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February 11, 2021
The Chamber submitted testimony in support of several amendments made by the Baker-Polito Administration to the recently enacted bill S.9, An Act creating a next-generation roadmap for Massachusetts climate policy. To ensure a cost effective and balanced transition to a net-zero economy by 2050, we urge the Legislature to approve these amendments when reconsidering this legislation.
Municipal Opt-In Stretch Energy Code
The Chamber supports Governor Baker’s amendment to Section 31. The amendment differs from the enacted language because it omits the requirement to develop a “net-zero” definition for buildings within the state’s updated stretch energy code. While well-intended, this requirement was vague and would result in higher building costs and discourage the development of certain residential and commercial buildings as well as energy grid infrastructure.
Instead, the amendment requires the Department of Energy Resources (DOER) to develop a specialized stretch energy code that includes a higher performing municipal opt-in standard designed to comply with the state’s statutorily required greenhouse gas (GHG) emissions limits. By omitting the requirement to incorporate a net-zero building definition, this change makes clear that the target is building structures and not energy procurement. The change further strengthens the bill because it aligns with the 2050 Decarbonization Roadmap’s technical analysis and the stretch energy code proposal within the Clean Energy and Climate Plan for 2030.
While we support the changes proposed by the Governor, several challenges will need to be addressed during the regulatory process to ensure the state develops and implements a financially feasible stretch code in a predictable manner with broad input from stakeholders. These challenges include:
Sector Sublimits
The Chamber supports the amendment to Section 9, which makes the bill’s sector-based GHG emission sublimits non-binding in years when the Commonwealth complies with the statewide GHG limit. While measuring these metrics is important, sector-based sublimits diminish the state’s flexibility to decarbonize and may unintentionally hinder progress toward the overarching statewide GHG reduction goal. For example, reducing building sector emissions will require substantial electrification, but doing so may result in a short-term increase in emissions from the generation sector. Sector sub-limits do not provide for this type of flexibility.
Environmental Justice
The Chamber supports the proposed amendments to Section 58 and Section 60. As enacted, these sections set forth new requirements to the state’s review process for proposals in proximity to environmental justice communities based on the “significance” of likely environmental damage caused by the proposal. The amendments strike the undefined standards of “significance” and the Legislature can further strengthen these sections by defining the standard of environmental damage that triggers the new review process requirements.
James Sutherland, PhD
Director of Policy & Research
[email protected]617-557-7312
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