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12/09/2025
9:45am - 11:00am
Greater Boston Chamber of Commerce
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Chamber Supports the Balanced Building Energy Code Straw Proposal to Help Progress Climate Goals
The Greater Boston Chamber of Commerce submitted testimony expressing gratitude to the Department of Energy Resources for developing a balanced Building Energy Code Straw Proposal that makes progress towards our climate goals.
Using in-depth building code analysis developed since 2019, the approach taken by the Department considers the outcomes of building code updates, the needs of different building types, and lifecycle costs for building ownership. Importantly, the straw proposal notes that the goal of the energy code analysis is to achieve least-cost decarbonization.
With that goal in place, the Department’s Energy Efficiency Analysis conducted in tandem with the development of the straw proposal identifies a feasible path for our built environment to reduce emissions. Through this well-researched process, the Department offers three building code options that will drive emissions reductions from the building sector, use incentives to encourage a shift to electric, and recognize the current capabilities of New England’s power grid.
The Chamber supports many aspects of the straw proposal and urges the Department to maintain its balanced approach in the final regulations.
The straw proposal’s plan to update the residential stretch code for one and two family homes, town homes, and low-rise multi-family up to three stories largely strikes the correct balance between reducing emissions, feasibility, and cost factors. Under the proposal, builders and homeowners will meaningfully reduce emissions and be protected from broad, one-size-fits-all mandates or prohibitions.
Specifically, both the stretch and opt-in proposals will reduce emissions by adjusting the Home Energy Rating System (HERS) standard and providing incentives to influence homeowners’ choices. Importantly, nearly 300 of the state’s 351 municipalities already adopted the stretch code, so changes to the stretch code will impact a large swath of the state.
In developing the proposal specifics, we urge the Department also to recognize current limitations, particularly on the power grid’s capabilities and in different living environments.
Like the residential changes, the proposed updates to the commercial building code also will result in demonstrable emissions reductions while maintaining flexibility for builders. The proposal achieves this balance by emphasizing demand reduction, requiring adaptability for an electric future, and recognizing the nuances of building use.
The Department’s proposal does acknowledge that the proposed codes would increase costs for small office buildings. Given the pressures on small businesses right now, and potential additional pressures from policies like the tax on income over $1 million, anything that raises the costs of production – and therefore occupancy costs – should be carefully reviewed.
Worth noting, the update to our building codes is only one piece of the overall effort to achieve our emissions reductions. The Commonwealth continues its aggressive procurement of renewable energy to ensure our electric grid provides cleaner energy to our future electrified buildings. This necessary clean energy faces years of development and construction and will require further upgrades to the distribution system. We must be mindful that the transition of our electric grid and built environment to net-zero emissions will take time and the Department should continue to carefully consider real-world costs and limitations while formulating any new requirements on buildings.
The Chamber also recognizes that the move towards own-source energy has a new urgency and significance given global events and the U.S. decision to discontinue Russian oil imports. We believe that reducing and eliminating reliance on foreign energy sources is necessary, but our infrastructure cannot handle an immediate transition. The proposed code changes move Massachusetts towards these goals, while also recognizing the reality of our system’s capabilities and cost impacts.
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