The Getting to Net Zero Action Plan Fiscal Year 2019 progress report

The City of Cambridge’s Climate Protection Action Committee (CPAC) is tasked with overseeing the City’s Net Zero Action Plan (Plan) and assessing its progress on an annual basis. This letter serves as the fourth annual progress assessment (Assessment), which includes comments and recommendations regarding both the content of the Plan, as well as the implementation of the Plan by the Community Development Department (CDD) and other City officials. The Assessment is based upon the annual City of Cambridge Getting to Net Zero Action Plan – Fiscal Year 2019 Progress Report (Progress Report) drafted by CDD (attached), as well as the deliberations of CPAC.

Since the Net Zero Action Plan was finalized and adopted by the City in 2015, the science surrounding climate change, the impacts of climate change and social awareness of climate change have all advanced and become more compelling. Meanwhile, the implementation of some of the key actions within the Net Zero Action Plan have fallen behind schedule. As noted in more detail below, CPAC recommends increased resources, legislative action and sense of urgency to facilitate the achievement of the Plan’s carbon neutrality goals.

The following are specific comments and recommendations aimed at getting the Plan “back-on- track” and in a position to meet Plan milestones:

1. Legislative Actions – CPAC strongly supports all six of the legislative recommendations outlined in the Progress Report, but particularly the two described below. As stated in the Progress Report: As the Plan moves from an emphasis on feasibility and design to the implementation of recommendations, there is an increased need for legislative action by the Cambridge City Council and related stakeholders…Legislative actions may include amendments to existing Zoning or City Ordinances or the creation of new regulations. Two policy adoptions that are core to the Plan and require action according to the following schedule are:

a. Fall 2019: Amend Article 22 of the Zoning Ordinance to Increase Green Building

Requirements [from LEED Silver to Gold] (Plan Action 2.3), and Remove Barriers

to Increased Insulation (Plan Action 2.5). These proposed Ordinance changes have undergone thorough stakeholder vetting and after significant delay are poised to be adopted by the City Council. In order to keep on pace with the Net Zero Action Plan schedule and have a meaningful impact, the next round of green building requirements is due for adoption in FY21. CPAC recommends that the City Manager and staff maintain the commitment to this schedule of phased increases in green building stringency and promptly move forward with this next set of requirements.

b. Fall/Winter 2019: Submit Building Energy Use Disclosure Ordinance (BEUDO) amendments to introduce performance requirements. (Plan Action 1.1.2) As noted in CPAC’s 2018 Assessment, BEUDO is moving from data gathering/measurement to managing/reducing emissions which requires energy performance requirements for existing buildings. The BEUDO performance requirements were due to be adopted in FY19 and are now behind schedule.

CDD has proposed the performance requirement that all BEUDO buildings improve their GHG emissions by 20% every 5-years. CPAC supports this effort to advance performance requirements and strengthen the impact of BEUDO for existing buildings to reduce their GHG emissions, and encourages the City and BEUDO stakeholders to pursue a stringent approach to these requirements. Expeditious adoption of these amendments is needed to meet the City’s GHG reduction commitments.

2. Collaboration and Alignment of City Climate Initiatives a. CDD should monitor the various climate resiliency and energy efficiency initiatives occurring in the City and integrate them, where appropriate, into the Net Zero Action Plan to strengthen support for Plan goals and policies and to avoid redundancy. Energy efficiency investments and retrofits are easier to monetize than resiliency investments, and energy efficiency and resilience investments can be mutually reinforcing. As such, CDD should provide incentives and technical support for both of these investments to be done simultaneously whenever possible.

Such initiatives include: Envision Cambridge (in particular the recommendations of the Climate and Environment Working Group), the Climate Resilience Zoning Task Force (recommendations expected in early 2020), and the Urban Forest Master Plan. The findings and recommendations of these initiatives should be studied and integrated as part of the 5-year Comprehensive Review required under the Plan, which will occur in FY20. (The City’s participation in various regional Climate initiatives, such as the Zero Cities Initiative and Metro Mayors Coalition, should also be monitored and integrated into the Plan as relevant.)

b. CDD should also monitor and support ongoing Council ordinance proposals that align with the goals of the Plan and integrate them into the Plan as appropriate. One such recent ordinance proposal from Council aims to ban natural gas hook- ups in new construction and force new buildings to be all-electric, in anticipation of increased grid supplied renewable energy.

3. Budgeting The Plan released in 2015 was adopted with a 5-year budget that expires in FY20. CDD needs to propose, and the City Manager and Council approve, a reasonable Plan implementation budget to bridge the gap between the expiration of the original Plan budget and the development and approval of a new 5-year Plan budget as part of the 5- year Comprehensive Review occurring in 2020. Examples of near-term funding needs include increased staff and tools to manage BEUDO data analysis and implementation of the proposed performance requirements, and funding for implementation of the recommendations of the Low Carbon Energy Supply Strategy.

4. As previously noted, the 2015 Plan required a Comprehensive Review in 2020, its 5-year anniversary. The Plan review committee should re-assess Plan policies and timing within the context of experience and rates of progress to date and updated scientific and technological knowledge. In order to achieve the City’s commitment to 100% carbon neutrality by 2050, it is likely that the policies under the Plan will need to become more aggressive, implemented sooner and require substantial additional funding. CDD should commence the 5-year Comprehensive Review as soon as possible and aim to have it completed prior to the FY22 budgeting cycle.

CPAC commends the City for its efforts to date developing and implementing the Plan, which is necessarily multi-pronged and evolving. In order to attain the goals of the Plan, the City must implement Plan findings and recommendations in a timely manner. CPAC urges the City Manager and City Council to fully support the implementation of the Net Zero Action Plan, including the recommendations outlined above combined with those described in CDD’s Fiscal Year 2019 Progress Report. Time is of the essence.

Respectfully,