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April 13, 2022
The Greater Boston Chamber of Commerce offered comments on S.2819, An Act driving climate policy forward. The Chamber supports the Commonwealth’s commitment to net-zero emissions by 2050 and the robust efforts underway to reduce our state’s greenhouse gas emissions and the Chamber also recognizes that a smooth transition to zero emissions requires solutions that balance reliability, technical feasibility, and costs in both the short-term and the long-term.
The Chamber supports several aspects of both the House and Senate’s climate bills this session, including further developing the offshore wind industry and deploying electric vehicle charging stations.
Utility-scale renewable projects, like the current and proposed offshore wind procurements, are necessary to reach emission reduction goals. Historically, Massachusetts has been at the end of the energy pipeline, relying on out of state sources of energy fuel production for our energy needs. Now with advances in offshore wind technology, we have the opportunity to harness abundant and clean wind resources just off the coast to power our homes and businesses at an affordable price. Focus should turn to ensuring these projects are built on time and on budget to begin the needed influx of clean energy into the electric grid.
In addition, to meet the expected demand for electric vehicle charging, the state needs to begin creating its infrastructure now, and the Senate bill provides funding to start that process. Additionally, the Senate’s proposal to track vehicle data can be used to inform local strategies to prepare for and adapt to EV adoption. The legislation also directs the MBTA bus fleet to be fully zero-emission by 2040 and recognizes that changes to bus garages and maintenance facilities are a crucial part of that conversion.
To encourage a transition to widespread electric vehicle adoption, we urge the Senate to make hybrid vehicles eligible for the vehicle purchase rebate. Hybrids provide an ultra-low emissions bridge for customers concerned with current limitations of electric vehicles, including range in cold weather, length of charging time, and cost. Hybrids are also an important option for residents living in dense or urban residential environments who may not have access to private or overnight charging sources.
While the Chamber supports these policies, it has concerns with other aspects of the proposed legislation that interrupt regulatory efforts underway and unnecessarily add costs for ratepayers who are already facing extraordinarily high energy costs.
For instance, just last year the state adopted a law requiring the Department of Energy Resources to update the state’s stretch energy code and create a specialized municipal opt-in code. Rightfully, the law allowed for a year-long process to develop the code so it could include extensive analysis and stakeholder feedback. The Senate’s legislation circumvents this process in section 52, which creates a 10-municipality pilot program that would allow municipalities to withhold building permits for buildings that are not fossil-fuel free.
Furthermore, through its straw proposal, the Department has thoughtfully recognized that different types of buildings will need to make a net-zero transition at different speeds over time. The proposed blunt tool risks unintended results on housing development and the state’s business climate without taking into account the policy nuances and stakeholder feedback afforded by the Department’s current process. Instead, this provision would allow a select group of communities – most of them with higher than average median household incomes and home values – to skip the state process by creating a potentially duplicative, though less stringent, way to change local building codes. Several other proposed amendments to S.2819 would similarly undermine this process.
The Chamber is also concerned with section 48 because it would interfere with a process already underway and insert the Legislature into a regulatory process. If adopted, section 48 would delay the Department of Public Utilities’ review of the business operations of local gas distribution companies in light of the Commonwealth’s emissions limits. Already 18 months into the process, DPU sought and received significant stakeholder engagement and provided opportunity for public comment. While the Chamber takes no position on the substantive policy issues in this proceeding, section 48 would create a troubling precedent that regulatory stakeholders with different policy or procedural positions will simply turn to the Legislature whenever an adverse ruling is made. This creates a significant degree of uncertainty in any regulatory process in the Commonwealth, which in turn hurts our business climate.
There are also several provisions of this legislation that will unnecessarily increase electricity costs for ratepayers. Sections 36 and 37 further expand the role of net metering in the Commonwealth, which is unnecessary given the success of the Commonwealth’s solar incentive program and will only pass along more inefficient costs to ratepayers. Section 39 decreases remuneration to utility companies accepting long-term offshore wind contracts, which impacts a utility’s balance sheet and may lead ultimately to higher borrowing costs for utility infrastructure improvements.
I would also like to take this opportunity to note that numerous proposed amendments to S.2819 would impose significant costs on employers or impose unfeasible mandates that do not support the Commonwealth’s climate goals. The Chamber hopes that as the Senate closely reviews these proposals that address many policy areas not contemplated by the underlying legislation, concerns around technical feasibility and ratepayer costs are prioritized. This is particularly true of several amendments that would, with no doubt, increase housing costs in the Commonwealth at a time when housing prices are soaring, including amendments 7, 8, 63, 89, and 126.