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September 13, 2022
Dear City Council President Flynn,
On behalf of the Greater Boston Chamber of Commerce and our 1,300 members, I write regarding Docket #1017, An Act Authorizing the City of Boston to Establish Fossil Fuel-Free Standards for New Construction and Major Renovation Projects.
The Chamber strongly supports the Commonwealth’s greenhouse gas reduction goals, including net-zero greenhouse gas emissions statewide by 2050. We recognize that reaching those goals will mean adapting to new methods and standards for the built environment and new energy sources for powering, heating, and cooling our buildings. However, we have significant concerns about the City Council’s home rule petition containing few details and developed without stakeholder feedback. Among our concerns is that potential fossil fuel-free building standards will have wide-ranging impacts on Boston’s development and economy. Furthermore, the state regulatory process governing implementation details has not begun.
For these reasons, the Chamber strongly urges the City Council to delay action on the petition until the Council considers concrete proposals, conducts an impacts analysis, and allows for technical feedback to avoid unintended or costly consequences to proposed standards.
Filed just weeks ago, the petition advanced with few details and little debate or analysis of the impact on development in the city despite wide ranging implications. City policies that dramatically impact the economy – including employers and homeowners – must be thoroughly considered and vetted prior to passage, particularly in the remote work environment. Although Boston is home to world class institutions in technology, health care, finance, research, higher education, and innovation, it faces increasingly formidable competition from regional and international competitors due to the high cost of local housing and development.
Despite broad references to a future process to develop an ordinance and an unspecified advisory committee, the petition fails to outline any guidance on the structure of proposed standards. While the Chamber understands that Boston wants to signal its interest in the state’s 10 municipality pilot program, such a broad petition sends a chilling signal for both residential and commercial development in the city, just as it grapples with some of the highest costs in the country.
In addition to these concerns, the Department of Energy Resources is responsible for promulgating regulations governing the pilot project for fossil fuel-free building standards but has not begun that process. These regulations may outline requirements for home-rule petitions, ordinances, or processes that are not contemplated within this petition. It is premature to move forward without a full picture of how the pilot program will work.
Thank you for your time and consideration. Please don’t hesitate to reach out with any questions.
James E. Rooney President and CEO
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