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08/07/2025
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July 2, 2025
Dear Chair Cusack and Chair Barrett,
On behalf of the Greater Boston Chamber of Commerce and our 1,200 members, I write to offer comments on H.4144, An Act relative to energy affordability, independence and innovation. We would like to thank Governor Healey for focusing on energy affordability in the Commonwealth and its impact on residents and businesses. As you are aware, the Commonwealth is home to some of the highest energy prices in the United States. Addressing affordability for ratepayers is important to attracting and retaining businesses and a talented workforce.
As the Legislature begins an important conversation about energy affordability in the Commonwealth, the Chamber offers the following comments on H.4144 for your consideration.
Long-Term Contracting (Sections 6 & 10)
The Chamber supports the Legislature’s previous authorizations of long-term, competitively bid, contracting processes for renewable energy sources, with particular support for offshore wind generation resources. However, with a large amount of contracting capacity already authorized by statute and yet to be awarded to project proponents, the Chamber believes there is no need to shift the procurement process to the Department of Energy Resources (DOER), particularly without adequate limitations and controls regularly embraced by the General Court. The authorization would allow DOER to govern a procurement process as it sees fit – an extraordinary grant of authority with few constraints or checks and balances to ensure appropriate scale, transitions, and frequency.
Given the length of the procurement process, contracting, and construction of many of these complex projects and their impacts on ratepayers, these procurements should not be subject to changes to personnel or policy in the Administration. Instead, the process should be governed by the Legislature’s guidance in the amount, timing, and structure of contracts as in past energy legislation. To the extent policy changes are necessary, the deliberative process in the House and Senate, not DOER, is the appropriate place for consideration and debate. As the Legislature has demonstrated in previous sessions, it regularly revisits energy policy based on the needs of the Commonwealth and makes adjustments, with input from DOER, as necessary.
We also believe that electric distribution companies are an essential part of the contracting process. They provide valuable technical expertise and ratepayer protection and should continue to be an essential part of the procurement process, in partnership with DOER.
Securitization (Section 20)
H.4144 authorizes the use of “rate reduction bonds” for certain costs as determined by DOER. It is unclear how these bonds will result in decreased costs for ratepayers, while also adding substantial bonding authority for unclear goals and open-ended potential impacts. As currently written, it is unclear if the complex rate reduction bond proposal will ultimately save costs for ratepayers, or instead add borrowing, governance, and administrative costs over the long-term. Employers and business ratepayers need further information about how, in fact, bonds will result in overall savings. We would welcome the opportunity to engage with legislators and the Administration to understand their overall goals for this section but currently believe that more discussion is needed before moving forward.
A Diversified Energy Portfolio (Section 45)
Adding more options to our energy generation portfolio is a critical component in reducing costs and increasing energy affordability. It is important to note that any new energy facility – including nuclear power – would face a strict and robust permitting and oversight process from the State. Utility-scale projects 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 new technologies in the solar, wind, nuclear and other renewable and green industries, we have the opportunity to harness abundant and clean resources to power our homes and businesses at an affordable price.
As you know, tariffs and other changes to energy policy at the Federal level have caused delays in offshore wind power, hydropower and other sources of energy. We continue to encourage the Committee to avoid policies that impede access to current reliable sources of energy while embracing and fostering other sources of clean energy systems as they continue to expand.
Please reach out if you have any questions.
Sincerely,
James E. Rooney
President and CEO
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