On Monday, November 7th the Massachusetts Department of Environmental Protection hosted their final stakeholder meeting to develop a set of regulations to reduce greenhouse gas (GHG) emissions in the electricity sector. You can read more about their proposals for other sectors in our first blog post.
Although Governor Baker’s Executive Order 569 directs MassDEP just to create regulations to satisfy the mandate of Section 3(d) of the Global Warming Solutions Act, the Department is also looking at creating regulations to satisfy Section 3(c) which states:
“Emissions levels and limits associated with the electric sector shall be established by the executive office and the department, in consultation with the department of energy resources, based on consumption and purchases of electricity from the regional electric grid, taking into account the regional greenhouse gas initiative and the renewable portfolio standard.”
State emissions from the most recent complete inventory found emissions to be 19.7% below the 1990 level. While this seems like an easy drop in emissions, most of this is due to switching our coal-fired power plants to natural gas. This means the minimum reductions needed by 2020 calculate to an additional 5.3%. Getting this extra percent reduction will grow increasingly challenging as we’ve already phased out our dirtiest emitters.
MassDEP is considering proposing an aggregate cap on GHG emissions from electricity generators. The regulation would, starting in 2018, establish a declining emissions cap for every power plant in Massachusetts. The Department is predicting a 4% reduction in emissions from the power plant cap.
Increasing deployment of renewable energy will be extremely important in meeting our GWSA requirements. Despite new offshore wind and large-scale hydropower due to recent legislation, it is unlikely that the full array of procurements will come online within the next 4 years. In order to ensure more clean energy, MassDEP is considering a Clean Energy Standard (CES) that would seek to bring in additional renewable energy between now and 2020. The CES would provide incentives and extend the existing clean energy framework beyond RPS-eligible renewable resources. Over the past decade, the electricity portfolio serving Massachusetts became much cleaner. The major changes came from the substitution of natural gas for coal and oil, and the tripling of imports of hydropower. This demonstrated that technologies that are not eligible for crediting under the RPS have made a significant contribution to a cleaner electricity grid already. The CES would serve to further increase this – a less preferable alternative to increasing the RPS.
Of course, the Department’s work and proposals are commendable, but many pointed out during the stakeholder session the lack of comprehensive and streamlined motivation to reducing emissions. The proposals seem more to be a reactionary measure to an unexpected SJC decision. With states like New York undertaking ambitious reforms to base utility revenue on things like performance, efficiency, and reliability, the Administration’s proposals in Massachusetts seem more like a hodgepodge of policies to meet our baseline requirements. The SJC decision and the recent stakeholder response has made it very clear just how important the GWSA really is, beyond our requirements. The Administration has taken a rudimentary step, but needs to look ahead to 2030, 2040, and 2050. MassDEP will be accepting comments within the electricity sector until November 21.