Part of a large and growing group of environmental organizations that includes Acadia, Conservation Law Foundation, Environmental League of Mass., Gas Transition Allies, HEET, MAPC, PLAN, and Zero Carbon MA, the Green Energy Consumers Alliance has presented state lawmakers with a specific list of recommendations on how Massachusetts can cost-effectively and equitably reduce greenhouse gas emissions from buildings. The resulting recommendation is the Mass Clean Heat Platform, detailed in a letter to legislative leaders in late October, 2023.
Here is the letter in full:
Under the leadership of the Joint Committee on Telecommunications, Utilities, and Energy, the Massachusetts Legislature has led the nation in passing bold measures to address the climate crisis, starting with the Global Warming Solutions Act of 2008 and ending most recently with the Driving Clean Energy and Offshore Wind Act of 2022.
Despite the Commonwealth’s past progress, more legislation is needed if Massachusetts is to meet its greenhouse gas emission reduction mandates. This is especially true when it comes to the second largest source of emissions in the Commonwealth, the residential and commercial building sector.
To support the Legislature in crafting solutions to this daunting challenge, the undersigned climate organizations have come together to put forward specific strategies to reduce greenhouse gas emissions from buildings in a cost-effective, equitable, and timely manner. These strategies would:
- Be sufficient to meet the requirements of M.G.L. Chapter 21N and the sublimits for the heating and cooling sectors (49% by 2030) as established by the Secretary of Energy and Environmental Affairs.
Equitably provide resources to low- and moderate-income households and place greater responsibility for emissions reductions on owners of large commercial buildings. - Require electrification of both new construction and retrofits of existing buildings.
- Place responsibility for emissions reductions on the oil, propane, and gas industries (including both investor-owned utilities and municipal gas utilities).
- Shift investments away from the gas distribution system that come with significant risks of stranded assets and move toward strategic, cost-effective investments in building electrification, including air-source heat pumps, ground-source heat pumps, networked geothermal systems, heat pump water heaters, induction stoves, and electric clothes dryers.
No one bill or policy proposed this session is sufficient by itself to meet these objectives. However, several complementary policies have been proposed that together can accomplish what is necessary. Where appropriate we have cited bills or bill sections that would achieve specific goals. The legislative package we support would:
Pursue an Equitable Transition
To ensure that all communities across the Commonwealth benefit from the shift away from fossil fuel use in buildings, legislation should:
- Prioritize funding, such as Clean Heat Credits, Alternative Compliance Payments, and specific appropriations, for low- to moderate-income households (LMI) and environmental justice communities (EJC), to ensure at least 40% of funding goes to LMIs or EJCs. (S.2365/H.3232; H.3192/S.2144, Section 21(d); H.3694, Section 2 (c).)
- Establish an Equity Advisory Council to oversee and ensure that the Commonwealth’s building decarbonization programs minimize harm and maximize benefit for vulnerable and traditionally underserved communities, with representation on the Council from EJCs, LMI households, and other relevant stakeholders.
- Kick start building decarbonization efforts with a $300 million dollar fund that targets support for affordable housing and public buildings in EJCs and Gateway Cities. (S.2365/H.3232.)
- Create a surcharge of 1.5 cents per therm on gas ratepayers to be allocated to assist LMI households to switch to non-gas appliances and to provide training for gas workers affected by the transition. (S.2105/H.3203, Section 1.)
Focus on Electrification
Electrification has consistently proven to be the most cost-effective method of building emission reduction. With that in mind, legislation should:
- Prohibit the injection of hydrogen into the gas pipeline system for the purpose of heating buildings, and restrict the use of biomethane/RNG and synthetic gas into the gas system unless it has a non-emitting lifecycle, does not pose a safety hazard, and is affordable. (S.2105/H.3203, Section 13.)
- Prohibit state subsidies for renewable natural gas or hydrogen to heat buildings as part of a Clean Heat Standard or any other climate policy. (H.3694, Section 1.)
- Provide sufficient incentives for electric heat, hot water, induction stoves, and dryers.
Ensure that any subsidies for delivered biofuels are contingent on those fuels being produced from waste feedstocks. (See 225 CMR 16.02.) - Update Mass Save services to provide no-cost decarbonization assessments and other technical support necessary for building owners to make and implement well-informed decisions on how to decarbonize their buildings. (S.2103, Section 1.)
Work Towards a Future Beyond Gas
The Commonwealth’s natural gas utilities are currently making large scale investments in the natural gas system, including planning to spend over $40 billion replacing aging gas mains with new gas pipes. A better use of these funds would be to decommission the gas infrastructure and install in an equitable and synergistic way non-combusting infrastructure (e.g. networked geothermal systems) and electric equipment (e.g. air source or ground source heat pumps) in buildings that formerly relied on gas. In this area, legislation should:
- Remove the cap on the number of communities that are currently allowed to participate in the fossil fuel free construction pilot, to prevent the unnecessary expansion of our natural gas infrastructure. (H.3227/S.2093.)
- Require gas companies to draw up specific plans, updated annually, to meet the Commonwealth’s greenhouse gas emissions reduction mandates, and to reduce gas leaks through electrification and pipeline retirement. Allow the DPU to penalize utilities for failing to meet targets within these plans. (S.2105/H.3203, Sections 16 and 17.)
- Allow gas companies to meet their obligation to serve by selling non-combusting thermal energy, and allow for the merging of the rate bases of thermal and gas customers in order to keep gas companies financially viable during the gas decommissioning process. (S.2105/H.3203, Sections 4, 12, and 14 (c).)
Repeal the current law permitting expansion of the gas distribution system to new customers (S.2105/H.3203, Section 18), and disallow depreciation and cost recovery for gas pipeline replacement after 2050. (S.2105/H.3203, Section 16.) - Accurately track the climate impacts of methane by measuring greenhouse gas emissions over both the 100-year and 20-year timescales and accounting for methane leaked in transmission, storage, and distribution to customer equipment. (H.873/S.2092.)
- Place a moratorium on future new large scale fossil fuel projects, unless they are necessary for the safety of the public. (H.3238/S.2135, Sections 2 and 3.)
Tackle Large Building Emissions
Large buildings are responsible for a significant percentage of building emissions across the Commonwealth. Further, large buildings often present an additional challenge due to split incentives between owners and tenants. Legislation should therefore:
- Create a statewide building performance standard for buildings greater than 20,000 square feet that aligns with the Commonwealth’s goal of reaching a 49% reduction in building emissions by 2030.
- Allow a variety of compliance pathways to meet the needs of small business and LMI households. (H.3192/S.2144, Section 20.)
- Allow cities and towns with local building performance standards to continue their programs without being superseded by the state-wide standard, so long as the local standard is as stringent or more stringent than the state standard.
Update Existing Programs
Finally, the Commonwealth should update existing programs that relate to building decarbonization. To that end, legislation should:
- Update and expand the Green Communities program to encourage municipalities to opt in to the specialized stretch code and to take other actions to reduce greenhouse gas emissions. (H.3192/S.2144, Sections 6-8.)
- Repeal Chapter 25 Section 11F1/2, ending the Alternative Energy Portfolio Standard, since most of its goals are better met through a Clean Heat Standard. A repeal would also provide relief to electricity ratepayers.
- Update the Commonwealth’s building codes to require that new construction meet energy efficiency standards, and add a PV Ready mandate to the Commonwealth’s stretch code (S.2176/H.3236, Section 1.)
- Update the PACE program to include district heating, energy storage, and microgrids (H.3192/S.2144, Section 1.)
- Encourage electrification by stabilizing and reducing electric supply rates by improving the municipal aggregation process (H.3852.)
While not every organization signing this letter necessarily supports every provision in each bill cited in this letter, we believe the principles specifically listed above contain important pieces of the necessary statutory structure to put the Commonwealth on a realistic, achievable path toward building decarbonization by 2050. We urge you to examine these bills closely as you consider the best way to weave them together to create comprehensive legislation addressing this most crucial challenge.
Thank you for your attention to these important issues so vital to the wellbeing of the residents of the Commonwealth. We look forward to working with the members of the House and the Senate to advance building decarbonization legislation this session.
Sign on here:
https://forms.gle/PgQekK87tk4KWWHp7
Signed,
Green Energy Consumers Alliance
Acadia Center
HEET
Pipe Line Awareness Network for the Northeast, Inc
Conservation Law Foundation
Mothers Out Front Massachusetts
Gas Transition Allies
Environmental League of Massachusetts
ZeroCarbonMA
Additional signers,
Sierra Club Massachusetts
Mass Audubon
350 Mass
Northeast Clean Energy Council
Elders Climate Action Mass
Boston Housing Authority
Canton Sustainable Equitable Future
Citizens’ Climate Lobby, Hilltown Western MA chapter
UndauntedK12
Local Energy Advocates of Western Mass
Climate Reality Massachusetts Southcoast
Franklin County CPR Climate Crisis Task Force
Unitarian Universalist Mass Action
Jewish Climate Action Network, MA
Greater Boston Physicians for Social Responsibility
No Fracked Gas in Mass
Berkshire Environmental Action Team
Sheffield Saves
Sustainable Wellesley
Vote Solar
Springfield Climate Justice Coalition
Citizens Climate Lobby, Chapter in the Berkshires, MA
Sustainable Lexington Committee
350-MA Berkshires
350 Central Mass
Boston Climate Action Network
Lexington Climate Action Network
Sustainable Sharon Coalition
Longmeadow Pipeline Awareness Group
Partnership for Policy Integrity
Boston Catholic Climate Movement
Massachusetts Interfaith Power and Light, Inc
Fore River Residents Against the Compressor Station
Cape Ann Climate Coalition – Organizing Committee
Massachusetts Climate Action Network
SAFE-Salem Alliance for the Environment
Brookhaven Residents’ Climate Change Committee
South Shore & Cape Chapter, Citizens Climate Lobby
Climate Action Now (Western Mass)
350 Cambridge Somerville Node
North Shore Citizens Climate Lobby
Passive House Massachusetts
Cape Cod Climate Change Collaborative
Environmental Defense Fund
MassEnergize
Health Care Without Harm
Eastie Farm
Breathe Easy Berkshires
Sustainable Weston Action Group
Boston Green Action
Boston Clean Energy Coalition
Climate Code Blue
Climate Finance Action
Greening Greenfield
Boston Green Action
LISC Boston
Old Colony Planning Council
Arise for Social Justice
Sustainable Arlington
