise that bigger emissions cuts cost more, and costs per ton escalate as the least expensive options are exhausted first. Here, increased costs could mean that some polluting cars and fossil-fueled heating equipment would be replaced before they completely wear out. But the vast difference between these numbers, both of which come out of the same Administration within a few weeks of one another, suggest that different math is being used to tackle the same question.
Figure 5 from the Economic and Health Impacts Report, showing annual costs for modeled scenarios versus the “Reference” scenario. The area below the brown “All Options” line shows the cumulative cost difference for that scenario to be approximately $4.75 billion between 2020 and 2030.
Figure 46 in the Energy Pathways to Deep Decarbonization Report, showing cumulative emissions for the “All Options” and “Reference” scenarios. By 2030, the accumulated difference between the two would be 150 million metric tons.
A recent Boston Globe article by David Abel sheds some light on the Administration’s math, focusing on what it would take to stretch beyond the 45% target. For example, the article cites members of the Administration who say the Commonwealth would need 450,000 additional electric vehicles (EVs), which alone would cost $2.4 billion. That would mean over $5 thousand per car in extra costs. But what about the lower fuel and maintenance costs that EV owners enjoy? Even Consumer Reports acknowledges that the total cost of ownership for EVs is less than a car running on gasoline. And what about the other benefits to the public from breathing cleaner air with almost half a million fewer fossil-powered cars on the road? It appears that the Baker Administration’s math may not be accounting for all the benefits in the same way that the Decarbonization Roadmap does.
To be clear, achieving either of these 2030 aspirations, whether 45% or 50%, would be a significant milestone in Massachusetts’ fight against climate change. All other things being equal, fewer total emissions are better than more, since what really matters is the accumulation of GHGs in the atmosphere. Acadia Center is a firm believer in evidence and data-backed policymaking, and the CECP is a tremendous accomplishment, founded on solid analysis. If the Baker Administration is going to use cost to explain why it opted for a less aggressive emissions target, Acadia Center simply feels that the same level of rigor should be brought to that decision as is seen in the Decarbonization Roadmap. Luckily, the bill containing the 50% goal is already back on the Governor’s desk. Acadia Center urges him to reevaluate his position – or at least base it on cost figures that are supported by evidence his own Administration has gathered.
Image credit: https://www.flickr.com/photos/massgovernor/50881414713/
[1] This can be calculated from the annual GHG emissions inventory.
[2] This value lies in between 25% in 2020 and 90% in 2050, and Acadia Center understands that the “All Options” scenario follows this straight line emissions trajectory.
[3] This is Acadia Center’s estimate of the range of marginal abatement costs implied by the Baker Administration’s letter. It relies on approximate values estimated from charts and simple reasoning, since the complete information needed to perform the calculation has not been provided.
Next Generation Energy Efficiency
The buildings in which we live and work are a main driver of energy use and play a key role in determining public health outcomes. Emissions from appliances and heating and cooling systems negatively impact indoor air quality, exposing residents, especially in poorly ventilated buildings, to toxic pollutants. In New England and New York, building heating, cooling, lighting, and operations are responsible for over a third of the overall emissions that contribute to climate change.
Energy efficiency, including services ranging from home insulation improvements to replacing appliances with more efficient alternatives, can improve comfort, reduce exposure to pollutants, and save consumers money. Energy efficiency is also the most cost-effective way to reduce greenhouse gas emissions and has played a major role in helping the Northeast lower carbon pollution.
The Northeast is a national leader in energy efficiency. Efficiency programs in the Northeast lead the nation in important criteria: the highest per capita investments in energy efficiency and the most ambitious energy savings goals. The regional grid operator in the six-state New England region relies on energy efficiency resources for over 14% of the power needs of the region – the highest in the country. Millions of homes and businesses have received efficiency services, which have reduced energy bills, avoided billions of dollars in higher cost energy resources, and improved public health.
Acadia Center is proud of the role it has played in advancing energy efficiency in the region and promoting the creation of stakeholder boards to guide efficiency programs, budgets and goals, but far more must be done to improve the efficiency of our homes and businesses and to ensure that all overburdened and underserved communities reap the full benefits of efficiency offerings. Programs have not delivered services adequately across all income levels and communities. Many consumers face unequal access to benefits under existing efficiency programs, and underserved communities that face the worst impacts of climate change and poor housing quality have not been able to take full advantage of efficiency programs. Clean electric heating and whole house electrification must be priorities to support the acceleration of clean energy resources and the transition away from fossil fuels. There must be better alignment between state climate goals by reforming key energy efficiency policies, regulations, and stakeholder systems, and the region must continue to value energy efficiency as a core energy resource.
Acadia Center’s Next Generation Energy Efficiency initiative seeks to tackle these challenges through a new approach – one that focuses on energy savings as a core consumer and energy system resource, but is also centered around meeting climate, environmental justice, and electrification goals. It is an approach that recognizes the interrelatedness of these efforts, which can work in concert to bring Northeast communities the future of energy efficiency.
The four challenges the Next Generation Energy Efficiency will prioritize are 1) sub-standard housing quality, 2) climate mitigation, 3) clean heating and whole-house electrification, and 4) sustaining investments in efficiency as the leading energy resource option for utilities and the power grid.
Prioritize Housing Quality Improvements
Energy efficiency must be at the center of addressing the region’s old housing stock. Energy efficiency can improve thermal comfort, reduce exposure to toxins, and lower energy costs. To better serve vulnerable populations and environmental justice communities, existing benefit-cost methodologies, which determine how efficiency programs are implemented, must incorporate climate, equity, and health benefits from building retrofits. Acadia Center will work with environmental and consumer advocates, environmental justice leaders, business interests, and efficiency vendors to develop policy recommendations that identify reforms needed to fully account for all the health, safety, and equity benefits that energy efficiency improvements deliver.
Ensure Alignment with Climate Mitigation
Every kilowatt-hour of electricity that does not need to be produced because of energy efficiency means less dirty fossil fuel use. But energy efficiency programs can achieve even deeper emissions savings if they are refocused with a greater emphasis on climate mitigation. Acadia Center will press to:
- Update efficiency statutes and regulations, including the way programs are screened through benefit-cost tests, to emphasize reductions in greenhouse gas emissions in addition to energy savings.
- Make certain that public utilities commissions consider climate and health impacts when evaluating efficiency programs; and
- Ensure that laws, regulations, and planning processes support efforts to transition from fossil fuels to clean electrification.
Embrace Clean Heating and Whole-House Electrification
If deployed together, energy efficiency and electrification can deliver greater emissions reductions while improving indoor air quality. To better align efficiency programs and electrification, Acadia Center will push for incentives for clean heating and weatherization, as well as for changes in how efficiency programs are administered to ensure co-delivery of building upgrades that are currently delivered in silos. Acadia Center will publish state-specific reports on the value of electrification and flexible demand and will push states to include electrification retrofit pathways in their efficiency plans.
Sustain Investments in Efficiency as the Leading Energy Resource
Northeast states must expand efficiency investment levels and energy savings goals to ensure deeper savings and benefits for all. As one of the fundamental components of meeting state emissions targets, efficiency efforts must be sustained in states that are already leading and improved in states that are falling behind. Acadia Center will work to ensure that decision-makers in the Northeast recognize the value and necessity of efficiency to spur large savings in public health and economic benefits. Through membership on efficiency boards and through PUC intervention related to efficiency plans, Acadia Center will continue to advocate for increased budgets and the maximum possible savings goals, provide expert commentary on state energy issues, and offer data and recommendations to counter bad decisions.
For more information:
Oliver Tully, Policy Strategist, otully@acadiacenter.org, (860) 246-7121, ext. 202
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