Massachusetts
MA Climate Coalition Comments on An Act Relative to Green Communities (H. 4373)
December 10, 2007
Senator Michael Morrissey
Chair, Joint Committee on Telecommunications, Utilities & Energy
State House, Room 413-D
Boston, MA 02133
Dear Chairman Morrissey:
The Massachusetts Climate Coalition appreciates the opportunity to submit the following comments in response to An Act Relative to Green Communities as passed on November 15th by the House of Representatives. We are grateful for the time and efforts that you and your staff have invested developing this important legislation and in outreach to our organizations, and we look forward to working with you to pass visionary energy policy in Massachusetts this session.
The Massachusetts Climate Coalition is composed of dozens of health, environmental, and faith-based organizations that came together in 2001 to work to reduce global warming pollution from Massachusetts. The steering committee is comprised of Clean Water Action, Conservation Law Foundation, Environment Massachusetts, Environment Northeast, Environmental League of Massachusetts, Massachusetts Climate Action Network, and the Union of Concerned Scientists.
Introduction
We are excited that the Green Communities Act has the potential to put energy efficiency and clean, renewable energy at the heart of new energy policy. This bill represents a bold step that will allow Massachusetts to address our energy problems, reduce global warming from power plants and buildings, and launch our state into the forefront of the energy debate nationally. We recognize the far-reaching benefits of this bill as a whole, but are concerned about a few provisions of the bill and have offered suggestions for improvement.
The Green Communities Act includes many important initiatives that are anticipated to have substantial economic and environmental benefits.
The Massachusetts Climate Coalition lauds the following provisions of An Act Relative to Green Communities:
- The establishment of a least-cost procurement model for electric and gas utilities that will boost energy efficiency, reduce strain on our electric infrastructure, and lower energy bills.
- Electric efficiency programs that will help to stabilize and lower energy bills by reducing demand.
- The maintenance of strong definitions for Class I renewable energy under the Renewable Portfolio Standard (RPS) and the extension of the RPS target to at least 15% new renewable energy by 2020, in addition to setting a broader goal of 20% new renewable energy by 2020, to spur clean, renewable energy development in the commonwealth.
- The increase in the cap for net metering eligibility and the creation of neighborhood net metering capability that will encourage crucial distributed generation projects by making them more affordable.
- The pilot program for utilities to enter into long term contracts with renewable energy developers that will encourage more renewable energy development.
- The update for Massachusetts building codes to meet IECC standards every three years, coupled with implementation plans, that will advance high performance homes and businesses in Massachusetts.
We urge the Senate to support these key provisions while addressing other issues that raise concerns, as discussed below.
Critical efforts to reduce global warming pollution must not be undermined by coal gasification incentives in Section 20 of the bill:
The proposed program to provide financial incentives for coal gasification technologies as set forth in Section 20 of the bill is unacceptable absent clear assurances to guard against any net increases in greenhouse gas emissions from facilities benefiting from the incentives. The Massachusetts Climate Coalition is opposed to the use of ratepayer money to subsidize increases in greenhouse gas emissions. New or retrofitted generating facilities running on gasified coal produced without reliable and permanent sequestration of the associated carbon dioxide (CO2) will exceed the average global warming pollution emissions rate in New England. Indeed, to the extent that methane from gasified coal should be used to displace the natural gas currently used by the region's gas-fired power plants, the increase in greenhouse gas emissions would be substantial absent permanent and reliable sequestration of the CO2 from the gasification process. Additionally, permanent sequestration of global warming emissions has not been proven, is not likely to be proven within the next few years, and may never be possible in regions like New England. Moreover, it does not make sense to direct public incentives toward fossil fuel technologies when there are still significant untapped opportunities to invest in clean, renewable resources and energy efficiency.
The Alternative Energy Portfolio Standard offers incentives for coal gasification, combined-heat-and-power (CHP), and technologies that may be identified later by the Department of Clean Energy. We support the AEPS as an effective way to promote technologies that increase efficiency and decrease greenhouse gas emissions. However, because coal gasification and associated CO2 sequestration are at a pre-commercial/demonstration stage, and involve processes that could actually increase greenhouse gas emissions, coal gasification is not well suited for a portfolio standard like this, especially a standard that calls for experimental coal gasification to compete with tried and tested technologies such as CHP. Setting requirements to deploy experimental technology – especially one that seriously risks increasing greenhouse gas emissions – would be unproductive at best and potentially a dramatic step backward. We are therefore looking to the Senate to ensure that the energy bill will not include coal gasification in the AEPS, or any other incentive for generation that increases net global warming emissions.
Because of the importance of advancing truly clean technologies for and in Massachusetts, any form of generation supported by the AEPS should at an absolute minimum meet or beat the emissions standards of a new natural gas plant (1,100 pounds of CO2 emissions per megawatt hour), and DOER should be empowered to incrementally lower emissions standards to the extent feasible as technologies improve.
Section 5
The Massachusetts Renewable Energy Trust (MRET) is an essential tool for ensuring the growth of renewable energy markets in the commonwealth. While MRET admittedly has not been as prolific in its endeavors to catalyze new renewable energy megawatts as hoped, Section 5 of An Act Relative to Green Communities would likely do more damage than good by creating confusion, inconsistencies, and transitional delays in the funding mechanisms for new renewable energy facilities.
MRET needs a streamlined and discrete focus – to encourage the development of clean, renewable energy. Moving the fund at this point and broadly expanding its mission would only muddle its purpose and restrict its ability to be an effective ongoing tool for increasing the use of clean, renewable energy. That said, there should be opportunities for MRET to fund the development of clean renewable energy projects in "Green Communities" established pursuant to the legislation, and such opportunities should be explored.
Section 19
On-site renewable energy solves many problems and inefficiencies associated with our electricity infrastructure. Distributed generation cuts down on transmission costs, augments system reliability, and benefits the environment by providing clean, renewable energy from solar and wind power. For these reasons, we support the Save Energy Coalition's proposed amendment to create an on-site renewable energy carve-out within Section 19, pertaining to the RPS.
Section 23
Renewable energy imports from areas adjacent to New England play an important role in meeting our state's and our region's energy demands and goals in the most economically and environmentally appropriate manner. Restricting those imports would have significant negative impacts, in making our energy supply more expensive by not exposing the market to price-lowering competition and diminishing potential greenhouse gas emissions reductions. We therefore object to unduly restrictive provisions that extend beyond codification of existing practice on RPS eligibility for imported renewable energy, such as the requirement to commit to 5-year participation in the Forward Capacity Market and to sell "all" of a facility's power into the ISO New England grid.
Section 28
Because alternative compliance payments result from a temporary gap between renewable energy supply and demand, these funds should be focused only on directly supporting the construction of renewable energy facilities (consistent with existing requirements), rather than for more general purposes through the proposed green communities fund.
Section 35
While the Massachusetts Climate Coalition strongly supports responsible renewable energy development and recognizes that offshore renewable energy resources have considerable potential that should be tapped, we object to Section 35 of the Green Communities Act because this language was included through an eleventh-hour amendment that was not made available for public scrutiny or debate and is in conflict with the Oceans Act that was recently passed by the Senate. We support the opening up of state ocean sanctuary waters for offshore renewable energy development, but this should be done in a context such as that offered by the Oceans Act – i.e., in connection with a commitment to undertake thoughtful ocean management planning that will balance ocean development with the protection of natural resources.
The Green Communities Act would benefit from the inclusion of several additional relevant provisions:
- Oil Efficiency Standards
The bill should contain a provision to create efficiency programs for oil, like those for electricity and gas. With home heating oil at all-time high prices, the need for oil efficiency could not be more clear. Using oil more efficiently will cut demand and reduce emissions. The Massachusetts Climate Coalition supports the establishment of an oil systems benefit change that would fund oil efficiency programs and the requirement of oil distribution utilities to develop plans to provide for the acquisition of all available energy efficiency and demand resources that are cost effective. - Home Energy Scoring
An additional lost opportunity in the House version of the bill is the removal of provisions (found in sections 35 and 70 of the committee bill) which would have created a home energy scoring component of standard home inspections. The House instead removed this provision and replaced it with language calling for a study of this issue. Many homeowners undertake significant renovations within twelve months of purchasing a home; this is a critical time to reach them with information that can not only improve the value and comfort of their homes, but also save them energy and money. The study contained in the house bill will delay this important initiative. We therefore respectfully urge the Senate to restore the original home energy scoring provision. - Interaction with a Federal Renewable Portfolio Standard
With the prospect of a federal RPS that is weaker than the one in An Act Relative to Green Communities, this bill should include a provision to ensure that the full impact and intent of the Massachusetts RPS are preserved, by ensuring that the same renewable energy used by one electric supplier for complying with the Massachusetts RPS may not be used by any other entity for complying with any state or federal renewable portfolio standard. In the absence of such language, ratepayers in other states with no RPS or a weak RPS may be "let off the hook" for supporting any incremental renewable energy generation that would not have otherwise occurred. A reshuffling of dollars should not be allowed to substitute for progress in increasing the market share of renewable energy.
Thank you again for the opportunity to provide these comments. We appreciate your leadership and look forward to working with you to make Massachusetts a national leader on energy policy.
Sincerely,
Katy Krottinger
Clean Water Action
Sue Reid
Conservation Law Foundation
Diana Connett
Environment Massachusetts
Sam Krasnow
Environment Northeast
Nancy Goodman
Environmental League of Massachusetts
Rob Garrity
Massachusetts Climate Action Network
John Rogers
Union of Concerned Scientists
