I thank the Executive Office of Energy and Environmental Affairs (EEA) for the opportunity to comment on the Clean Energy & Climate Plan (CECP) 2030.
As you know, the next nine years are the most critical for avoiding the worst devastation of the climate crisis, and the CECP will determine statewide energy and climate policy for this period. Strong climate policy and targets will increase economic growth, expand jobs in energy efficiency and renewable energy, and lower statewide healthcare costs because of cleaner air.
I recommend that the CECP be strengthened in the following ways both to benefit Massachusetts and to serve as a model for other states to ensure that we avoid the economic and personal costs from increasingly frequent climate disasters, such as floods and fires, affecting residents and businesses across the country:
· Raise the overall emission reduction target from 45% to 50% by 2030 and require an interim limit to be set for 2025, to keep the state on target for this goal.
· Maintain the regulations on biomass energy facilities established by the Department of Energy Resources in 2012, that require these facilities to meet strict greenhouse gas (GHG) emissions standards. The existing regulations disallow the burning of wood for high GHG emitting, electric-only energy generation plants, protecting us from harmful emissions.
· Set accelerated emission reduction targets for the next couple of years. The plan’s GHG reduction targets are too heavily weighted in 2025-2029, posing a considerable risk that its emissions reduction targets will not be achieved.
· Establish a zero net opt-in stretch building code that takes into account the GHG emissions embodied in building materials, in 2022, and adopt it as a statewide base code in 2025.
· Set explicit targets and incentives for clean energy, energy efficient retrofits, and related workforce development in environmental justice and low to moderate income communities most affected by the impacts of fossil fuel emissions. These communities should have strong representation during planning, development and implementation of CECP programs.
· Phase out and set policies for repairing leaks of the extremely high GHG emission refrigerants called hydrofluorocarbons (HFCs) in air source heat pumps and mini splits as soon as viable, as MA presses for their rapid and widespread adoption.
Sincerely,
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