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:
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
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