How Massachusetts Can Make this Decade Count: Acadia Center Weighs in on the Interim CECP
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