City Council support of letter to State Lawmakers on the Mass Clean Heat Platform

‭Date‬ ‭The Honorable Michael J. Barrett, Chair‬ ‭Joint Committee on Telecommunications, Utilities, and Energy‬ ‭24 Beacon Street, Room 109-D‬ ‭Boston, MA 02133‬ ‭The Honorable Jeffrey N. Roy, Chair‬ ‭Joint Committee on Telecommunications, Utilities, and Energy‬ ‭24 Beacon Street, Room 43‬ ‭Boston, MA 02133‬ ‭Dear Chair Barrett and Chair Roy:‬ ‭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 and‬‭the sublimits for the‬ ‭heating and cooling sectors‬‭(49% by 2030) as established‬‭by 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 ‭1‬

‭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, Section‬‭1.)‬ ‭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.‬ ‭2‬

‭●‬ ‭Ensure that any subsidies for delivered biofuels are contingent on those fuels being‬ ‭produced from waste feedstocks. (See‬‭225 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:‬ ‭3‬

‭●‬ ‭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.)‬ ‭●‬ ‭Repeal‬‭Chapter 25 Section 11F1/2‬‭, ending the Alternative‬‭Energy 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 the‬‭principles‬‭specifically‬‭listed 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.‬ ‭4‬

‭Sincerely,‬ ‭You can 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 ‭Canton Sustainable Equitable Future‬ ‭Mass Audubon‬ ‭Citizens' Climate Lobby, Hilltown Western MA chapter‬ ‭UndauntedK12‬ ‭Local Energy Advocates of Western Mass‬ ‭Climate Reality Massachusetts Southcoast‬ ‭Franklin County CPR‬‭Climate 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 ‭350 Mass‬ ‭Sustainable Wellesley‬ ‭Vote Solar‬ ‭Springfield Climate Justice Coalition‬ ‭Elders Climate Action Mass‬ ‭Citizens Climate Lobby, Chapter in the Berkshires, MA‬ ‭Sustainable Lexington Committee‬ ‭5‬

‭350-MA Berkshires‬ ‭350 Central Mass‬ ‭Boston Climate Action Network‬ ‭Lexington Climate Action Network‬ ‭Sustainable Sharon Coalition‬ ‭Northeast Clean Energy Council‬ ‭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 ‭6‬