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9:45am - 11:00am
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3:00pm - 5:00pm
Another Age Productions
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4:30pm - 8:00pm
Boston Convention and Exhibition Center
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June 14, 2022
The Greater Boston Chamber of Commerce offers the following comments to the conference committee on bills H.4524, An Act advancing offshore wind and clean energy and S.2842, An Act driving climate policy forward. The Chamber appreciates the opportunity to provide its perspective and urges a targeted and balanced approach that is achievable, technically feasible, and cost effective for the Commonwealth’s communities and ratepayers.
The Chamber supports several aspects of both the House and Senate’s climate bills this session. However, there are provisions that unnecessarily disrupt long-standing clean energy or energy efficiency programs or processes or impose unnecessary costs that do not accelerate the Commonwealth’s climate goals.
Support House Section 8 – Empowering MassCEC to provide statewide coordination for offshore wind initiatives
The offshore wind industry presents an enormous economic opportunity for Massachusetts. Historically at the end of the energy pipeline, the Commonwealth can now begin to harness its own local, renewable, natural resource and generate clean energy for the state and the region. Offshore wind development is essential for the climate, and if cultivated could create and grow a homegrown industry of construction, maintenance, and supply chain businesses to build and service the hundreds of turbines supported by our state’s clean energy procurement programs.
The Massachusetts Clean Energy Center can play a critical role in coordinating these efforts, partnering with our world leading higher education institutions and innovation sector to develop industry-leading research, workforce training, and a vibrant local supply chain. Coordinating statewide, MassCEC can incorporate the strengths of every region in the Commonwealth and ensure the benefits of offshore wind energy impact the entire state.
Oppose House Sections 13 and 14 – Energy Surcharges
These sections dramatically increase energy surcharges on ratepayers to fund the Massachusetts Offshore Wind Industry Investment Fund and the Massachusetts Renewable Energy Trust Fund. However, many of the spending purposes for the Offshore Wind Industry Investment Fund are similar to initiatives that offshore wind companies include in their long-term contract proposals, which are fully recovered by ratepayers through electric rates by a guaranteed purchase of the energy. As a result, ratepayers will be double-charged for the initiatives.
In addition, the surcharges result in ratepayers subsidizing energy developers to pay for interconnection costs, factories, and port facilities that are usually part of the contracting process. The Chamber urges the conference committee to eliminate the increases to these surcharges and instead fold these priorities into the competitive bidding process or tax incentives as proposed by the House.
Support ARPA or Budget Surplus Funding for Clean Energy and Transportation
As an alternative to energy surcharges, the Chamber urges the Legislature to allocate a portion of the $750 million allocated to climate priorities in H.4720 to offshore wind priorities. Alternatively, the Legislature can use other federal or ongoing surplus state revenues to fund needed offshore wind infrastructure or other renewable energy initiatives outside of the long-term contracting process. The latter is similar to Senate proposals in section 67 to fund clean energy investments, electric vehicle adoption, and charging infrastructure deployment, initiatives the Chamber supports.
Both the availability of federal funding through ARPA and the Bipartisan Infrastructure Legislation, as well as large budget surpluses and a record high rainy day fund balance allows for targeted climate investments the will both help the transition to a cleaner economy and create jobs.
Oppose Senate Section 65 – Additional Municipal Opt-in Building Code
The Department of Energy Resources (DOER) is in the process of updating the state’s stretch energy code and creating a specialized municipal opt-in code. This process, which is not yet complete, includes extensive stakeholder feedback and research on impact and feasibility. The Chamber offered comments to DOER as a part of its process, and therefore opposes section 65 because it creates an additional opt-in building code before drafts of new building code requirements have even been released.
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. Combined with the region’s desperate need for new housing and the implementation of MBTA transit-oriented zoning districts, the proposed additional opt-in building code is a blunt tool that, without the stakeholder input and attention to nuance that is in the DOER’s process, risks drastic unintended results on housing development.
Support Senate Section 57 – Interagency Planning for EV charging Infrastructure
The Chamber supports section 57 in the Senate bill because statewide planning and coordination among state agencies is essential to a successful transition to cleaner transportation options. The transportation sector remains the largest source of greenhouse gas emissions in the Commonwealth and reducing transportation sector emissions is a pressing issue due to the state’s ambitious emission reduction goals for 2030. Deploying adequate infrastructure to support electric and hybrid vehicles is only in the beginning stages, and is a formidable hurdle to widespread use of low or no emission vehicles. State agencies must coordinate on issues of land use and infrastructure.
Oppose Senate Section 32 in part – Large Building Energy Use Reporting
The Chamber strongly opposes section 32 in the Senate bill, which creates new requirements for complex energy use reporting by both utilities and owners on “large buildings.” While purportedly targeting buildings with at least 25,000 square feet of gross floor area, the definition allows for any
building to be subject to these requirements and encompasses reporting of electricity; natural gas; steam, hot or chilled water; heating oil; propane or “other products” used for heating, cooling, lighting, industrial, and manufacturing processes; water heating; cooking; clothes drying; and “other purposes.” These incredibly broad definitions raise numerous privacy concerns for both building owners and tenants and raise questions about the practical implementation and possible use of such data by the Department of Energy Resources.
Support House Section 11A/Senate Section 8 – MassCEC clean energy equity workforce and development program
As the Commonwealth strives to reduce greenhouse gas emissions and transitions to cleaner forms of energy and transportation, equity must be a priority. Creating a Clean Energy Equity Workforce and Market Development Program within the Massachusetts Clean Energy Center will promote the inclusion of minority-owned and women-owned small businesses, environmental justice populations, and federally recognized tribes into the new clean energy economy. In order to meet the state’s ambitious greenhouse gas reduction goals, there will be major changes in how we power our homes and businesses, how we commute and travel, and how we work. Equity should be front and center as these changes occur, including ensuring there are adequate opportunities for all people and all businesses to thrive in the resulting new economic environment.
Oppose Senate Section 59 – Regulatory Interference
The Chamber has concerns about section 59, which will delay the Department of Public Utilities’ review of the business operations of local gas distribution companies in light of the Commonwealth’s emissions limits. This 18-month process involved significant stakeholder engagement and opportunity for comment, and section 59 creates significant uncertainty for all similar regulatory proceedings in the future. Businesses and regulated entities rely on the direction from state agencies to navigate the regulatory process. This process, which has also not reached any conclusion, is significantly undermined by the Legislature’s interference, and creates a disturbing precedent that regulatory stakeholders with different policy or procedural positions will simply turn to the Legislature whenever an adverse ruling is made.
Other Cost Concerns
There are also several provisions under consideration that will unnecessarily increase electricity costs for ratepayers. Sections 45 and 46 of S.2842 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 50 of S.2842 decreases remuneration to utility companies accepting long-term offshore wind contracts, undermining the ability of these companies to offset the risks, real costs, and liabilities created by implementing the state’s clean energy policies that result in increased borrowing costs for utility infrastructure.