Letter to Secretary Theoharides: Clean Energy & Climate Plan



Dear Secretary Theoharides:

On behalf of our 130 member businesses and institutions, thank you for your vision and leadership in developing both the 2050 Decarbonization Roadmap and the Interim Clean Energy and Climate Plan for 2030 (CECP). A Better City appreciates the Baker Administration's commitment to identifying cost-effective and equitable strategies to ensure that Massachusetts reduces greenhouse gas emissions by at least 85% by 2050 and achieves net-zero emissions.

A Better City is honored to sit on the Global Warming Solutions Act Implementation Advisory Committee (IAC) and to serve on both the Transportation Working Group and Buildings Sector Working Group. The enclosed comments are informed by A Better City’s participation on the IAC and ongoing collaboration with the business community. A Better City is grateful for the opportunity to review the interim CECP and respectfully submits the enclosed comments, which focus primarily on the CECP transportation and buildings sector strategies.

Overall, the CECP transportation sector strategies fail to prioritize investment in public transit, instead focusing almost exclusively on the promotion of zero emission vehicles (ZEVs). This short-sighted, one-dimensional focus on ZEVs contradicts Governor Baker's own Commission on the Future of Transportation report, which stated that “high-frequency, high-capacity public transit is the most efficient and sustainable way to move large numbers of people as they go about their daily lives. This is true today and will be true in 2040.” The current CECP transportation approach does not adequately encourage near-term vehicle miles traveled (VMT) reduction to reduce crippling roadway congestion and represents a missed opportunity to maximize co-benefits that will create a more vibrant, equitable, and connected Commonwealth for all.

Similarly, the narrowly-focused CECP buildings sector strategies emphasize the electrification of thermal heating systems, neglecting to adequately acknowledge or address the major hurdles that must be overcome in order to electrify systems in commercial, industrial, and institutional building stock. These hurdles include enormous technical and financial constraints associated with implementing so-called deep energy retrofits, as well as access to a qualified workforce and access to clean, reliable, affordable electricity. As explored further in A Better City’s June 2020 report, “Thermal Electrification of Large Buildings in the Commonwealth,” a variety of policies and strategies will be required to address the market barriers to thermal electrification technologies.

In summary, A Better City offers the following recommendations to strengthen the CECP:

  • Transportation Sector: 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 train and bus fleets, including the MBTA’s commuter rail and bus systems. Beyond prioritizing investment in public transit, the CECP should advance smart roadway pricing strategies; set more aggressive, annual VMT reduction targets for all passenger vehicle trips, not just for commutes; prioritize the electrification of commercial fleets, including delivery vehicles; incentivize the development of flexibly-designed commercial EV charging infrastructure, as well as the purchase of e-bikes; support Transportation Management Association (TMA)-led transportation demand management (TDM) strategies as well as the development of active transportation infrastructure; and ensure the affordability of clean, reliable power via the grid.
  • Buildings Sector: A Better City recommends adding a suite of new standalone strategies to address the following overlooked priorities: deep energy building retrofits; workforce development; grid and building electric capacity; clean, reliable, and affordable electricity; and statewide financing strategies. Additionally, A Better City recommends targeted changes to the proposed stretch energy code development and implementation process; additional analysis to assess the impact of phasing out combined heat and power (CHP) incentives in the commercial, industrial, and institutional sectors; the addition of an A Better City representative on the Clean Heat Commission; and further study of low-and zero-carbon fuels to understand how they could support commercial building decarbonization.
  • Other: A Better City suggests establishing a new strategy within the natural and working lands chapter to develop offsetting best practices to inform the proposed market-based accounting frameworks for carbon sequestration. Moreover, A Better City recommends expanding the composition of the Carbon Sequestration Task Force to include a representative from A Better City and other carbon offset experts in the Greater Boston business community.

As the Commonwealth begins its post-pandemic economic recovery, uncertainty about the future of work trends and the related impacts on the real estate sector cannot be used as an excuse to further delay long-needed investment in public transit, which is the backbone of our regional economy. Additionally, COVID-19 recovery and financial uncertainty should not stymie state investment in the efficiency and decarbonization of our commercial, industrial, and institutional buildings. The Commonwealth must take bold action now to achieve our climate goals and to create the clean economy of the future. Thank you again for your leadership and for your time and consideration.



Richard A. Dimino

President and CEO


Enclosures: 3


Jamey Tesler, Acting Secretary, Massachusetts Department of Transportation

Judy Chang, Undersecretary of Energy

Steve Poftak, General Manager, MBTA

Martin J. Walsh, Mayor, City of Boston

Kim Janey, City Council President, City of Boston

Chris Osgood, Chief of Streets, City of Boston

Chris Cook, Chief of Environment, City of Boston

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