In December 2020, the Massachusetts Executive Office of Energy and Environmental Affairs filed its first draft of the 2030 Clean Energy & Climate Plan (CECP). The plan outlines specific strategies to ensure that the state’s carbon emission limit is met by 2030.

Although it's a good first draft, public comment and participation can steer the final draft to be even better. The deadline for submitting comments has been extended to March 22, 2021. In addition to the blogposts we've already written about the transportation and electricity sections of the CECP, we’ve submitted all of our feedback on the plan early, which you can read here. Here are our main takeaways.

We commend the Commonwealth for the ambition in its interim 2030 Clean Energy and Climate Plan and for including several strategies that, from our perspective, will do the most to move the needle on reducing carbon emission in the next decade, including:

• Increasing the Clean Energy Standard to at least 60% by 2030;
• Implementing the Transportation Climate Initiative;
• Creating a Low Carbon Fuel Standard;
• Adopting California’s Advanced Clean Car regulations in order to put one million electric vehicles (EVs) on the road by 2030;
• Establishing a Heating Fuels Emissions Cap.

Although there are many possible paths to net zero by 2050, all models agree that investing in energy efficiency, electrifying heating and transportation, and bringing renewables onto the grid—especially through offshore wind development—are essential by 2030. Our organization stands ready to work with the Executive Office of Energy and Environmental Affairs  on the public processes regarding the development and implementation of the policies and regulations.

Emissions reductions are too backloaded to the end of the coming decade.

Across the 2030 CECP’s Strategy Actions, we find that the emission reductions are backloaded to the years 2025-2029, which poses a considerable risk that the Plan’s emissions reduction target of 45% by 2030 will not be achieved. This concern is exacerbated by the legislature’s intent to raise the emission reduction to 50% by 2030 and to require a new limit to be set for 2025 in "An Act creating a next-generation roadmap for Massachusetts climate policy." We strongly support both of those provisions in the climate bill, believe they are feasible and appropriate, and recommend that they be incorporated into the final 2030 CECP.

While the Plan might serve well as a guidance document, the regulations required to carry out the Plan need to be promulgated at a pace that might be unusually fast for state government. 

The Plan lacks specificity in key Strategy Actions.

The number of instances in which the Plan uses words such as “explore” and “investigate” concerns us. In some of those cases, we would urge the Plan to declare a firm commitment because the stated policy makes obvious good sense.

For example, the Plan makes a recommendation to "explore a utility-based residential charging incentive program" and "explore and support time-varying rates and active demand response programs." (We wrote all about this in a blog from July 2019- Good things happen when you smart charge your electric car.) Exploration and investigation, however, will not result in smart-charging programs unless programs are implemented that benefit consumers. Therefore, we recommend the Commonwealth change these "Strategy Actions" to committing to implement good ideas such as residential charging incentive programs. 

In other cases, our ability to express support or opposition is hindered until we see more detail. For example, the CECP commits to a “high-performance stretch energy code” that will be available as opt-in starting in 2023 and mandatory beginning in 2028. Although the high-performance stretch energy code is described as having a “focus on deep efficiency and electrification” and as requiring “passive-house level building envelope efficiency,” the CECP does not list concrete policies.

The Plan should more fully consider equity.

The area in which we deem the Plan to be the most deficient has to do with a surprising lack of expressed support for public transportation. The Transportation and Climate Initiative (TCI) offers funding that could greatly help boost our regional transit authorities. The benefits of doing so are clear – increased mobility for people who need buses and trains to get to work and reduced localized air pollution, public health impacts, vehicle miles traveled in cars, and greenhouse gas emissions. Investing in public transportation, in addition to reducing greenhouse gas emissions, is a key strategy to support communities currently overburdened and underserved by our transportation systems.

Massachusetts residents - it's your turn.

Every year in the next decade is crucial to address climate change. Anyone in Massachusetts is welcome to submit their opinion on the 2030 Clean Energy & Climate Plan. Specific feedback is most helpful to inform the finalization of the plan in the spring of 2021. Here’s how you can help.

1. Read the Clean Energy & Climate Plan. We focused our comments on the Transportation, Buildings, and Electricity sector strategies, but there are other sectors you can review as well. 
2. Review Green Energy Consumers' comments. Our suggestions may help provide you context about where the plan can be improved. 
3. Submit comments through this online form. The form makes it easy to comment on specific strategies, so feel free to focus on the section you’re most comfortable with or feel most strongly about.
4. Share this blog with other climate advocates and savvy energy consumers in your life. This is a unique opportunity to influence the state’s priorities on climate and energy for the next ten years. Let’s make the most of it.