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.