Clean Energy & Climate Plan for 2025 & 2030
May 5, 2022
Written by YVE TORRIE, DIRECTOR OF CLIMATE, ENERGY & RESILIENCE with Isabella Gambill, SENIOR POLICY ADVISOR ON CLIMATE, ENERGY & RESILIENCE
The Massachusetts Clean Energy and Climate Plan (CECP) for 2025 and 2030 provides details on the actions the Commonwealth will undertake through the next decade to ensure the 2025 and 2030 emissions limits are met. The CECP development is informed by the 2050 Decarbonization Roadmap such that the strategies, policies, and actions outlined in the CECP will put the Commonwealth on a pathway to achieve net zero greenhouse gas emissions by 2050.
The State Executive Office of Energy and Environmental Affairs (EEA) held public hearings on April 14th and 15thto provide an update to the Interim CECP that was released in December 2020 and accepted public comment through April 30. EEA is now working to finalize the CECP by July 1st.
A Better City , which sits on the Governor’s Global Warming Solutions Act Implementation Advisory Committee, provided a comprehensive set of comments on the proposed policies, sublimits, and targets and metrics, summarized below.
Overall, A Better City recognizes the many improvements made to the interim CECP and encourages EEA to further refine the proposed policies to address two key shortcomings: 1) the CECP transportation sector policies fail to prioritize investment in public transit, instead focusing almost exclusively on the promotion of zero emission vehicles (ZEVs)—this strategy contradicts Governor Baker's own Commission on the Future of Transportation report and represents a missed opportunity to maximize co-benefits that will create a more vibrant, equitable, and connected Commonwealth for all, and 2) the CECP building sector policies do not adequately address some of the major hurdles that must be overcome to electrify systems in existing commercial, industrial, and institutional building stock, including the scale of existing building retrofits that must be prioritized, technical and financial constraints, and access to clean, reliable, and affordable electricity.
In summary, A Better City offers the following recommendations to strengthen the CECP as the Baker Administration considers final changes before the end of June deadline:
- Transportation Sector Policies: A Better City urges EEA to revise the CECP to include a new standalone strategy to modernize, expand, and improve public transit throughout the Commonwealth and to decarbonize passenger train and bus fleets. More specifically, this policy should include commitments to fully fund and expedite the MBTA Bus Modernization Plan; advance Regional Rail as endorsed by the MBTA Fiscal Control and Management Board in November 2019, including electrification of the commuter rail network, frequent all-day service, and accessible stations with high-level platforms; establish a new MBTA low-income fare program to increase ridership; and launch an integrated workforce development program to train existing MBTA/RTA employees and to build the skilled labor force of the future. Beyond prioritizing investment in public transit, the CECP should provide point of sale incentives to support a more comprehensive category of LEVs (not just e-bikes); support Transportation Management Association (TMA)-led transportation demand management (TDM) strategies as well as the development of active transportation infrastructure; advance smart roadway pricing strategies; consider offering incentives for the purchase of select used ZEVs and LEVs for both individual and businesses; support the electrification of commercial and government fleets; and prioritize the build out of fast, adaptable charging infrastructure at MBTA-owned parking lots, including commuter rail lots, in addition to other state and municipal government facilities.
- Buildings Sector Policies: To further improve the CECP, A Better City recommends enhancing the proposed buildings sector policies to include: prioritizing deep building weatherization—both passive efficiency and digital technologies, which are currently not addressed in the CECP; continuing the discussion of advancing hybrid heating solutions for unique, hard-to-decarbonize commercial and industrial buildings; including comments made during the update to the Massachusetts Stretch Energy Code and development of the Municipal Opt-In Specialized Stretch Energy Code considering the use of source energy for building performance calculations and an update to the Straw Proposal’s data modelling to account for COVID-19 impacts; working with Boston and Cambridge to develop a streamlined state reporting structure that is aligned with existing building energy and emissions reporting mechanisms within municipalities; clarifying how energy scorecards at point of lease/sale are anticipated to work within commercial buildings; and conducting a building electrification sequencing study to understand the optimal timing of building electrification as a key step in a comprehensive and strategic energy transition. A Better City also supports: the development of a climate finance mechanism pilot to support the equitable decarbonization of the built environment; the management of energy price impacts and reduced electricity rates for heating; the development of GHG accounting for biofuels, biogas, and green hydrogen; and the expansion of workforce development, with a recommendation that career training and job placement for residents of historically excluded and environmental justice communities be prioritized.
- Other Policies: A Better City has also enclosed comments to improve the Natural and Working Lands (NWL), Electricity, and Climate Justice recommendations of the CECP. Primary points for NWL include: incorporating carbon sequestration data into the Massachusetts Greenhouse Gas Inventory; including targets for reduction of methane emissions from agriculture; tracking tree canopy coverage on public and privately owned lands and partnering with institutional landholders on implementation; engaging construction companies, engineering firms, and developers in scaling up MA Timber; prioritizing environmental justice communities across all NWL strategies; encouraging community and climate resilience co-benefits alongside decarbonization, and; considering the recommendations of A Better City’s June 2021 caron offsets report for carbon removal best practices. Primary points for the electricity sector include: initiating a grid decarbonization planning process, including a timeline and strategy for new clean energy procurement, as well as sequencing for grid, transmission, and interconnection capacity upgrades; including grid resiliency through the expansion of district-based microgrids, storage, and peak demand management, and; including financial subsidies to transition to a decarbonized future, with a carve out for lower income and environmental justice communities. Finally, primary recommendations for enhanced CECP climate justice include: considering the cross-sector recommendations from the IAC Climate Justice Working Group as well as including sector-specific commitments to climate justice in the CECP; establishing a Massachusetts Climate Bank to help leverage public-private partnerships, regional initiatives, and multi-year climate solutions to help equitably fund the critical infrastructure needed to achieve our statutory climate commitments, and; establishing the state-level Environmental Justice Council, as statutorily mandated by the A Better City will remain engaged throughout this process.
Please read A Better City’s complete comments here and reach out to Yve Torrie with any comments and questions.
