Once again, Massachusetts is working on a clean energy and climate plan – this time for 2050 – and your input is needed by October 21.
Why another plan?
Thanks to the climate roadmap bill that passed in 2021, Massachusetts must reach net-zero carbon emissions by 2050; meaning at least an 85% reduction in actual greenhouse gas (GHG) emissions under 1990 levels by 2050, plus carbon capture and sequestration for any remaining emissions. In addition to setting these mandated emissions reductions, the 2021 climate roadmap bill also required the Commonwealth to write a Clean Energy and Climate Plan (CECP) on how to get there. The state has just released a draft outline of that plan.
You may remember that the state recently produced a CECP for 2025 and 2030, which we wrote about here. That plan took the state well over a year to write. Its 127 pages lay out goals and strategies in the various sectors to reach 50% GHG reductions by 2030.
Recently, the state released a draft plan for 2050 in the form of a PowerPoint presentation and three public hearings. You can take a look here if you’d like to review the slides yourself, but we will summarize them here.
What’s in the draft plan?
The draft plan shared by the Massachusetts Executive Office of Energy & Environmental Affairs (EEA) is the result of the EEA’s modeling of how the state can best achieve net-zero by 2050. At a high level, it:
- Results in more than 85% of GHG emissions (88.6%, to be exact), to allow for uncertainty;
- Sets emissions sublimits by sector (see table below);
- Offers a high-level outline of strategies to achieve these emissions reductions by sector, breaking out which ideas are extensions of what is already in the CECP for 2025 and 2030 and which are new;
- Stresses a commitment to workforce development and environmental justice (EJ) (on the latter, specifically tracking the percentage of clean energy and climate investments to benefit EJ communities or populations).
A screenshot of slide 7 of EEA’s presentation showing sector sublimits for 2050
Green Energy Consumers comments
Overall, nothing in the draft 2050 CECP came as a huge surprise to us here at Green Energy Consumers Alliance. Many of the outlined strategies are extensions of strategies already in the 2025 and 2030 CECP. As an organization, we are much more focused on the 2030 requirements than the 2050 requirements, because only if we reach 50% GHG reductions by 2030 can we have a hope of reaching 85% by 2050. This decade is key in the fight against climate change.
With that said, we will be submitting comments to EEA on the draft 2050 CECP to make the following points.
- We need more specificity.
The draft plan lists several policies to reduce GHG emissions but fails to delineate how much each policy will contribute to the overall goal for any particular sector (transportation, buildings, and electricity). For that reason, we are not assured that the plan has what it takes to reach net zero emissions by 2050. Without more specificity, it will be difficult to hold state government accountable between now and 2050.
- Large buildings should be required to reduce emissions over time. For the building sector, the plan discusses Building Performance Reporting for buildings over 20,000 square feet. We would like to see a commitment to require large buildings across the state to reduce their emissions over time. Boston has such a policy in effect today.
- The state should increase its Clean Energy Standard for electricity. Currently, the CES would have 40% of the state’s power coming from sources such as wind, solar, and hydro by 2030. The state is planning on increasing the standard to 60% by 2030. Green Energy Consumers has been saying that the CES should be raised to 100% by no later than 2035. (Rhode Island passed a law to that effect this past June.) The federal Inflation Reduction Act provides excellent tax credits that will make green power even more affordable. Given today’s skyrocketing electricity prices (caused by our overdependence on natural gas), we stand to benefit economically and environmentally by procuring more offshore wind, onshore wind, solar, and hydro.
- We need to track pollution levels more closely, particularly in environmental justice communities.
With respect to environmental justice, we like how the plan will track and report where clean energy investments and installations are going. However, we would also like to see a tracking and reporting of pollution reductions in parts of the Commonwealth that are now suffering the most from dirty air.
- We encourage more emphasis on workforce development.
The plan talks about the importance of workforce development. Every day, more and more people are looking to purchase heat pumps and electric vehicles. It will be impossible to meet the demand unless we bring into the workforce more trained people to perform the work.
- Stabilizing total driving is not enough.
At Green Energy Consumers, we run a program called Drive Green to help people make the switch to electric cars, but we recognize that decarbonizing transportation requires a two-pronged approach: swiftly electrifying everything on our roads AND reducing vehicle miles traveled by making alternatives like walking, biking, and transit safer and more accessible. The draft 2050 CECP talks about “stabilizing” total driving. Recognizing that, barring any intervention, total driving would likely increase as the state’s population and economic activity increases, this is a good thing. However, we think the state should go one step further and aim to reduce driving by 2050. The fewer vehicle miles traveled, the fewer vehicle miles we need to electrify.
- Federal developments have changed the game.
This plan should explicitly recognize the fact that the federal Inflation Reduction Act (IRA) provides immense resources to households, businesses, states, and municipalities. The Commonwealth should organize itself to maximize the federal funds available by promoting IRA benefits to consumers and establishing capacity within state government itself to harvest IRA resources. For example, the Commonwealth should be working to establish a Massachusetts Green Bank as a counterpart to the national Green Bank, which is funded at $27 billion.
How do I take action?
EEA is accepting written comments until October 21, 2022. You can submit your comments in two ways:
- Using this portal, or
- Emailing firstname.lastname@example.org
We would recommend your comments take this format:
My name is ____ and I am a resident of ____, MA. I am writing today to offer comments on the draft Clean Energy and Climate Plan (CECP) for 2050. For the final draft of the 2050 CECP, I encourage the Executive Office of Energy and Environmental Affairs to:
These changes will result in a stronger, more transparent final CECP for 2050. Thank you for your consideration.
Let us know by leaving a comment here or emailing email@example.com if you sent a comment!