Acadia Center Comments in Response to Massachusetts Discussion Draft Regulation Voluntary Clean Heat Standard Early Registration Program

Acadia Center recently submitted comments in response to the release of the Massachusetts Discussion Draft Regulation Voluntary Clean Heat Standard Early Registration Program (“ERP”) drafted by the Massachusetts Department of Environmental Protection (DEP). These comments are narrowly focused on the ERP proposal and serve to compliment Acadia Center’s more extensive comments from December 2023 on the CHS Draft Framework. These ERP comments emphasize that the program should send a clear signal that early action heat pump installations will generate future streams of emissions avoided credits, limit early action crediting to electrification measures only, expand the ERP to include heat pump water heaters, and only make ‘cold climate’ heat pumps eligible under the ERP.