Climate Organizations’ Priorities for the House Climate Bill

To the 193rd General Court of the Commonwealth of Massachusetts, House of Representatives,

RE: Climate Organizations’ Priorities for the House Climate Bill

The Commonwealth of Massachusetts has made a commitment to environmental justice and to meeting our climate goals in order to ensure a livable planet and a just transition for all. The  Legislature is poised to take a major step towards modernizing the electric grid and promoting the electrification of transportation and buildings. We call on the House of Representatives to take this opportunity to meet critical environmental justice (EJ) goals and to equitably and rapidly transform the gas industry into one that meets the Commonwealth’s climate goals while keeping gas rates down.

The undersigned organizations present elements that must be in this year’s climate bill when it lands on Governor Healey’s desk.

1. Siting and Permit Approvals tied to a robust cumulative impact analysis. A cumulative impacts analysis (or a reference to it in legislation) will not be meaningful for EJ populations if the analysis is limited to foreseeable impacts related only to the project. In a dramatically streamlined permitting process, like the one envisioned in S.2829, redrafted as S.2838, a cumulative impacts analysis that takes the entire context of a community’s pollution and industrial burden into account is a critical protection for environmental justice communities. A cumulative impacts analysis is not a cure-all or a blanket requirement for a project proponent to redress all of the burdens existing in a host community. It would allow project proponents, decision-makers, and the public to better understand the existing conditions in a host community, weigh the benefits and burdens associated with projects that promote decarbonization of the electricity sector, and ensure that the people living in the communities where that infrastructure is sited are able to benefit from it.

2. Clean air for environmental justice populations and all. Environmental Justice (EJ) populations — people of color, Indigenous people, low-income people, and limited English proficient speakers— are especially affected by air quality problems. Including air quality policy will improve indoor and outdoor air quality, especially for EJ populations and residents burdened by pollution from congested roadways and ports, gas stoves, and mold in rental housing. Policies should include updating the state sanitary code to require annual mold inspections and create clear timelines for remediating mold in rental housing; Setting and achieving ambitious air pollution reduction targets by 2030 and 2035; Requiring installation of air filters in existing eligible buildings, such as schools, residential buildings with more than 2 tenant-occupied units; Requiring advanced filtration systems (e.g.,MERV 16) for new eligible buildings, such as day care facilities, residential developments, hospitals, schools, long-term care facilities, school aged child care programs, temporary shelters, nursing homes; Expand outdoor air monitoring ultrafine particulate matter and black carbon in pollution hotspots identified by an advisory committee.

3. End large scale gas pipeline expansion. The Commonwealth’s statutory mandate to reach net zero emissions by 2050 requires an orderly transition to clean  heat for buildings. Every new mile of high pressure pipeline installed is an expensive asset that will have to be paid off over decades by ratepayers or, if stranded, by taxpayers. Stopping the installation of these large scale pipeline expansions (more than 1 mile and more than 100 pounds per square inch), will improve public health and safety and reduce the future financial exposure of ratepayers and taxpayers. 

4. Put gas companies on a path to provide clean, non-emitting renewable energy rather than fossil gas that leaks methane into the atmosphere and into our homes and businesses. Heating and cooling buildings contributes a third of the Commonwealth’s greenhouse gas emissions, mostly a result of burning gas. There are several important changes the Legislature can make to accelerate this transition to clean, non emitting energy.:

1. Change the definition of gas company to allow  gas companies to sell non-emitting renewable thermal energy, such as networked geothermal systems. These systems are six times more efficient than conventional gas burners for heating buildings.
2. Limit the expansion of new gas mains unless there are no feasible alternatives to gas that can provide substantially similar service, taking into account the public interest in meeting greenhouse gas emission reduction mandates and in avoiding stranded assets, the cost of which will be borne by ratepayers.
3. Permit gas companies to meet their “obligation to serve” by providing customers with adequate non-emitting renewable substitutes.
4. Reform the current program (called GSEP) to encourage gas companies to repair or retire leak-prone pipelines, rather than replacing pipes that are projected to cost ratepayers some $34 billion between 2022 and 2039.  We should instead encourage gas companies to install non-emitting renewable sources of energy such as ground source heat pumps connected through  networked geothermal systems.
5. Require gas companies to plan and implement an orderly, safe transition to non-emitting energy for heating buildings.

5. Other Important Policies From Frontline Communities
   1. Require the MBTA to electrify the entire commuter rail system: The Massachusetts Bay Transportation Authority should be required to develop and implement short-term, medium-term and long-term plans for each line of the commuter rail system, ensuring that the line is fully integrated into the Commonwealth’s transportation system and designed to make the system more productive, equitable and decarbonized. 
   2. Remove woody biomass from the alternative energy portfolio standard: Limiting the eligibility of woody biomass as an alternative energy supply removes ratepayer funded subsidies for toxic woody biomass by excluding large and intermediate-sized wood heating units from qualifying for credits through the Alternative Portfolio Standard (APS) and  is consistent with Governor Healey’s campaign platform. 
   3. Removing woody biomass from the greenhouse gas emissions standard for municipal lighting plants would close the “biomass loophole” for Municipal Light Plants (MLPs).  Last session, the legislature removed biomass power plants from qualifying for the Renewable Portfolio Standard (RPS), with the passage of An Act Driving Clean Energy and Offshore Wind.  Because the RPS does not apply to municipal light plants , incentives remain for developers to build and operate wood-burning power plants in the Commonwealth, using ratepayer “clean energy” subsidies, or even to purchase biomass energy from other New England states. 
   4. Establish Labor Standards and Reporting for Clean Energy Procurement: A special commission charged with assessing the  impacts on the fossil fuel workforce caused by public or private efforts to reduce greenhouse gas emissions or transition from fossil fuels to clean energy will provide us with the necessary information to develop labor standards and to make thoughtful decisions to achieve a just transition to clean energy. 

These additions expand the impact of the pending climate bill, from a necessary expansion of the electric grid itself (crucial to bringing in the thousands of megawatts of renewable electricity we need) to ensure that Environmental Justice populations are not overburdened and to protect gas customers and taxpayers from the ballooning costs of maintaining an expensive and dangerous gas system that will soon be obsolete.  We hope the House will show strong support for environmental justice and rapid decarbonization, and adopt these recommendations.

The following organizations comprising most of the members of the MA Environmental Justice Table, Mass Power Forward coalition and Gas Transition Allies:

1. 350 Central Mass
2. 350 Mass of Greater Lowell
3. 350 Mass
4. 350 Mass Boston
5. 350 Mass Berkshire Node
6. 350 Mass Newton Node
7. 350 Mass North Shore
8. All In Energy
9. Alternatives for Community & Environment (ACE)
10. Andover WECAN
11. Arborway Coalition
12. Arise for Social Justice
13. Becket Energy Committee
14. Berkshire Environmental Action Team
15. Boston Clean Energy Coalition 
16. Boston Climate Action Network (BCAN)
17. Boston Green Action
18. Boston Harbor Storm Surge Working Group
19. Boston Teachers Union Climate Justice Committee, Steering Committee*
20. Breathe Easy Berkshires
21. Brimmer and May Environmental Club
22. Brookhaven Residents’ Climate Change Committee
23. Canton Democratic Town Committee 
24. Canton Sustainable Equitable Future
25. Cape Ann Climate Coalition Organizing Committee
26. Centro Presente
27. Chase Systems
28. Citizens’ Climate Lobby, Mass. North Shore Chapter
29. Citizens Climate Lobby South Shore & Cape chapter
30. Clean Water Action Massachusetts
31. Climate Action Group, the Unitarian Society of Northampton and Florence
32. Climate Action Now Western Mass
33. Climate Code Blue
34. Climate Reality Project Boston Metro chapter
35. Climate Reality Project Massachusetts Southcoast
36. Coalition For Social Justice
37. Conservation Law Foundation
38. Elders Climate Action Mass chapter
39. Energy Allies
40. Fairmount Indigo CDC Collaborative (FICC)
41. First Parish Unitarian Universalist of Arlington Climate Action Working Group
42. First Parish in Bedford
43. First Parish in Cambridge
44. First Parish of Concord Environmental Team
45. First Unitarian Universalist Society in Newton Climate Action Task Force
46. Food & Water Watch
47. Fore River Residents Against Compressor Station (FRRACS)
48. Franklin County Continuing the Political Revolution- Climate Crisis Task Force
49. Greater Boston Physicians for Social Responsibility
50. Green Energy Consumers Alliance
51. Green Newton
52. Green Sanctuary Committee of FPUU Medfield
53. GreenRoots
54. H.E.R.O. Nurturing Center Inc
55. HEET
56. HEETlabs
57. Jewish Climate Action Network
58. Lexington Climate Action Network (LexCAN)
59. LISC Massachusetts
60. Longmeadow Pipeline Awareness Group
61. Massachusetts Climate Action Network
62. Massachusetts Interfaith Power & Light, Inc.
63. Massachusetts Youth Climate Coalition
64. Melrose UU Church Climate Action Team
65. Mothers Out Front Acton
66. Mothers Out Front Amherst
67. Mothers Out Front Arlington
68. Mothers Out Front Bedford Chapter
69. Mothers Out Front Brookline
70. Mothers Out Front Cambridge
71. Mothers Out Front Concord
72. Mothers Out Front Downtown Boston
73. Mothers Out Front East Boston
74. Mothers Out Front Jamaica Plain
75. Mothers Out Front Massachusetts
76. Mothers Out Front Medford 
77. Mothers Out Front Newton
78. Mothers Out Front Northampton
79. Mothers Out Front Somerville
80. Mothers Out Front Waltham
81. Mothers Out Front West Roxbury/Roslindale/Hyde Park chapter
82. Mothers Out Front Winthrop
83. Mt. Hope Canterbury Neighborhood Association
84. Mystic Valley Progressives
85. No Fracked Gas in Mass
86. North Parish UU Climate Justice Group
87. Our Climate
88. Our Revolution MA (ORMA) Climate Crisis Working Group
89. Partnership for Policy Integrity
90. Pipe Line Awareness Network for the Northeast
91. Progressive Massachusetts
92. Renewable Renegades
93. Resist the Pipeline
94. Resonant Energy
95. Sierra Club Massachusetts
96. Slingshot
97. South Coast Neighbors United
98. Speak for the Trees, Boston
99. Springfield Climate Justice Coalition
100. Springfield No One Leaves
101. Sunwealth
102. Sustainable Wellesley
103. The Enviro Show
104. Third Act Massachusetts
105. Trustees Collaborative for Parks & Open Space
106. Union of Concerned Scientists
107. Unitarian Universalist Association of Greater Springfield
108. Unitarian Universalist Mass Action
109. Vote Solar
110. Watertown Faces Climate Change (a node of 350Mass)
111. Worcester Congregations for Climate and Environmental Justice
112. ZeroCarbonMA