Massachusetts Clean 

Energy and Climate Plan 

for 2020

A report to the Great and General Court pursuant to the

Global Warming Solutions Act 

(Chapter 298 of the Acts of 2008, and as codified at 

M.G.L. c. 21N) 

Secretary of Energy and Environmental Affairs

Ian A. Bowles

December 29, 2010
Massachusetts Clean Energy and Climate Plan for 2020

ii

Acknowledgements

CLIMATE PROTECTION AND GREEN ECONOMY ADVISORY COMMITTEE

Convener:

Ian A. Bowles

Secretary

Executive Office of Energy and 

Environmental Affairs (EEA)

Secretary’s Designee:

David Cash

Assistant Secretary for Policy

EEA

Co-Chair:

Susan Avery, PhD

President and Director

Woods Hole Oceanographic 

Institute

Co-Chair:

Martin Madaus

Former President and CEO

Millipore Corp.

Julian Agyeman Ph.D. FRSA

Professor and Chair, Urban and 

Environmental Policy and Planning

Tufts University 

Marty Aikens

Business Agent

International Brotherhood of 

Electrical Workers Local 103

Craig Altemose

Executive Staffperson

Students for a Just and Stable 

Future and Executive Director

Stop the Burning

Roger Berkowitz

President and CEO

Legal Sea Foods

Timothy Brennan

Executive Director

Pioneer Valley Planning 

Commission

Grace Chang

Vice President, Air Quality

A123 Systems, Inc.

Anne M. Finucaine

Vice President

Bank of America Corp.

John Fish

Chairman and CEO

Suffolk Construction Co.

Paul Gaynor

President and CEO

First Wind

Charles Harak, Esq.

Senior Attorney

National Consumer Law Center

Berl Hartman

Director

E2 New England

James W. Hunt III

Chief, Environmental and Energy 

Services

City of Boston

John Kassel

President 

Conservation Law Foundation

Thomas King

Executive Director

National Grid

Kevin Knobloch

President

Union of Concerned Scientists

Penn Loh

Professor, Urban and 

Environmental Policy and Planning

Tufts University

Mindy Lubber

President

CERES

Thomas J. May

Chairman, President, Chief 

Executive Officer and Trustee

NSTAR

Carmichael Roberts

General Partner

North Bridge Venture Partners

James Ruberto

Mayor 

City of Pittsfield

Una S. Ryan, Ph.D.,O.B.E.

President and CEO

Diagnostics for All

Laura Scott

Senior Vice President, Finance & 

Strategy

Gulf Oil Limited Partnership

Nancy Stevens

Mayor

City of Marlborough

Hernant Taneja

Managing Director

General Catalyst Partners

Steve Wofsy

Professor, Atmospheric and 

Environmental Science

Harvard University

Lisa Wong

Mayor

City of Fitchburg

CLIMATE PROTECTION AND GREEN ECONOMY ADVISORY COMMITTEE SUBCOMMITTEES

BUILDINGS AND ENERGY 

EFFICIENCY

CoChairs: Penni Conner (NSTAR) 

and Marcy Reed (National Grid) 

Berl Hartman (E2), Betsy Boyle 

(CERES), Brad Swing (City of 

Boston), Charlie Harak (NCLC), 

replaced Amy Stacy with Nancy 

Doyon (National Grid), Jared 

Eigerman (Gouston & Storrs), 

Heather Henricksen (Harvard U.), 

Shanna Cleveland (CLF), Yakir 

Siegal (Suffolk Construction), 

Jeremy McDiarmid (ENE), Ed 

Mitchell (Legal Sea Foods)

State staff: Alissa Whiteman, Ian 

Finlayson & Frank Gorke (DOER), 

Ann Berwick (DPU), Marc Breslow 

(EEA), Mike Guigli (DPS)

COMMUNICATIONS

Chair: Karen Marinella Hall 

(Millipore Corp.)

Karen Wood (CLF), Emily Dahl 

(Nexamp), Walter Frick (Clean 

Energy Council), Ted Page 

(Captains of Industry), Craig 

Altemose (SJSF)

State staff: John Clarkeson, Bob 

Keough, Marc Breslow & Lisa 

Capone (EEA), Sarah Weinstein & 

Lee Dillard Adams (MassDEP), 

Susan Kaplan (DOER), Elizabeth 

Cellucci (DPU), Ned Codd 

(MassDOT)
Massachusetts Clean Energy and Climate Plan for 2020

iii

ECONOMY-WIDE AND 

WORKFORCE

CoChairs: Penn Loh (Tufts) & 

Laura Scott (Gulf Oil)

Kathleen Freeman (NSTAR), 

Charlie Harak (NCLC), Seth Kaplan 

(CLF), Hemant Teneja (General 

Catalyst), James Hunt (City of 

Boston), Galen Nelson (Boston 

Redevelopment Authority), Craig 

Altemose (SJSF)

State staff: Ben Davis (DPU), Bill 

Lamkin (MassDEP), Vivek Mohta & 

Zazy Atala (DOER)

FORESTRY, AGRICULTURE,

MARINE AND LAND USE CHANGE

Chair: Andy Solow (WHOI)

David Damery (UMass), Sue Reid 

(CLF), Steven Wofsy (Harvard U.), 

Timothy Griffin (Tufts U.), 

Dominique McCadden 

(Northeastern U, SJSF), Stephen 

Long & Laura Marx (The Nature 

Conservancy), Emily Russell-Roy 

(Pacific Forest Trust), Laura Hartz 

(Tufts U., SJSF), Jennifer Ryan & 

Heidi Ricci (MassAudubon)

State staff: Bob O’Connor & Celia 

Riechel (EEA), Ian Finlayson & Rob 

Rizzo (DOER), Saiping Tso, Gerard 

Kennedy & Hotze Wijnja (DAR), 

Will Space & Lee Dillard Adams 

(MassDEP)

INDUSTRIAL PROCESSES, SOLID 

AND HAZARDOUS WASTE 

REDUCTION AND MANAGEMENT

CoChairs: David Newman 

(Millipore) & Tom O’Rourke 

(NSTAR)

Steve Changaris (National Solid 

Waste Management Association, 

Mass. Chapter),

Shanna Cleveland (CLF), John 

Harland (Intel), Emanuele Ostuni 

(Nano Terra Inc.),

Rick Heller (Legal Sea Foods)

State Staff: John Fischer, Marc 

Wolman, Tom Bienkiewicz & 

Sharon Weber (MassDEP) 

LOW CARBON ENERGY SUPPLY

CoChairs: Paul Gaynor (First 

Wind) & John Kassel (CLF)

Susan Reid (CLF), David Wilby 

(First Wind), Parker Weil (Bank of 

America), Ellen Angley & James 

Daly (NSTAR), Andy Chu (A123 

Systems), Porter Hoagland 

(WHOI), Dan Bakal (CERES), 

Laura Scott (Gulf Oil), Nick 

Dahlberg (Boston U., SJSF), Joe 

Fitzpatrick (Atlantic Hydrogen)

State staff: Nathan Phelps (DPU), 

Dwayne Breger (DOER), Yaara 

Grinberg (fellow, DOER), Sharon 

Weber, Eric Fahle & Nancy 

Seidman (MassDEP) 

TRANSPORTATION AND LAND 

USE PLANNING

Chair: Tim Brennan (Pioneer 

Valley Planning Commission)

Berl Hartman (E2), Penn Loh 

(Tufts U.), Laura Scott (Gulf Oil 

Limited Partnership), Andre 

Leroux (Smart Growth Alliance), 

Lisa Wong (City of Fitchburg), 

Rafael Mares (CLF), John Dalzell 

(Boston Redevelopment 

Authority), Carol Lee Rawn & 

Sharleen Leurig (CERES), Richard 

Heller (Legal Sea Foods), John 

Read & Vineet Gupta (City of 

Boston)

State staff: Marc Breslow, 

Catherine Cagle, Ned Codd, 

Victoria Maguire, Christine Kirby, 

Kurt Gaertner 

STATE STAFF

STEERINGCOMMITTEE

David Cash, Assistant Secretary 

for Policy Executive Office of 

Energy and Environmental Affairs 

(EEA)

Laurie Burt, Commissioner, 

Department of Environmental 

Protection (MassDEP)

Phil Giudice, Commissioner, 

Department of Energy Resources 

(DOER)

Tim Woolf, Commissioner, 

Department of Public Utilities 

(DPU)

David Mohler, Executive Director, 

Office of Transportation Planning, 

Department of Transportation 

(MassDOT)

April Anderson Lamoureux, Permit 

Ombudsman, Executive Office of 

Housing and Economic 

Development (HED)

INTERAGENCY MANAGEMENT 

TEAM

Marc Breslow, EEA

Vivek Mohta, DOER

Ben Davis, DPU

Lee Dillard Adams, MassDEP

Jim Colman, MassDEP

Lucy Edmondson, US EPA, 

formerly MassDEP

IMPLEMENTATION TEAM 

Marc Breslow, EEA

Ian Finlayson, DOER

Vivek Mohta, DOER

Jim Colman, MassDEP

Lee Dillard Adams, MassDEP

Lucy Edmondson, US EPA, 

formerly MassDEP 

Bill Lamkin, MassDEP

Nancy Seidman, MassDEP

Sharon Weber, MassDEP

Ben Davis, DPU

Catherine Cagle, MassDOT

Ned Codd, MassDOT

Victoria Maguire, EOHED

POLICY DEVELOPMENT

Ann Berwick (Commissioner, DPU)

Maeve Vallely Bartlett (EEA)

Rich Bizzozero (OTA)

Amy Branger (MassDOT)

Dwayne Breger (DOER)

Janet Curtis (DOER)

John Fischer (MassDEP)

Eric Friedman (DOER)

Kurt Gaertner (EEA)

Thomas Gatzunis (Commissioner, 

DPS)

Mike Guigli (DPS) 

Christine Kirby (MassDEP)

Audrey Lee (fellow, DOER)

Lawrence Masland (DOER)

Bob O’Connor (EEA) 

Scott Peterson (MassDOT/CTPS)

Celia Riechel (EEA)

Mike Sherman (DOER)

Alissa Whiteman (DOER)

Marc Wolman (MassDEP)

CONTRIBUTORS

Kathy Baskin (EEA) 

John Clarkeson (EEA)

David Howland (MassDEP)
Massachusetts Clean Energy and Climate Plan for 2020

iv

Holly Johnson (MEPA)

Geri Lambert (MassDEP)

Marilyn Levenson (MassDEP)

Bob Levite (UMass Agricultural 

Extension)

Ann McGahan (MassDOT/CTPS)

Ann McGovern (MassDEP)

Gerry Palano (DAR)

Steve Petsch (Office of State 

Geologist)

Jane Pfister (EEA) 

Susan Quinones (MassDOT)

Vandana Rao (EEA) 

John Raschko (OTA)

Sue Ann Richardson (MassDEP)

Tom Riley (DPS)

Tom Witkin (DOER)

Sarah Weinstein (MassDEP)

INTERNS

Elizabeth Barthelmes (MassDEP)

Hilary Dennis (MassDEP)

Bailey DiOrio (EEA)

Jeffrey Kalmus (DOER)

Leslye Penticoff (EEA)

Mary Schnoor (DOER)

Consultants

Eastern Research Group: Paula 

Fields, Jason Veysey, Stacy 

DeGabriele, Robyn Liska, Scott 

Warner, Jan Connery, John 

Wilhelmi, Charlie Goff

Synapse Energy Economics: 

Bruce Biewald, Ezra Hausman, 

Kenji Takahashi, David White, 

Lucy Johnston, Patrick Knight

Cambridge Systematics, Inc.: 

Christopher Porter, Nathan Higgins

Abt Associates: Michael Fisher, 

Isabelle Morin, Dan Basoli

Stockholm Environment 

Institute-U.S.: Charles Heaps, 

Victoria Clark

Ventana Systems: Tom 

Fiddaman, Ron Suiter, Bill Arthur, 

Bill Kilpatrick (Real Ability)

Statutory Requirement

This report fulfills the requirements of Chapter 298 of the Acts of 2008, and as codified at M.G.L. 

c. 21N.

Section 4. (a) The secretary shall adopt the 2020 statewide greenhouse gas emissions limit 

pursuant to subsection (b) of section 3 which shall be between 10 per cent and 25 per cent below 

the 1990 emissions level and a plan for achieving said reduction. 
Massachusetts Clean Energy and Climate Plan for 2020

v

Table of Contents

Executive Summary ......................................................................................................ES-1

I. A Clean Energy Revolution .............................................................................................. 1

Energy Independence.................................................................................................. 2

Energy Costs and Volatility........................................................................................... 2

Economic Opportunity ................................................................................................. 3

Employment Projections for 2020.................................................................................. 5

Climate Change .......................................................................................................... 8

Impacts of Local and Regional Air Pollution ...................................................................11

Meeting Challenges, Seizing Opportunities ....................................................................12

II. An Integrated Portfolio of Policies ..................................................................................13

Buildings......................................................................................................................14

All Cost-Effective Energy Efficiency...............................................................................18

Advanced Building Energy Codes .................................................................................20

Building Energy Rating and Labeling.............................................................................23

―Deep‖ Energy Efficiency Improvements for Buildings.....................................................26

Expanding Energy Efficiency Programs to Commercial/ Industrial Heating Oil ....................28

Developing a Mature Market for Solar Thermal Water and Space Heating..........................29

Tree Retention and Planting to Reduce Heating and Cooling Loads ...................................32

Federal Appliance and Product Standards......................................................................35

Electricity Supply ..........................................................................................................37

Renewable Portfolio Standard (RPS) .............................................................................40

Regional Greenhouse Gas Initiative (RGGI) ...................................................................42

More Stringent EPA Power Plant Rules ..........................................................................44

Clean Energy Imports.................................................................................................45

Clean Energy Performance Standard (CPS) ...................................................................47
Massachusetts Clean Energy and Climate Plan for 2020

vi

Transportation..............................................................................................................49

Federal and California Vehicle Efficiency and GHG Standards ...........................................53

Federal Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Vehicles ......55

Federal Renewable Fuel Standard and Regional Low Carbon Fuel Standard........................56

Clean Car Consumer Incentives ...................................................................................59

Pay As You Drive (PAYD) Auto Insurance Pilot ...............................................................61

Sustainable Development Principles .............................................................................64

GreenDOT.................................................................................................................66

Smart Growth Policy Package ......................................................................................68

Non-Energy Emissions ...................................................................................................71

Reducing GHG Emissions from Motor Vehicle Air Conditioning..........................................73

Stationary Equipment Refrigerant Management .............................................................75

Reducing SF6 Emissions from Gas-Insulated Switchgear..................................................77

Reducing GHG Emissions from Plastics..........................................................................79

Cross-cutting Policies ....................................................................................................80

MEPA GHG Policy and Protocol.....................................................................................81

Leading by Example ...................................................................................................83

Green Communities Division........................................................................................85

Consideration of GHG Emissions in State Permitting, Licensing & Administrative 

Approvals.................................................................................................................87

III. Implementing the Global Warming Solutions Act ............................................................88

Setting the 2020 Limit...................................................................................................88

Putting the Plan into Action ............................................................................................93

IV. Beyond 2020: The Road to 80 Percent Lower Emissions in 2050 ......................................95

Scenarios for a Clean Energy Future................................................................................95

V. Appendix...................................................................................................................107

VI. References ...............................................................................................................110
Massachusetts Clean Energy and Climate Plan for 2020

Executive Summary

ES-1

Executive Summary

A Clean Energy Revolution

Between 2007 and the end of 2010, solar 

photovoltaic (PV) systems installed and 

scheduled for installation in Massachusetts 

increased 20-fold – with jobs in solar 

manufacturing, installation, and services 

nearly tripling — while installed wind energy 

increased 10-fold. In that same time period, 

Massachusetts launched the most aggressive 

energy efficiency program in the country, 

with estimated savings of over $6 billion for 

residential, municipal, industrial and 

commercial customers and 4,500 jobs 

sustained or created. 

This is not a vision of a possible future for 

Massachusetts. This is Massachusetts today. 

It is in this context that the Executive Office 

of Energy and Environmental Affairs (EEA) 

presents the Massachusetts Clean Energy 

and Climate Plan for 2020. The Global 

Warming Solutions Act (GWSA, or the Act) of 

2008 requires the Secretary of Energy and 

Environmental Affairs to establish a 

statewide limit on greenhouse gas (GHG) 

emissions of between 10 percent and 25 

percent below 1990 levels for 2020 — on the 

way toward an 80 percent reduction in 

emissions by 2050 — along with a plan to 

achieve the 2020 target. Secretary Bowles 

has set that 2020 limit at 25 percent — and 

this Clean Energy and Climate Plan for 2020 

contains the measures necessary to meet the 

limit. 

Fulfilling that mandate will do much more 

than meet the requirements of the Act. It will 

allow the Commonwealth to address a 

number of challenges, only one of which is 

climate change. Most importantly, it will give 

powerful impetus to the clean energy 

revolution that has already begun.

Energy Independence: Massachusetts is 

at the end of the energy pipeline, figuratively 

and literally. All of our fossil-based energy 

sources — oil, natural gas, and coal — are 

derived from other regions of the country 

(e.g., the Gulf Coast or Western states) and 

other parts of the world, many of them 

unstable or hostile to the United States, 

(e.g., countries in the Middle East and 

Venezuela). Thus, all spending on fossil fuel 

energy — whether to fuel power plants, 

buildings, or vehicles — flows out of state 

and fails to provide income to in-state 

businesses or employees. This exported 

economic value is significant, totaling almost 

$22 billion in 2008.1In 2008, an average 

Massachusetts household spent about 

$5,200 for energy costs, of which about 

$1,700 was for heating (space and water), 

$1,300 for electricity, and $2,200 for 

gasoline. Almost all of these expenditures 

leave Massachusetts.

Energy Costs and Volatility: In addition 

to the economic drain represented by 

Massachusetts dollars flowing out of the 

state for energy resources, energy 

consumers have experienced wild price 

swings and long term energy price increases. 

The figures below show both steadily 

increasing and volatile prices for natural gas, 

electricity and gasoline.

 

1 Energy Price and Expenditure Estimates by Source, Selected 

Years, 1970-2008, Massachusetts, U.S. Energy Information 

Administration (EIA).

/www.eia.doe.gov/states/sep_prices/total/pdf/pr_ma.pdf
Massachusetts Clean Energy and Climate Plan for 2020

Executive Summary

ES-2

Figure ES-1. Increase and volatility in natural gas 

prices (source: DOER)

Figure ES-2. Increase and volatility in electricity 

prices (source: DOER)

Figure ES-3. Increase and volatility in gasoline 

prices (source: U.S. Energy Information 

Administration (EIA))

Economic Opportunity: Along with the 

rest of the nation, Massachusetts is coming 

out of the most severe recession in half a 

century. In the transition to a clean energy 

economy, Massachusetts has many 

resources to bring to bear — and should be 

the disproportionate beneficiary as the 

economy becomes cleaner and greener. 

Clean Edge, Inc., has found that 

Massachusetts is the leading state on the 

East Coast for clean energy innovation, 

investment, deployment, and jobs.2

Massachusetts already has a core of 

companies and jobs in clean energy, and this 

industry has been growing even during 

challenging economic times. According to a 

Massachusetts Clean Energy Center 

(MassCEC) survey of 471 local companies, 

more than 11,000 people are employed in 

clean energy at the end of 2010, up 65 

percent since 2007. Some 3,500 people are 

employed in manufacturing of energy 

efficiency products, with growth of 20 

percent since 2007, and the fastest growth 

(67 percent) in energy storage, represented 

by such companies as A123 Systems, Inc., 

Beacon Power Corp., and Premium Power

Corp.

Policies in this Plan will result in large 

reductions in fossil fuel use in buildings, 

electricity generation, and transportation. 

These include energy efficiency programs, 

advanced building codes, requirements for 

increased renewable electricity generation, 

federal vehicle efficiency standards, state 

incentives for purchasing more efficient 

vehicles, incentives to reduce vehicle miles 

traveled, and ―smart growth‖ policies. 

Through both direct and indirect impacts, 

these policies will create an estimated 

42,000 to 48,000 jobs in Massachusetts in 

2020. 

 

2

A Future of Innovation and Growth: Advancing 

Massachusetts’ Clean Energy Leadership, Clean Edge, 

April 2010, Massachusetts Clean Energy Center.
Massachusetts Clean Energy and Climate Plan for 2020

Executive Summary

ES-3

Table ES-1. Approximate Massachusetts job increases, direct and indirect, in 

2020 due to Implementation of the Massachusetts Clean Energy and Climate Plan

Federal and California vehicle efficiency and GHG standards 6,000

Federal emissions and fuel efficiency standards for medium

and heavy duty vehicles

1,000

Pay As You Drive auto insurance (PAYD) 3,000

Clean car consumer incentives 2,000

Smart growth policy package 1,000

subtotal — transportation 13,000

Electric efficiency programs 10,000

Natural gas, heating oil efficiency programs 9,000

Advanced building energy codes 3,000

Federal appliance & product standards 1,000

subtotal — buildings efficiency 23,000

Renewables (solar, wind, biomass, biofuels) 6,000 - 12,0003

Total 42,000 - 48,000

Note: see the methodological appendix for sources and description of how the employment gains were 

estimated.

Artist’s rendering of proposed New Bedford Marine Commerce Terminal, staging area for offshore wind 

installation. (Courtesy of MassCEC)

 

3 The figure for renewables is given as a range, because most of the value added for renewables is in manufacturing, and 

the degree to which renewable components will be manufactured in the Commonwealth is fluid at this time, as is the 

degree to which the state’s 2020 renewable energy requirements will be met from in-state sources.
Massachusetts Clean Energy and Climate Plan for 2020

Executive Summary

ES-4

Climate Change: The international

consensus on climate released in 2007 by 

the Intergovernmental Panel on Climate 

Change (IPCC) found that the ―warming of 

the climate system is unequivocal, as is now 

evident from observations of increases in 

global average air and ocean temperatures, 

widespread melting of snow and ice, and 

rising global average sea level.‖4

Massachusetts is vulnerable to severe 

impacts from climate change. Impacts are 

expected to include increased coastal 

flooding from intense storms and permanent 

inundation of low-lying coastal areas; 

infrastructure and development located along 

the coast affected by storm surges, sea level 

rise, and saltwater intrusion; degraded water 

quality and quantity, habitat loss, and 

increased sedimentation and pollution of 

waterways due to changes in precipitation; 

increased number of extreme heat days, 

impacting those with respiratory and 

cardiovascular conditions; habitat for 

commercially important fish and shellfish 

species, such as cod and lobster, shifted 

northward; and for recreation areas,

decreased average ski and snowboard 

seasons and increased need for artificial 

snow making. 

Local and Regional Air Pollution: In 

addition to causing climate change, 

emissions from the combustion of fossil fuels 

result in a range of negative human health 

and ecosystem impacts. The U.S. 

Environmental Protection Agency (EPA) has 

established health-based National Ambient 

Air Quality Standards (NAAQS) for six 

pervasive pollutants that have welldocumented health and environmental 

impacts: ozone (O3), nitrogen dioxide (NO2), 

sulfur dioxide (SO2), particulate matter (PM), 

lead, and carbon monoxide (CO). Exposure 

 

4 4th Assessment Report, Intergovernmental Panel on 

Climate Change, 2007.

to each of these pollutants has been linked 

to adverse health effects. Ozone can also 

irritate the respiratory system, causing 

coughing, throat irritation, chest pain and 

reduced lung function. Ozone can also 

aggravate asthma, leading to more asthma 

attacks and increased hospital admissions 

and emergency room visits for respiratory 

problems. Fine PM is associated with 

aggravation of respiratory and cardiovascular 

disease resulting in increased hospital 

admissions, emergency room visits and 

premature mortality.

These pollutants also damage ecosystems.

Acid rain is created when SO2 and NOx 

emissions mix with water in the atmosphere.

Acid rain lowers the pH levels of lakes, 

rivers, and soils, harming fish and 

invertebrates. Exposure to ozone is 

associated with a range of adverse impacts 

to vegetation, including impairment of tree 

growth and loss of agricultural crop yield.

Ozone can increase the rate of water loss by 

trees causing forests to drain streams and 

soils of water, thus stressing natural 

ecosystems beyond the trees themselves.

Meeting Challenges, Seizing 

Opportunities: At roughly 2 percent of the 

U.S. economy and 1.3 percent of the nation’s 

GHG emissions, Massachusetts could not, on 

its own, stop global climate change even if it 

reduced statewide emissions to zero 

instantly. However, Massachusetts is in a 

position to show the way to a clean energy 

economy — and reap direct benefits in 

economic growth — through the 

development of smart, targeted policies that 

reduce emissions by promoting greater 

energy efficiency, developing renewable 

energy, and encouraging other alternatives 

to the combustion of fossil fuels. In the 

process, Massachusetts will also start to get 

off the fossil fuel rollercoaster, become more 

energy independent, and jump start its 

economy with new technologies, new 

companies, and new jobs. 
Massachusetts Clean Energy and Climate Plan for 2020

Executive Summary

ES-5

The Massachusetts Clean Energy and Climate 

Plan for 2020 will put Massachusetts on a 

path to meeting its statutory obligation to 

reduce GHG emissions, and on the road to a 

vibrant clean energy economy. 

Setting the 2020 Emissions 

Limit

The statewide GHG emissions limit set for 

2020 was based on two years of analysis and 

public comment, and followed a process to 

determine the baseline Massachusetts 1990 

emissions level and the predicted ―Business 

as Usual‖ (BAU) emissions trajectory for 

2020. The trend line of GHG emissions was 

found to be relatively stable since 1990 and 

projected as remaining relatively stable 

through 2020. Policies and programs 

implemented or initiated since the beginning 

of the Patrick-Murray Administration in 2007 

— including the Green Communities Act and 

various state government executive actions, 

and federal government actions — are

projected to result in GHG emissions 

reduction of roughly 18 percent — roughly 

the midpoint of the 10 percent to 25 percent 

range required by the GWSA.

Further analysis showed that it would be 

technically feasible to reduce emissions by 

up to 35 percent below 1990 levels by 2020 

with additional policies that are costeffective. In a series of eight public hearings 

held in June 2010, as required by the Act, 

nearly 200 individuals and organizations 

provided oral or written comment on the 

2020 emissions reduction requirement and 

on policy measures to meet the requirement.

The vast majority of commenters called for 

the Secretary to set the GHG limit at 25 

percent below 1990 levels, the maximum 

allowed under the statute. The Secretary of 

EEA then directed state technical teams to 

conduct in-depth analyses of measures that 

satisfy criteria of cost-effectiveness and 

reducing GHG emissions.

0%

5%

10%

15%

20%

25%

30%

35%

40%

% Reduction Below 1990 Statewide Emissions

by 2020

Projected Emission Reduction Range

Range 

allowed 

by GWSA

Maximum reduction projected

Minimum reduction projected

Figure ES-4. Projected emission reduction range 

below 1990 by 2020. The range results from 

uncertainties in Business as Usual (BAU) 

emissions, policy designs, and impacts of 

individual policies.

Table ES-2 (on page ES-6) displays the 

portfolio of policies incorporated in this Clean 

Energy and Climate Plan for 2020, and the 

associated potential contribution to GHG 

reduction below 1990 levels by 2020 for 

each policy. In aggregate, these policies, 

which include measures put in place since 

2007 and new initiatives proposed in this 

Plan, are projected to achieve emissions 

reductions in the range of 18 percent to 33 

percent by 2020 (see Figure ES-4). The 

lower end of this range represents a scenario 

in which Business as Usual (BAU) emissions 

are higher than projected and actual 

emissions reduction from the policies as 

implemented is at the low end of estimates.

The higher end of the range represents a 

scenario in which BAU emissions are lower 

than projected and implementation success 

is relatively high. A mid-range estimate for 

the portfolio of policies results in GHG 

emissions approximately 27 percent below 

1990 levels by 2020 (See Figure ES-5 on 

page ES-7).
Massachusetts Clean Energy and Climate Plan for 2020

Executive Summary

ES-6

Table ES-2. The Portfolio of Policies

middle estimate 

% reduction 

below 1990

Buildings 9.8%

All cost-effective energy efficiency/RGGI 7.1%

Advanced building energy codes 1.6%

Building energy rating and labeling ---

―Deep‖ energy efficiency improvements for buildings 0.2%

Expanding energy efficiency programs to C/I heating oil 0.1%

Developing a mature market for solar thermal water/space heating 0.1%

Tree retention and planting to reduce heating and cooling loads 0.1%

Federal appliance and product standards 0.6%

Electricity 7.7%

Expanded Renewable Portfolio Standard (RPS) 1.2%

More stringent EPA power plant rules 1.2%

Clean energy imports 5.4%

Clean energy performance standard (CPS) ---

Transportation 7.6%

Federal and California vehicle efficiency and GHG standards 2.6%

Federal emissions and fuel efficiency standards for medium and heavy

duty vehicles 0.3%

Federal renewable fuel standard and regional low carbon fuel standard 1.6%

Clean car consumer incentives 0.5%

Pay As You Drive (PAYD) auto insurance (pilot program, possible 

expansion later) 1.1%

Sustainable Development Principles 0.1%

GreenDOT 1.2%

Smart growth policy package 0.4%

Non-Energy Emissions 2.0%

Reducing GHG emissions from motor vehicle air conditioning 0.3%

Stationary equipment refrigerant management 1.3%

Reducing SF6 emissions from gas-insulated switchgear 0.2%

Reducing GHG emissions from plastics 0.3%

Cross-cutting Policies ---

MEPA GHG policy and protocol ---

Leading by Example ---

Green Communities Division ---

Consideration of GHG emissions in State permitting, licensing and 

administrative approvals ---

Overall reductions versus 1990 (adjusted for uncertainty in Business as Usual (BAU) 

emissions, policy designs, and impacts of individual policies)

High BAU emissions and low policy impacts 18%

Middle BAU emissions and policy impacts 27%

Low BAU emissions and high policy impacts 33%

Note: the overall reduction is adjusted for overlap among policies, so is smaller than the sum of the 

individual policies. Individual lines may not sum to subtotals due to rounding. 
Massachusetts Clean Energy and Climate Plan for 2020

Executive Summary

ES-7

60

65

70

75

80

85

90

95

100

1990 1995 2000 2005 2010 2015 2020

Million tons GHG 

Clean Energy and Climate Portfolio Impacts vs. 

Business as Usual

Buildings (-9.8%)

Electricity

Supply (-7.7%)

Transportation 

(-7.6%)

Non-Energy

(-2.0%)

Business as Usual

25% below 1990

Figure ES–5. Emissions reductions by sector for the portfolio of policies, at the mid-range estimate 

of 27 percent below 1990 levels by 2020. 

Based on these analyses, input from the Climate Protection and Green Economy Advisory 

Committee created by the GWSA, and full consideration of the public comments received, EEA 

determined that a responsible and achievable GHG emissions reduction limit for 2020 that 

maximizes opportunities to realize energy cost savings, increase energy independence, and 

promote growth in clean energy jobs in Massachusetts is 25 percent. The limit is at the high end 

of the range for 2020 authorized by GWSA, but the middle of the range of possible outcomes for 

the policies incorporated in this Plan. 

An Integrated Portfolio of Policies

The GWSA provides broad authority to 

choose policy tools — from targeted and 

technology-specific policies to economy-wide 

and market-based mechanisms — to 

advance a clean energy economy while 

reducing GHG emissions. An integrated 

portfolio approach plays to Massachusetts 

strengths and, taken as a whole, has the 

greatest likelihood of reaching the goals of 

addressing energy costs, energy security and 

independence, and reducing GHG emissions.

In the last four years, Massachusetts has 

demonstrated the effectiveness of a portfolio 

approach. A combination of legislation, 

executive action and private sector 

entrepreneurship has aligned incentives and 

created opportunities for clean energy 

growth and GHG reductions. 

The directive from the Secretary was to build 

on this portfolio — expanding existing 

programs where practical and developing 
Massachusetts Clean Energy and Climate Plan for 2020

Executive Summary

ES-8

new complementary policies that could 

accelerate clean energy growth and lower 

GHG emissions. Each of the policies 

presented in this Plan — GHG reductions; 

cost-effectiveness; lowering energy costs for 

consumers and businesses; job growth; 

equity; implementability; and co-benefits —

underwent rigorous analysis focusing on 

criteria established by the Act and input from 

the public hearings and Advisory Committee.

Some policies can be put in place immediately; others will be tested first through pilot 

programs. Not every one of these policies 

must be implemented to its fullest extent in 

order to achieve the 2020 mandate. But 

these represent the suite of policies that the 

Patrick-Murray Administra-tion is committed 

to pursuing over the next four years as we 

build on the foundation created in the past 

four years and work toward the 2020 

emissions limit set by the Secretary.

This portfolio is divided into five categories: 

buildings, electricity supply, transportation, 

non-energy emissions, and cross-cutting 

policies.

BUILDINGS

9.8 PERCENT REDUCTION OF GHG EMISSIONS

Buildings consume over 50 percent of the 

energy used in Massachusetts and are 

therefore responsible for the greatest GHG 

emissions of any sector. Energy use in 

buildings comes from these two primary 

areas: 1) fuels for heating — primarily 

natural gas and heating oil, and 2) electricity 

for air conditioning, lighting, ventilation, 

appliances and equipment. The Clean Energy 

and Climate Plan for 2020 takes into account 

Massachusetts nation-leading energy 

efficiency efforts mandated by the Green 

Communities Act (GCA) of 2008, which will 

produce substantial GHG reductions for 

2020, and proposes additional measures that 

will contribute toward meeting the 2020 

limit. This category is expected to yield GHG 

reductions of 9.8 percent. 

All Cost-Effective Energy Efficiency 

Existing Policy

With the Governor’s signing of the GCA of 

2008, Massachusetts embarked on a path 

to greatly increase investments in—and 

return on investments from—building 

energy improvements. From 2010 to 

2012—the first three year plan approved 

by the Department of Public Utilities

(DPU) under the GCA mandate to capture 

all cost-effective energy efficiency 

opportunities — the state will invest over 

$2 billion, with an anticipated return of 

over $6 billion in savings for customers, 

and creation of thousands of clean 

energy jobs that cannot be outsourced 

overseas. 

Advanced Building Energy Codes 

Expanded Policy

Massachusetts has adopted a pathway to 

greater energy efficiency in building 

codes through a commitment in the GCA

to adopt the latest IECC, as well as by 

creating a local-option ―stretch‖ code that 

has been adopted by over 60 

municipalities. This policy would complete 

the transition to performance-based 

codes by 2020 that go beyond the IECC 

code in terms of efficiency while reducing 

their complexity, giving developers flexibility and clear performance targets and 

creating ―green‖ jobs.

Building Energy Rating and Labeling 

New Policy

The real estate market currently operates 

without explicit consideration of energy 

efficiency. This policy would address this 

market failure by introducing an energy 

rating program designed to facilitate 

―apples-to-apples‖ comparisons between 

buildings. Initially in a pilot form, this 

would be the buildings equivalent of the 

EPA miles-per-gallon (MPG) rating on 

cars and light trucks. 
Massachusetts Clean Energy and Climate Plan for 2020

Executive Summary

ES-9

―Deep‖ Energy Efficiency Improvements for Buildings New Policy

To reach our 2050 GHG reduction requirement, energy use in existing buildings must fall dramatically. To accomplish 

this, it is necessary to begin retrofitting 

buildings with much higher levels of insulation, less air leakage, and better windows than are typically installed in the 

retrofit energy efficiency programs. This 

policy, begun with pilots with utilities, 

would make rebates and appropriate 

training and technical support widely 

available for ―deeper‖ energy improvements for residential buildings. 

Expanding Efficiency Programs to 

Commercial/Industrial Heating Oil 

New Policy

Currently, electric utility programs provide funding for heating-related efficiency 

measures in homes that use oil heat but 

not for commercial and industrial buildings that use fuel oil for heating. Expanding the programs to such customers 

would yield significant cuts in energy use 

and GHG emissions.

Developing a Market for Solar 

Thermal Water and Space Heating 

New Policy

A policy framework will be established to 

develop a mature and self-sustaining 

market for solar thermal water and space 

heating in both residential and commercial buildings as part of a broader effort 

to support renewable heating technologies (such as clean biomass heating and 

efficient heat pumps) for low-grade 

heating needs and spur job and business 

growth in renewable thermal.

Tree Retention and Planting to 

Reduce Heating and Cooling Loads 

New Policy

Trees help to reduce heating and cooling 

loads in buildings. This policy would provide incentives to plant new trees around 

existing housing, and retain trees within 

new housing developments. This pilot 

program might be feasible within current 

utility efficiency programs, or might require new funding and/or regulatory 

authority. 

Federal Appliance and Product 

Standards Existing Policy

The federal government sets energy efficiency standards for appliances, electronics, and other products. Under 

President Obama, the DOE has planned 

an accelerated schedule for setting new 

standards between 2009 and 2013. 

Nationwide these are expected to yield 

major savings in electricity (11.5 percent 

of total consumption in 2020), fuel, costs 

to homeowners and businesses, and 

carbon dioxide emissions, with Massachusetts getting its proportional share. 

ELECTRICITY SUPPLY

7.7 PERCENT REDUCTION OF GHG EMISSIONS

The vast majority of existing power plants 

burn fossil fuels to generate electricity, producing millions of tons of pollution. Nonfossil fuel electricity generation technologies 

include nuclear, hydro, wind, solar, and 

eligible biomass and anaerobic digestion, 

which vary in their emissions profiles. The 

character of the electric power sector as a 

whole is determined by three key factors: 

the demand for electricity overall, existing 

generation capacity by technology type, and 

how much of each type of existing capacity is 

utilized to meet demand. The Clean Energy 

and Climate Plan for 2020 relies on progress 

in each of these areas made since 2007, 

along with proposed new measures to move 

toward a cleaner electricity supply.
Massachusetts Clean Energy and Climate Plan for 2020

Executive Summary

ES-10

Massachusetts Renewable Portfolio 

Standard (RPS) Existing Policy

The RPS was created as part of electricity 

restructuring in Massachusetts in 1997 

and then expanded in the GCA. The RPS 

requires retail electricity suppliers—both 

distribution companies and other retail 

suppliers—to buy a growing percentage of 

their electricity sales from eligible 

resources. The RPS will require 15 percent 

of electricity supply to be from renewable 

sources by 2020.

Regional Greenhouse Gas Initiative

(RGGI) Existing Policy

Massachusetts is one of the 10 Northeast 

and Mid-Atlantic states participating in a 

regional effort to limit carbon dioxide 

emissions from electric generating units.

The program, which began in January of 

2009, establishes a region-wide cap on 

CO2 emissions from fossil fuel-fired power 

plants that will remain at the initial level 

for six years then decrease 2.5 percent 

per year for the next four years, for a 

total reduction of 10 percent by 2018. Allowances are made available for purchase 

in quarterly auctions. Massachusetts is investing over 80 percent of its auction 

proceeds in energy efficiency, with smaller 

amounts for renewable energy and other 

consumer benefit programs.

More Stringent EPA Power Plant Rules 

New Policy

The EPA is in the midst of proposing and 

implementing a variety of regulations that 

will affect allowable water and air emissions of the nation’s power plant fleet.

The owners of some older, smaller power 

plants may find it is not economical to retrofit their plants to meet EPA’s new regulations, and will instead choose to shut 

down the plants. In Massachusetts, The 

Somerset Power Station last ran in January 2010, and its permits will eventually 

expire if it is not restarted, and the owner 

of the Salem Harbor Station has indicated 

that it expects the plant to close within 

five years.

Clean Energy Imports Expanded Policy

Canada has substantial hydro-electric 

resources, which have very low emissions, 

and are available at relatively low cost 

and with no need for renewable energy 

subsidies (see RPS above). A new transmission line being developed by two 

Massachusetts utilities, NSTAR and Northeast Utilities Service Co., in partnership 

with Hydro Quebec (HQ) and with the 

support of the Patrick-Murray Administration would tap more of these resources. 

When this power line is completed, at 

HQ’s expense, it will bring to New England 

enough clean power to serve up to 15 

percent of Massachusetts present electricity demand. Additional transmission lines 

may also be possible.

Clean Energy Performance Standard 

(CPS) New Policy

A market-based framework is needed to 

provide a clear signal to the electricity 

market to improve upon the cleaner 

energy portfolios of the last few years. 

One approach to be considered is a CPS, 

which would require electricity suppliers to 

favor lower- and no-emissions sources in 

the mix of electricity delivered to their 

customers.

TRANSPORTATION

7.6 PERCENT GHG EMISSION REDUCTION

Transportation is second only to buildings in 

responsibility for GHG emissions in Massachusetts. The Clean Energy and Climate Plan 

for 2020 takes into account state and federal 

measures to improve vehicle efficiency, 

reduce vehicle miles traveled (VMT), and 

increase use of lower-carbon fuels; and 

proposes additional measures that will 

contribute toward meeting the 2020 limit.
Massachusetts Clean Energy and Climate Plan for 2020

Executive Summary

ES-11

Federal and California Light Vehicle 

Efficiency and GHG Standards 

Existing Policy

The EPA and the National Highway Traffic 

Safety Administration (NHTSA) have set 

harmonized standards for light-duty MPG 

and GHG emissions; raising the fuel efficiency standard from 27.5 MPG at present 

to 35.5 MPG for model year 2016. California is expected to propose stricter standards for model year 2017-2020 vehicles, 

and Massachusetts law requires the 

Commonwealth to adopt the California 

standards. In combination, the federal

and California standards are forecasted to 

yield a 17 percent reduction in GHG emissions in 2020 (primarily from lower gasoline consumption, but also some reduced 

emissions from vehicle air conditioning 

systems). 

Federal GHG Emissions and Fuel 

Efficiency Standards for Medium- and 

Heavy-Duty Vehicles Existing Policy

The EPA and the U.S. Department of 

Transportation (DOT) have announced 

complementary programs to reduce GHG 

emissions and improve fuel efficiency, for 

medium- and heavy-duty vehicles, such 

as the largest pickup trucks and vans, 

combination tractors (semis), and all 

types and sizes of work trucks and buses 

for model years 2014-2018.

Federal Renewable Fuel Standard and 

Regional Low Carbon Fuel Standard 

(LCFS) Existing Policy

Title II of the federal Energy Independence and Security Act of 2007 creates a 

―renewable fuel standard,‖ which requires 

an increase in the volume of renewable 

fuels used in the U.S. Massachusetts 

biofuels law, passed in 2008, instructs the 

state to pursue development of a LCFS on 

a regional basis throughout the Northeast. 

The LCFS (first developed by California) 

would require that the average carbon 

intensity of vehicle fuels falls by a specific 

percentage compared to petroleum fuels.

Clean Car Consumer Incentives 

New Policy

There are various means by which the 

Commonwealth could provide incentives 

for consumers to shift their vehicle purchases to more fuel-efficient (or lower 

GHG) models. This includes varying the 

rates on new car sales taxes, annual auto 

excise (property) taxes, and registration 

fees, with rates raised on low-MPG 

vehicles and reduced on high-MPG ones. 

The change could be designed to be 

revenue-neutral to consumers as a whole 

and to the state. EEA and MassDOT will 

conduct a study to examine critical 

implementation challenges and possible 

regulatory or legislative paths for this 

policy.

Pay As You Drive (PAYD) Auto 

Insurance Pilot New Policy

PAYD would convert a large fixed annual 

premium into a variable cost based on 

miles traveled, creating a major incentive 

to reduce discretionary driving, while cutting the overall cost of insurance due to 

fewer accidents. Miles driven would fall 

substantially, along with CO2 emissions 

and costs for gasoline, accidents, and 

congestion. The Commonwealth plans to 

conduct a PAYD pilot program initially, 

and, depending on results, work with the 

insurance industry to make this payment 

method more widely available. 

Massachusetts Sustainable 

Development Principles 

Existing Policy

In 2007, the Patrick-Murray 

Administration updated the Massachusetts

Sustainable Development Principles. 

Making state investments consistent with 

the Principles increases the amount of 

growth that takes place in locations and 

densities that reduce VMT and GHG 
Massachusetts Clean Energy and Climate Plan for 2020

Executive Summary

ES-12

emissions and have other clean energy 

benefits.

GreenDOT New Policy

GreenDOT is MassDOT’s sustainability 

initiative, announced through a Policy 

Directive by the Secretary of 

Transportation in June 2010. GreenDOT is 

focused on three related goals: reducing 

GHG emissions; promoting the healthy 

transportation modes of walking, 

bicycling, and public transit; and 

supporting smart growth development.

Smart Growth Policy Package 

Expanded Policy

Additional ―smart growth‖ would make it 

easier for households and businesses to 

decrease the number and distance of 

vehicle trips, reducing VMT and related 

emissions. Massachusetts already has 

several policies promoting smart growth, 

but new, complementary policies are 

necessary to achieve our smart growth 

targets. Such policies would focus on influencing infrastructure investments by 

state agencies and planning decisions 

made by local governments. 

NON-ENERGY EMISSIONS

2.0 PERCENT GHG EMISSIONS REDUCTION

Greenhouse gas emissions not related to 

energy use represent a small but important 

part of statewide GHG emissions. Although 

these sources currently represent only 7 

percent of total emissions, many of the 

gases emitted by these processes have high 

global warming potential (GWP) — thousands 

of times greater than CO2. The Massachusetts Clean Energy and Climate Plan for 2020

addresses a number of non-energy sources 

of GHG emissions.

Reducing GHG Emissions from Motor 

Vehicle Air Conditioning New Policy

Massachusetts law requires adoption of 

California’s emissions standards for new 

motor vehicles, and the California Air 

Resources Board (CARB) is developing 

regulations to reduce emissions associated with motor vehicle air conditioning 

(MVAC). CARB’s standard aims to 

minimize emissions by reducing direct 

GHG emissions from MVAC systems, by 

using low GWP refrigerants and reducing 

leaks, as well as improvement in the efficiency of the AC system (e.g., more efficient compressors, fans and motors; 

systems that avoid over-chilling and 

reheating; and technologies to reduce 

heat gain in the passenger cabin). 

Stationary Equipment Refrigerant 

Management New Policy

This policy aims to minimize emissions of 

high GWP refrigerants used in nonresidential refrigerating equipment 

through: facility registration, leak detection and monitoring, leak repair, system 

retrofit and retirement, required service 

practices, recordkeeping and reporting, 

and eventual replacement with equipment using no-GWP or lower GWP 

substances, where such alternatives are 

available and practical. The policy would 

affect facilities with refrigeration units 

containing at least 50 pounds of refrigerant, beginning with a voluntary pilot 

program focused on leak detection and 

repair.

Reducing SF6 Emissions from GasInsulated Switchgear 

New Policy

Through a pilot program, followed by 

possible regulatory action, this policy 

aims to minimize emissions of sulfur hexafluoride (SF6), a high GWP substance, 

from leakage of gas insulated switchgear 

(GIS) used in electricity transmission and 

distribution systems by setting limits on 

leakage rates and implementing best 

management practices for the recovery 

and handling of SF6.
Massachusetts Clean Energy and Climate Plan for 2020

Executive Summary

ES-13

Reducing GHG Emissions from 

Plastics Expanded Policy

Diverting plastics from the waste stream 

under this Plan will result in materials 

with a lower carbon content being 

combusted at Massachusetts’ municipal 

waste–to-energy facilities, reducing 

emissions of CO2.

CROSS-CUTTING POLICIES

Several policies pursued under the Clean 

Energy and Climate Plan for 2020 do not 

neatly fit in the categories of buildings, electricity supply, transportation or non-energy 

emissions, but involve state actions that 

drive clean energy adoption across all of 

these domains.

MEPA GHG Policy and Protocol 

Expanded Policy

MEPA requires that all major projects proposed in the Commonwealth that have 

state involvement (in the form of state 

permits, land transfers or financial assistance, for example) undertake an 

assessment of project impacts and alternatives in an effort to avoid, minimize and 

mitigate damage to the environment to 

the maximum extent feasible. Building on 

this general requirement, the MEPA GHG 

Policy requires that certain projects 

undergoing review by the MEPA office 

quantify their GHG emissions and identify 

measures to avoid, minimize, and 

mitigate such emissions. 

Leading by Example Expanded Policy

The Leading by Example (LBE) Program, 

established in April 2007 by Governor 

Patrick’s Executive Order No. 484, works 

to lower costs and reduce environmental 

impacts at all Executive Branch agencies, 

public colleges and universities and quasipublic authorities. The program oversees 

efforts to reduce energy use by the state’s 

buildings and vehicles, expand recycling 

programs, cut water consumption, promote green procurement, facilitate the 

construction of high performance state 

buildings, and reduce carbon emissions 

across state government. In addition, the 

Administration has proposed creation of a 

Commonwealth Energy Solutions program 

charged with managing and purchasing

low-cost, clean energy across all public 

agencies, authorities, and facilities —

providing an integrated strategy for 

energy procurement that capitalizes on 

economies of scale.

Green Communities Division 

Existing Policy

Created by the GCA, the Green Communities Division of the Department of Energy 

Resources (DOER) helps municipalities 

become more sustainable, control rising 

energy costs, and incubate the clean 

energy technologies and practices. Envisioned as a way to encourage municipalities to make greener energy decisions, 

the Division offer assistance to municipalities in order to be designated as ―Green 

Communities‖ and qualify for grant 

funding. 

Consideration of GHG Emissions in 

State Permitting, Licensing and Administrative Approvals New Policy

The Global Warming Solutions Act 

requires all state agencies, departments, 

boards, commissions and authorities to 

consider climate change impacts, such as 

GHG emissions, when they issue permits, 

licenses and other administrative approvals in the context of environmental 

review. EEA, in collaboration with other 

state and quasi-public agencies, will 

develop a plan to implement this 

requirement in selected agency actions.
Massachusetts Clean Energy and Climate Plan for 2020

Executive Summary

ES-14

The Road to 80 Percent Lower Emissions in 2050

The clean energy economy of 2050 will be 

very different than the fossil-fuel dominated 

economy of today. With many of the policies 

embodied in this Plan in place, 2050 would 

find a Massachusetts where energy costs are 

less volatile and comprise a smaller part of 

budgets. Businesses, households, 

municipalities and institutions are better able 

to manage their energy needs. Renewable 

and alternative sources of energy have 

largely displaced fossil-based sources, and a 

smart grid and advanced storage 

technologies release to the grid as needed 

electricity generated during the night by 

massive wind farms off the coast of the 

Northeast. Both small and large-scale solar 

installations are ubiquitous across the state.

National security has been strengthened by 

an economy driven by homegrown sources of 

energy that no longer depend on fossil fuel 

from unstable regions or countries that do 

not share the interests of the U.S.

By 2050, the clean energy cluster in 

Massachusetts has matured, much as the 

biotechnology and health care sectors 

matured in the early part of the 21st 

century. Massachusetts plays a major role in 

the global market for technologies in 

offshore wind, solar PV and thermal, 

electricity storage and energy management. 

Massachusetts architects and engineers are 

leaders internationally in green building 

design and building energy management.

Massachusetts companies that pioneered 

battery technology have robust partnerships 

with American, European, Indian and 

Chinese car and truck manufacturers.

And by law, in 2050, GHG emissions are 80 

percent lower than in 1990 and the air 

cleaner.

Getting to this clean energy future will 

require significant innovation in policy, 

technology and business practices over the 

next 40 years. Unlike the 2020 limit, which 

can be met with actions that we take here in 

Massachusetts, reaching 80 percent 

reductions below 1990 emission levels, as 

required by the Global Warming Solutions 

Act, will mean broad changes that are 

beyond the reach of Massachusetts alone. 

Between 2010 and 2050, much will change 

— in the economy, in federal regulation, and 

in technology — that will make possible GHG 

emission reductions that would be 

unthinkable today. But in imagining — and 

planning for — a path to the mandated GHG 

emissions reduction of 80 percent in 2050, it 

is important to ask now: How do we get 

there? 

The Clean Energy and Climate Plan for 2020

describes two scenarios — one based on 

maximum energy conservation, the other on 

widespread switching from fossil fuels to 

electricity for transportation, buildings, and 

industry, powered by an extremely clean 

electricity supply. While there are differences 

between the two scenarios — the former 

allows marginally greater use of conventional 

fuels for meeting the remaining energy 

needs after fundamental efficiency 

improvements, while the latter allows for 

marginally greater energy utilization, as long 

as the source is clean — but there is more 

that they have in common. Both require 

dramatic reductions in energy use to meet 

heating, cooling, lighting, transportation, and 

production needs, and both require dramatic 

shifts in where the energy we use comes 

from. 

Although it could not, by itself, get 

Massachusetts to the mandated 2050 

emissions levels, the Plan contains a number

of policies that produce modest emissions 

reductions for 2020 but, if put in place under 

the Plan for 2020, will make substantial 

contributions to meeting the 2050 

requirement. These include advanced 
Massachusetts Clean Energy and Climate Plan for 2020

Executive Summary

ES-15

building codes and building energy rating 

and labeling, since building stock turns over 

slowly. The same is true for smart growth, 

which will take many years to reap emissions 

dividends in changed transportation 

patterns. Also vital will be reducing the 

carbon content of vehicle fuels through a low 

carbon fuel standard, which will require the 

development and widespread 

commercialization of advanced, truly lowcarbon biofuels that are not yet in the 

marketplace, and/or the near universal 

installation of fueling infrastructure for 

electric vehicles, which will take time. 

Conclusion

Developed under the authority of the GWSA

of 2008, the Commonwealth’s Clean Energy 

and Climate Plan for 2020 provides the 

means for meeting the Secretary’s GHG 

emissions reduction requirement of 25 

percent in 2020, putting the Commonwealth 

on track toward the GWSA’s mandate of 80 

percent reduction in 2050 — and 

accelerating the development of a clean 

energy economy for Massachusetts. 

As this Plan is implemented, homeowners 

and businesses will discover new ways to 

save money on energy costs, make living 

and work spaces more comfortable, and 

make production processes cleaner and more 

efficient. The air we breathe will be cleaner, 

and we will be less dependent on energy 

from unstable parts of the world. Above all, 

we will be putting Massachusetts in a 

leadership position in the clean energy 

economy of the future. 

Capitalizing on the state’s advantages in 

academic resources, venture capital, and 

skilled resources, the measures advanced in 

this Plan will give rise to technological 

innovation and commercialization, company 

formation, and job creation up and down the 

skill ladder. There will be clean energy jobs 

for scientists and engineers, construction 

workers and insulation installers, as 

Massachusetts develops the products and 

services not only needed here, but across 

the country and around the world. There will 

be opportunities for those displaced by 

economic change to retool for a new 

industry, and for those long disadvantaged in 

the mainstream economy to find a new point 

of entry.

Clean energy is an industry of the future, but 

for Massachusetts, the future is now. 

Deep retrofit with super-insulation. 

(source: DOER)
Massachusetts Clean Energy and Climate Plan for 2020

I. A Clean Energy Revolution

1

I. A Clean Energy Revolution

Between 2007 and the end of 2010, solar 

photovoltaic (PV) systems installed and 

scheduled for installation in Massachusetts 

increased 20-fold — with jobs in solar 

manufacturing, installation, and services 

nearly tripling — while installed wind energy 

increased 10-fold. In that same time period, 

Massachusetts launched the most aggressive 

energy efficiency program in the country, 

with estimated savings of over $6 billion for 

residential, municipal, industrial and 

commercial customers and 4,500 jobs 

projected. Companies that are saving on 

energy costs can devote those dollars to 

business development and job expansion.

School districts that cut energy costs can 

devote more resources to students. 

Homeowners who reduce their energy bills 

can spend more on other needs and desires.

By the end of 2010, thousands of new jobs 

will have been added in clean energy 

services, manufacturing and research and 

development (R&D) — this at a time when 

the country is undergoing the most severe 

economic recession in a generation. Vibrant 

high-tech clusters in biofuels, wind energy, 

solar power, energy storage, and energy 

efficiency services have taken root and are 

leading clean energy technology 

development globally.

This is not a vision of a possible future for 

Massachusetts. This is Massachusetts today. 

Here in the Commonwealth, the transition to 

a clean energy economy has begun — and 

has already shown itself to be an engine of 

economic growth. Driven by an 

entrepreneurial private sector, and an 

integrated state framework of legislation, 

regulation and executive branch programs, 

Massachusetts has launched the clean 

energy revolution. Unparalleled academic 

and technical resources, local sources of 

investment capital, and a highly skilled 

workforce are all ingredients of this 

revolution — lowering costs to consumers, 

increasing our energy independence, growing 

clean energy jobs, and reducing our 

contribution to climate change and other 

environmental impacts. Massachusetts is 

poised to lead the transition to a clean 

energy economy nationally and to 

disproportionately benefit from the economic 

development and jobs resulting from that 

transition. 

It is in this context that the Executive Office 

of Energy and Environmental Affairs offers 

the Massachusetts Clean Energy and Climate 

Plan for 2020. The Global Warming Solutions 

Act (GWSA) of 2008 requires the Secretary 

of Energy and Environmental Affairs to 

establish a statewide limit on GHG emissions 

of between 10 percent and 25 percent below 

1990 levels for 2020, on the way toward 80 

percent reduction in emissions by 2050, 

along with a plan to achieve the 2020 target. 

Secretary Bowles has set that 2020 limit at 

25 percent — and the Massachusetts Clean 

Energy and Climate Plan for 2020 contains 

the measures necessary to meet that limit. 

But fulfilling that mandate will do much more 

than meet the requirements of the Act. It will 

allow the Commonwealth to address a 

number of challenges, only one of which is 

climate change. Importantly, it will give 

powerful impetus to the clean energy 

revolution that has already begun. Rather 

Solar array at Chelmsford Drinking Water 

Plant

Photo Credit: MassDEP
Massachusetts Clean Energy and Climate Plan for 2020

I. A Clean Energy Revolution

2

than putting a burden on our economy, a 

statewide mandate to reduce GHG

emissions, achieved through measures that 

are carefully chosen, designed, and 

implemented to reduce costs or maximize 

job growth, will accelerate the transition to a 

clean energy economy that has already 

taken hold across the state. 

Energy Independence

Massachusetts is at the end of the energy 

pipeline, figuratively and literally. All of our 

fossil-based energy sources — oil, natural 

gas, and coal — are derived from other 

regions of the country (e.g., the Gulf Coast 

or Western states) and other parts of the 

world, many of them unstable or hostile to 

the United States, (e.g., countries in the 

Middle East and Venezuela). Thus, all 

spending on fossil fuel energy — whether to 

fuel power plants, buildings, or vehicles —

flows out of state and fails to provide income 

to in-state businesses or employees. This 

exported economic value is significant, 

totaling almost $22 billion in 2008.5 To put 

this is at a smaller scale, in 2008, an 

average Massachusetts household spent 

about $5,200 for energy costs, of which 

about $1,700 was for heating (space and 

water), $1,300 for electricity, and $2,200 for 

gasoline. Almost all of these expenditures 

leave Massachusetts.

Energy Costs and Volatility

In addition to the economic drain 

represented by Massachusetts dollars flowing 

out of the state for energy resources, energy 

consumers have experienced wild price 

swings and long term energy price increases.

Figures 1-3 show both steadily increasing 

and volatile prices for the cost of natural gas, 

electricity and gasoline.

 

5 Energy Price and Expenditure Estimates by Source, 

Selected Years, 1970-2008, Massachusetts, EIA.

www.eia.doe.gov/states/sep_prices/total/pdf/pr_ma.pdf

Figure 1. Increase and volatility in natural gas 

prices (source: DOER)

Figure 2. Increase and volatility in electricity 

prices (source: DOER)

Figure 3. Increase and volatility in gasoline prices 

(source: U.S. Energy Information Administration 

(EIA))

As has been experienced numerous times in 

the past decades, events in other regions 

and countries drive global energy markets 

and prices, often to the detriment of 

Massachusetts consumers and businesses.

Between 2005 and 2008, the combination of 

Hurricane Katrina’s impact on refining and 

pipeline capacity and exploding demand in 
Massachusetts Clean Energy and Climate Plan for 2020

I. A Clean Energy Revolution

3

China and India for petroleum products 

resulted in some of the most rapid increases 

in energy prices that Massachusetts has 

experienced. Basic service electricity prices 

quadrupled between 1998 and 2008, before 

dropping at the onset of the global recession. 

The price of home heating oil peaked at 

$4.71 per gallon in 2008 and regular 

gasoline topped $4 a gallon. Over the past 

decade, price shocks have forced 

Massachusetts consumers, businesses and 

governments to struggle with an increasing 

burden of costs and 

uncertainty.

Economic 

Opportunity 

Along with the rest of 

the nation, 

Massachusetts is 

coming out of the 

most severe recession in half a century.

Massachusetts has fared better than most 

other states during this difficult period, but 

still faces a steep climb to regain the 

prosperity its citizens expect and deserve.

Routinely recognized as one of the nation’s 

centers of economic innovation,6

Massachusetts has 

many strengths to draw 

on, but local fossilbased energy sources 

are not among them.

With no oil, coal, or 

natural gas of its own, 

Massachusetts has paid 

dearly for energy, 

sending precious 

economic resources out 

of state and out of the country in order to 

fuel its economy. But in the transition to a 

clean energy economy, Massachusetts has 

many resources to bring to bear — and 

 

6 2008 Index of the Massachusetts Innovation Economy, 

Massachusetts Technology Collaborative/John Adams 

Innovation Institute.

should be the disproportionate beneficiary as 

the economy becomes cleaner and greener.

This is, in fact, already happening, as clean 

energy innovations developed at academic 

centers such as the Massachusetts Institute 

of Technology (MIT) and the University of 

Massachusetts translate into products and 

companies, and as laws, regulations, and 

incentive programs developed under 

Governor Patrick have created or expanded 

markets in Massachusetts for clean energy 

products and services. A study earlier this 

year by Clean Edge, Inc. found that 

Massachusetts has become the leading state 

on the East Coast for clean energy 

innovation, investment, deployment, and 

jobs.7

Massachusetts already has a core of 

companies and jobs in clean energy, and this 

industry has been growing even during 

challenging economic times. According to a 

Massachusetts Clean Energy Center 

(MassCEC) survey of 471 local companies, 

more than 11,000 people are employed in 

clean energy at the end of 2010, up 65 

percent since 2007. Some 3,500 people are 

employed in manufacturing of energy 

efficiency products, with growth of 20 

percent since 2007, and the fastest growth 

(67 percent) in energy storage, represented 

by such companies as A123 Systems, Inc., 

Beacon Power, and Premium Power. 

Jobs in solar manufacturing, installation, and 

services have nearly tripled in the same 

period, from 1,200 to 3,000; solar 

manufacturing jobs alone have jumped from 

750 in 2007 to 2,000 in 2010. Despite fierce 

competition from overseas, Marlboroughbased Evergreen Solar, Inc. has more than 

maintained its commitment to manufacturing 

jobs in Massachusetts in exchange for state 

 

7 A Future of Innovation and Growth: Advancing 

Massachusetts’ Clean Energy Leadership, April 2010, 

Clean Edge, for Massachusetts Clean Energy Center.

...more than 11,000 

people are employed 

in clean energy at the 

end of 2010, up 65 

percent since 2007.

Jobs in solar 

manufacturing, 

installation, and 

services have nearly 

tripled in the same 

period, from 1,200 to 

3,000
Massachusetts Clean Energy and Climate Plan for 2020

I. A Clean Energy Revolution

4

support, with a payroll of more than 900 

employees at the end of 2010. Meanwhile, 

1366 Technologies, a Lexington-based startup that received a prestigious 

―transformational energy technologies‖ grant 

from the U.S. Department of Energy (DOE), 

has developed production technology that 

promises to slash the cost of solar power, 

and plans to break ground on a 

Massachusetts manufacturing facility within a 

year. 

0

1 0

2 0

3 0

4 0

5 0

6 0

7 0

8 0

Commonwealth Solar (CS) I

Stimulus (Stim)

Utility Owned

CSII & CS Stim

SREC

Pre 

2007

2007

2007-2010

Solar PV Installed 

or Under Contract 

by program

MW

Figure 4. Expansion from 3.5 MW to over 75 MW 

installed and in the pipeline from 2007 to 2010. 

(source: DOER)

With nation-leading firms such as 

Conservation Services Group, Ameresco and 

Noresco based in Massachusetts, 

employment in energy efficiency services has 

nearly doubled, from 1,000 in 2007 to 1,972 

in 2010 in just the 69 firms that responded 

to the MassCEC survey — representing just 

one fifth of energy efficiency services 

companies in the state. Anecdotal 

information indicates similar growth is taking 

place across the Commonwealth’s energy 

efficiency sector. 

This growth should accelerate in the coming 

years, thanks in part to state initiatives, 

including those contained in this report. 

From 2010 to 2012 the state’s electric and 

gas utilities will invest close to $2 billion in 

energy efficiency incentives, as a result of 

the Green Communities Act, producing $6 

billion in savings for consumers — and 4,500 

direct jobs. The Advanced Biofuels Task 

Force estimated that development of nonfood-crop-based alternatives to petroleum 

fuels could yield 2,500 permanent 

Massachusetts jobs within the industry by 

the year 2025, with another 3,700 jobs 

through indirect spending effects.8

Massachusetts has the only tax incentive in 

the nation for cellulosic biofuel — exemption 

from the state gasoline tax, and nationleading companies like Qteros, Inc. in 

partnership with research at UMass, are 

leading the way to a non-fossil future. 

In addition to solar power, which has 

boomed from 3.5 megawatts (MW) at the 

start of 2007 to over 75 MW installed or 

slated for installation at the end of 2010 (see 

Figure 4), wind power is another local energy 

resource — and opportunity for economic 

growth. Governor Patrick has set a goal of 

2,000 MW of wind — enough to power 

800,000 homes — by 2020 (see Figure 5 on 

page 5). Much of that will come from 

offshore wind — the greatest renewable 

energy resource available to Massachusetts.

At 468 MW, Cape Wind will be the first 

offshore wind project in the United States, 

and installation — which will be based in a 

new port facility in New Bedford — will create 

600 to 1,000 jobs. Siemens AG, one of the 

world’s largest manufacturers of wind 

turbines, has located its U.S. offshore wind

headquarters in Boston, because of its 

contract to supply Cape Wind with 130 

turbines, and EEW Group of Germany, a 

leading maker of foundations for offshore 

wind, has partnered with Middleboro-based 

Mass Tank Corp. to supply monopile 

foundations and other structural components 

 

8

―Advanced Biofuels Task Force Report,‖ 

Commonwealth of Massachusetts, Spring 2008, page 

20.
Massachusetts Clean Energy and Climate Plan for 2020

I. A Clean Energy Revolution

5

for Cape Wind at a new manufacturing 

facility in Massachusetts.

The Wind Technology Testing Center 

(WTTC), now under construction in 

Charlestown, will also bolster Massachusetts’ 

emerging role as a center for wind energy 

advancement and jobs. Backed by a $25 

million grant from the DOE, the WTTC will be 

the first facility in the United States capable 

of testing the large-scale (up to 90 meters 

long) wind turbine blades that represent the 

next generation of wind energy technology, 

specifically applicable to offshore 

installations. The WTTC has already attracted 

TPI Composites, Inc. a leading manufacturer 

of turbine blades, to establish an R&D facility 

in Fall River. Devens-based American 

Superconductor Corp. is engaged in 

development of technology for ever-larger 

wind turbines (a 10 MW turbine is now under 

development), and Massachusetts-based 

ePower LLC was acquired by Vestas

Technology R&D Americas, Inc., one of the 

world’s largest wind turbine companies, for 

its direct drive technology. With support from 

the MassCEC, FloDesign Wind Turbine 

Corporation — another ―transformational 

energy technology‖ grant winner — has 

established a new facility in Waltham, with a 

promise of creating 150 new jobs as it brings 

its innovative ―shrouded‖ wind turbine design 

to market.

In addition to companies that are providing 

the new technologies of the clean energy 

future, Massachusetts also has thousands of 

individuals and small companies who are 

taking risks and making investments to 

power their businesses with smaller scale 

energy installations to provide energy 

stability, diversification, and in some cases 

powering back to the grid. In the last four 

years, these entrepreneurs have invested in 

small-scale anaerobic digestion, solar 

thermal, low head hydro and geothermal.

Employment Projections for 2020

Reducing energy use through efficiency and 

conservation — for both buildings and 

vehicles — cuts living costs for households 

and expenses for business, improving 

prosperity and creating jobs. Efficiency relies 

more heavily on local labor and companies 

than do fossil-fuel based industries. 

Efficiency programs not only create 

employment directly, but households and 

companies will spend their energy cost 

savings at other businesses within the state, 

creating ―indirect‖ and ―induced‖ jobs and 

economic growth. Renewable energy 

facilities tend to be more capital-intensive, 

but also provide many local jobs in 

construction. 

0

2,000

4,000

6,000

8,000

10,000

12,000

14,000

16,000

2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

Installed Wind Capacity

kW

Figure 5. Expansion from about 3MW to over 16 

MW installed from 2007 to 2010, with more in the 

pipeline. (source: DOER)

A number of the most important policies in 

this Plan will cause large reductions in fossil 

fuel use in buildings, electricity generation, 

and transportation. These include energy

efficiency programs, building codes, 

requirements for increased renewable 

electricity generation, federal vehicle 

efficiency standards, state incentives for 

purchasing more efficient vehicles, incentives 

to reduce vehicle miles traveled, and ―smart 

growth‖ policies. Through both direct and 

indirect impacts, we estimate that these 

policies will create 36,000 jobs in 
Massachusetts Clean Energy and Climate Plan for 2020

I. A Clean Energy Revolution

6

Massachusetts in 2020, including about 

13,000 via transportation policies and 

23,000 via policies to improve efficiency of 

energy use in buildings.

The estimate for employment from in-state

demand for renewable energy in 

Massachusetts in 2020 is 6,000 to 12,000 

full-time jobs.

The figures for transportation, efficiency and 

renewables are based on employment 

needed to cover in-state demand for these 

clean energy sectors. They do not include 

the ability of Massachusetts companies to 

export both services and products to other 

states and countries in greater amounts than 

we import. To the degree that the 

Commonwealth can continue and expand its 

leadership in clean energy R&D, 

manufacturing, and service provision (such 

as Massachusetts companies that operate 

energy efficiency programs across the 

nation), the employment gains could be 

significantly larger than shown in the table 

on page 7. However, projecting such 

changes in industry growth is difficult, and 

beyond the scope of the modeling conducted 

for this Plan. 

Artist’s rendering of proposed New Bedford Marine Commerce Terminal, staging area for offshore wind 

installation. (Courtesy of MassCEC)
Massachusetts Clean Energy and Climate Plan for 2020

I. A Clean Energy Revolution

7

Table 1. Approximate Massachusetts job increases, direct and indirect, in 2020 

due to implementation of the Massachusetts Clean Energy and Climate Plan

Federal and California vehicle efficiency and GHG standards 6,000

Federal emissions and fuel efficiency standards for medium

and heavy duty vehicles

1,000

Pay As You Drive auto insurance (PAYD) 3,000

Clean car consumer incentives 2,000

Smart growth policy package 1,000

Subtotal — Transportation 13,000

Electric efficiency programs 10,000

Natural gas, heating oil efficiency programs 9,000

Advanced building energy codes 3,000

Federal appliance & product standards 1,000

Subtotal — Buildings, Efficiency 23,000

Renewables (solar, wind, biomass, biofuels) 6,000 - 12,0009

Total 42,000 - 48,000

Note: See the methodological appendix for a description of how the employment gains were 

estimated and for the data sources and studies utilized.

Retrofitting a house with new windows and energy efficient insulation.

(source: DOER)

 

9 The figure for renewables is given as a range, because most of the value-added for renewables is in manufacturing, and 

the degree to which renewable components will be manufactured in the Commonwealth is fluid at this time, as is the 

degree to which the state’s 2020 renewable energy requirements will be met from in-state sources.
Massachusetts Clean Energy and Climate Plan for 2020

I. A Clean Energy Revolution

8

Transportation and buildings efficiency 

policies that reduce consumption of fossil 

fuels aid employment not only in 

Massachusetts, but in other states and 

nationally. One study, conducted at the 

UMass Amherst, estimated that $100 billion 

of national spending directed toward the 

green economy would create approximately 

2 million jobs through both direct and 

indirect effects, compared to only 540,000 

jobs if the same amount of money continued 

to be spent on oil, natural gas, and 

electricity. The differences are due to how 

much of the spending stays within the U.S. 

economy and to how much pays for labor 

expenses versus capital costs.10

Another recent study, ―Green Jobs/Green 

Homes New York,‖ estimated the economic 

impacts of conducting energy efficiency 

retrofits of one million housing units over the 

course of five years. It found that the 

program would cut home energy 

consumption by 30 percent to 40 percent, 

save New York households $1 billion annually 

in energy bills, and create about 120,000 

―job years‖ (one year’s worth of 

employment, reflecting that many of these 

would be temporary construction jobs). Half 

of these jobs would be direct results of the 

retrofit activity and half would come from the 

re-spending of increased incomes throughout 

the New York economy.11

In short, the private sector has already 

grasped the potential huge revenue growth 

by capitalizing on the Commonwealth’s 

emerging clean energy policies and 

 

10

―Green Recovery: A Program to Create Good Jobs 

and Start Building a Low-Carbon Economy,‖ Robert 

Pollin et al, Political Economy Research Institute and 

Center for American Progress, Sept. 2008, page 10.

11 ―Green Jobs/Green Homes New York: Expanding 

home energy efficiency and creating good jobs in a 

clean energy economy,‖ Center for Working Families, 

Green Jobs New York and Center for American Progress, 

May 2009, page 5. 

programs. The Bay State has a long and 

impressive entrepreneurial history, and it is 

that spirit — fueled by the intellect and 

innovation of world-class academic centers 

such as Harvard, MIT, and UMass, and 

catalyzed by the state’s nation-leading clean 

energy policies — that will continue to propel 

the Commonwealth forward. 

Climate Change 

The international consensus on climate 

released in 2007 by the Intergovernmental 

Panel on Climate Change (IPCC) found that 

the ―warming of the climate system is 

unequivocal, as is now evident from 

observations of increases in global average 

air and ocean temperatures, widespread 

melting of snow and ice, and rising global 

average sea level.‖12 There is broad 

agreement and high confidence that the 

documented increase in GHG concentrations 

is changing the earth’s climate — not only 

raising average global temperatures but 

altering regional and local climatic and 

weather patterns. Observed effects of 

climate change include: increased 

atmospheric and ocean temperatures, heat 

waves, increased evaporation and changes in 

precipitation patterns, and a greater 

intensity of storms, floods, and droughts.

Thermal expansion of a warmer ocean and 

the melting of glaciers are contributing to a 

rise in sea level. These trends are expected 

to continue for a minimum of several 

decades even if GHG emissions are reduced.

Global atmospheric concentrations of carbon 

dioxide (CO2), methane, and nitrous oxide

have increased markedly as a result of 

human activities since 1750 and now far 

exceed pre-industrial values (see Figure 6 on 

page 9).

The global increases in CO2 concentration are 

primarily due to increased fossil fuel use and 

 

12 Fourth Assessment Report, Intergovernmental Panel 

on Climate Change, (IPCC, 2007.)
Massachusetts Clean Energy and Climate Plan for 2020

I. A Clean Energy Revolution

9

land use change, while increases in methane 

and nitrous oxide are primarily due to 

agriculture. Carbon dioxide is the most 

important anthropogenic (human induced) 

GHG. Globally, CO2 concentrations have 

reached 385 parts per million (ppm) — about 

105 ppm greater than during pre-industrial 

times. The increasing atmospheric CO2 and 

other heat trapping greenhouse gases are 

causing an increase in the earth’s air 

temperatures. Eleven of the 12 warmest 

years on record have occurred in the period 

between 1995 and 2006.13 A recent study by 

the National Oceanic and Atmospheric 

Administration (NOAA) indicated that the 

summer of 2010 tied with 1998 as the 

warmest global temperature on record.

Figure 6. Increasing concentrations of 

atmospheric GHGs: carbon dioxide; methane and 

nitrous oxide. (source: IPCC)

For the period between January and 

September in 2010, the global combined 

land and ocean surface temperature was 

 

13 Climate Change 2007: The Physical Science Basis. 

Contribution of Working Group I to the Fourth 

Assessment Report of the Intergovernmental Panel on 

Climate Change [Solomon, S., D. Qin, M. Manning, Z. 

Chen, M. Marquis, K.B. Averyt, M. Tignor, and H.L. Miller 

(eds.)], IPCC (Intergovernmental Panel on Climate 

Change), 2007. Cambridge University Press, Cambridge, 

UK, and New York, 996 pp.

0.65°C (1.17°F) above the 20th century 

average of 14.1°C (57.5°F).14

In order to understand the potential impacts 

of climate change in Massachusetts, EEA 

undertook a year-long study driven by the 

Climate Adaptation Advisory Committee, a 

body created by the GWSA to advise the 

Secretary on adaptation strategies.15 The 

Adaptation Advisory Committee found that 

Massachusetts’ climate is already changing 

and will continue to change over the course 

of this century. Under the IPCC’s high 

emissions scenario, by the end of the 

century Massachusetts is set to experience a 

3° to 5°C (5° to 10°F) increase in average 

ambient temperature16; summer 

temperatures would feel like the current 

summer climate of the Carolinas. Days with 

temperatures greater than 32°C (90°F) are 

predicted to increase from the five to 20 

days a year that Massachusetts presently 

experiences to between 30 and 60 days each 

year (IPCC, 2007). Sea surface temperatures 

are predicted to increase by 4°C (8°F) (IPCC, 

2007); precipitation is expected to increase 

in winter months by 12 percent to 30

percent, but will fall mostly in the form of 

rain5; and the number of snow days is 

predicted to decrease from five each month 

to one to three each month. Finally, while no 

single event can be entirely attributed to 

global warming, a warming climate is 

increasing the likelihood of more extreme 

weather. The Northeast has recently 

experienced major storms, with notable 

 

14 State of the Climate Global Analysis. National Oceanic 

and Atmospheric Administration, September 2010. 

www.ncdc.noaa.gov/sotc/?report=global

15 Massachusetts Climate Change Adaptation Report, 

forthcoming.

16 Past and Future Changes in Climate and Hydrological 

Indicators in the U.S. Northeast, K. Hayhoe et al., 2006, 

Climate Dynamics 28:381-407, DOI 10.1007.

www.northeastclimateimpacts.org/pdf/tech/hayhoe_et_

al_climate_dynamics_2006.pdf
Massachusetts Clean Energy and Climate Plan for 2020

I. A Clean Energy Revolution

10

rainfall and flooding events occurring in May 

2006, April 2007, and March 2010. 

Massachusetts is vulnerable to severe 

impacts from climate change. Impacts to 

natural resources include:

Coastal

Substantial increases in the extent and 

frequency of coastal flooding and 

increased risk of severe storm-related 

damage.

Permanent inundation of low-lying 

coastal areas and increased shoreline 

erosion and wetland loss due to projected 

sea-level rise and increased wave action.

Rivers and wetlands

Alteration of stream flow timing and 

volumes due to precipitation changes, 

punctuated by increased winter flooding 

events and longer low-flow periods.

Degraded water quality and quantity, 

habitat loss, and increased sedimentation 

and pollution of waterways due to 

precipitation changes, higher 

temperatures, and more frequent 

droughts.

Changes in temperature will lead to shifts 

in wetlands species and types and/or 

composition, changes to wetland soils 

that could result in increased erosion, 

decreased species diversity, and reduced 

groundwater recharge capabilities. 

Forests

Certain species may succumb to climate 

stress, increased competition, and other 

pressures, resulting in trickle-down 

impacts to dependent bird and animal 

species, increasing vulnerability to 

invasives and pests.

A shift northward of suitable habitat by 

350 to 500 miles is expected for most of 

the Northeast region’s tree species.

Climate change will also impact a number of 

business sectors in Massachusetts that 

depend on overall ecosystem health, 

including fisheries, agriculture, and 

recreation. These impacts include:

Fisheries

As ocean temperatures continue to rise, 

the range of suitable habitat in the 

Northeast for many commercially 

important fish and shellfish species, such 

as cod and lobster, is projected to shift 

northward. Certain fisheries will decline in 

productivity, impacting the economic 

viability of fishing-related industries.

Temperature, precipitation, nutrient, and 

salinity changes will result in a loss of 

habitat for marine species, altering the 

location or productivity of commercial 

and recreational fishing. 

Agriculture

Changes to growing seasons, frequency 

and duration of droughts, increased 

frequency of extreme precipitation 

events, and heat stress will make some 

areas unsuitable for growing popular 

varieties of produce (e.g., apples, 

cranberries), depress milk production 

from dairy cows, and increase irrigation 

needs to maintain viable crop production.

A longer growing season may allow 

farmers to experiment with new crops, 

but many traditional farm operations in 

the region will become unsustainable 

without adaptation strategies that could 

be costly, impacting already narrow profit 

margins.

Recreation

Global warming is projected to profoundly 

affect winter recreation and tourism in 

the Northeast as winter temperatures 

continue to rise and snow cover declines.

With warmer winters, the average ski and 

snowboard season will decrease and 

operation costs will increase with greater 

requirements for artificial snow making.
Massachusetts Clean Energy and Climate Plan for 2020

I. A Clean Energy Revolution

11

Infrastructure/developed land

Climate change will also profoundly impact 

the built environment such as energy 

infrastructure, transportation, water supply, 

wastewater and stormwater, dam safety and 

flood control, solid and hazardous waste, and 

telecommunications.

Key infrastructure and development that 

is located along the coast will particularly 

be affected by storm surges, sea level 

rise, and salt water intrusion. The 100-

year coastal storm floodplain can get 

shifted further inland.

Inland, the predicted changes in

precipitation patterns and more frequent 

and intensive precipitation events will 

inundate development that is located in 

the floodplains. 

Increased temperature can affect the 

structural integrity of many elements of 

the built environment.

Human Health

Higher temperatures and intensive and 

increased precipitation events impact human 

health (especially the most vulnerable 

populations) both directly and indirectly.

Higher temperatures including extreme 

heat days will increase heat stress, 

impact those with respiratory and 

cardiovascular conditions, increase ozone 

and particulate matter production 

resulting in poor air quality, and increase 

pollen production.

Increased runoff from precipitation 

events can degrade surface water 

quality, increase outbreaks of waterborne diseases, and result in more algal 

blooms.

There is compelling evidence that the 

Northeast’s climate has already begun to 

change, with additional changes predicted to 

unfold over the next century. All of these will 

require the implementation of adaptation 

measures to help decrease the state’s 

vulnerability and increase resilience. 

Impacts of Local and Regional Air 

Pollution

In addition to causing climate change, 

emissions from the combustion of fossil fuels 

result in a range of negative human health 

and ecosystem impacts.

The U.S. Environmental Protection Agency 

(EPA) has established health-based National 

Ambient Air Quality Standards (NAAQS) for 

six pervasive pollutants that have welldocumented health and environmental 

impacts: ozone (O3), nitrogen dioxide (NO2), 

sulfur dioxide (SO2), particulate matter (PM),

lead, and carbon monoxide (CO). The 

federally regulated pollutant of greatest 

concern in Massachusetts is ozone. 

Ozone concentrations in Massachusetts 

exceed the health-based NAAQS due to a 

combination of locally generated emissions 

(particularly from vehicles), and the 

transport of pollutants from states to the 

south and west of Massachusetts. 

Massachusetts’ overall air quality has 

improved significantly over the last 25 years. 

Nonetheless, ozone concentrations in the 

Commonwealth regularly exceed the national 

standards, despite the adoption of a wide 

range of control programs that have reduced 

emissions of the pollutants that contribute to 

ozone.

Exposures to each of the criteria pollutants 

have been linked to adverse health effects.

For example, ozone can irritate the 

respiratory system, causing coughing, throat 

irritation, chest pain and reduced lung 

function. Ozone also can aggravate asthma, 

leading to more asthma attacks and 

increased hospital admissions and 

emergency room visits for respiratory 

problems. Fine PM is associated with a 

number of serious health effects including 

aggravation of respiratory and cardiovascular 

disease reflected in increased hospital 
Massachusetts Clean Energy and Climate Plan for 2020

I. A Clean Energy Revolution

12

admissions, emergency room visits and 

premature mortality. 

In its 2010 proposed Transport Rule,17 EPA 

proposes to reduce emissions from power 

plants in 32 eastern states. In the proposal, 

EPA concludes that reducing the emissions 

from power plants that contribute to ozone 

and fine PM pollution will lead to significant 

health benefits. EPA estimates that the 

national benefits, which include the value of 

avoiding approximately 14,000 to 36,000 

premature deaths, 22,000 nonfatal heart 

attacks, 11,000 hospitalizations for 

respiratory and cardiovascular diseases, 1.8 

million lost work days, 100,000 school 

absences, and 10 million days when adults 

restrict normal activities because of 

respiratory symptoms exacerbated by fine 

PM and ozone pollution, significantly 

outweigh the costs of the emission 

reductions.18

Since air pollution levels are highly sensitive 

to weather, climate change may significantly 

affect our overall air quality. For example, 

ozone is formed in warm weather, so higher 

summer temperatures may result in 

increased ozone concentrations in 

Massachusetts. Climate-driven increases in 

global and regional wild fires and duststorms and changes in precipitation may 

impact PM concentrations in Massachusetts.

Criteria pollutants also damage ecosystems.

Acid rain is created when SO2 and NOx

emissions mix with water in the atmosphere.

Acid rain lowers the pH levels of lakes, 

rivers, and soils, harming fish and 

invertebrates. It damages forest ecosystem 

health by making plant roots more likely to 

 

17 Federal Implementation Plans to Reduce Interstate Transport 

of Fine Particulate Matter and Ozone. (August 2, 2010, 75 FR 

45210-45465).

18 EPA estimates that the benefits from the reductions outweigh 

the costs by 60 to145 to one or 55 to 130 to one depending on 

the discount rate used in the economic analysis. Regulatory 

Impact Analysis for the Proposed Federal Transport Rule, EPA,

June 2010, page 1. 

http://www.epa.gov/ttn/ecas/regdata/RIAs/proposaltrria_final.pdf

dry out and by washing away calcium and 

other minerals essential for plant growth. 

Exposure to ozone is associated with a range 

of adverse impacts to vegetation, including 

impairment of tree growth and loss of 

agricultural crop yield. Ozone can increase 

the rate of water loss by trees causing 

forests to drain streams and soils of water, 

thus stressing natural ecosystems beyond 

the trees themselves. Ozone interferes with 

photosynthesis, thus reducing carbon 

capture by trees, affecting the efficiency of 

large forested areas to act as carbon sinks.

Meeting Challenges, Seizing 

Opportunities

At roughly 2 percent of the U.S. economy 

and 1.3 percent of the nation’s GHG

emissions, Massachusetts could not, on its 

own, stop global climate change even if it 

reduced statewide emissions to zero 

instantly. But the severity of the climate 

change challenge requires leadership at 

every level, and Massachusetts is in a 

position to show the way toward a clean 

energy economy through the development of 

smart, targeted policies that reduce 

emissions by promoting greater energy 

efficiency, developing renewable energy, and 

encouraging other alternatives to the 

combustion of fossil fuels. There are 

opportunities to reduce emissions this way 

across the economy, and Massachusetts 

should continue to be a leader in identifying 

and capitalizing on those opportunities. 

But, more importantly, Massachusetts can 

make use of the climate change imperative 

to get off the fossil fuel rollercoaster, become 

more energy independent, and jump start its 

economy with new technologies, new 

companies, and new jobs. The 

Massachusetts Clean Energy and Climate 

Plan for 2020 will put Massachusetts on a 

path to meeting its statutory obligation to 

reduce GHG emissions, and on the road to a 

vibrant clean energy economy. 
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

13

II. An Integrated Portfolio of Policies

The GWSA gives broad authority to the state 

to choose policy tools — from targeted 

technology-specific policies to economy-wide 

market-based policies — to advance a clean 

energy economy while reducing GHG 

emissions. Since the passage of the Act in

2008, the interagency technical team, the 

Climate Protection and Green Economy 

Advisory Committee, and an outside group of 

consulting experts in energy, transportation, 

buildings, and industrial emissions have 

analyzed a wide range of policies and 

explored other states’ and other countries’ 

efforts to make concrete steps toward a clean 

energy economy. Public comments collected 

during hearings held through the summer of 

2010 focused on policy choices, design and 

outcomes. 

In weighing the different paths forward, it 

became clear that an integrated portfolio 

approach plays best to Massachusetts’ 

strengths and, taken as a whole, has the 

greatest likelihood of reaching the goals of 

addressing energy costs, energy security and 

independence, and reducing GHG emissions in 

the absence of broad federal action on climate 

and clean energy. In the last four years 

Massachusetts has demonstrated the 

effectiveness of a portfolio approach: a 

combination of legislation, executive actions 

and private sector entrepreneurship has 

aligned incentives and created opportunities 

for clean energy growth and GHG reductions. 

Successful energy efficiency programs, solar 

incentives, building codes, transportation 

planning, ocean planning and green jobs 

training are tailored to the Masaschusetts 

economic and workforce landscape. The 

portfolio that the state has built in the last 

four years is greater than the sum of its 

parts, working synergistically to launch the 

Commonwealth on a path to GHG reductions 

of 18 percent below 1990 levels by 2020.

The directive from the EEA Secretary was to 

build on this portfolio — expand existing 

programs where practical and develop new 

complementary policies that could accelerate 

clean energy growth and lower GHG 

emissions. Each of the policies presented in

this section underwent rigorous analysis that 

focused on criteria established by the Act and 

input from the public hearings and Advisory 

Committee: GHG reductions, costeffectiveness, energy cost mitigation, job 

growth, equity, implementability, and cobenefits. 

The portfolio of policies that follow are those 

deemed most likely to reach our clean energy 

and climate goals. Some can be put in place 

immediately; others will be tested through 

pilot programs, with those that show the best 

results ultimately implemented statewide 

through regulation or legislation, as needed. 

Depending on actual (as opposed to 

projected) results, not every one of these 

policies must be implemented to its fullest 

extent in order to achieve the 2020 mandate. 

But these represent the suite of policies that 

the Patrick-Murray Administration is 

committed to pursuing over the next four 

years as we build on the foundation created in 

the past four years and work toward the 2020 

emissions limit set by the Secretary.

This portfolio is divided into five categories: 

buildings, energy supply, transportation, nonenergy emissions, and cross-cutting policies. 

Each policy is labeled as either ―Existing‖, 

―Expanded‖ or ―New‖. Existing policies are 

those that were put in place prior to our Draft 

Implementation Plan in June of 2010. An 

example is the energy efficiency programs 

that started with the passage of the Green 

Communities Act of 2008. Expanded policies 

are those that build on already existing 

policies and exand their scope. An example is 

Smart Growth policies. New policies are those 

that have not yet been initiated or were 

begun since June of 2010. The GreenDot 

policy is an example of a new policy.
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

14

Bu i ld ing s 

Buildings consume more than 50 percent of 

the energy used in Massachusetts and are

therefore responsible for the greatest GHG 

emissions of any sector; 49 percent of GHGs, 

including over 21 percent from direct fuel 

use excluding electricity. Energy use in 

buildings comes from these two primary 

areas: 1) fuels for heating, primarily natural 

gas and heating oil, and 2) electricity for air 

conditioning, lighting, ventilation, appliances 

and equipment. The character of energy use 

in the buildings sector overall is determined 

by three factors: the amount and location of 

existing and new building space in use, the 

energy performance of these buildings, and 

the choice of energy sources. There are 

several effective approaches for enabling 

changes, primarily related to the latter two 

factors.19 The issue of location is covered in 

the transportation chapter.

Global, national and regional studies have 

consistently pointed to energy efficiency and 

improved energy performance of residential 

and commercial buildings as the largest and 

most cost-effective clean energy 

opportunities. This is particularly true in the 

Northeast, where the combination of a cold 

climate and heavy reliance on heating oil 

 

19 In general, the amount of building space is driven by 

broader trends such as economic growth, Federal policy 

relating to real estate and capital markets, and personal 

preferences. Innovations such as e-commerce, 

virtualization, and telepresence (telecommuting and 

teleconferencing) could one day substantially change the 

amount of building space in use.

results in both high heating energy use20 and 

high average fuel costs. For existing 

buildings, energy improvements can be 

encouraged through financial incentives, 

access to financing, and rating of building 

energy performance. For new buildings, 

energy performance can be moved to higher 

standards through advanced building energy 

codes.

In addition to eliminating energy waste in 

buildings, there is a significant opportunity to 

transition to cleaner energy sources. For 

example, oil heating can be replaced by solar 

thermal, sustainable biomass/biofuels, or 

heat pumps, while electricity supply can be 

shifted from fossil fuels such as coal and oil 

to wind and hydro.21

Massachusetts began to address many of 

these opportunities through the Zero Net 

Energy Buildings Task Force, created by 

Governor Deval Patrick in 2008. This 

stakeholder group, made up of energy and 

building industry professionals working with 

the DOER, released a roadmap for the state 

called Getting to Zero22 in March 2009.

The Clean Energy and Climate Plan for 2020

takes into account Massachusetts’ nationleading energy efficiency efforts mandated 

by the Green Communities Act of 2008, 

which will produce substantial GHG 

reductions for 2020, and proposes additional 

measures that will contribute toward meeting 

the 2020 limit set as part of implementation 

of the GWSA. 

 

20 The Northeast census region uses 16% more energy 

per capita than the U.S. average, due largely to having 

46% more heating degree days than the U.S. average. 

EIA Annual Energy Review 2009.

21 Electricity supply is discussed further in a separate 

chapter.

22 The ―Getting to Zero‖ report can be downloaded at: 

http://www.mass.gov/Eoeea/docs/eea/press/publication

s/zneb_taskforce_report.pdf
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

15

All Cost-Effective Energy Efficiency

With the Governor’s signing of the Green 

Communities Act (GCA) of 2008, 

Massachusetts embarked on a path to 

greatly increase investments in — and return 

on investments from — building energy 

improvements. From 2010 to 2012 — the 

first three year plan approved by the 

Department of Public Utilities (DPU) under 

the GCA mandate to capture all costeffective energy efficiency opportunities —

the state will invest more than $2 billion, 

with an anticipated return of over $6 billion 

in savings for customers.

Under the Massachusetts Clean Energy and 

Climate Plan for 2020, additional changes 

need to be implemented to maximize 

emissions reductions through energy 

efficiency. For example, deep energy 

improvements, which substantially improve 

building energy performance, should be 

encouraged in a way they are not in the 

existing program structure. Commercial and 

industrial buildings heated with fuel oil 

should have access to energy efficiency 

programs in the same way that residential 

buildings do. Finally, new measures, such as 

tree planting and retention that can reduce 

heating and cooling loads over the longterm, even if not so much for 2020, should 

be supported. 

Performance-based Energy Codes

In addition to achieving energy efficency

upgrades in existing structures, the 

Commonwealth needs to set standards for 

construction and rehabilitation that ensure 

higher energy performance. New 

construction in Massachusetts accounts for 

additions and turnover of around 0.75

percent a year in the total building stock for 

residential units and 1 percent for 

commercial space. That translates into 

turnover of 7 percent to 10 percent of the 

building stock through 2020, and 30 percent40 percent by 2050. These buildings have an 

expected lifetime ranging from 30 to more 

than 300 years. The design of buildings 

newly built today and in coming years will 

have a large and lasting impact on fossil fuel 

use and corresponding GHG and local air 

pollution emissions. 

Massachusetts has already adopted a 

pathway to greater energy efficiency in 

building codes through a commitment in the 

Green Communities Act of 2008 to adopt the 

latest International Energy Conservation 

Code (IECC) from the International Code 

Council (ICC), the body that develops and 

maintains model building codes for the 

United States. In addition to this energy 

code baseline, which updates every three 

years, the Massachusetts Board of Building 

Regulations and Standards (BBRS) adopted a 

local-option ‖stretch‖ energy code for 

municipalities in 2009. Over 60 

municipalities in Massachusetts have already 

adopted this higher-efficiency code. More 

significantly, ―stretch‖ is now approaching 

the norm: The 2009 stretch code for 

commercial buildings recently became the 

basis for the 2012 IECC code for commercial 

buildings, the largest improvement in the 

energy efficiency of the national model code 

in its 35 year history. 

The Massachusetts Clean Energy and Climate 

Plan for 2020 proposes to move away from 

the traditional approach of ‖prescriptive‖ 

codes, which set minimum standards for 

each building component or system, and 

toward ‖performance‖ or ‖outcome-based‖ 

codes, which set a maximum energy usage 

criterion for buildings but allow flexibility to 

meet that criterion in any number of ways. 

The Massachusetts stretch code has 

spearheaded ―performance-based‖ energy 

codes, through performance targets and 

testing requirements for new homes and 

through energy modeling requirements for 

large commercial buildings.
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

16

By shifting to performance-driven energy 

codes that get progressively more effective 

in reducing energy needs, new construction 

in 2020 will use half the energy of the same 

buildings under a business-as-usual scenario. 

This results in a total savings over the 

coming decade of 30 percent to 40 percent

of the expected energy use from new 

construction in residential and commercial 

sectors, with similar reductions in their total 

GHG emissions by 2020. Each year this 

number compounds, making it a critical 

component of any 2050 plan.

Energy Rating and Labeling of Buildings

In addition, this Plan proposes to use energy 

rating and labeling of buildings to create 

greater markets for energy-saving 

investments in existing structures. Currently, 

there is little data available on the energy 

use of existing buildings, which prevents 

buyers and renters — and their lenders —

from placing a value on the energy 

performance of spaces. Under this Plan, 

Massachusetts proposes to pilot and then 

broadly deploy residential building energy 

labeling that allows apples-to-apples 

comparisons of home energy performance in 

much the same way that miles per gallon 

(MPG) ratings allow fuel efficiency 

comparisons of cars and light trucks. A pilot 

program in western Massachusetts beginning 

in 2011 will seek to integrate this new 

information on energy use into the real 

estate marketplace through Multiple Listing 

Service listings and trainings for contractors, 

realtors and home appraisers. In addition, 

Massachusetts will develop a commercial 

building rating pilot that would deploy both 

operational energy ratings (based on utility 

energy bills and the EPA Energy Star 

Portfolio Manager program) and asset ratings 

(similar to home energy ratings or vehicle 

miles-per-gallon) ratings. These two forms of 

ratings reveal to prospective tenants what 

impact on energy use previous tenants have 

had, as well as the inherent energy 

performance of the building under average 

tenant use. The DOER has been working with 

a team from both the public and private 

sectors to design a commercial building 

energy rating program, with plans to launch 

a pilot in eastern Massachusetts in 2011.

Solar Thermal Water and Space Heating

While water and space heating together 

account for around half of total building 

energy use and carbon emissions in 

Massachusetts, it does not require very highgrade fuels (unlike powering aircraft and 

motor vehicles for example). These large but 

low intensity heating needs make them 

excellent candidates for active solar heating 

which has no fuel expense, and can provide 

significant heating from a small roof, wall or 

ground-mounted system. Unlike in the 

1970’s, the technology for active solar 

thermal heating is now mature and comes 

with decade-long warrantees to protect the 

up-front investment in a solar thermal 

system. This technology has been broadly 

adopted and even required in new 

construction in places as varied as Hawaii, 

Cyprus, Israel, and Austria (where there is 

less solar radiation available per square foot 

than in Massachusetts). However, the 

market for solar thermal in New England is 

currently small, and needs support to reach 

maturity and become a broadly viable option 

for new and existing construction alike. Solar 

thermal is only one of several renewable 

thermal technologies that over time can 

replace a growing portion of our heating 

needs that are currently met with fossil fuels.

Buildings as Elements of Livable 

Communities

While improving the design and efficiency of 

buildings is the focus of this chapter, we 

cannot lose sight of the importance of 

location. When considering energy and GHG 

gas footprints of homes and businesses, 

siting is also a critical consideration. The 

chapter on transportation covers in more 
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

17

depth the importance of liveable and 

walkable communities and the necessity of 

―smart growth‖ policies as we continue to 

build infrastructure in our growing economy. 

Consideration of these factors builds 

community cohesion and improves both our 

long-term quality of life and our economic 

competitiveness.

Heat leakage as shown by infrared camera, identifying where 

insulation and air sealing are needed. (source: DOER)
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

18

ALL COST-EFFECTIVE ENERGY EFFICIENCY

Policy summary: With the Governor’s signing of the Green Communities Act of 2008, 

Massachusetts embarked on a path toward significant energy improvements in homes and 

commercial buildings. The Act required that the electric and gas utilities pursue all cost-effective 

energy efficiency, i.e. eliminating energy waste whenever it is cheaper to do so than buying 

additional supply. From 2010 to 2012 — the duration of the first three year plan — the state will 

invest more than $2 billion, with an anticipated return of over $6 billion for participants. The 

program is administered by the investor-owned utilities in the state and the Cape Light Compact, 

together known as Program Administrators (PAs). The PAs work under the guidance of the Energy 

Efficency Advisory Council (EEAC), which represents a broad range of stakeholders.

Economy-wide GHG reductions in 2020 6.7 million metric tons; 7.1%23

Gigawatt (GWh) electricity savings in 2020 9,50024

Million BTU (MMBTU) natural gas savings in 2020 36 million

Million BTU (MMBTU) heating oil savings in 2020 7.7 million

Cumulative net benefits 2010-2020 (discounted) $17.5 billion25

Jobs gained in 2020 (direct and indirect) 19,60026

Clean energy economy impacts: From 2010 to 2020, the program will induce investments of 

$10.2 billion in buildings, creating approximately 19,600 jobs in 2020. In addition, the program 

will generate $17.5 billion in net benefits, largely in avoided future costs of energy and avoided 

energy system expansion. These savings will largely enter the local economy rather than flowing 

out of state and out of the country, while reducing living costs for residents and operating costs 

for businesses.

Rationale: A substantial amount of energy efficiency is cheaper than energy supplies now 

provided by coal, oil, natural gas, and nuclear power. However, due to various market barriers, 

investments in energy efficiency fall short of optimal, either for an individual organization or for 

 

23 6.7 million tons is based on expansion of the efficiency programs since 2008, due to the Green Communities Act. The 

program savings from levels of efficiency spending prior to 2008 are excluded, since the emissions trend in the Business 

as Usual (BAU) projection is estimated to include them.

24 Energy savings in 2020 are based on the full value of efficiency programs, including the spending levels that existed 

prior to 2008, in order to be consistent with DOER required reporting to the Department of Public Utilities (this differs 

from the calculation of GHG savings, as discussed in prior footnote). 

25 $13.7 billion electric, $3.4 billion natural gas, and $0.5 billion fuel oil, all discounted to 2010 at a 2.5 percent real 

discount rate. Includes savings from 2010 to 2020 from the full value of efficiency programs, to be consistent with DOER 

required reporting to the DPU. DPU order 08-50-A directs programs to use a discount rate pegged to the 10-year Treasury 

note over the previous year. Rather than vary the rate year by year, 2.5 percent was used as a reasonable approximation 

of the real Treasury rate historically.

26 Approximately 10,300 jobs from electric efficiency, 7,000 from gas efficiency, and 2,300 from heating oil efficiency. 

More than two-thirds of the employment gains are ―indirect‖ and ―induced‖ — due to lower energy bills causing greater 

respending of household and business incomes within the Massachusetts economy, and to purchases by efficiency-related 

companies from other businesses in the state.

Existing Policy
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

19

the state as a whole. The PAs, as a primary point of contact with customers on energy, are wellsuited to incentivize customers to undertake building energy improvements. Participation in 

energy efficiency could be increased greatly. 

Policy design and issues: The PAs, with guidance from the EEAC and DOER, attempt to reduce 

consumption of electricity, natural gas, and heating oil by conducting energy assessments on 

buildings, and providing financial incentives for customers to implement a variety of efficiency 

measures, such as installing higher-efficiency lighting, HVAC systems and appliances; adding 

insulation to attics, walls, and basements; and reducing air leakage from buildings. Both technical 

and financial assistance are provided to developers of new buildings, such as the Energy Star 

Homes program and customized project support for commercial buildings. 

There are a variety of market barriers that make achievement of all cost-effective efficiency a 

challenge. One of these is customers’ lack of up-front capital to pay for efficiency investments, 

and the PAs are currently addressing this through providing subsidized financing, targeted to 

different types of customers. Another is the ―split incentive‖ problem for rental space, when a 

tenant is paying the utility bills but only the owner has the ability to invest in efficiency measures. 

Efforts are also being made to address this issue. 

GHG impact: The programs will reduce emissions by 6.7 million tons in 2020.

Other benefits: By reducing fossil fuel combustion, the program will help reduce criteria 

pollutants and other hazardous air pollutants, providing public health and environmental benefits.

Cost: From 2010 to 2020, the electricity, natural gas, and oil efficiency programs will generate 

$27.7 billion of energy savings, at a cost of $10.2 billion, yielding $17.5 billion in net benefits for 

the state, largely in avoided future costs of energy and energy system expansion.

Experience in other states: Many states have energy efficiency programs operated by utilities 

within a similar framework. Massachusetts’ program is one of the most well established in the 

nation, and its 2010-12 plan represents the largest per capita investment in energy efficiency in 

the country.

Uncertainty: It remains uncertain how much energy efficiency there is to be captured and what 

program elements will capture it. 
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

20

ADVANCED BUILDING ENERGY CODES

Policy summary: Massachusetts recently adopted a requirement that building energy codes 

meet or exceed the latest International Energy Conservation Code (IECC) and stay current with 

its three-year update cycle. In addition, the Commonwealth developed one of the first ―stretch‖ 

energy codes, which moves away from the traditional code approach that prescribes specific 

energy measures that must be installed (levels of insulation, methods for air sealing, etc.), toward a ―performance‖ oriented code that mandates a percentage reduction in total building 

energy use, while allowing developers to make their own design choices on how to achieve that 

reduction. This policy would complete the transition to performance-based codes by 2020 that go 

beyond the IECC codes in terms of efficiency while reducing their complexity.

Economy-wide GHG reductions by 2020 1.5 million metric tons; 1.6%

Energy saved by 2020, million BTU (MMBTU) 28 million

Net cumulative benefit 2011 to 2020 discounted (from 

new residential construction only27)

$1.3 billion

Jobs created in 2020 (direct and indirect) 3,000 jobs

Clean energy economy impacts: Building construction is one of the largest economic sectors 

in the U.S. and is a major employer of skilled labor, with excellent potential for clean energy job 

growth. Between now and 2020 new construction is estimated to account for 7 percent to 10 percent of the total building stock. In addition, major renovations of existing buildings trigger code 

compliance requirements, and this will affect a significant percentage of buildings. The avoided 

fuel and electric costs due to enhanced codes will cut the long-term operational costs of this real 

estate and increase its durability. In addition, these projects will require more energy and design 

expertise, generating clean energy jobs in these sectors. In taking a leadership position on 

energy efficient design and construction Massachusetts-based firms are also likely to become 

national leaders in green design and to grow demand for their services in the increasingly global 

building design and engineering sector.

Rationale: Massachusetts has recently moved to the forefront of a national shift toward greater 

energy efficiency in building codes. This growing attention is due to the underlying economics, 

emphasized in analyses such as the McKinsey climate studies which point to modernized energy 

codes as one of the most cost-effective climate mitigation strategies.

28 Further, given the long 

lifespan of the building stock, decisions made today determine energy demands of the buildings 

sector for the rest of the century and beyond. 

Massachusetts has the opportunity to build on its recent leadership in energy codes by developing 

a clear roadmap for both residential and commercial code reform over the next decade. Clear and 

bold action can ensure that we put ourselves on a path to zero-net energy buildings, and provide 

 

27 Cost data is not broadly available for either new commercial buildings or the residential and commercial renovation and 

retrofit market.

28 The November 2007 McKinsey report: ―Reducing U.S. greenhouse gas emissions: How much at what cost?‖ lists 

―improving energy efficiency in buildings and appliances‖ at number 1 in its 5 clusters of GHG abatement potential in the 

U.S. by 2030. http://www.mckinsey.com/clientservice/sustainability/costcurves.asp

Expanded Policy
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

21

improved competitiveness for our nation-leading design, construction and developer 

communities.

The shift from prescriptive codes that try indirectly to reduce energy waste, to performancebased codes that directly measure and reduce energy waste, is one of the clearest ways to improve energy codes. Historically it was not possible to meaningfully measure or model the energy 

use of residential or commercial buildings, but the advance of diagnostic tools such as duct-testing equipment, blower doors, and infra-red cameras have revolutionized that process for residential buildings. In larger commercial building spaces, the sophistication of energy models has 

grown rapidly.

Design issues: Building energy codes are relatively complex, particularly for commercial buildings, and there are numerous stakeholders across the design and construction supply chain to 

factor into the rate of improvement that is possible. The early ―windfall‖ gains come from redirecting the emphasis of the energy code to more directly drive improvements in energy performance. Once these gains have been achieved the rate of progress will depend somewhat on design innovation and the appropriate application of new technologies that respond to marketplace 

demands. The dominant commercial building types are also the ones with the most turnover in 

real estate markets: office, retail and lab space and multi-family rental housing. The Commonwealth is looking to pilot programs in these sectors first, and to initially focus code improvement 

efforts there. 

On the residential side the pathway to zero-net energy homes has already been paved by several 

industry-leading builders, who build and sell net-zero homes at both market and affordable 

housing prices. However, the broader market transition will take time, a focused set of building 

codes, and a supporting framework of training, outreach and technical assistance. More than a 

third of new residential construction in Massachusetts voluntarily adopted the Home Energy Rating System (HERS) index in 2009, and this has been complemented by more than 60 communities opting into the ―stretch‖ energy code. A steady ratcheting down of the maximum allowed 

HERS index for new construction allows home builders and their subcontractors the time to retrain and modernize their design practices to meet performance targets without major shocks to 

the price of construction.

GHG impact: Estimated at 1.6 percent of statewide GHG emissions in 2020, based on an average reduction of over 50 percent in the energy use of new code-built buildings in 2020 versus 

2008, and improved levels of energy code compliance.

Other benefits: A stronger emphasis on energy use requires earlier attention to building design 

and performance considerations than is currently practiced. This generally is the most cost-effective time to find cost savings, and results in the use of more skilled labor early in a project, while 

reducing energy and material costs later during construction and occupancy. Further, more 

energy efficient buildings can better manage air quality and moisture in a building through controlled ventilation. Energy modeling forces consideration of benefits such as daylighting that improve health, productivity and quality of life for building occupants. Added thermal insulation both 

reduces drafts and improves sound insulation, and mechanical ventilation reduces dust and mold 

build-up in homes.

Costs: On average, up-front design and construction costs are likely to increase marginally. To 

date, cost estimates have been in the 1 percent to 3 percent range for both residential and commercial buildings that achieve a 20 percent to 30 percent improvement over the base code. In 
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

22

return for this upfront investment the developer is able to more clearly differentiate new construction as higher-performance than the stock of existing buildings, and the final owner/operator 

of the building receives significant energy cost savings.

Equity issues: Inability to afford heating fuel is widespread in Massachusetts, and the cost of 

subsidizing fuel needs of low-income households is borne broadly by ratepayers as a result. 

Higher-efficiency homes are a direct and sustainable method of addressing this social issue. More 

efficient homes reduce the cost of homeownership, they directly benefit renters who pay the cost 

of utilities, and indirectly benefit them when utilities are included in rents. For commercial buildings improved codes reduce the cost of doing business for retail and commercial office tenants, 

and operating costs fall for all investors in new commercial real estate. 

Experience in other states: California is the first state to propose a roadmap to zero-net 

energy homes and commercial buildings, and their approach has several similarities to that proposed in Massachusetts. However, as our climates are somewhat different the specific measures 

and building designs differ, particularly given our heating-load dominated residential market. The 

commercial building sector initiatives in New York City, California, and Washington D.C. show 

broad support for improvement in building energy performance.

Legal authority: The building energy code is governed by the independent Board of Building 

Regulation and Standards (BBRS). The Department of Public Safety (DPS), EEA and DOER will 

continue working together to craft future energy code provisions for consideration by the BBRS.

The Commonwealth could also pass legislation to clarify the scope29 and direction of the building 

energy code and to provide longer-term certainty for the real estate marketplace.

Implementation issues: The residential sector has begun the market-led transition to performance-based energy codes remarkably smoothly. However, as the rest of the market follows and 

as energy code requirements increase, the need for training and technical assistance is likely to 

rise. In order to ensure and improve code compliance, ongoing resources will be needed to provide continued training in best practices to builders, designers and subcontractors working in the 

new construction and retrofit markets. 

The commercial sector is perhaps earlier in the transition to high performance buildings, but the 

professionalization of design and engineering teams is higher. In order to effectively transition to 

performance-based codes for commercial buildings improvements and standardization in energy 

modeling will be needed, and there will be increased demand for building energy modelers. These 

are new clean energy jobs that require 21st century skill sets, and Massachusetts will only retain 

its leadership in green building design and engineering by cultivating this workforce.

Uncertainty: With the baseline energy codes in Massachusetts now tied to decisions of the 

International Code Council (ICC) there is a delegation of authority to this national body. The 

policy described here would reduce the uncertainty inherent in relying on the ICC by laying out a 

codes road map for the next three code cycles from 2012 through 2018. The impact of these 

codes on overall GHG emissions depends greatly on the economic performance of the broader 

economy and the resulting level of investment in new construction and building renovation.

 

29 The mandate of the BBRS is presently limited in regard to areas such as water conservation, siting, and other ―green‖ 

building considerations that impact energy use and that are addressed in recent ―green‖ codes from ASHRAE and the ICC.
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

23

BUILDING ENERGY RATING AND LABELING

Policy summary: The current real estate market operates without the explicit consideration of 

energy performance of the property – a significant factor in future operating costs. Potential 

building owners or tenants of either residential or commercial buildings make major investments 

without the ability to compare the energy performance of the buildings they are interested in. 

This policy would address this market barrier by introducing an energy rating program designed 

to facilitate ―apples-to-apples‖ comparisons between buildings. Initially in a pilot form, this would 

be the buildings equivalent of the EPA MPG rating on cars and light trucks. This policy 

complements existing efforts to track actual energy use through utility billing data, but the 

ratings are intended to be independent of tenant or user behavior, and are known as ―asset‖ 

ratings. The DOER is developing pilot programs for new ―asset ratings‖ of both residential and 

commercial buildings.

Clean energy economy impacts: Building energy labeling is anticipated to enable significant 

additional investments in energy efficiency. This investment in turn leads to large reductions in 

fuel expenses and creates and supports clean energy jobs in residential and commercial 

remodeling and construction. Less spending on imported fuel will keep more money in the state 

economy and thereby create additional jobs. 

Rationale: At present the voluntary market is providing a glimpse of the potential for an ―MPG 

rating‖ for buildings. For commercial buildings the Leadership in Energy and Environmental 

Design (LEED) green building rating has become a must-have requirement for class-A office 

space in cities across the country, including the greater Boston area. But while the LEED program 

has steadily improved its emphasis on energy costs, it remains a poor proxy for energy savings 

potential, and instead signifies that the building underwent a more thoughtful design process 

than is typical elsewhere in the market. In addition, a growing number of relatively energy 

efficient buildings have opted into the Energy Star Portfolio Manager program for commercial 

buildings — which allows buildings above the 75th percentile in energy performance to receive an 

Energy Star designation.

For the residential market a similar story is apparent. The Energy Star homes program has 

achieved significant market penetration in MA and other states around the country, and LEED for 

homes is also a growing ―green building‖ presence, alongside several other green homes 

certification programs.

While these voluntary programs have shown that there is market interest in energy and green 

design data, their impact has been limited largely to new construction, particularly toward the 

higher end of the market, leaving existing residential and commercial real estate markets largely 

unaffected. Initially developed as pilot programs serving the much larger existing buildings 

market, this policy could become a standardized source of energy comparison information. This 

would enable investment decisions that improve energy performance once developers are able to 

demonstrate and market the results of their investment.

Design issues: Any energy benchmarking and rating metric needs to be clear, transparent and 

trusted if it is to support increased energy efficiency investment. However, residential and 

commercial real estate markets face different design issues. For the relatively homogenous 

New Policy
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

24

residential market, a comparison of total annual energy needs (primarily heating and 

standardized electric plug loads) is likely to be the most intuitive metric. DOER, in collaboration 

with three other states and funding from the DOE, is launching a pilot along these lines in 

western Massachusetts in 2011.

For the more diverse commercial real estate market, an accurate comparison of energy needs per 

square foot (primarily heating, cooling, ventilation and lighting in office/retail/lab spaces) is the 

generally accepted metric. DOER in collaboration with a public and private sector team is 

developing a pilot to launch in eastern Massachusetts.

GHG impact: The GHG impact for this policy is indirect, in that it enables larger and more 

targeted energy efficiency investments in the covered real estate markets. It is too early to 

estimate the actual level of GHG savings attributable to this policy. However, given the large 

number of existing buildings and the equally large level of annual investment made in building 

renovations, retrofits and other improvements, enabling the market valuation of energy 

performance has the potential to foster significant private investment in energy-saving measures 

and hence reduced carbon emissions. Two major constraints to energy efficiency investment are 

lack of awareness of potential savings, and lack of credible metrics to support financing from 

lenders. This policy tackles both of these market failures, and enables smarter real-estate 

investment decisions.

Other benefits: The task of rating and labeling building energy performance is a labor intensive 

and skilled exercise. The resulting clean energy jobs are paid for from the energy savings and the 

other actionable building condition information that results from the building assessments. Energy 

assessments conducted for asset ratings generally uncover operational issues that can affect 

building durability (such as water damage, mold, and mechanical problems) as well as more 

energy-specific improvement opportunities. This information on buildings results in better market 

valuation and reduced investor risk, and also facilitates improved comfort and early identification 

of any health and life-safety issues.

Costs: The primary costs of energy asset rating and labeling programs is in the initial building 

assessments. It is critically important that these assessments are conducted in an independent, 

consistent and professional manner to ensure the integrity of the ratings. At the same time it is 

important to minimize costs to building owners and property managers. The Commonwealth is 

moving forward with pilot programs for both residential and commercial building energy rating to 

better assess the likely costs of implementation and to allow for both technology and process 

innovations to be tested, to reduce costs prior to any broader statewide deployment.

Equity issues: Providing access to energy use comparison data is likely to have equity benefits 

for low and moderate income households for whom energy costs represent a significant portion of 

their disposable income. As a result, there has been relatively high voluntary adoption of the 

Energy Star homes program by public and affordable housing programs both in Massachusetts 

and elsewhere in the U.S. Similarly, for the commercial buildings sector it is likely that small 

business owners and tenants who lease space will be the primary beneficiaries of more 

transparent and comprehensive access to energy comparison data in making decisions about 

where to lease and buy commercial space.

Experience in other states: Residential energy labeling has been successfully piloted in 

various metro-areas in the U.S., and has become a cornerstone of the European Union climate 
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

25

and energy policy framework for buildings. Notable examples in the U.S. on the residential side 

include Portland, Oregon; Seattle, Washington; and Austin, Texas. On the commercial side 

California is moving to a mandatory utility bill disclosure and benchmarking program through 

Energy Star Portfolio Manager. Similar programs are underway in New York City and Washington 

D.C. for public sector buildings and commercial office markets. A growing number of property 

management companies are developing internal metrics to assess building energy assets and 

performance in order to inform investment decisions across their portfolio. Adopting an ―asset‖ 

rating, which has credibility for building appraisers in commercial real estate, is a new idea in the 

U.S., although it has been the policy direction of the European Union for the past several years.

Legal authority: The Commonwealth can likely require energy ratings as part of the building 

code governed by the independent Board of Building Regulation and Standards (BBRS). Based on 

the findings of the pilots, DOER and the Department of Public Safety will develop plans for 

widespread adoption of rating and labeling and their possible incorporation into the building code.

However, the state may opt to put such a requirement in legislation in order to provide longerterm certainty for investors and businesses in the real estate marketplace. 

Implementation issues: If energy labeling pilot programs are subsequently expanded to a 

statewide level, the large number of existing buildings to assess and rate mean that it will 

necessarily take many years to fully implement this policy. As a result, the timing of market 

coverage will likely vary in different market segments and different geographic areas around the 

state. Further, in order to be effective energy ratings need to be accessible prior to any major 

financial transactions, and ensuring awareness and access to this information may be initially 

difficult while market coverage is low.

Uncertainty: The rate of adoption of energy ratings and labels by different segments of the real 

estate market, and the impact that this new information will have on efficiency investment 

decisions, is unknown. A certain threshold level or ―critical mass‖ is needed for both the 

residential and commercial markets to make full use of energy comparison data in their 

purchasing and leasing decisions, and it will likely take a few years before a broader trend in 

energy efficiency investments can be seen in response to these market signals. Availability of 

sufficient financing to improve properties is also likely dependent on broader economic trends.
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

26

―DEEP‖ ENERGY EFFICIENCY IMPROVEMENTS FOR BUILDINGS

Policy summary: To reach our 2050 GHG reduction requirement, energy use in existing 

buildings must fall dramatically. To accomplish this, it is necessary to begin retrofitting buildings 

with much higher levels of insulation, less air leakage, and better windows than are typically 

installed in the retrofit energy efficiency programs. This policy would make rebates and 

appropriate training and technical support widely available for ―deeper‖ energy improvements for 

residential buildings 

Economy-wide GHG emissions reduced in 2020 0.1 - 0.2 million metric tons; 0.1%-0.2%

Total Fuel Savings in 2020 (MMBtu) 2.7 million

Total Electricity Savings in 2020 (MWh) 79,000

Energy cost savings in 2020 $84 million

Note: energy savings are for the “high” case, with 0.2 million metric tons of CO2 reductions.

Clean energy economy impacts: Deep retrofits will save large amounts of both electricity and 

heating fuels, reducing living costs and cutting energy imports; while expanding job opportunities 

for skilled contractors and construction workers. 

Rationale: At present the energy efficiency program administrator (PA)-operated programs 

provide financial incentives for ―moderate‖ retrofits of residential buildings, such as adding 

insulation to attics and walls, upgrading fossil-fuel-based heating and cooling equipment, and air 

sealing. If all the standard measures are done, these improvements typically achieve 20 percent

to 30 percent reductions in heating energy use. While a major contributor to our 2020 emissions 

target, this level of savings is far from adequate for achieving the 2050 requirement of an 80

percent emissions reduction. For 2050 ―deeper‖ measures are needed –higher and more 

consistent levels of insulation on all the outside surfaces of a building, along with sharp 

reductions in air leakage. When needed building maintenance is done without adding insulation, 

such as re-roofing and re-siding, there is a huge ―lost opportunity‖ for achieving energy savings. 

The PAs currently have pilots that provide incentives for such deep retrofits. This policy would 

make such incentives a standard part of the PA offerings, with the expectation that their adoption 

by consumers would gradually rise from now through 2020.

Design issues: Until recently the utilities’ pilot only provided incentives for whole-house deep 

retrofits. The cost of such retrofits is quite high, for both the homeowner and the utilities, and is 

unlikely to be done broadly. More attractive to homeowners may be ―partial‖ deep retrofits, 

where one part of a house is done at a time when the owner was planning to do a renovation 

anyway. The incremental cost of energy saving improvements is greatly reduced when they are 

integrated with other work on the same portion of a home, such as when replacing a roof, 

residing exterior walls, or replacing windows. This policy would provide rebates that are 

substantial enough to attract widespread adoption of deep retrofits, such as rigid insulation 

installed below the roofing shingles or inside new siding, and triple-pane windows. 

Another design option is to continue what some PA deep retrofit pilots are doing currently, paying 

higher incentives for comprehensive projects that go deeper still, to Net Zero Energy, Passive 

House and Thousand Homes Challenge levels. Once heating needs are reduced to this level, there 

are significant savings on heating and cooling equipment. This practice provides additional 

New Policy
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

27

leveraging and measure bundling advantages, and builds the skills needed to reach the 2050 

GHG reduction requirement. 

In addition, the particular methods that are used to evaluate programs for cost effectiveness should 

be reviewed to ensure that deep retrofits can be implemented to the maximum possible extent. 

GHG impact: 0.1 to 0.2 million tons in 2020, depending on the rate of adoption by consumers. 

The state’s consultants have projected a relatively small number of project completions, based on 

(a) homeowners only undertake deep retrofits at the time when they are doing building 

maintenance anyway, (b) consumer adoption begins at low levels and grows slowly until it 

reaches 10 percent of normal maintenance projects by 2020. Since these are long-lasting 

improvements to buildings the cumulative impacts continue growing beyond 2020, contributing 

substantially to the 2050 reduction requirement. 

Other benefits: Substantial reductions in energy use, cost savings to homeowner, and 

improvements to building comfort. 

Costs: Costs to the utility efficiency budgets and to homeowners are significant. For an 

expanded program that goes beyond the current pilots, impacts on utility budgets would depend 

on the scale of adoption by consumers.

Equity issues: In most cases the incentives for deep retrofits will be substantially larger than 

those offered for ―moderate‖ retrofits. This creates possible equity issues between participants 

and non-participants in the program.

Experience in other states: The pilots currently underway by Massachusetts utilities are at the 

forefront of deep retrofit efforts in the United States. California has made a commitment to 

achieving sharp reductions in energy use by existing buildings, and the Province of Yukon in 

Canada has a program to super-insulate existing buildings. 

Legal authority: These kinds of programs fall within the authority of the electric and gas 

utilities under their existing efficiency programs.

Implementation issues: Deep retrofits involve more complex construction techniques than are 

needed for conventional construction or moderate retrofits. To achieve the projected energy 

savings, and to not create or worsen other problems such as moisture and mold issues in a home, 

the deep retrofit shell must be installed correctly. As less heat is used in a building the drying 

potential is greatly reduced, so both interior and exterior water management details become critical 

for the health of occupants and durability of the structure. To avoid other indoor air quality 

problems, as well as to capitalize on smaller heating loads, shell measures should be carefully 

integrated with mechanical ventilation and smaller heating equipment that has sealed combustion 

or forced draft. Further, deep measures, if installed incrementally, should be deployed in a manner 

that does not hamper future energy improvements. This requires contractors with appropriate deep 

retrofit expertise, partnered with others with advanced HVAC expertise. At present these 

skills\teams are in limited supply and there is a need for training of contractors, along with a 

contractor guidance and inspection component such as in the Energy Star Homes program. Also 

needed is a system or incentives for a party involved to have long-term responsibility for the 

energy performance, durability, health, and safety of buildings that undergo deep retrofits.

Uncertainty: The rate of adoption of deep retrofits by consumers, even with substantial utility 

incentives, is not known and could be lower than projected. Availability of sufficient funds, from 

utility budgets or other sources, could be a question if the rate of adoption is high. 
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

28

EXPANDING ENERGY EFFICIENCY PROGRAMS TO COMMERCIAL/ INDUSTRIAL 

HEATING OIL

Policy summary: At present the electric utilities provide funding for heating-related efficiency 

measures in homes that use oil heat. There is no funding available for commercial and industrial 

buildings that use fuel oil for heating. Expanding the programs to such customers would yield 

significant cuts in energy use and GHG emissions.

Economy-wide GHG emissions reduced in 2020 0.1 million metric tons; 0.1%

MMBTU oil savings in 2020 230,000

Clean energy economy impacts: These programs would result in increased employment in 

efficiency audits and installation of efficiency measures and reduced spending on fuel oil imports, 

which keeps more money in the state and thereby helps to provide jobs throughout the 

Commonwealth’s economy. Companies using fuel oil would see lower operating costs, which 

increase their ability to continue operating in Massachusetts. 

Rationale: The exclusion of commercial and industrial (C/I) customers from oil heating 

efficiency programs is a significant missed opportunity for reducing energy use and GHG 

emissions. Given that heating oil is a relatively high-carbon fuel, and that the lack of programs in

the past means that such buildings will typically have low efficiency levels, the savings both in 

energy and GHG should be relatively high per dollar of funds spent. 

Design issues: At present there may not be legal authorization for the electric utilities to 

provide funding to C/I customers in the same way that they do for residential customers. If this is 

the case then other funding sources will be needed, such as RGGI funds. 

GHG impact: Assuming that C/I customers participate at the same rate, relative to their total 

use of heating oil, as do residential customers at present and as projected for the future, we 

estimate savings of 0.1 million metric tons of CO2 in 2020. 

Other benefits: Non-CO2 air pollutants from fuel oil will be reduced due to lower consumption, 

including reductions in SO2, NOx, and particulates.

Costs: Relatively small since C/I customers constitute only about one-quarter of total heating oil 

consumption in Massachusetts, with the rest being residential.

Equity issues: Heating oil customers do not pay into a specific efficiency funding pool, as do 

electricity and natural gas customers. However, in almost all cases they are also electricity 

ratepayers, and as with residential customers, if there are highly cost-effective efficiency 

opportunities available for heating-related measures, it can be argued that this is a good use of 

utility-administered efficiency funds. If other funding sources are used, equity considerations will 

depend on the source.

Legal authority: Needs further investigation, depending on anticipated sources of funds.

Uncertainty: Measures to improve the efficiency of building shells, heating systems, and 

heating distribution systems are well known and there is extensive experience with them, so 

there is little risk of not being able to achieve cost-effective energy and GHG savings. 

New Policy
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

29

DEVELOPING A MATURE MARKET FOR SOLAR THERMAL WATER AND SPACE 

HEATING

Policy summary: A policy framework will be established to achieve a mature and selfsustaining market for solar thermal water and space heating in both residential and commercial 

buildings. This support for the nascent solar thermal market is part of a broader goal of 

developing renewable heating technologies (such as clean biomass heating and efficient heat 

pumps), to facilitate a market transition to renewable fuels as the dominant fuels for heating 

purposes by 2050. The policy will also establish robust job and business growth in the renewable 

thermal sector in the Commonwealth.

Economy-wide GHG emissions reduced in 2020 0.1 million metric tons; 0.1%

Clean energy economy impacts: Large reductions in fuel costs in exchange for investments in 

solar thermal heating equipment will reduce the cost of living for residents and the cost of 

business for commercial customers. New installations will result in the growth of the solar 

thermal industry in Massachusetts, and to a lesser extent, local maintenance work. Directly 

offsetting spending on imported fuel will keep more money in the region and thereby create 

additional jobs in the broader state economy. 

Rationale: Hot water and space heating are large energy users that do not require very highgrade fuels (unlike motor vehicles for example). This makes them excellent candidates for active 

solar heating, which has no fuel expense and can provide significant heating from a small roof, 

wall or ground-mounted system. Unlike in the 1970’s, the technology for active solar thermal 

heating is now mature and comes with decade-long warrantees to protect the up-front 

investment in a solar thermal system. However, the market for solar thermal in New England is 

currently very small, and needs ‖infant industry‖ support to accelerate its growth to the scale 

needed to maintain continued growth and provide a realistic option to interested customers. 

Design issues: Similar to the Solar PV industry in MA prior to its recent exponential growth in 

the last four years, the small size of the solar thermal market burdens it with high levels of ‖soft‖ 

costs in sales and marketing (finding customers and designing and installing well-sized systems). 

This forms a barrier to consumer awareness and competitive pricing in comparison to the 

dominant market share of fossil fuel-based heating systems. The ‖hard‖ costs of quality 

equipment are being driven down by global market growth, and so once Massachusetts can 

develop a significant demand entrepreneurial companies will likely be able to bring turn-key 

pricing down considerably. Solar thermal systems require a back-up system in the event of a cold 

and cloudy week in winter, so most customers will retain their pre-existing fossil fuel heating 

system and new construction will likely move to on-demand electric or much smaller backup 

fossil fueled boilers .

GHG impact: For purposes of this Plan, a modest 0.1 million ton reduction in emissions due to 

solar thermal is forecast. However, larger reductions could be attained through a broader 

program applying to all renewable thermal technologies, including heat-pumps, biomass/biofuels, 

and solar thermal. If the displacement of 20 percent of the fuel oil used for thermal energy and 

50 percent of propane heating and electric water heating could be attained, this would reduce 

GHG emissions in Massachusetts by approximately 2 million tons, or slightly more than 2 percent 

New Policy
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

30

of total 1990 emissions. This 2020 goal would be for all renewable thermal technologies, 

including heat-pumps, biomass/biofuels, and solar thermal applications. GHG emissions from 

biomass and biofuels used for thermal energy are important to consider, but Massachusetts 

policies will limit the eligibility of feedstocks (advanced biofuels and residue woody biomass) to 

those which demonstrate real and rapid GHG benefits, such as advanced biofuels and residue 

woody biomass

Other benefits: Expanding solar thermal energy will create and expand businesses in 

Massachusetts in a manner similar to our early stimulation of the solar PV market. For solar PV, 

the Commonwealth has added 1,800 new jobs since 2008 when the solar PV programs were 

launched. PV installations grew from 3 MW to 35 MW between 2007 and 2010, with another 35 

MW in the development pipeline. Jobs will include system marketing, design, finance, installation 

and maintenance, along with manufacturing and fabrication of solar thermal panels and system 

components. In addition a mature solar thermal market complements the utility energy efficiency 

and advanced building energy codes policies. For existing homes in particular, there is a large 

stock of buildings that are heated with hot water, and where solar exposure is available these 

distribution systems can be easily retrofitted to provide space heating from renewable solar 

heated water with the fossil fuel systems retained as back-up systems.

Costs: In order to accelerate the market for solar thermal systems a highly publicized state 

rebate program analogous to the successful Commonwealth Solar program for PV is 

recommended. Due to the lower per system costs of solar thermal the MassCEC has proposed 

launching a pilot program to explore the most effective way to implement such a program. Any 

state rebate would leverage existing incentives primarily from Federal tax credits and the utility 

managed zero-interest HEAT loan program.

Equity issues: As with any upfront capital intensive investment, the early adopters of solar 

thermal systems are often relatively affluent homeowners, large well capitalized businesses, and 

the public sector, that have the resources to take advantage of the long term benefits of 

renewable heating both for their bottom-line and co-benefits. However, these early actors 

catalyze the market, provide useful exposure and marketing, and bring down costs, all of which 

makes these technologies increasingly accessible and desirable to the broader market. Among the 

early adopters of solar PV in Massachusetts was the public housing and affordable housing sector, 

with a notable role played by Boston Community Capital. 

Experience in other states: Solar thermal subsidies to support the industry are relatively 

widespread and have grown in use in U.S. states including: New Hampshire, California, 

Delaware, Wisconsin, New Jersey, and Arizona. Total state incentives typically account for 25

percent to 50 percent of the system installed cost, but are expected to fall substantially over 

time. In particular, Arizona, Nevada, North Carolina and Washington D.C. have added solar 

thermal to the ―solar carve-out‖ of their Renewable Portfolio Standard (RPS) programs, which are 

primarily designed to support electric renewable energy sources. Massachusetts would also have 

this option once a pilot rebate period runs its course.

Legal authority: In order to add an incentive for solar thermal to the Massachusetts RPS 

regulations, new legislation would be required. In the absence of this, the Clean Energy Center is 

able to provide rebate funding and other incentives to thermal renewables as part of their 

enabling mandate in the Green Communities Act of 2008.
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

31

Implementation issues: The perceived barriers to solar thermal adoption can be summarized 

in the following four areas:

1. Upfront cost of system

2. Lack of consumer education and confidence

3. Shortage of experienced solar hot water designers

4. Permitting costs and inspections

All of these can be addressed in a well designed pilot, followed by a broader program.

Uncertainty: Projections of the rate of adoption of solar thermal systems in response to a well 

designed solar thermal incentive program are highly uncertain. The precise rate at which rebates 

or other incentives would be taken up by the private market is also unknown. However, the 

lessons of the Commonwealth Solar Rebate program for PV and the experiences of other states 

are instructive. As with any alternative to fossil fuels, the volatility in the price of oil and to a 

lesser extent the price of natural gas over the coming decade is a critical uncertainty. 
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

32

TREE RETENTION AND PLANTING TO REDUCE HEATING AND COOLING LOADS

Policy summary: Trees help to reduce heating and cooling loads in buildings. This policy would 

provide incentives to plant new trees around existing housing, and retain trees within new 

housing developments, to conserve energy and reduce GHG emissions. This pilot program might 

be feasible within current utility efficiency programs, or might require new funding and/or 

regulatory authority. 

Economy-wide GHG emissions reduced in 

2020

100,000 metric tons in 2020, 300,000 tons in 

2035 from trees planted by 2020

Clean energy economy impacts: On the order of 500 direct jobs per year from the scale of 

tree planting envisioned here, in nurseries, planting, and maintenance. Reduced energy costs and 

lower fuel imports.

Rationale: Strategically located around housing, trees can significantly reduce cooling and 

heating loads.30 Retaining trees when new homes are built, and planting new ones around 

existing housing, can be a low-cost means of saving energy and reducing GHG emissions. 

Optimally trees should be located on the southeast and southwest sides of a building to provide 

shade and reduce air conditioning load. Evergreen trees planted on the north and northwest sides 

(given prevailing winds in Massachusetts) provide wind breaks and can reduce winter heating 

needs. Retaining and planting trees could be subsidized by the electric and gas utilities on the 

same basis that they provide incentives for other efficiency measures. 

Design issues: For existing residential buildings, incentives could be provided to owners to 

plant new trees in the correct locations. For new housing development, incentives could be 

provided to developers to retain existing tree cover, and to particularly keep trees in the optimal 

locations for cooling and heating savings. Another option would be to provide incentives to 

municipal governments that pass local planning ordinances requiring developers to follow specific 

tree retention practices. Because trees generally take 15 years to reach their full shade potential, 

this policy would need to begin soon to have much impact by 2020. On the other hand, even if 

impacts by 2020 are small, they will rise after 2020 as trees mature, contributing to the 2050 

GHG requirement. 

 

30 Studies of large scale tree-planting programs in New York, Chicago, and Philadelphia resulted in a 1.7C average 

reduction in maximum air temperature in the hottest areas. Chicago heat island reduction measures reduced annual 

cooling degree days by 39. ―Energy Savings for Heat-Island Reduction Strategies in Chicago and Houston (including 

updates for Baton Rouge, Sacramento, and Salt Lake City,” S. Konopacki and H. Akbari, 2002, Lawrence Berkeley 

National Laboratory LBNL-49638; ―Shade trees reduce building energy use and CO2 emissions from power plants,‖ H. 

Akbari, 2002, Environmental Pollution 116: S119-S126; ―Energy conservation potential of urban tree planting,‖ E.G. 

McPherson and R.A. Rountree, 1993, Journal of Arboriculture 19(6):321-331. Trees also reduce ambient air temperature 

through evapotranspiration. Per-tree calculation: a single white spruce with dbh 8inches is projected to save 1.1MBTU in 

heating energy for a single family home in Boston. (Casey Trees, based on the USFS iTree model). Toronto area heat 

energy savings: single family residences saved 3 percent (built pre-1980) and 2.5 percent (after 1980); efficient R-2000 

houses 2 percent; row-houses 1.6 percent (built before 1980) and 1 percent (built after 1980) (Konopacki and Akbari, 

2002). 

New Policy
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

33

GHG impact: About 100,000 metric tons CO2e potential by 2020 under realistic assumptions of 

possible participation. Savings become much greater over time, rising to 300,000 tons in 2035 

from the trees planted/retained by 2020, because most will not have reached their full growth 

until well past 2020. (Note that GHG savings from trees sequestering CO2 are real but are not 

included here. Due to data problems, tree sequestration is not included in the 1990 baseline 

emissions estimate, nor are reductions or increases in sequestration in the years since then 

included. Without those numbers it is not valid to include sequestration gains due to a policy 

measure.)

Other benefits: Trees significantly improve the quality of life for immediate residents and the 

neighborhoods around them. This may have other secondary benefits which have not been 

quantified — such as higher real estate values, better-maintained homes, lower crime, etc.

Costs: Depending on the scale and scope of these programs, their costs could vary greatly. More 

than most efficiency programs, the benefits accrue over a long time period. Pilot programs 

between state agencies and utilities will allow for analysis of cost and benefits, as well as 

identifying implementation issues. One current estimate is on the order of $150 per tree for 

purchase and planting.

Equity issues: To fairly distribute benefits to urban and lower-income residents, it would be 

essential to ensure that the tree planting take place on a large scale in cities as well as around 

suburban homes, despite the likelihood of greater siting difficulties. As with the existing efficiency 

programs, this could be a particular challenge for rental housing, where landlords often lack the 

incentive to cut energy costs when tenants are paying the electricity and/or heating bills. Greater 

efforts would need to be made to achieve participation in rental properties. 

Experience in other states: Utility-funded tree-planting programs are already in place in 

several cities and states. Sacramento, CA has avoided the cost of constructing a new 19 MW 

power plant by planting over 450,000 trees next to homes. With funding from the Sacramento 

Municipal Utility District (SMUD), the Sacramento Shade (for residences) and Neighbor Woods 

(for public spaces) Programs aim to plant 5 million trees by 2025. Residents are eligible for up to 

10 free trees. SMUD estimates that each tree provides $90 in annual benefit.31 In Iowa, the 

Municipal Tree Planting Program is a partnership between the non-profit Trees Forever and four 

utilities, in which the utilities provide funding for community planting programs.32 Here in 

Massachusetts, Grow Boston Greener is a collaborative effort of the City of Boston and its 

partners in Boston’s Urban Forest Coalition to increase the urban tree canopy cover in the city by 

planting 100,000 trees by 2020.

 

31 The partnership between the Sacramento Municipal Utility District and Sacramento Tree Foundation has been ongoing 

since 1990. http://www.smud.org/en/residential/trees/Pages/index.aspx or http://www.sactree.com/doc.aspx?25 .

Riverside, California program: http://www.riversideca.gov/UTILITIES/resi-treepower.asp. Pasadena, Alameda, and a 

number of other California utility companies have similar programs. Initiatives to capture environmental savings from 

trees are also underway in more temperate climates. The Department of Public Services in Portland, Maine will deliver and 

plant trees that residents purchase at local nurseries. The ―Treebate‖ program in Portland, Oregon offers residents a 

rebate on trees they purchase and plant (funded for water quality). Washington, DC residents can receive a $50 rebate 

for each eligible species of tree. 

32 www.treesforever.org
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

34

Legal authority: PAs have the authority to conduct pilots and to expand these into new 

efficiency programs, based on approval of the Energy Efficiency Advisory Council and the DPU. 

Pilots will help determine whether and over what time period energy savings exceed costs. The 

results of such pilot programs will help determine the value and feasibility of tree planting and 

retention activities.

Implementation issues: This would be a pioneering program in the northeast, and so a variety 

of program approaches to achieving participation, planting trees effectively, and maintaining 

them could occur.

Uncertainty: We do not know the degree to which residents will be willing to participate, even 

with subsidies; nor the degree to which developers and landlords will participate; nor 

municipalities for a program design in which they require developers to retain trees. 
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

35

FEDERAL APPLIANCE AND PRODUCT STANDARDS

Policy summary: The federal government sets energy efficiency standards for appliances, 

electronics, and other products. Under President Obama, DOE has planned an accelerated 

schedule for setting new standards between 2009 and 2013. Nationwide these are expected to 

yield major savings in electricity (11.5 percent of total consumption in 2020), fuel, costs to 

homeowners and businesses, and carbon dioxide emissions, with Massachusetts getting its 

proportional share.33

 Savings (above current trends)

34

Economy-wide GHG emissions reduced 2020 0.5 million metric tons; 0.6%

Electricity saved — Gigawatt hours (GWh) 2020 1,04035

Natural gas, fuel oil saved — MMBtu 2.9 million

$ value energy savings in 2020 $330 million

Cumulative net benefits 2011-2020 (discounted) $2.7 billion

Jobs gained 2020 (direct and indirect) 1,200 jobs

Clean energy economy impacts: Reduction of $330 million in costs in 2020 will improve cost 

of living for residents and reduce operating costs for businesses, also helping to keep jobs in the 

state.

Rationale: As with most efficiency measures, appliance and product efficiency faces market 

barriers that result in consumers making short-term purchasing decisions that don’t reflect the 

optimal financial decisions long-term. To some degree this occurs because products, particularly 

appliances, are often bought on an emergency basis when the old item has failed. By mandating 

that products be built to specifications that will minimize their lifecycle costs, including both 

capital and energy costs, DOE can drive large savings. 

Policy design and issues: The federal government sets nationwide standards, in some cases, 

due because climate conditions standards vary by region (such as with windows), but in other 

cases DOE has not made this distinction, as with heating system efficiencies. For this reason, 

Massachusetts applied for a federal waiver to set a standard for gas furnaces higher than the 80

percent federal standard, due to our colder climate. DOE denied Massachusetts’ waiver request; 

although it has said that it is looking to develop a higher standard for the entire northern tier of 

the country. 

 

33 ―Ka-BOOM! The Power of Appliance Standards. Opportunities for New Federal Appliance and Equipment Standards,‖ 

American Council for an Energy-Efficient Economy and Appliance Standards Awareness Project, July 2009.

34 Because federal standards have existed in the past and exist today, the state’s consultants estimate that half the 

savings from forthcoming standards are already embedded in the ―business as usual‖ trend lines; so only half the savings 

expected from the planned federal standards are included here. Also, the savings given here for 2020 include a portion of 

savings over the lifetime of products purchased by 2020, some of which occur after 2020.

35 ―State-Level Benefits from Potential Federal Appliance Standards,‖ Appliance Standards Awareness Project, 2009.

Existing Policy
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

36

GHG impact: ACEEE and the Appliance Standards Awareness Project (ASAP) forecast that the 

forthcoming standards will reduce GHG emissions by 1.0 million tons in 2020. The 

Commonwealth’s consultants estimate that half of these reductions are already counted in the 

business-as-usual (BAU) trend for electricity emissions in 2020, and so 0.5 million tons are 

counted as a reduction versus the BAU.

Other benefits: The standards yield large savings in electricity and costs. In parallel with the 

GHG reductions, half of the savings are counted in the existing trends, so the incremental gains 

are estimated at 1,040 gigawatt hours of electricity and $200 million in 2020. 

Costs: Incremental costs of production vary for each product, and are required to be less than 

the lifetime energy savings in each case in order for DOE to set a standard. Sample costs are $52 

for a refrigerator, $50 for a clothes dryer, and $2 for microwave ovens. There have been reports 

of more frequent or more expensive repairs needed for some items, such as the computer boards 

for variable speed motors in refrigerators. 

Equity issues: Not significant, due to low incremental cost of attaining higher efficiency 

standards. 

Experience in other states: This is a nationwide program.

Legal authority: The federal government has preempted authority over efficiency standards for 

products; states can apply for waivers.

Implementation issues: None known.

Uncertainty: Energy savings per product are dependable due to mass production and quality 

standards. Durability of products can be an issue, and higher frequency of replacements would 

reduce energy savings due to the embodied energy in manufacturing of products. 
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

37

E le c tr ic i ty S upp ly 

The vast majority of existing power plants 

burn fossil fuels to generate electricity, 

producing millions of tons of pollution. 

Additional electricity generation technologies 

include nuclear, hydro, wind, solar, and 

eligible biomass, which vary in their 

emissions profiles. The character of the 

electric power sector as a whole is 

determined by three key factors: the 

demand for electricity across sectors, 

existing generation capacity by technology 

type, and actual generation, which depends 

on how much of each type of existing 

capacity is utilized to meet demand. There 

are several approaches related to each of 

these factors that can push the 

Commonwealth toward a clean energy future 

for electricity supply.

Demand for electricity can be reduced by 

improving the energy efficiency of our enduse devices, such as refrigerators and office 

equipment, as is discussed in the buildings 

section of this Plan. Both generating capacity 

and actual generation of clean energy 

technologies can be increased by a spectrum 

of activities based on the maturity of the 

technology.36 Grants and other direct 

 

36 A framework for effective clean electricity policies by 

technology/market maturity has been developed by the 

International Energy Agency. 

http://www.iea.org/Textbase/npsum/DeployRenew2008

SUM.pdf

investments are best suited for research and 

development and early-stage companies or 

projects. A Renewable Energy Portfolio 

Standard can create market demand for all 

qualifying technologies, while specific 

requirements for particular technologies can 

target support for emerging technologies. By 

setting a price for carbon dioxide emissions 

from power plants by auction, the Regional 

Greenhouse Gas Initiative (RGGI) provides 

the power generating market with a 

transparent, stable, technology-neutral 

signal that influences both new investments 

and current operations. And implementation 

of Federal Clean Air Act rules encourages 

generators to retire or upgrade their dirtiest 

plants.

In order to achieve the GHG emission limit 

set by the Secretary, the Massachusetts

Clean Energy and Climate Plan for 2020

relies on progress in each of these areas 

made since 2007, along with proposed new 

measures to move toward a cleaner 

electricity supply. 

Massachusetts Clean Energy Center

The Green Jobs Act of 2008 created the 

MassCEC to accelerate job growth and 

economic development in the state’s clean 

energy industry. MassCEC serves as a 

clearinghouse and support center for the 

clean energy sector, making direct 

investments in new and existing 

technologies, clean energy companies, and 

workforce development to meet the skill 

needs of this growing industry.

In November 2009, an Act Relative to Clean 

Energy transferred the state's Renewable 

Energy Trust Fund to MassCEC. The Trust 

Fund was created in 1998 by the Legislature 

to provide financial assistance for 

development of renewable energy projects. 

With funds and programs to support clean 

energy development, entrepreneurship, 
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

38

workforce development, and installation, 

MassCEC is a unique one-stop shop for 

growing a clean energy economy.

Renewable Portfolio Standard

The RPS is used in more than 20 states and 

in other countries to create demand for 

renewable energy technologies such as wind, 

solar, biomass, and small hydro that are not 

yet price competitive with conventional 

power sources.37 In Massachusetts, retail 

sellers of electricity are required to obtain a 

growing share of their supply from new

renewable sources, thereby creating a 

demand for new projects. The eligible 

renewable resources are categorized into 

―classes‖ of similar maturity and type 

(―technology banding‖). For example, wind, 

eligible biomass and anaerobic digestion, and 

small hydro are all in Class I while solar is 

carved out into a separate class. Beginning 

in 2003, the share of total electricity supply 

required to come from Class I resources 

increased one-half percent a year, reaching 4 

percent in 2009. Starting in 2010, the 

required percentage increased by 1 percent a 

year, and will rise to 15 percent by 2020.

In addition to requiring increasing amounts 

of renewables in the market, the Department 

of Energy Resources (DOER) has taken steps 

to assure that the kind of renewables that 

receive state incentives produce GHG 

savings over time. In 2009, DOER 

commissioned a study from the Manomet 

Center for Conservation Sciences to explore 

the lifecycle GHG implications of biomass 

energy plants. The results of the study, 

published in 2010, questioned long-held 

assumptions about the carbon-neutrality of 

biomass electricity technologies, and DOER is 

currently in the midst of finalizing RPS 

regulations to assure that biomass projects 

 

37 Large hydro dams are considered a mature 

technology that requires no market support and are 

typically not included in Renewable Portfolio Standards.

are only eligible for the RPS if they yield true 

and substantial GHG reductions. 

The Green Communities Act of 2008 (GCA) 

also made several other changes to further 

drive investment in the renewable energy 

market enabled by the RPS. It requires that 

the electric distribution companies solicit bids 

for long-term contracts of 10 to 15 years 

from new renewable energy projects. Lack of 

such a long-term power purchase agreement 

is often a stumbling block for renewable 

energy projects to obtain financing. In 

addition, operators of distributed renewable 

electricity generation such as rooftop solar 

panels and community wind turbines are now 

eligible to sell excess electricity back into the 

grid at the price they pay (known as ―netmetering‖), effectively having their electric 

meters turn backwards. Finally, distribution 

utilities were granted authority to each build 

and own up to 50 megawatts (MW) of solar 

generation. There are 11 MW underway or 

completed thus far. 

Regional Greenhouse Gas Initiative 

(RGGI)

Massachusetts is one of 10 states 

participating in the RGGI. The initiative, 

which began in January 2009, establishes a 

region-wide constraint on CO2 emissions 

from fossil fuel-fired power plants. The 

current program design calls for the cap to 

remain at the initial level for six years (2009 

to 2014), and then to decrease by 2.5 

percent per year for the next four years, for 

a total reduction of 10 percent by 2018. 

RGGI provides a transparent and stable 

signal to the electricity market to plan future 

investments with an understanding that 

higher emitting generators will need a 

greater number of emissions allowances than 

cleaner generators. Proceeds from the 

auction of allowances have been effectively 

used to fund a range of energy efficiency 

programs in the state, resulting in cost 
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

39

savings for residential and business 

consumers.

Clean Energy Imports

Canada has substantial hydro-electric 

resources, which have very low emissions 

and are available at relatively low cost, but 

transmission lines that deliver this resource 

to southern New England are currently at full 

capacity. One effort to tap more of this 

resource is the Northern Pass transmission 

line being developed by NSTAR and 

Northeast Utilities, in partnership with Hydro 

Quebec (HQ) and with the support of the 

Patrick-Murray administration. When this 

power line is completed, at HQ’s expense, it

will bring to New England enough 

inexpensive clean power to serve up to 15 

percent of Massachusetts’ present electricity 

demand. Additional transmission lines may 

also be possible. 

Federal Clean Air Act Implementation

The Supreme Court, in its 2007 decision 

Massachusetts vs. Environmental Protection 

Agency, ordered the EPA to regulate GHG

under the Clean Air Act (CAA) as ―pollution 

which may reasonably be anticipated to 

endanger public health and welfare.‖ While 

the CAA is federal law covering the entire 

country, it is largely implemented by the 

states, which are often better suited to 

understand local industries and conditions. 

Implementation of the CAA will provide the 

dirtiest power plants the choice of making 

upgrades in control technology of those 

plants or retiring them.

Cleaner Energy Performance Standard

From 2005 to 2009, the electricity portfolio 

serving Massachusetts became more than 20 

percent cleaner. This was largely the result 

of how much of the time each existing power 

plant was operated and which fuel they 

utilized, rather than investment in new 

capacity. The major changes were the nearly 

complete phase-out of fuel oil by 2007 

because of high oil prices, a reduction in coal 

operation relative to natural gas since 2007 

because of low natural gas prices, and a 

doubling of large hydro imports into New 

England from Canada. These developments 

demonstrate that the electricity sector even 

as it exists can operate more cleanly. 

This Plan will provide a signal to electricity 

suppliers to maintain and improve upon 

these cleaner energy portfolios by proposing 

a Clean Energy Standard, which would 

require electricity suppliers to increasingly 

favor low-emissions and no-emissions 

sources in the mix of electricity delivered to 

their customers. This could be designed to 

favor in the long-term sources like wind, 

solar, and hydro, which emit no GHGs, but 

also initially favor cleaner fossil fuels like 

natural gas, to act as a bridge to a clean 

energy future.
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

40

RENEWABLE PORTFOLIO STANDARD (RPS)

Policy summary: The Massachusetts RPS was created as part of electricity restructuring in 

Massachusetts in 1997 and then expanded in the Green Communities Act of 200838. The RPS 

requires retail electricity suppliers — both distribution companies and other retail suppliers — to 

buy a percentage of their portfolio of electricity sales from eligible resources.

Economy-wide GHG emissions reduced 2020 1.1 million metric tons, 1.2%

Clean energy economy impacts: Over the period from 2010 to 2020, the Massachusetts RPS 

classes will stimulate $360 million in annual investment, or $3.9 billion in cumulative investment 

in clean power generation that would have not occurred on its own. This is expected to create 

approximately 900 full-time construction jobs throughout that period. 

Rationale: Because of low prices for fossil fuels, the lack of a market price for the negative 

impacts of pollution from fossil fuels (―externalities‖), and other market barriers, the private 

market is not, on its own, supplying as much renewable, low-carbon power as society needs. By 

creating market demand, Renewable Portfolio Standards drive investments in renewable energy 

supply.

Policy design: The Massachusetts RPS includes ―technology banding‖ in classes, with the Green 

Communities Act expanding the number of renewable classes to the following: Class 1 — New 

Renewables; Class 1 — Solar Carve-Out; Class 2 — Existing Renewables; and the Alternative 

Portfolio Standard (APS). Suppliers meet their commitments by buying Renewable Energy Credits 

(RECs), the accounting mechanism for ensuring that every unit of renewable energy generated is 

counted exactly once in terms of state requirements. As a result of the Green Communities Act, 

the RPS will require 15 percent of electricity supply to be from new Class 1 renewable resources, 

such as wind, solar, small hydro and eligible biomass and anaerobic digestion, by 2020. In total, 

all classes will account for 27 percent of electricity supply in that year.

GHG impact: 1.1 million tons of emissions will be avoided in 2020, from the expansion of the 

RPS due to the Green Communities Act, not including the RPS requirements that existed prior to 

the Act.

Other benefits: As with other electric sector policies, the RPS results in reduced burning of 

fossil fuels and therefore reduced local air pollution and improved public health. For example, a 

study by the independent National Research Council found that coal use around the country 

resulted in 20,000 premature deaths annually.39

Cost: There is a great deal of uncertainty in cost estimates for the RPS, due to unknown future 

changes in fuel prices, federal policies, and technology. Just in the last three years REC prices 

have dropped by a factor of three. A more detailed electricity supply study is underway. Although 

 

38 The GCA’s annual report for 2009 has a more detailed summary and charts at: 

http://www.mass.gov/Eoeea/docs/doer/rps/rps+aps-2009annual-rpt.pdf

39 Hidden Costs of Energy: Unpriced Consequences of Energy Production and Use, National Research Council.

www.nap.edu/catalog.php?record_id=12794

Existing Policy
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

41

some renewable power is relatively high-cost, the RPS also helps to reduce electricity prices 

throughout New England, due to the mechanics of the regional electricity market. Power, like 

many other commodities, is bought and sold both under longer-term contracts and in a ―spot‖ 

market. The spot market price is set by the most expensive supply needed to meet demand at a 

particular time. New renewable resources that have low operating costs displace the most 

expensive supply needed to meet demand, thereby reducing prices for all spot market power and 

providing savings to all customers.

Experience in other states: Twenty-four states have some type of Renewable Portfolio 

Standard. Key features of successful programs are those which provide transparency, longevity, 

and certainty to the market. Repeated changes to the program design create concern in the 

market.

Legal authority: RPS authority derives from electricity restructuring statues from the late 

1990s as well as the Green Communities Act.

Implementation issues: The RPS (Class I) program compliance began in 2003. After several 

years in which eligible renewable generation fell short of requirements, and while project 

development continued to make progress, the program has successfully met its annual 

compliance obligation with new renewable energy since 2007. In 2009, the minimum standard of 

5 percent was met, though an increasing portion of the generation is coming from imports from 

New York and adjacent Canadian provinces into the New England region.

Since the restructuring of energy markets in Massachusetts in 1997, supply contracts between 

the electric distribution companies and power generators have typically been for only three 

months to one year, far too short a period to allow financing of the high capital costs involved in 

developing renewable generating facilities. This has been a contributing factor in limiting supplies 

of RPS-eligible renewables in Massachusetts. To rectify this problem, the Green Communities Act 

required that the distribution companies solicit proposals from renewable energy developers and 

enter into cost-effective long-term contracts for at least a limited amount of renewable energy, in 

order to facilitate the financing of renewable energy generation. Such contracts can assist 

renewable energy developers in obtaining financing by providing assurance of revenues from 

sales of RECs and electricity over a number of years. 

Uncertainty: Siting constraints both for generation nearby or for transmission to remote 

resources could constrain the renewable supply. In addition, restructured markets like New 

England may lack parties to enter into long-term power purchase agreements that are often 

required for financing of renewable energy projects, particularly at a time of low natural gas 

prices.
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

42

REGIONAL GREENHOUSE GAS INITIATIVE (RGGI)

Policy summary: Massachusetts is one of the 10 Northeast and Mid-Atlantic states participating 

in a regional effort to limit carbon dioxide emissions from electric generating units in the region40.

The program, which began in January 2009, establishes a region-wide cap on CO2 emissions from 

fossil fuel-fired power plants in the region. The current program design calls for the cap to remain 

at the initial level for six years (2009 to 2014), and then to decrease at 2.5 percent per year for 

the next four years, for a total reduction of 10 percent by 2018.

By the end of each three-year compliance period, facilities covered under the program are 

required to have purchased allowances — a limited authorization to emit one ton of CO2 — equal 

to their total emissions; the allowances are then retired so they cannot be used again. Allowances 

are made available by the states for purchase in quarterly auctions. Massachusetts is investing 

over 80 percent of its auction proceeds in energy efficiency, with smaller amounts for renewable 

energy and other consumer benefit programs.

Clean energy economy impacts: Over $120 million in auction proceeds has been invested in 

energy efficiency projects across the Commonwealth since 2009, creating jobs in the clean 

energy economy. In addition, the efficiency investments will reduce electricity and fuel costs for 

property owners, leaving them with savings to be invested elsewhere in the local economy.

Rationale: The electric generating sector represents approximately a quarter of total GHG 

emissions in Massachusetts at present. The RGGI program provides a transparent and stable 

signal to the electricity sector to plan for a cleaner energy future. In addition, improvements in 

building energy efficiency reduce the demand for electricity and help keep emissions below the 

cap, reducing the cost of compliance.

Policy design: Recent trends in relative fuel prices, weather, investments in energy efficiency, 

and the downturn in the economy have resulted in actual total regional emissions much lower 

than anticipated. The RGGI states, along with broad stakeholder engagement, are currently in the 

process of a comprehensive program review which will include evaluation of program success, 

program impacts, additional reductions, imports and emission leakage, and offsets.

GHG impact: RGGI has a regional emissions cap, providing for a 10 percent reduction in CO2

emissions across the 10-state region by 2018, and there is no specific limit on emissions deriving 

from the power plants in a particular state. Massachusetts’ significant policies for electrical energy 

efficiency and renewable electricity are supported, in part, by proceeds from the RGGI auctions. 

Therefore, in this Massachusetts-specific analysis, emissions reductions are attributed to all of 

these programs in combination.

Other benefits: By providing incentives for reduced operation of the dirtiest plants and greater 

operation of cleaner ones, the RGGI program also reduces criteria and hazardous pollutant 

emissions (NOx, SO2, mercury, and fine particulate matter). These reductions will have public 

health and environmental benefits.

 

40 The states participating in the RGGI are CT, DE, MA, MD, ME, NH, NJ, NY, RI, VT.

Existing Policy
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

43

Costs: Since funds received from sale of RGGI allowances are largely invested in the state’s 

utility-administered energy efficiency programs, RGGI’s costs in fractionally higher electricity 

prices are offset by reductions in the costs of the efficiency program.

Experience in other states: Other states are in the process of developing and implementing 

similar programs. These efforts include the Western Climate Initiative and the Midwest Climate 

Accord.

Legal authority: Massachusetts RGGI regulations derive from authority under the Green 

Communities Act.

Uncertainty: A range of factors affect emissions from power plants, some under the control of 

power plants or the state and some not, ranging from weather and relative prices of fuels used to 

generate electricity to the aggressiveness of the implementation of energy efficiency programs.
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

44

MORE STRINGENT EPA POWER PLANT RULES

Policy summary: The EPA is in the midst of proposing and implementing a variety of 

regulations that will affect the nation’s power plant fleet, impacting their allowable water and air 

emissions. It is likely that the owners of some older, smaller power plants will find it is not 

economical to retrofit their plants to meet EPA’s new regulations, and they will instead choose to 

shut down the plants. In Massachusetts, it is possible that two of the state’s older coal-fired 

power plants will close. The Somerset Power Station in Somerset last ran in January 2010, and its 

permits will eventually expire if it is not restarted. The owner of the Salem Harbor Station in 

Salem has indicated that it expects the plant to close within five years.41

Economy-wide GHG emissions reduced 2020 1.2 million metric tons; 1.2%

Rationale: Power plant emissions have severe consequences for human health. 

Policy design: Among the new rules being proposed by EPA are air emissions regulations 

addressing the transport of power plant pollution from one state to another (Clean Air Transport 

Rule, or CATR). Power plants contribute to high levels of ground-level ozone and fine particulates.

These rules will require significant reductions in nitrogen oxides and sulfur dioxide emissions, 

which will tend to favor more efficient, cleaner power plants.

The Clean Air Act also requires EPA to propose air emission limits to control the release of 

mercury and other hazardous substances contained in power plant fuels (National Emission 

Standards for Hazardous Air Pollutants) and Maximum Available Control Technology standards). 

In addition, under Clean Water Act Section 316(b), cooling water intake structures may need to 

be redesigned to minimize the adverse environmental impact associated with the entrainment of 

fish, shellfish and their eggs and larvae by power plants drawing in large volumes of water to 

condense steam used in making electricity. Finally, Coal Combustion Residuals disposal 

regulations will ensure the safe disposal of coal ash.

Legal authority: EPA has the authority to issue new rules under the Clean Air and Clean Water 

Acts.

GHG impact: If these rules result in power from two older Massachusetts power plants being 

displaced by natural gas-fired power plants, there would be a net 1.2 million metric ton reduction 

in CO2e in 2020.

Other benefits: Reduced exposure to fine particulates and ozone will have health and 

environmental benefits.

 

41 See http://www.boston.com/business/articles/2010/11/28/old_plant_begins_to_break_spell_over_salem_mass/

New Policy
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

45

CLEAN ENERGY IMPORTS

Policy summary: Canada has substantial hydro-electric resources, which have very low 

emissions, and are available at relatively low cost and with no need for renewable energy 

subsidies (see Renewable Portfolio Standard, above). The amount of Canadian hydro has risen to 

8.5 percent of New England’s electric consumption, but transmission lines that deliver this 

resource to southern New England are at full capacity, preventing any additional Canadian hydro 

from getting to our market. One effort to tap more of this resource is the Northern Pass 

transmission line being developed by two Massachusetts utilities, NSTAR and Northeast Utilities, 

in partnership with Hydro Quebec (HQ) and with the support of the Patrick-Murray administration. 

When this power line is completed, at HQ’s expense, it will bring to New England enough 

inexpensive clean power to serve up to 15 percent of Massachusetts’ present electricity demand. 

Additional transmission lines may also be possible. 

Clean energy economy impacts:42 The project represents an infrastructure investment in the 

region by Hydro Quebec estimated at $1.1 billion. It will create hundreds of jobs related to 

clearing and site work, harvesting, construction and materials, including electrical, professional, 

and technical services. While the vast majority of these jobs will be in New Hampshire and 

Quebec, it is likely to have spillover effects in Massachusetts.

Economy-wide GHG emissions reduced in 2020 5.1 million metric tons; 5.4%

Rationale: Canadian hydro resources are extensive and have low operating costs. The 

transmission lines necessary to bring more Canadian hydropower to load centers in southern New 

England do not have to be financed by ratepayers apart from the price of delivered electricity, 

which will be sold in the competitive market.

Policy design: This policy involves working with the Massachusetts utilities to help overcome 

any hurdles. 

GHG impact: The Northern Pass transmission line alone would provide 1,200 MW of clean 

electricity, enough to power nearly 1 million homes. This would result in up to 5 million tons of 

emissions reduction in the Commonwealth, depending on how much of the power is utilized in 

Massachusetts versus other states.

Other benefits: Like other electric sector policies, by incentivizing the reduced operation of 

fossil fuel plants, these additional low-emissions electricity imports would help reduce criteria and 

hazardous pollutants in the air (NOx, SO2, mercury, and fine particulate matter). These 

reductions will have public health and environmental benefits. In addition, additional hydro 

imports will significantly improve the region’s fuel diversity, improving energy security and price 

stability. 

Cost: There are no additional costs to this effort to ratepayers or taxpayers. The power is 

expected to be sold in the market. In fact, as a ―price-taker‖ in the market, it is possible that it 

would lower the wholesale electricity price and therefore reduce costs for business and residential 

 

42 www.northernpass.us/transmission_project_impact.pdf

Expanded Policy
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

46

consumers. According to Northeast Utilities, a comprehensive analysis by Charles River 

Associates (CRA) shows that, even with conservative assumptions, the Northern Pass line will 

reduce energy prices in the wholesale market, potentially saving New England customers $200 

million to $300 million in annual energy costs.

Experience in other states: Massachusetts and other Northeast states already have 

transmission lines to Canada and have imported hydro power for years. In fact, additional hydro 

power imports have been a significant contributor to a cleaner New England electricity grid in the 

last five years. 

Legal authority: DPU and DOER have already begun working with utilities and ISO-New 

England on increasing such imports. 

Uncertainty: Transmission lines involve federal, state and local permitting, and often raise 

siting concerns, with potential delays from legal action.
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

47

CLEAN ENERGY PERFORMANCE STANDARD (CPS)

Policy summary: From 2005 to 2009, the electricity portfolio serving Massachusetts became 

nearly 20 percent cleaner. The major changes came from substitution of natural gas for coal and 

oil, doubling of imports of hydro power from Canada into New England, and the up-rating — or 

increasing of capacity — of existing nuclear plants regionally. This demonstrated that mature 

technologies have made a significant contribution to a cleaner electricity grid, without the federal 

or state incentives required for developing earlier stage technologies. They have an important 

role to play moving forward. 

A market-based framework is needed to provide a clear signal to the electricity market to 

improve upon the cleaner energy portfolios of the last few years and to encourage projects such 

as the Northern Pass line (see ―Clean Energy Imports‖ above). One approach to be considered is 

a Clean Energy Performance Standard (CPS), which applies an output-based performance 

standard to either portfolios of retail electricity sellers or to generators in terms of tons of 

pollution per megawatt-hour of electricity. As the performance standard becomes more stringent 

over time, the electricity market uses the least-cost mechanism for meeting it. The existing RPS 

fits neatly into this framework as a technology-specific means of meeting the standard. 

Clean energy economy impacts: The CPS is a transparent and stable market-based 

framework that provides market certainty and enables investments to be made. It would 

encourage further replacement of power plant capital stock with cleaner technologies and cleaner 

fuels while disadvantaging dirtier power plants in the electricity marketplace. 

Rationale: By being performance-based rather than technology-based, the CPS allows the 

market to find the least-cost approach to achieving a cleaner energy portfolio. In addition, it 

could empower electricity suppliers to manage their portfolios, akin to the CAFE standard for 

vehicles, offering cleaner products to interested customers to help meet their portfolio targets.

Policy design: Design issues include setting the targets; creating tracking mechanisms, 

particularly for system power; allowing tradability among suppliers, and minimizing ―shuffling,‖ in 

which generators shift cleaner power to Massachusetts and dirtier power to other states. 

Resolving these and other design issues would require substantial consultation with the electricity 

industry.

GHG impact: The potential GHG impacts are substantial; however, they are completely 

dependent on the targets set and include the impacts from both the RPS and the clean energy 

imports. Therefore no additional GHG reductions from this potential policy were included in the 

overall estimates.

Other benefits: Like other electric sector policies, by providing incentives for the reduced 

operation of the dirtiest plants and greater operation of cleaner ones, a CPS reduces criteria and 

hazardous pollutant emissions (NOx, SO2, mercury, and fine particulate matter). These reductions 

will have public health and environmental benefits.

New Policy
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

48

Cost: In the near-term, a CPS is likely to have a limited impact on electricity prices for 

consumers. 43

Experience in other states: Generator-level performance standards for new generators have 

recently been considered or implemented in several states and countries. However, portfolio-level 

performance standards for retail sellers of electricity or tradable performance standards for 

existing plants are less common, but have been analyzed recently. California has been working 

on a preferred loading order meant to encourage dispatch of lower emissions resources. 

Legal authority: DOER and DPU will begin analysis of possible paths forward for creating a CPS, 

including regulatory or legislative avenues, as well as cost-benefit and implementation issues.

Uncertainty: The CPS ensures a cleaner energy portfolio over time. However, since it sets a 

limit on the carbon intensity of electricity generation, it does not constrain overall emissions. For 

example, if demand growth exceeded expectations, overall emissions would grow. Effective 

implementation of energy efficiency policies are a critical complement to mitigate this risk. 

 

43 Carolyn Fischer and Richard G. Newell, ―Environmental and Technology Policies for Climate Mitigation‖.

http://rff.org/rff/Documents/RFF-DP-04-05-REV.pdf
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

49

Tra n spor ta t ion

Transportation is second only to buildings in 

responsibility for GHG emissions in the state, 

and is a fast-growing emissions sector. The 

vast majority of emissions come from cars 

and trucks, although air travel is a rapidly 

rising emissions source. There are several 

means of addressing transportation 

emissions, all of which Massachusetts has 

been pursuing — improving vehicle 

efficiency, moderating the growth in auto 

travel through providing alternatives to it, 

and promoting the development and use of 

vehicle fuels that yield lower GHG emissions 

than petroleum-based fuels. The

Massachusetts Clean Energy and Climate 

Plan for 2020 takes into account state and 

federal measures to improve vehicle 

efficiency, reduce vehicle miles traveled, and 

increase use of lower-carbon fuels, and 

proposes additional measures that will 

contribute toward meeting the 2020 limit.

Improving Vehicle Efficiency

Improving vehicle efficiency has been 

primarily a federal government 

responsibility, implemented through 

Corporate Average Fuel Economy (CAFE) 

standards first put forth in 1975 by the 

National Highway Traffic and Safety 

Administration (NHTSA). These standards 

had been stagnant for many years, but were 

raised in the 2007 federal Energy 

Independence and Security Act. Under 

President Obama, the standards were raised 

sharply in 2010, from 27.5 miles per gallon 

currently to 35.5 MPG (in 2016), and for the 

first time NHTSA and the Environmental 

Protection Agency (EPA) issued joint 

regulations that will control both fuel 

efficiency and GHG emissions from cars and 

light trucks. 

During the period when federal CAFE 

standards were stagnant, the state of 

California passed its own law to regulate 

GHG emissions from light vehicles, under a 

longstanding waiver provision of the federal 

Clean Air Act. Massachusetts law requires 

adoption of California’s standards if they are 

stricter than the federal ones, and the 

Commonwealth did so in December 2005. 

These standards apply to model year 2009 

and newer vehicles. However, the federal 

government requires California to obtain a 

waiver of federal law in order to impose its 

own emission standards. In 2007 EPA denied 

California’s waiver request, although it was 

later approved under President Obama.

In October 2010, NHTSA and EPA announced 

that they would propose regulations to 

require improved efficiency and lower GHG 

emissions from medium- and heavy-duty 

vehicles, including delivery trucks, buses and 

semi trucks (tractor trailers). These will also 

yield substantial GHG reductions in 

Massachusetts. 

This Plan proposes a complementary 

measure to improve the overall efficiency of 

light-duty vehicles in Massachusetts: 

providing incentives to consumers to 

purchase more fuel-efficient vehicles. Such 

incentives would involve varying charges 

and/or rebates on vehicles according to their 

GHG emissions per mile (similar to fuel use 

per mile) — such as varying the sales tax on 

new cars, the annual vehicle excise tax, or 

registration fees. The variable charges could 

be designed to be revenue-neutral to 

consumers as a whole and to the state, with 

tax increases and decreases balancing each 

other.
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

50

Reducing Vehicle Miles Travelled (VMT)

Massachusetts has a number of programs to 

rein in the growth of driving, which is 

generally measured by vehicle miles traveled 

(VMT). Most of these programs have as their 

primary purposes improving mobility options 

for state residents by providing alternative 

methods of travel and reducing congestion 

on the roads, and reducing air pollutants that 

damage human health, such as nitrogen 

oxides, carbon monoxide, and particulates. 

Among these are support for public transit 

and for infrastructure that improves 

conditions for bicyclists and pedestrians. The 

state also operates programs that encourage 

ride-sharing among commuters, van pooling, 

and employer-based methods for reducing 

single-occupancy travel to work. 

The amount of driving is greatly influenced 

by patterns of new housing and business 

development in the state. The more spread 

out development is, the more driving people 

must do to get to work and school, to shop 

and participate in other activities. Although 

decisions on development are primarily up to 

local governments and the private sector, 

the state has several policies designed to 

influence them. The state has issued 

Sustainable Development Principles to guide 

state agency programs, as well as 

investment in land and infrastructure. The 

principles call for encouraging building 

homes ―near jobs, transit, and where 

services are available,‖ and encourage the 

creation of pedestrian-friendly 

neighborhoods — practices known as ―smart 

growth‖. Adherence to the principles is aided 

by the Commonwealth Capital program, 

under which about $600 million annually in 

grants and loans for municipalities is 

distributed in part on the basis of 

communities meeting sustainable 

development criteria. 

The Massachusetts Department of 

Transportation (MassDOT) took a major step 

forward in June, 2010 with its ―GreenDOT‖ 

policy directive, which commits MassDOT to 

―be a national leader in promoting 

sustainability in the transportation sector.‖ 

Among the three primary goals of GreenDOT 

is reducing GHG emissions, in part through 

implementation of the Global Warming 

Solutions Act.44 Critical to the specific efforts 

under GreenDOT is consideration of GHG 

impacts in statewide and regional 

transportation planning, and in the selection 

of particular projects that receive funding in 

the regional and statewide transportation 

plans.45 GreenDOT also specifies several 

other efforts (to be discussed later in this 

Plan), such as enhanced support for 

alternative modes of transportation and 

promotion of ―eco-driving‖ (fuel-saving auto 

maintenance and driving practices). GHG 

emissions from auto travel can also be 

reduced by enabling more efficient roadway 

operation through the use of intelligent 

transportation systems and mitigating 

―bottlenecks‖ that create local congestion, if 

such mitigation is designed so that it does 

not expand overall system capacity, facilitate 

increased auto travel, nor increase GHG 

emissions over time.

This Plan proposes several new policies to 

aid in the effort to limit miles traveled. First, 

an extension of policies to steer new 

development toward smart growth —

through a new law designed to improve local 

zoning, provide assistance to communities to 

help them develop zoning policies, and 

require that state infrastructure funding 

 

44 MassDOT Policy Directive on GreenDOT, Jeffrey B. 

Mullan, Secretary of Transportation, June 2, 2010. 

45 Although Green DOT is now an ―existing‖ state policy, 

it was released subsequent to completion of ERG’s 

February 2010 report on the impacts of the state’s 

current GHG reduction policies, and so was not included 

in those numerical estimates. Therefore in the present 

document the impacts of GreenDOT are treated as 

―new‖ policies. 
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

51

decisions take into account impacts on GHG 

emissions.

Second, the Plan proposes that the state 

implement a pilot program of ―Pay As You 

Drive‖ (PAYD) auto insurance, with the 

possibility of its expansion later. PAYD is an 

innovation that many studies have shown 

would significantly reduce miles driven,46 by 

converting a fixed annual cost into a cost 

that varies by the amount of driving. In 

addition, average insurance costs across all 

drivers would fall, as less driving also means 

fewer accidents, and there would be 

significant reductions in traffic congestion, 

particularly in urban areas. 

Reducing the Carbon Content of Vehicle 

Fuel

Emissions controls on cars have greatly cut 

emissions of health-damaging pollutants 

such as nitrogen dioxide. But such controls 

are unable to reduce carbon dioxide 

emissions from petroleum fuels, the primary 

GHG pollutant. As a result, to limit the GHG 

emissions from vehicle fuel, it is necessary to 

find alternatives to gasoline and petroleumbased diesel fuel, such as bio-diesel, ethanol,

natural gas, and electricity. 

In recent years, the actual GHG benefits of 

liquid biofuels made from food crops, such as 

corn-based ethanol and soy-based bio-diesel, 

have been questioned. When one examines 

the entire lifecycle of such fuels, including 

their impacts on food supplies and 

deforestation, it is unclear whether and to 

 

46 See, for example, ―Pay-As-You-Drive Auto Insurance: 

A Simple Way to Reduce Driving-Related Harms and 

Increase Equity,‖ Jason E. Bordoff and Pascal J. Noel, 

The Hamilton Project, The Brookings Institution, July, 

2008; Pay-As-You-Drive Auto Insurance In 

Massachusetts: A Risk Assessment And Report On 

Consumer, Industry And Environmental Benefits, MIT 

Professor Joseph Ferreira, Jr. & Eric Minikel 

Commissioned by Conservation Law Foundation & 

Environmental Insurance Agency, November 2010.

what degree GHG emissions are reduced 

compared to petroleum fuels. As a result, 

Massachusetts has concentrated its efforts 

on supporting non-food crop based or 

―advanced‖ biofuels, and has required that 

alternatives to petroleum demonstrate 

significant GHG benefits.

In 2008, Governor Patrick signed the Clean 

Energy Biofuels Act, which has several parts.

First, it exempts non-food crop based, or 

cellulosic, biofuel from the state’s gasoline 

tax. Second, it requires that initially 2 

percent of the diesel fuel and home heating 

fuel sold in the state consist of bio-diesel, 

rising to 5 percent in 2013. However, the 

bio-diesel must be shown to yield a 50 

percent reduction in GHG emissions 

compared to petroleum diesel. A lack of 

supply of such fuel, along with other 

obstacles to implementation, have caused 

the state to delay implementation of the 

content mandate. Third, the Act instructs the 

state to pursue development of a ―low 

carbon fuel standard‖ (LCFS) on a regional 

basis throughout the Northeast. The LCFS 

concept originated in California, where the 

legal target is to reduce the average carbon 

content of motor fuel 10 percent by 2020.

During the past two years Massachusetts has 

been leading an effort by the Northeast and 

Mid-Atlantic states to construct such a 

standard. A target for the Northeast/MidAtlantic LCFS has not been set. 

In addition, two federal laws are designed to 

bring more alternative fuels into the market. 

First, Title II of the federal Energy 

Independence and Security Act of 2007 

creates a ―renewable fuel standard,‖ which 

requires that such fuel used in the U.S. will 

rise from 4.7 billion gallons in 2007 to 36 

billion gallons in 2022. Of that, "advanced 

biofuel" must rise from 0.6 billion gallons in 

2009 to 21 billion gallons in 2022, and 

cellulosic biofuel must rise from 0.1 billion 

gallons in 2010 to 16 billion gallons in 2022. 

Renewable fuels must be produced from 
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

52

renewable biomass, replace other 

transportation fuel, and achieve at least a 20

percent reduction in GHG emissions on a 

lifecycle basis for "new facilities." (Existing 

facilities, such as those producing corn-based 

ethanol, and their expansion are exempt 

from the GHG criterion.) Advanced biofuel 

excludes ethanol derived from corn starch, 

and must yield at least a 50 percent lifecycle 

reduction in GHG emissions, while cellulosic 

biofuel must achieve a 60 percent reduction.

Second, the federal Energy Improvement 

and Extension Act of 2008 provides a $2,500 

tax credit for the first 250,000 light-duty 

plug-in hybrid electric vehicles sold until 

2015, requiring that each must have a 

battery capacity of at least 4 kW. The tax 

credit rises with battery capacity to a 

maximum of $7,500.

This Plan relies primarily on development of 

a regional Low Carbon Fuel Standard, along 

with the federal policies described above, to 

obtain reductions in the average carbon 

content of vehicle fuels; which constitutes 

one of the three main methods of reducing 

GHG emissions from transportation. 
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

53

FEDERAL AND CALIFORNIA VEHICLE EFFICIENCY AND GHG STANDARDS

Policy Summary: The EPA and the National Highway Traffic Safety Administration (NHTSA) 

have set harmonized standards for light-duty vehicle MPG and GHG emissions for model year 

2012 through 2016 vehicles. The standard is raised from 27.5 MPG at present to 35.5 MPG in 

2016. California has harmonized its standards with the federal standards through 2016, but is 

expected to propose stricter standards for model year 2017 to 2020 vehicles, and Massachusetts 

law requires the Commonwealth to adopt the California standards. In combination, the EPA and 

California standards are forecast to yield a 17 percent reduction in GHG emissions in 2020 

(primarily from lower gasoline consumption, but also with some reduced emissions from vehicle 

air conditioning systems). 

Economy-wide GHG emissions reduced in 2020 2.4 million metric 

tons; 2.6%

Cumulative net benefits discounted, 2012-lifetime of vehicles (fuel 

savings and other social benefits, less increased vehicle costs) $8.0 billion 

Jobs gained in 2020 (direct and indirect) 6,200 jobs

Note: benefits are calculated over the lifetimes of vehicles purchased from 2012 through 2020, which 

extend beyond 2020.

Clean energy economy impacts: The vast majority of spending on motor fuel goes out of 

state, so reducing those expenditures by billions of dollars means more money can be spent on 

in-state businesses, stimulating the economy and creating jobs. 

Rationale: Federal fuel economy (CAFE) standards were first enacted in 1975 but have been 

relatively stagnant since the 1980s. Federal law raised them in 2007, but the Obama 

administration proposed an accelerated schedule through 2016. Improving the fuel economy of 

vehicles is one of the most effective tools to reduce energy consumption and GHG emissions.

Design issues: The federal regulations continue the practice of having different standards for 

cars and light trucks, although two-wheel drive SUVs will be reclassified as cars. EPA/NHTSA 

project the fraction of vehicles sold in the two categories; average MPG and fuel savings could be 

lower than expected if a higher proportion of light trucks are sold. 

GHG impact: 2.4 million tons in 2020 for Massachusetts, based on EPA/NHTSA and California 

projections.

Other benefits: EPA’s benefit calculations include lower air pollution from vehicles, less time 

spent refueling, security benefits of lower petroleum imports, and the social value of lower carbon 

emissions. 

Costs: About $3.4 billion in additional vehicle costs through 2020, far outweighed by $11.4 

billion in reduced fuel costs (all in net present value). 

Equity issues: Both higher initial capital costs and subsequent fuel savings will accrue first to 

purchasers of new vehicles. Lower income drivers more commonly buy used vehicles, and will 

only be affected in later years as the new models are sold on the used car market. 

Existing Policy
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

54

Experience in other states: The federal regulations are required in all states. Massachusetts 

and a number of other states have adopted California’s stricter standards in the past, with no 

implementation problems. 

Legal authority: The federal government has authority over vehicle efficiency and air 

emissions. However, there is an exemption under the 1970 Clean Air Act for California to adopt 

standards stricter than EPA’s (if awarded a waiver by EPA) and for other states to adopt 

California’s standards.

Implementation issues: None.

Uncertainty: See discussion under ―design issues‖ concerning the distribution of sales between 

cars and light trucks. 
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

55

FEDERAL EMISSIONS AND FUEL EFFICIENCY STANDARDS FOR MEDIUM- AND 

HEAVY-DUTY VEHICLES

Policy summary: The EPA and the DOT have announced complementary programs to reduce 

GHG emissions and improve fuel efficiency, respectively, for medium- and heavy-duty vehicles, 

such as the largest pickup trucks and vans, combination tractors47, and all types and size of work 

trucks and buses in between, for model years 2014-2018. 

Economy-wide GHG emissions reduced in 2020 0.3 million metric tons; 0.3%

Motor fuel savings in 202048 $140 million per year

Cumulative net benefits (discounted) 2011-lifetime of vehicles $240 million

Jobs gained in 2020 (direct and indirect) 1,000 jobs

Clean energy economy impacts: Using commercially available technologies, a payback period 

of one to two years is estimated for the majority of vehicles. Vehicles with lower annual miles 

would have payback periods of four to five years. For example, an operator of a semi truck could 

pay for the technology upgrades in under a year, and have net savings up to $74,000 over the 

truck’s useful life.49 Large reductions in fuel use will improve air quality. Less spending on 

imported fuel will keep more money in the Massachusetts economy and thereby create jobs. 

Rationale: Transportation is projected to account for close to 40 percent of total GHG emissions 

in Massachusetts in 2020, and medium- and heavy-duty vehicles are projected to account for 13 

percent of transportation sector emissions. These vehicle standards will reduce fuel consumption 

and GHG emissions while providing regulatory certainty for manufacturers. 

GHG impact: 0.34 percent of statewide GHG emissions in 2020, based on a reduction of 6.4

percent in emissions from medium- and heavy-duty vehicles. 

Equity issues: The federal regulations are carefully designed to set efficiency standards that are 

appropriate and cost-effective for different sizes and types of vehicles. There are no significant 

predicted equity issues with the promulgation of this federal regulation.

Uncertainty: Current projections of the impact of these standards by the EPA and NHTSA may 

not turn out to be correct, in terms of fuel savings and costs and benefits, as the regulation is not 

final. In addition, if manufacturers cannot meet the standard and pay penalties instead, then GHG 

and fuel consumption targets will not be met.

 

47 Also known as semi trucks that typically pull trailers.

48 At $3.34/gallon gasoline, $3.51/gallon diesel, in 2008$. Energy Information Administration, Annual Energy Outlook 

2010.

49

―EPA and NHTSA Propose First-Ever Program to Reduce Greenhouse Gas Emissions and Improve Fuel Efficiency of 

Medium- and Heavy-Duty Vehicles: Regulatory Announcement,‖ Report No. EPA-420-F-10-901, October 2010.

New Policy
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

56

FEDERAL RENEWABLE FUEL STANDARD AND REGIONAL LOW CARBON FUEL 

STANDARD

Policy summary: Title II of the federal Energy Independence and Security Act of 2007 creates 

a ―renewable fuel standard,‖ which requires that the volume of renewable fuels used in the U.S. 

will rise from 4.7 billion gallons in 2007 to 36 billion gallons in 2022. In a similar fashion, 

Massachusetts’ biofuels law, passed in 2008, instructs the state to pursue development of a ―low 

carbon fuel standard‖ (LCFS) on a regional basis throughout the Northeast. The LCFS (first 

developed by California) would require that the average carbon intensity of vehicle fuels fall by a 

specific percentage compared to petroleum fuels.

Economy-wide GHG emissions reduced in 2020 1.5 million metric tons; 1.6%

Clean energy economy impacts: To the degree that imported petroleum used in 

Massachusetts can be replaced by feedstocks such as solid waste, forest residues, and other 

cellulosic material, money that would otherwise go overseas is retained in the regional economy. 

If advanced fuels (including electricity powering plug-in hybrid and all-electric vehicles) 

eventually become less expensive than petroleum fuels, consumer costs are expected to fall. 

There are significant economic development opportunities in growing feedstocks, converting 

those into fuel, and in research and development. The report of the Massachusetts Advanced 

Biofuels Task Force forecast that the sector could employ 2,500 people in the state by 2025. 

Rationale: The carbon intensity (or GHG emissions per unit of energy used) of fuel is one of the 

three main ways that emissions from motor vehicles can be reduced. In theory, if crops or other 

plants are used to produce fuel, the emissions from burning the fuel can be canceled out by the 

re-growth of plants on the same land absorbing equal amounts of carbon dioxide during its 

growth. Given the United States’ large supply of land and agricultural produce, this is a logical 

method of reducing the use of petroleum. In addition, if electric vehicles become prominent, they 

would reduce the carbon intensity of fuels, since electric motors are far more efficient at powering 

motor vehicles than are gasoline engines. 

Policy design and issues: Under the Federal RFS, supplies of "advanced biofuel" (including 

cellulosic) must rise from 0.6 billion gallons in 2009 to 21 billion gallons in 2022, and cellulosic 

biofuel by itself must rise to 16 billion gallons in 2022. Advanced biofuel excludes ethanol derived 

from corn starch, and must yield at least a 50 percent lifecycle reduction in GHG emissions, while 

cellulosic biofuel must achieve a 60 percent reduction. Renewable fuels that don’t qualify as 

advanced can constitute up to 15 billion out of the 36 billion total gallons of fuel; they must still 

be produced from renewable biomass, replace other transportation fuel, and achieve at least a 20

percent reduction in GHG emissions on a lifecycle basis for "new facilities." Existing facilities, and 

expansion of such facilities, such as those producing corn-based ethanol, are exempt from the 

GHG criterion, leaving some question as to how much of the non-advanced fuel will actually meet 

the 20 percent criterion. 

As required by the Biofuels Act, during the past two years Massachusetts has been leading an 

effort by the Northeast and Mid-Atlantic states to develop a Low Carbon Fuel Standard in the 

region. The LCFS concept originated in California, where regulations require a reduction in the 

Existing Policy
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

57

average carbon content of motor fuel of 10 percent by 2020. Targets and timelines for the 

Northeast/Mid-Atlantic LCFS are being developed. Unlike the RFS, the LCFS is a ―technology 

neutral‖ standard — rather than requiring specific volumes of different fuels, it allows fuel 

suppliers to choose any motor fuel in any quantity — including petroleum, biofuels, natural gas, 

electricity, and other possibilities. First, the average carbon intensity of each fuel is determined.

If the intensity of a particular fuel exceeds the annual target, then suppliers of this fuel have a 

―deficit‖ and must purchase credits from sellers of fuels that have a carbon intensity below the 

annual target. 

A major issue for the RFS and the LCFS is calculating the carbon intensity of different fuels. This 

requires examining the entire lifecycle of a fuel, including, for example, how electricity is 

generated and how crops are grown — calculations that are difficult to do with any degree of 

precision. Important numerically, and controversial, are the carbon impacts from what is known 

as ―indirect land use change‖ (ILUC). When large amounts of food crops are used for fuel (corn 

for ethanol, soybeans or rapeseed for biodiesel), this may cause the need for more food 

production. Forests may be cut down to expand the amount of land on which crops can be grown, 

causing reductions in the CO2 sequestered by trees and soil. The US EPA and the California Air 

Resources Board (CARB), along with the European Union and specific European countries, are 

currently calculating ILUC for each fuel, but each source has published different numbers. The 

Northeast and Mid-Atlantic states are examining which methodologies and figures are best to use, 

and these choices substantially affect how much ―credit‖ each fuel would receive under the LCFS.

There are a number of other design issues involved in constructing a regional LCFS for the 11 

states currently involved, and an interstate group of agency staff, along with an interstate agency

— the Northeast States for Coordinated Air Use Management (NESCAUM) — have been 

addressing design issues for the past two years. 

GHG impact: For purposes of this Plan, the LCFS is estimated conservatively to achieve a 5 

percent reduction in the average carbon content of vehicle fuel by 2020, with greater reductions 

in following years. The LCFS is more specifically focused on GHG reductions than the federal RFS. 

Without the LCFS, the RFS by itself might yield about a 3 percent reduction, depending on what 

reductions are actually achieved from corn-based ethanol produced throughout the U.S.

Other benefits: Possible reductions in other air pollutants, depending on which fuels are used in 

place of petroleum. 

Costs: NESCAUM is working on a regional economic analysis which will be available in early 

2011. This analysis will include estimates of cost and benefits to the region and to each state. 

Equity issues: Any price impacts from the RFS and LCFS will be spread across all drivers in 

proportion to the amount of fuel that they use. 

Experience in other states: California has adopted regulations for implementation of its LCFS, 

which goes into effect in 2011. 

Legal authority: Massachusetts’ biofuels law gives the state the authority to implement the 

LCFS. In other participating states, new regulations or legislation will be necessary, or both. 

Implementation issues: As with any interstate policy, achieving agreement on how to 

implement a uniform policy among a number of states presents many complexities. The 
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

58

interstate effort currently underway, led by Massachusetts and NESCAUM, is addressing these. 

For example, distribution infrastructure for new fuels and vehicles may be needed. This would 

require large capital investments (e.g., liquid fuel distribution for biofuels, charging stations for 

electricity, etc.) and it is unclear whether the incentive system created by the LCFS will be 

sufficient to draw out that investment. Nor is it clear whether the auto manufacturers will develop 

the vehicles needed to utilize the fuel, particularly in the case of plug-in hybrid and all-electric 

vehicles. Complementary policies may be necessary for all parts of the system to be developed in 

tandem. 

Uncertainty: As a technology-neutral policy, the LCFS is not picking between the several 

possibilities for alternatives to petroleum, and it is uncertain at this time which ones will succeed 

best in terms of eventual cost, and what that cost will be. 
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

59

CLEAN CAR CONSUMER INCENTIVES

Policy summary: There are various means by which the Commonwealth could provide incentives 

for consumers to shift their vehicle purchases to more fuel-efficient (or lower GHG) models. This 

includes varying the rates on new car sales taxes, annual auto excise (property) taxes, and 

registration fees, with rates raised on low-MPG vehicles and reduced on high-MPG ones. The 

change could be designed to be revenue-neutral to consumers as a whole and to the state. 

Economy-wide GHG emissions reduced in 2020 0.2 - 0.4 million metric tons; 0.2% - 0.5%

Motor fuel savings (at $3.34/gallon50) in 2020 $110 - $230 million

Cumulative net benefits (discounted) 2011-

2020 for higher end of annual benefits $570 million

Jobs gained in 2020 (direct and indirect) 1,700 jobs

Clean energy economy impacts: Large reductions in fuel costs for consumers, and less 

spending on imported fuel, which keeps more money in the Massachusetts economy and thereby 

creates jobs. For a tax or fee that varies with CO2 but is still a percentage of vehicle price or 

value, and is revenue neutral to the state, costs would fall for a majority of auto buyers or 

owners (possibly around 60 percent), because the most expensive vehicles also tend to get the 

worst MPG and these would bring in much greater revenues. 

Rationale: Transportation is expected to account for close to 40 percent of total GHG emissions 

in Massachusetts in 2020, and light vehicles by themselves (cars, SUVs, minivans, pickups) 

around 28 percent of the total. The efficiency of the vehicles themselves is probably the easiest 

factor to influence among the several that determine vehicle emissions (the others being miles 

traveled and carbon content of the fuel). Although the federal government preempts authority 

over setting efficiency standards for automakers, the state does have the ability to influence 

consumer choice through tax and fee policies. Given the state’s budget realities, a policy that 

combines incentives and disincentives can be accomplished without a loss of tax revenue. 

Design issues: The simplest design, which has been proposed in California and Europe, is a 

charge measured in cents per gram of carbon per mile driven, or cents per gallon per mile driven, 

varying linearly from a minimum to a maximum rate. This would provide the strongest incentive, 

but would not be tied to the price of the vehicle. A tax or fee that varied by carbon emissions but 

was a percentage of vehicle sales price or current value (for vehicle property taxes or registration 

fees) would concentrate the impact on buyers of more expensive vehicles, but would provide a 

weaker incentive to buy fuel-efficient vehicles. 

In addition, there could be rate variations designed to assist particular groups of drivers, such as 

those with large families who need vehicles with seating capacity for six or more, or contractors 

who need trucks for their businesses. 

The tax or fee design could be revenue-neutral to the state and to consumers as a whole, with 

reductions and increases in payments balancing out. The sales tax on motor vehicles in 

 

50 EIA forecast for 2020, in constant 2009 dollars.

New Policy
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

60

Massachusetts is currently 6.25 percent, as for all non-exempt products. Preliminary modeling by 

the state, with the rates varying from 0 percent to twice the current sales tax rate, found that 

expensive, low-MPG vehicles would yield a large tax revenue increase. In order to maintain 

revenue neutrality, the entire tax schedule would shift down, with the most efficient vehicles 

(hybrids) having a negative rate (receiving a rebate) while the top rate would be significantly 

below 12.5 percent.

GHG impact: For a variable sales tax, the impact would vary from around 0.2 million to 0.4 

million metric tons, due to an improvement of 1 percent to 2 percent in average vehicle fuel 

efficiency, as estimated by Cambridge Systematics, Inc. For a change to vehicle excise taxes or 

registration fees, the dollar amounts are lower and the impact would be lower. In the table 

above, the larger impact is from a straight fee on CO2 emitted per mile driven, that replaces the 

current sales tax, as has been proposed by California. The smaller impact is from a fee that 

varies according to CO2 emissions but is a percentage of vehicle purchase price. 

Other benefits: Fewer large, heavy vehicles on the road will reduce injury and death rates from 

accidents. Reduced fuel usage will cut emissions of other air pollutants that cause human health 

damage. 

Costs: Minimal costs to administer. The state would devise tax or fee rate schedules and provide 

these to auto dealers or the Registry of Motor Vehicles (RMV). Dealers already handle the sales 

tax through an electronic connection to the RMV. 

Equity issues: Lower-income households tend to buy used cars, whose sales tax rates will not 

change under this proposal. For new vehicles, size, weight and gas consumption are highly 

correlated with purchase price, so the tax increases will tend to be felt by higher-income 

purchasers, with buyers of smaller, cheaper cars seeing decreases in their sales taxes. Beyond 

the initial purchase price, virtually all drivers whose vehicle choice is modified by the incentive 

mechanism will see substantial savings in gasoline costs over time. 

Experience in other states: California has proposed a version of the sliding-scale sales tax, 

with the tax varying directly with CO2 emissions, in their climate planning process, and legislation 

is pending.

Legal authority: Legislation is required to change the tax rates. In some cases, fees such as 

registration fees can be changed by agencies without new legislation. EEA and MassDOT will 

conduct a study to examine critical implementation challenges and possible regulatory or 

legislative paths forward.

Implementation issues: Changes will be needed to the RMV’s computer systems. In order to 

maintain revenue neutrality, it will probably be necessary to adjust fees, rebates or tax rates over 

time. 

Uncertainty: The degree of consumer response to changes in taxes or fees is not precisely 

known, so the gains in reduced emissions and the exact tax revenues will only be seen with 

experience. 
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

61

PAY AS YOU DRIVE (PAYD) AUTO INSURANCE PILOT

Policy Summary: PAYD would convert a large fixed annual premium into a variable cost based 

on miles traveled, creating a major incentive to reduce discretionary driving, while cutting the 

overall cost of insurance due to fewer accidents. Miles driven would fall substantially, along with 

CO2 emissions and costs for gasoline, accidents, and congestion. The Commonwealth plans to 

conduct a PAYD pilot program initially, and, depending on results, consider working with the 

insurance industry to make this payment method more widely available in future years. Benefits 

from PAYD would depend on its degree of adoption by insurance companies and consumers.

Benefits from full-scale PAYD implementation

Economy-wide GHG emissions reduced 0.4 - 2.0 million metric 

tons; 0.4% - 2.1%

Motor fuel savings (at $3.34/gallon) in 2020 $160 - $830 million

Accident savings (medical costs, property damage, etc.) and 

reductions in insurance premiums in 2020 $160 - $800 million

Congestion savings (reduction in lost time) in 2020 $50 - $250 million

Total $ savings 2020 $370 - $1,880 million

$ savings per person in the state 2020 $60 - $290

Cumulative net benefits discounted 2011-2020 (for middle 

option) $5.3 billion

Jobs gained in 2020 (middle policy option, direct and indirect) 2,500 jobs

Note: The lower end of the benefits range is for a voluntary system, higher end is for a mandatory system 

with the entire insurance charge on a per-mile basis. A middle option, with a mandatory system that has a 

flat charge for the first 2,000 miles and a per-mile charge beyond that, would yield about 1.0 million tons 

GHG reduction in 2020, from a 5 percent reduction in vehicle miles traveled. 

Clean energy economy impacts: For a reduction of 5 percent in VMT (middle policy option), 

motor fuel spending would fall by $440 million at 2020 projected gas prices. Less spending on 

imported fuel will keep more money in the Massachusetts economy and thereby create jobs. A 

Brookings Institution study estimated that rates would fall for two-thirds of drivers, while rising 

for one-third. Benefits would accrue particularly to lower-income drivers, who need a vehicle for 

employment but can save money by controlling non-essential driving. Less congestion will 

improve quality of life. 

Rationale: Transportation is expected to account for close to 40 percent of total GHG emissions 

in Massachusetts in 2020, and light vehicles by themselves (cars, SUVs, minivans, pickups) 

around 28 percent of the total. One way to reduce emissions is by reducing VMT. At present, 

insurance premiums do not vary by VMT (though there is precedent in current discounts for low 

usage, such as 5,000 miles/year) and so they have little impact on people’s driving habits. If 

insurance were converted into a per-mile charge it would give drivers a new incentive to limit 

their driving when they can.

Design issues: Design of the program would depend upon the results of the pilot program. It is 

expected that the per-mile rate would not be uniform, but rather would vary by the traditional 

New Policy
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

62

rating factors, including location and driver experience. Thus, miles driven would only be one 

factor determining rates. For example, an inexperienced driver living in Boston would likely pay a 

per mile rate substantially higher than that of an experienced driver living in western 

Massachusetts. Because insurance companies set their rates by accident costs within a 

geographic area, PAYD would not favor urban residents over suburban or rural ones. PAYD would 

be ―revenue neutral‖ within a particular area, favoring low-mileage drivers over high-mileage 

ones. 

GHG impact: 0.4 percent to 2.1 percent of statewide GHG emissions in 2020, based on a 

reduction of 2 percent (for a voluntary system) to 9.5 percent (for a mandatory system with 

charges entirely by the mile) in vehicle miles traveled. A nationwide study by the Brookings 

Institution found that PAYD insurance would reduce VMT by 8 percent. 

Other benefits: Accidents, and the associated injuries, deaths, and monetary costs, would fall 

greatly, particularly in congested areas. In the middle policy option, there would be an estimated 

reduction in crashes of 11,000, 7,000 fewer injuries, and 36 fewer fatalities, yielding $420 million 

in total benefits, part of which would accrue to drivers in lower insurance rates. Congestion, and 

the lost time and money that result, would also fall significantly, particularly in urban areas. 

Cambridge Systematics, Inc. estimates that statewide congestion would be cut substantially. 

There would also be reductions in other air pollutants from motor vehicles, which will have health 

benefits.

Costs: On average, insurance costs would fall across all drivers. Costs would vary by driver, 

rising for high-mileage drivers who are unable to modify their driving habits. If mileage is 

monitored through annual safety inspections, as is done at present, there would be little 

additional cost for either drivers or the state. VMT could also be monitored through telematic 

devices in cars, which currently cost $100 to $200 per unit. These costs will probably fall as the 

devices become more common, and wouldn’t be needed for vehicles that already have GPS 

systems. A gradual transition could be made by requiring the devices for new cars, but allowing 

use of the safety inspection data for older cars. 

Equity issues: The MIT study for Massachusetts finds that accident costs are related to miles 

driven, and therefore having insurance rates tied to VMT improves fairness among drivers. 

Initially rates would increase for approximately one-third of drivers, but ultimately rates should 

decline for a higher fraction of all drivers due to reduced accident costs. Relative rates for 

different population groups — inexperienced drivers, adults, and senior citizens — would not 

change significantly, nor would relative rates between different areas of the state.

The most recent data available on vehicle miles traveled by income level is for 2001, and only at 

the national level.51 It shows that on average middle-income families drive about three-fourths as 

much as high-income families, and that low-income families drive about half as much as highincome ones. A Brookings Institution study found that, nationwide, lower-income households 

would generally save money due to PAYD while higher-income households would, on average, 

pay more, as shown in Figure 7 on page 63.

52

 

51 Table A2, U.S. Per Household Vehicle-Miles Traveled, Vehicle Fuel Consumption and Expenditures, 2001,‖ EIA.

52 Jason E. Bordoff and Pascal J. Noel Pay-As-You-Drive Auto Insurance: A Simple Way to Reduce Driving-Related Harms 

and Increase Equity, The Brookings Institution, July 2008.
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

63

Figure 7. Estimated Household Savings from PAYD, by Annual Household Income (source: Bordoff and 

Noel)

Experience in other states: PAYD does not exist as a mandatory system anywhere in the 

U. S., but several insurance companies have pilot programs, including Progressive Insurance

and GMAC. Pilots are also taking place in the United Kingdom. Several states are attempting to 

encourage PAYD, including Texas, California, and Oregon. The Federal Highway Administration 

is making available about $10 million for PAYD pilots in the next fiscal year. Fourteen states 

have PAYD in their climate action plans. Maryland forecasts that PAYD has the potential to 

reduce GHG emissions there by 1 million tons in 2015 and 4.3 million tons in 2020.53

Legal authority: The state’s Division of Insurance has authority over auto insurance rates. At 

present the Division can allow companies to offer PAYD but cannot require them to do so. 

Legislation would be needed to require companies to provide PAYD as an option, or to require 

them to put all policies on a per mile basis.

Implementation issues: If the state does not require insurance companies to offer PAYD, 

insurance companies are unlikely to do so, as has been the case in other states. If the policy is 

optional for drivers, only a fraction may choose it, greatly reducing the impacts on GHG emissions 

and savings for drivers. Monitoring VMT through annual inspections carries the risk of errors, and 

will significantly reduce the incentive mechanism, by giving drivers feedback only once per year. 

Use of a telematic device that can be used to bill drivers monthly for their insurance would be 

more effective in influencing driver behavior. Information on costs could also be provided on a 

real-time basis through an on-board device or through a web site look-up. Some drivers might 

have privacy concerns about their driving being monitored telematically, even if the information 

is limited to VMT. In addition, the Brookings study argues that the cost of the telematic devices 

exceeds the benefits to the companies, so that incentives may be needed in order to achieve the 

social benefits of lower pollution, accidents, and congestion.

Uncertainty: Projections of the impact of PAYD on driving may not be correct, with actual VMT 

reductions lower than expected. In addition, administrative costs could be higher than expected. 

 

53 Center for Climate Strategies, www.climatestrategies.us/, 11/12/10.
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

64

SUSTAINABLE DEVELOPMENT PRINCIPLES

Policy summary: In 2007, the Patrick-Murray Administration updated the Massachusetts

Sustainable Development Principles to guide creation and implementation of state agency policies 

and programs, as well as investments in land and infrastructure. Municipalities, through policies 

like Commonwealth Capital, are also encouraged to modify their planning, regulatory, and 

funding actions to achieve consistency with the principles. The principles include promoting clean 

energy, in the form of energy efficiency and renewable power generation, in order to reduce GHG 

emissions and consumption of fossil fuels. They also encourage reductions in vehicle miles 

traveled (VMT) through actions such as the creation of ―pedestrian-friendly‖ districts and 

neighborhoods that mix commercial, civic, cultural, educational, and recreational activities with 

parks and homes. In regard to housing, the principles call for building homes ―near jobs, transit, 

and available services.‖

State investments, particularly those in infrastructure, have an important influence on where and 

how growth occurs. The principles are intended to guide policies, programs, and expenditures, 

particularly those that affect where and how development occurs. Making state investments 

consistent with the principles increases the amount of growth that takes place in locations and 

densities that reduce VMT and GHG emissions and have other clean energy benefits.

Economy-wide GHG emissions reduced in 2020 (in 

conjunction with Commonwealth Capital and MEPA)

0.1 million metric 

tons; 0.1%

Clean energy economy impacts: Sustainable Development Principle #9 — Promote Clean 

Energy — explicitly encourages clean energy practices, aiding development of clean energy jobs 

and reduced energy costs. Also, Sustainable Development Principle #1 — Concentrate 

Development and Mix Use, along with Sustainable Development Principle #7 — Provide 

Transportation Choice, can enable significant transportation cost reductions for residents and 

business due to reduced vehicle ownership and fuel consumption. Finally, Principle #1 will help to 

increase building efficiency and make district energy and combined heat and power more 

feasible.

Rationale: The principles provide a value statement and basic guide that state and municipal 

employees, business interests, land owners, developers, conservation groups, and others can 

turn to when making choices about their actions and investments. State policies, such as 

Commonwealth Capital, have the principles as their foundation. These policies expand upon the 

principles and provide an incentive to implement them.

Policy design: Readily implemented, since legislation is not required and regulatory changes 

would be minimal. However, improving the consistency of a large number of programs with the 

principles will require Executive leadership, perseverance, and a willingness to overcome 

obstacles.

One example of a state program that has utilized the Sustainable Development Principles is the 

Commonwealth Capital Program. More than $600 million in grants and low interest loans are 

awarded annually based in part on Commonwealth Capital scoring. Municipal smart growth/smart 

energy consistency is assessed through a Commonwealth Capital application. Resulting scores are 

Existing Policy
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

65

part of the proposal evaluation process for each grant or loan program. The more smart 

growth/smart energy oriented a community is, the more likely it is to receive funding. Since 

2005, 315 out of 351 of the Commonwealth’s communities have applied at least once and 

hundreds of new plans and regulations have improved municipal consistency with the Sustainable 

Development Principles by 10 percent (the median score has risen from 63 to 76 out of a possible 

140).54

GHG impact: Existing smart growth policies, including the Sustainable Development Principles, 

are estimated to reduce GHG emissions by 0.1 percent in 2020. Recent studies3 have shown 

integrated land use strategies can produce GHG reductions of between 2.7 percent and 4.4 

percent from the baseline by 2050 depending on how aggressively the Commonwealth 

implements smart growth policies and practices.

Other benefits: Development consistent with the principles would lower operational and capital 

costs to government and society, improve energy conservation, better protect natural resources, 

increase housing and transportation choice, lower housing and transportation costs, improve 

public health, and enhance social and environmental justice.

Costs: There are predicted to be no incremental costs, as this policy simply requires more 

consistent decision making, particularly regarding the investment of current state resources in 

growth inducing infrastructure.

Equity issues: Smart growth increases affordability by reducing housing and transportation 

costs. It enhances access to jobs and services for those who can’t/don’t drive and provides a 

higher percentage of new jobs in urban areas where unemployment tends to be highest. Those 

who want to build commercial/industrial projects or live in homes in places and patterns that are 

inconsistent with the principles may pay more as these projects will no longer receive a state 

subsidy.

Experience in other states: Many states have successfully used sustainable development or 

smart growth principles to guide policies, programs, and investments.

Legal authority: The principles are presently implemented through an Executive Order. See 

Smart Growth Package for possible expanded scope of funding subject to principles and 

codification in legislation.

Implementation issues: Consistency of state policies, programs, and expenditures with the 

principles is not universal, and consistency is not always a prominent consideration in the 

decision making process.

Uncertainty: Calculating VMT and GHG benefits requires assumptions about how state policies, 

programs, and particularly spending will change to conform to the principles, as well as how 

dependent upon, or influenced by, state investments development is. Also, it is hard to predict 

how communities and developers will respond to incentives and other policies that encourage 

them to embrace the Sustainable Development Principles. 

 

54 See www.mass.gov/commcap for more information, including detailed analyses of past results and the 2011 

application.
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

66

GREENDOT

Policy summary: GreenDOT is the Massachusetts Department of Transportation’s sustainability 

initiative, announced through a Policy Directive in June 2010 by the Secretary of Transportation.

The Commonwealth’s consultants, Cambridge Systematics, Inc., estimated that, if fully 

implemented, GreenDOT could achieve 2.1 million tons of GHG reductions in 2020 and the 

Secretary’s Directive adopts this level as its target. 

GreenDOT is intended to fulfill the requirements of several state laws, regulations, Executive 

Orders, and MassDOT policies, including the Global Warming Solutions Act, the Green 

Communities Act, the Healthy Transportation Compact, and the ―Leading by Example‖ Executive 

Order Number 484 by Governor Patrick. MassDOT will work closely with DEP and the Advisory 

Group in determining the best regulatory and guidance framework for achieving the goals set 

forth in the Policy. GreenDOT is focused on three related goals: reduce GHG emissions; promote 

the healthy transportation modes of walking, bicycling, and public transit; and support for smart 

growth development. 

GreenDOT encompasses a number of different program areas, which are described briefly below: 

statewide and regional long-range transportation planning, transportation project prioritization 

and selection, ―complete streets‖ design guidelines, rail transportation, bicycle and pedestrian 

transportation, promotion of eco-driving, sustainable design and construction, system operations, 

facilities management, and travel demand management. 

Transportation long-range planning and project prioritization and selection: Long-range 

planning documents, including statewide planning documents (e.g. the Strategic Plan, State 

Freight Plan, and MassDOT Capital Investment Plan), as well as the long-range Regional 

Transportation Plans from the Metropolitan Planning Organizations (MPO), must address 

MassDOT’s three sustainability goals and plan for reducing GHG emissions over time. Similarly, 

the shorter-range regional and state Transportation Improvement Programs (TIPs and STIP), 

under which particular projects are chosen for funding in the coming four years, must be 

consistent with the Commonwealth’s GHG reduction target. This will require that the MPOs and 

MassDOT balance highway system expansion projects with other projects that support smart 

growth development and promote public transit, walking and bicycling. In addition, the project 

programming mix included in the RTPs, TIPs and STIP can contribute to GHG reduction through 

prioritizing roadway projects that enable improved system operational efficiency, without 

expanding overall roadway system capacity.

Over the long term, both long-range planning and project selection will affect where new 

development in the Commonwealth is located and how that development is spatially configured. 

These choices affect the degree to which future development represents ―smart growth,‖ or 

clustered development patterns that facilitate walking, bicycling, riding public transit and driving 

shorter distances, which would minimize the number of motor vehicle miles that people must 

travel in order to go about their lives. 

Project design and construction: The MassDOT Highway Division Project Development and 

Design Guide requires that all projects must adhere to a ―complete streets‖ design approach, 

meaning that new and redesigned roads must provide appropriate accommodation for all users, 

New Policy
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

67

including pedestrians, bicyclists, and public transit riders. These modes of transportation will also 

be promoted by several other means. These include taking steps to see that more projects move 

forward through the Transportation Enhancements Program, extending the Bay State Greenway,

improving accommodations for bicycles and pedestrians on bridges, and improving bicycle 

parking facilities at MBTA stations. 

Several efforts will continue to improve rail transportation in the state. The MBTA is striving to 

both improve service on existing subway and commuter rail lines and to develop new service, 

such as the Green Line Extension and the South Coast Rail Project. Other projects will improve 

long-distance rail service for both passengers and freight. 

MassDOT project design and construction will also reduce GHG impacts through such measures as 

the use of recycled content in paving materials, use of warm mix asphalt paving, implementation 

of stormwater remediation and use of best management practices, requirements for diesel engine 

retrofits for construction contractor vehicles, and other measures.

Travel demand management and travel information: MassDOT will continue to promote and 

deliver travel demand management (TDM) information and services, including ride-matching, 

traveler information, real-time bus tracking, and other measures for the general public and 

among MassDOT employees. MassDOT is currently working to implement a new ridematching/trip planning system to facilitate carpooling, vanpooling, and mode shifting from 

automobile travel. 

Eco-driving: Fuel efficiency can be improved greatly by maintaining vehicles properly, driving 

within the speed limit, and accelerating more gently. The EPA estimates that ―smart driving‖ can 

improve fuel efficiency by up to 33 percent, and EcoDriving USA estimates that Massachusetts’ 

drivers, with 5.4 million registered autos, could save about 4 million tons of CO2 emissions 

annually if eco-driving practices were followed. MassDOT will promote eco-driving through: 

internal education for staff and contractors; external education of all Commonwealth drivers 

through website content, RMV manual and testing content, signage, and brochures; and 

development of a plan to improve tire inflation infrastructure.

System Operations: MassDOT, along with the MBTA and other regional transit authorities, will 

take a variety of steps to minimize fuel use and GHG emissions from vehicles and facilities. This 

includes retrofitting diesel buses with emission control devices, truck stop electrification, using 

solar and wind power at MassDOT facilities and rights-of-way, improving energy efficiency in 

MassDOT facilities, and increasing the share of low-emission transit vehicles in the MBTA fleet. 

MassDOT will also facilitate more efficient roadway system operations; improvements that can 

reduce GHG emissions by reducing congestion and time spent idling in traffic. MassDOT will do 

this through the effective management of roadway capacity, using intelligent transportation 

systems - which may include such measures as real-time traveler information and management 

of traffic flow through improved traffic signal operations - ramp metering, and variable speed 

limits. MassDOT will also continue to address roadway system ―bottlenecks,‖ or points of localized 

capacity constraints, improvements that can reduce GHG emissions when traffic flow is improved 

without expanding overall system capacity.
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

68

SMART GROWTH POLICY PACKAGE

Policy summary: Development patterns significantly influence vehicle miles traveled (VMT), 

which could be substantially reduced by additional ―smart growth‖ that makes it easier for 

households and businesses to decrease the number and distance of vehicle trips. Diffuse single 

use development accessed by car results in 30 percent55 more VMT than compact mixed-use 

growth. Massachusetts already has several policies promoting smart growth, but new, 

complementary policies are necessary to achieve our smart growth targets. Such policies would 

focus on influencing infrastructure investments by state agencies and planning decisions made by 

local governments.

Economy-wide GHG emissions reduced in 2020 0.4 million metric tons; 0.4%

Motor fuel cost savings in 2020 $190 million

Jobs gained in 2020 (direct and indirect) 1,100 jobs

Clean energy economy impacts: Large transportation cost reductions can be expected for 

residents and business due to reduced vehicle ownership and fuel consumption. High density 

mixed-used development will increase building efficiency and make district energy and combined

heat and power more feasible. 

Rationale: Development of forests and open spaces increases GHG emissions in two ways: lost 

sequestration capacity and released carbon that had been stored in standing trees, and increased 

VMT due to sprawl. The Patrick-Murray Administration’s historic commitment to land conservation 

has permanently protected over 72,000 acres from development, preserving one of our most 

valuable carbon sinks, and this initiative will continue into the future. Meanwhile, better land use 

patterns will be important for reducing or eliminating projected VMT increases and realizing GHG 

reductions from the transportation sector, which is expected to account for close to 40 percent of 

total GHG emissions in Massachusetts in 2020, with light vehicles (cars, SUVs, minivans, pickups) 

accounting for about 28 percent of the total. The Plan assumes that aggressive implementation of 

current land use policies can result in a 0.4 million metric tons of GHG reduction in 2020, based 

on getting 80 percent of new residential development to occur in mixed-use areas that are bike 

and pedestrian friendly and higher than typical density. Strict adherence to and continued 

enhancement of current policies, along with the implementation of new policies and programs will 

be necessary to realize the 2020 and 2050 GHG targets.

Design issues: Existing state policies include (a) GreenDOT — which prioritizes transportation 

projects that preserve the existing system, support denser ―smart growth‖ development, and 

promote increased ridership, walking, and biking; (b) the MassWorks Infrastructure Program, 

that provides a one-stop shop for infrastructure funds via six separate programs, and promotes 

consistency with other state initiatives such as smart growth, Chapter 40R, and the 43D 

Expedited Permitting Program; and (c) the South Coast Rail Executive Order, which supports the 

South Coast Rail Economic Development and Land Use Plan by ensuring that agencies review 

 

55 See: Growing Cooler: The Evidence on Urban Development and Climate Change.

Expanded Policy
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

69

their policies, actions and investments to support and implement plan recommendations including 

priority development and preservation areas. Complementary policies are needed in order to 

achieve the 80 percent smart growth target. These are:

1. Reform state planning, subdivision, and zoning statutes — Pass the Land Use Partnership Act 

or similar legislation that provides municipalities a better framework for planning and zoning, 

enhanced tools to plan for and manage growth, and incentive to reduce VMT and GHG 

emissions through better development.

2. Provide technical assistance and undertake a smart growth promotional campaign — Expand 

efforts to help establish zoning and other land use regulations that reduce VMT. Provide direct 

technical assistance by state employees, tools such as model zoning, and grants to hire 

professional assistance. Also, use public appearances, the media, etc., to promote smart 

growth by pointing out its many benefits.

3. Require state infrastructure spending to include smart growth development in the criteria for 

funding decisions — State investments, particularly those in infrastructure and buildings, 

influence where and how growth occurs. Enhanced use of these investments to promote 

mixed-use, high-density development is critical to attainment of targeted VMT reductions 

resulting from better land use. This could be accomplished either via Executive Order or 

through legislation that codifies the Sustainable Development Principles and requires all 

agencies permitting, building, or funding infrastructure projects to take into account a set of 

smart growth criteria.

4. Significantly increase incentives to municipalities to plan and zone for development that 

reduces VMT — Much as the Green Communities Program has succeeded in persuading many 

communities to adopt desired practices - including the Stretch Code - strengthening existing 

incentives and offering new ones can persuade communities to use their regulatory authority 

in ways that reduce VMT. Enhance existing incentives such as Chapter 40R, Commonwealth 

Capital, and the Growth District Initiative, and implement new ones such as ―Municipal 

Challenge Grants‖ that recognize the GHG benefits of development practices that preserve 

forest cover. Grants could be awarded to communities that institute an open space zoning 

bylaw that protects 50 percent of a parcel as forest, limits lot clearance to one-third acre per 

house, and requires best management practices for lot layout and tree preservation.

GHG impact: Existing policies will reduce GHG emissions by 0.23 percent in 202056 and 

recommended enhancements will realize additional reductions. Recent studies57 have shown 

integrated land use strategies can produce GHG reductions of between 2.7 percent and 4.4 

percent from the baseline by 2050, depending on how aggressively the Commonwealth 

implements smart growth policies and practices.

Equity issues: Smart growth increases affordability by reducing the amount households spend 

on both housing and transportation. It further reduces housing costs by increasing the variety of 

housing types available and decreasing the amount of land and infrastructure needed per housing 

unit, and enhances access to jobs and services for the young and infirmed, as well as those 

without a car. Finally, smart growth provides a higher percentage of new jobs in urban areas 

where unemployment tends to be highest.

 

56 See: Eastern Research Group: Final Report to the Climate Protection and Green Economy Advisory Committee.

57 See: Moving Cooler: An Analysis of Transportation Strategies for Reducing Greenhouse Gas Emissions
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

70

Other benefits: Smart growth is as much as 70 percent cheaper for governments than the 

same amount of sprawl. It simply costs less to provide infrastructure (streets, schools, sewers, 

etc.) and services (like police and fire protection) to denser, more contiguous households than to 

far-flung, low-density communities.58 Studies found that New Jersey and Rhode Island would 

save $1.3 and $1.5 billion, respectively, over 20 years.59 It enhances public health by reducing 

air pollution and increasing physical activity, and enhances quality of life by improving 

neighborhoods, reducing travels times, and lowering costs. This, in turn, enhances economic 

competitiveness by appealing to prospective employees. Finally, it reduces development of open 

space, including forested land that sequesters carbon.

Costs: Existing and proposed smart growth policies have little cost as they rely almost entirely 

on enhanced use of existing funding. For example, state transportation funds should be shifted 

toward investments in support of desired development, without increasing the amount expended.

Similarly, the financial incentives anticipate the use of existing state funding sources rather than 

creation of new ones. Modest additional funds are needed for technical assistance to 

municipalities and other entities to implement better zoning and other land use practices. 

Experience in other states: Delaware, Maryland, New Jersey, New York, Rhode Island, and 

others have implemented smart growth programs that have improved growth patterns and 

thereby reduced VMT.

Legal authority: Legislation is needed to reform state planning, zoning and subdivision statutes 

and to codify and require agencies to implement the Sustainable Development Principles. The 

Commonwealth may also need to permit certain funding programs to implement municipal 

incentives and to authorize additional funding for incentives and technical assistance.

Implementation issues: It will be important achieve high levels of cooperation from all 

stakeholders, including development interests and local communities.

Uncertainty: Projected VMT and GHG reductions are taken from national level analyses and are 

not Massachusetts-specific. While state investments in infrastructure and buildings will help to 

steer growth to desirable locations and forms, developers can still finance their own projects and 

build in ways that result in excessive VMT. In addition, it is hard to project how many 

communities will take advantage of state incentives and whether growth will occur in these 

communities rather than others zoned for sprawl.

 

58 http://www.brookings.edu/opinions/2003/0413metropolitanpolicy_katz.aspx?p=1

59 See: Impact Assessment of the New Jersey State Development and Redevelopment Plan.
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

71

Non-E nergy 

Em is s ion s

Greenhouse gas emissions from activites not 

related to energy use represent a small but 

important part of statewide GHG emissions.

Although these sources currently represent 

only 7 percent of total emissions, many of 

the gases emitted by these processes have a 

high global warming potential (GWP), 

thousands of times greater than CO2.

Furthermore, projections of future emissions, 

including the Commonwealth’s 2020 BAU

scenario, show steady growth in industrial 

emissions while emissions from most energyrelated sectors — transportation excepted —

are projected to level off or even decline.

Specific industrial processes that emit 

significant quantities of GHGs in 

Massachusetts include: leakage of 

refrigerant chemicals from commercial 

equipment and motor vehicle air 

conditioners, leakage of SF6 from electric 

power transmission and distribution, and 

combustion of plastics in solid waste 

incinerators. The measures proposed in this 

section of the Massachusetts Clean Energy 

and Climate Plan for 2020 address these 

sources of GHG emissions. 

Reducing Leaks and Finding Substitutes 

for High GWP gases used in Refrigeration 

and Air Conditioning Units

The Montreal Protocol, which was designed 

to protect the ozone layer, has led to the 

substitution of ozone depleting substances

with non-ozone depleters —

hydrofluorocarbons (HFCs) and 

perfluorocarbons (PFCs) — in a range of 

applications including: insulating foams, 

refrigeration and air-conditioning, fire 

suppression, solvent cleaning, and 

propellants used in aerosols. Unfortunately, 

HFCs and PFCs are very potent GHGs. EPA 

has determined that the use of these 

chemicals comprises the most significant 

portion of non-energy related industrial 

emissions. This Plan will address emissions 

from the use of these chemicals in light duty 

motor vehicle air conditioning and 

commercial and industrial refrigeration.

For motor vehicle air conditioning, 

Massachusetts will adopt the California Air 

Resources Board (CARB) emissions 

standards for new motor vehicles (see 

Transportation). These standards will apply 

to model year 2017 vehicles and beyond, 

and include measures to both reduce leaks of 

high GWP gases and require use of lower 

GWP refrigerants. These measures are 

estimated to remove 0.27 MMTCO2e in 2020.

For refrigerants in stationary commercial and 

industrial equipment, the focus will be on 

reducing leaks from, and finding 

replacements for non-residential refrigeration 

equipment with units containing at least 50 

pounds of refrigerant. It will build on EPA’s 

voluntary program for grocery stores — in 

which many Massachusetts stores currently 

participate. CARB’s November 2010 

regulation phasing in leak detection and 

repair requirements will serve as a model for 

this program. The largest of these sources 

will report their emissions under 

Massachusetts GHG reporting rule and EPA’s 

November 2010 mandatory reporting rule.

The total impact estimated for this program 

is up to 1.18 MMTCO2e in 2020.

Reducing Leaks and Finding Substitutes 

for High GWP Gases Used in Electricity 

Distribution and Transmission
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

72

This policy will reduce emissions of sulfur 

hexafluoride (SF6) gas from leakage where it 

is used to insulate switchgear in electricity 

transmission and distribution systems. It will 

build upon EPA’s current voluntary program 

for SF6 reduction and could ultimately include 

enforceable limits on leakage rates as well as 

best management practices. CARB has 

proposed a similar program. The impact of 

this policy is up to 0.15 MMTCO2e reduction 

by 2020.

Reducing Emissions from Disposal of 

Plastic Waste 

Emissions associated with the combustion of 

plastics that remain in our solid waste 

streams can be minimized by greater 

diversion of plastics to recycling. Plastic 

recycling is already a priority in the 

Commonwealth and results in other 

environmental benefits, including the 

reduction of toxics in the environment and 

the growth of green jobs. This policy, 

implemented through the Massachusetts 

Solid Waste Master Plan, will aim to minimize 

the volume of plastic going to disposal in the 

Commonwealth, and instead divert these 

materials to recycling. Plastic diversion 

programs that include increasing assistance 

to cities and towns, increasing producer 

responsibility, and building markets for 

recycled materials are estimated to reduce 

GHG emissions by 0.3 MMTCO2e by 2020.
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

73

REDUCING GHG EMISSIONS FROM MOTOR VEHICLE AIR CONDITIONING

Policy summary: The California Air Resources Board (CARB) is developing regulations to reduce 

emissions associated with motor vehicle air conditioning (MVAC).60 Massachusetts General Law61

mandates that the Massachusetts Department of Environmental Protection (MassDEP) adopt 

CARB’s emission standards for new motor vehicles if they are more stringent than federal 

standards. CARB’s standard aims to minimize emissions of high GWP refrigerants from MVAC 

through the adoption of standards for new light-duty vehicles. These standards include measures 

to reduce direct GHG emissions from MVAC systems, such as by using low GWP refrigerants and 

reducing leaks, as well as measures to reduce indirect emissions of other pollutants through 

improvement in the efficiency of the AC system (e.g., more efficient compressors, fans and 

motors; systems that avoid over-chilling and reheating; and technologies to reduce heat gain in 

the passenger cabin). 

Annual benefits from improved motor vehicle air conditioning

Economy-wide GHG emissions reduced 2020 0.3 million metric tons CO2e; 0.3%

Net cumulative $ savings statewide 2018-202062 $50 - $130 million

Net annual $ savings per vehicle $40 - $90

Clean energy economy impacts: Several of the measures aimed at reducing refrigerant 

leakage and making MVAC more efficient also have a positive impact on fuel economy and can be 

expected to reduce fuel costs for owners. Vehicle owners who pay less for fuel will have more 

money to spend on other purchases — producing a positive ripple effect on the economy as a 

whole, including the creation of in-state jobs. Reducing leakage may also reduce the frequency 

with which vehicles need to be serviced for refrigerant recharge.

Rationale: Transportation is expected to account for close to 40 percent of total GHG emissions 

in Massachusetts in 2020, and light vehicles by themselves (cars, SUVs, minivans, pickups) are 

around 28 percent of the total. MVAC emissions account for about 9 percent of GHG emissions 

from cars and light trucks. Air conditioning use is estimated to account for approximately 5.5 

percent to 5.9 percent of vehicle fuel use in the US (although this figure is lower in 

Massachusetts).

Design issues: CARB is developing draft regulations. After the California rules are finalized and 

approved by EPA, MassDEP would adopt the CARB regulations if they are more stringent than 

federal standards.

GHG Impact: 0.27 million metric ton reduction in CO2e in 2020. The policy applies to new 

vehicles starting with model year 2017. Since the policy addresses emissions from new motor 

vehicles, benefits will grow progressively as older vehicles are replaced in the active vehicle stock 

 

60 http://www.arb.ca.gov/cc/hfc-mac/mvac-gwp/mvac-gwp.htm

61 http://www.malegislature.gov/Laws/GeneralLaws/PartI/TitleXVI/Chapter111/Section142K

62 Derived from California cost estimates, given in year 2000 dollars.

New Policy
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

74

(average of 10 years), with greater benefits after 2020 once the fleet has been fully replaced with 

compliant vehicles.

Other benefits: Between 2018 and 2020, the policy is estimated to save vehicle owners $50 

million to $130 million statewide, or $40 to $90 per vehicle per year. In addition, there will be 

reductions in tailpipe emissions of non-GHG pollutants due to reduced fuel combustion, which will 

benefit public health.

Costs: Estimated annual per-vehicle costs and savings from MVAC policy (2000$).

Item Values in 2020

Alternative refrigerant $30 - $80

Improved system (leak tightness and efficiency) $50

Gross incremental cost ($/year/vehicle) $80 - $130

Annual fuel and refrigerant savings $170

Net annual savings $40 - $90

Equity issues: Incremental savings from the policy are expected to be distributed over all 

classes of vehicles. However, initially the higher upfront vehicle purchase costs will affect higher 

income drivers more, since lower income drivers tend to buy used cars. But lower income drivers 

will enjoy the savings only after compliant vehicles become available in the used car market. 

Experience in other states: Fourteen jurisdictions use CARB’s auto emission standards, 

including Maine, Vermont, Massachusetts, Rhode Island, Connecticut, New York, New Jersey, 

Pennsylvania, Maryland, Oregon, Washington, Arizona, Washington, D.C., and Bernalillo County, 

New Mexico.

Legal authority: Massachusetts General Law Chapter 111, Section 142K mandates that 

MassDEP adopt and implement CARB emission standards for new motor vehicles if such standards 

are more stringent than federal standards.

Implementation issues: Because light-duty vehicle efficiency standards for 2011 through 2020 

(CAFE and California’s vehicle GHG standards, both accounted for in existing policies) allow 

manufacturers to meet the standards partly through voluntarily reducing MVAC emissions, this 

policy discounted the benefits from MVAC emissions reductions. But manufacturers could choose 

to voluntarily implement even greater MVAC reductions under CAFE than assumed here, which 

would result in lower combined benefits of the efficiency and MVAC policies.

The policy calls for measures — in particular the switch to substitute refrigerants — that are still 

in development. While there are strong incentives to develop and refine the necessary 

technologies to meet existing requirements (e.g., EU regulations, other CA regulations), there is 

still a risk that estimated reductions may not be achievable.

Uncertainty: At least one study has highlighted the risk that more stringent emissions 

standards in selected states may reduce scrapping of used non-compliant cars and/or may result 

in car manufacturers achieving reductions in adopting states while potentially allowing for larger 

emissions and less efficient vehicles in other states. If so, these dynamics could reduce the 

effectiveness of the policy in achieving the projected emissions reductions in the short run.
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

75

STATIONARY EQUIPMENT REFRIGERANT MANAGEMENT

Policy summary: This policy aims to minimize emissions of high Global Warming Potential 

refrigerants used in stationary non-residential equipment through: 

facility registration, leak detection and monitoring, leak repair, system retrofit and retirement, 

required service practices, and recordkeeping and reporting; and 

eventual replacement of non-residential refrigeration equipment at the end of its life by 

equipment using no-GWP or lower GWP substances, where such alternatives are available and 

practicable.

The policy would affect facilities with refrigeration units containing at least 50 pounds of 

refrigerant, beginning with a voluntary pilot program focused on leak detection and repair.

Economy-wide GHG emissions reduced 2020 1.2 million metric tons CO2e; 1.3%

Net annual $ savings statewide $1.6 million

Cumulative $ savings statewide 2012-2020, discounted63 $14 million

Clean energy economy impacts: Additional jobs in companies that engage in refrigeration 

system leak detection and repair. Cost savings to affected facilities from lower use of chemicals 

to refill systems. 

Rationale: Common refrigerants include several types of hydrofluorocarbons (HFC). These 

chemicals have global warming potentials up to 12,000 times more potent than CO2. Emissions 

from this source category have been growing steadily since the 1990s, in part due to the 

replacement with HFC of ozone depleting refrigerants targeted under the Montreal Protocol.

Design issues: California Air Resources Board (CARB) finalized a regulation64 effective 

November 19, 2010, phasing in requirements for a leak detection and repair program for 

refrigeration units containing a charge of 50 pounds of refrigerant or greater. Massachusetts 

could implement a voluntary program that transitions into utilization of California’s regulations as 

a model. Most of the businesses involved have been subject to similar EPA regulation on ozonedepleting chemicals used in refrigeration.

GHG impact: 1.2 million metric ton reduction in CO2e in 2020.

Implementation issues: Implementing a program to reduce refrigerant emissions requires 

development of an inventory of facilities using large quantities of refrigerants. The number of 

facilities can be estimated from the Economic Census 2007,65 a profile of U.S. businesses 

conducted every five years by the US Census Bureau. In addition, MassDEP will receive 2010 

refrigerant emission data from large emitters by April 15, 2011, under the mandatory 

 

63 In 2008 dollars, discounted at a 5 percent rate from current year.

64 http://www.arb.ca.gov/regact/2009/gwprmp09/gwprmp09.htm

65 http://www.census.gov/econ/census07/, U.S. Census Bureau reporting 1,305 supermarkets and other groceries; 34 

warehouse clubs and supercenters; 29 refrigerated warehousing and storage facilities; 523 cold product merchant 

wholesalers; and 153 cold manufacturing facilities in Massachusetts.

New Policy
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

76

Massachusetts GHG emissions reporting program. MassDEP has already established relationships 

with larger supermarket store chains through efforts to encourage composting of food waste and 

reduce use of disposable shopping bags.

A number of Massachusetts grocery stores participate in EPA’s voluntary ―GreenChill Advanced 

Refrigeration Partnership,‖66 including Hannaford Bros., Price Chopper, Shaw’s Supermarkets, and 

Whole Foods. In September 2009, a Star Market in Chestnut Hill became the first U.S. store 

certified at the Platinum level under EPA’s GreenChill Store Certification program, while a Whole 

Foods store in Dedham received Silver certification in August 2009.67

On November 8, 2010, EPA signed final regulation 40 CFR 98 ―Mandatory Reporting of 

Greenhouse Gases,‖ Subpart L ―Fluorinated Gas Production‖ and Subpart Q ―Importers and 

Exporters of Fluorinated GHGs Inside Pre-charged Equipment or Closed-cell Foams,‖68 which 

require manufacturers and importers of substances including high GWP refrigerants to report 

GHG emissions, beginning with 2011 emissions reported by March 31, 2012.

Costs: Costs incurred by regulated entities pertaining to leak detection and repair can be divided 

into technology costs (equipment upgrades to automatic leak detection), operation and 

maintenance costs (leak detection, inspection, repair, annual program fee), and recordkeeping 

costs (data management and reporting). CARB’s analysis of a similar policy indicates 2020 

compliance costs ranging from $14 per facility with systems containing 50 to 200 pounds of 

refrigerant, $30 per facility with systems containing up to 2,000 pounds, and savings of $8,700 

per facility with systems containing 2,000 pounds or more (net savings for larger facilities, due to 

economies of scale in reducing leakage).

CARB estimated savings of $2 per metric ton CO2e in the year 2020 after the proposed regulation 

is fully implemented. This estimate may understate the actual net savings, since it does not 

account for rising refrigerant prices, energy savings due to optimized system operation, or 

benefits from mitigated climate impacts. Based on the number of facilities estimated to be 

affected by the policy (about 2,000) and an estimated distribution of the facilities by size, the 

policy is estimated to provide net savings of $1.6 million per year statewide. 

Legal authority: MassDEP has authority to promulgate a regulation under Massachusetts 

General Law Chapter 111, Section 142 to create an enforceable refrigerants control program to 

prevent air pollution.

Uncertainty: Technical risks associated with leak detection and repair are expected to be 

relatively small. The practices promoted by the policy are already established. Implementation 

risks relate to the number and diversity of facilities that may be affected by the policy, which 

could complicate compliance assistance, verification, and enforcement. The effectiveness of the 

policy depends on facility owners actually implementing the practices called for in the policy, 

which may in turn depend on ensuring that technicians are trained and aware of the requirement.

 

66 http://www.epa.gov/ozone/partnerships/greenchill/

67 http://www.epa.gov/ozone/partnerships/greenchill/certcenter.html

68 http://www.epa.gov/climatechange/emissions/subpart/dd.html
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

77

REDUCING SF6 EMISSIONS FROM GAS-INSULATED SWITCHGEAR

Policy summary: Through a pilot program, followed by possible regulatory action, this policy 

aims to minimize emissions of sulfur hexafluoride (SF6) from leakage of gas insulated switchgear 

(GIS) used in electricity transmission and distribution systems by setting limits on leakage rates 

(declining to 1 percent leakage allowed in 2020) and implementing best management practices 

for the recovery and handling of SF6.

Economy-wide GHG emissions reduced 2020 0.2 million metric tons CO2e; 0.2%

Net cumulative $ costs statewide 2011-2020 (2008 $’s)69 $0.9 - $1.5 million

Clean energy economy impacts: There would be an expected increase in in-state employment 

for companies engaged in SF6 leak detection and repair and potential for technological innovation, 

company formation, and jobs in solid-state (non-gas insulated) switch gear. 

Rationale: SF6 is a GHG that is 23,900 times more potent than CO2 and has an atmospheric life 

of 3,200 years. One pound of SF6 has the same global warming impact as 11 tons of CO2. 

Approximately 80 percent of SF6 consumption and emissions are estimated to result from the 

leakage and handling losses from GIS. Mitigation options for this equipment focus on reducing 

leakage and handling losses. Best practices include SF6 leak detection and repair, and recovery 

and recycling.

Design issues: California Air Resources Board (CARB) has proposed a regulation70 requiring GIS 

owners to reduce SF6 emissions from electrical equipment throughout California 1 percent per 

year over a 10-year period. The initial allowed annual emission rate would be set at 10 percent of 

the total amount of SF6 that could leak; with the allowed annual rate declining to 1 percent in 

2020. Massachusetts could use CARB’s regulations as a model.

A number of Massachusetts utilities participate in EPA’s voluntary ―SF6 Emission Reduction 

Partnership for Electric Power Systems,‖71 including: National Grid, NSTAR, and Western 

Massachusetts Electric Company. EPA does not publish any state- or utility-specific data from its 

voluntary program. On November 8, 2010, EPA signed final regulation 40 CFR 98 ―Mandatory 

Reporting of Greenhouse Gases,‖ Subpart DD ―Use of electric transmission and distribution 

equipment,‖72 which requires reporting emissions from GIS, beginning with 2011 emissions 

reported by March 31, 2012.

As part of its development of a SF6 emissions reduction program, CARB distributed a survey73

requesting information from stakeholders on SF6 emissions from the electricity sector ―to 

 

69 In 2008 dollars, not discounted.

70 http://www.arb.ca.gov/regact/2010/sf6elec/sf6elec.htm

71 http://www.epa.gov/electricpower-sf6/

72 http://www.epa.gov/climatechange/emissions/subpart/dd.html

73 http://www.arb.ca.gov/cc/sf6elec/survey/sf6survey.doc

New Policy
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

78

determine SF6 GHG emission reduction potential and to assist ARB staff in developing appropriate 

control strategies.‖ After consideration of any 2010 SF6 emission data MassDEP receives by April 

15, 2011 as part of the first mandatory Massachusetts SF6 emission data reporting, MassDEP 

could consider whether a survey similar to CARB’s would provide useful information for designing 

a regulation. 

GHG impact: 0.15 million metric ton reduction in CO2e in 2020.

Costs: According to CARB’s analysis of a similar policy, the expense of compliance ranges from 

savings of $1/metric ton CO2e (in the case of SF6 recycling) to a cost of $55/metric ton CO2e (in 

the case of GIS repair and replacement), depending on the measure necessary to meet the 

emission limits in any given year. Entities are assumed to use the cheapest methods first and 

progressively move to more expensive methods to achieve further reductions. Some entities may 

not incur a cost for reducing SF6 emissions for some or all years to 2020, if their leak rates fall 

below a year’s allowed limit. CARB estimates the cost effectiveness of the policy at about $18 per 

metric ton CO2e reduced in the later years of the policy when the allowed leakage rate has 

declined to 1 percent. Similar cost effectiveness may be achieved in Massachusetts if the baseline 

practices and electric infrastructure profiles are comparable.

Equity issues: Full implementation of this policy may impose additional compliance costs on 

utilities, which could be passed on to customers — although that additional cost would be 

miniscule. CARB’s analysis of the proposed regulation estimated the incremental cost that could 

be passed on to electricity ratepayers at $0.000016 to $0.000025 per kilowatt-hour as a result of 

the policy. This represents an increase of less than 0.02 percent relative to average residential 

electricity rates in Massachusetts, or about 1.5 cents for the average monthly residential 

electricity bill.

Legal authority: MassDEP would need to promulgate a regulation to create an enforceable SF6

control program. MassDEP presently has the authority to regulate such air pollutants under 

Massachusetts General Law Chapter 111, Section 142; and it’s authority over GHG emissions is 

amplified by the Global Warming Solutions Act.

Implementation issues and uncertainty: The policy promotes greater implementation of 

current industry best practices that are generally low-cost. The maximum emission rate set in 

California by CARB for the early years is already being achieved by Massachusetts utilities that 

have taken voluntary measures to reduce their emissions. Achieving the 1 percent limit in later 

years may require the use of relatively more expensive measures but these measures already 

exist.
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

79

REDUCING GHG EMISSIONS FROM PLASTICS

Policy summary: Solid waste is generated by residences and businesses across Massachusetts. 

Diverting high-carbon-content materials, such as plastics, from the waste stream can reduce 

emissions released after materials are discarded, and for some part of the waste stream, 

incinerated. These diverted materials can then be recycled into other products. Diverting plastics 

from the waste stream under this Plan will result in materials with a lower carbon content being 

combusted at Massachusetts municipal waste–to-energy facilities, reducing emissions of CO2. 

Looking only at in-state emissions reductions, MassDEP conservatively estimates the reduction 

potential from diverting a portion of plastics from solid waste disposal in 2020 at 0.3 million 

metric tons of CO2e per year.

Economy-wide GHG emissions reduced 2020 0.30 million metric tons CO2e; 0.3%

Annual $ savings statewide in 2020 $8 to $11 million

Cumulative $ savings statewide 2009-202074 $69 to $92 million

Clean energy economy impacts: Recycling yields greater local employment than does waste 

combustion. Currently, industries associated with recycling support 14,000 jobs in Massachusetts, 

and increased recycling of plastics would spur growth. 

Rationale: The Commonwealth periodically prepares a Solid Waste Master Plan in accordance 

with Massachusetts General Law Chapter 16 Section 21. The solid waste sector includes sources 

of GHG emissions, such as landfills and municipal waste combustors, and plastics constitute a 

significant portion of the emissions. As detailed in a press release75 that accompanied release of 

the most recent Draft Solid Waste Master Plan, ―...The main objectives of the draft master plan 

include maximizing recycling, improving the environmental performance of solid waste facilities 

and developing integrated solid waste management systems. The draft master plan calls for a 

dramatic increase in residential, business and institutional recycling and composting, with an 

emphasis on paper and organics recycling...‖.

GHG impact: 0.3 million metric ton reduction in CO2e in 2020.

Costs: According to the Draft Solid Waste Master Plan: ―Diverting material from disposal, 

whether through upfront waste reduction, reuse, recycling or composting, can save significant 

disposal costs. Current disposal fees in Massachusetts typically range from $60 to $80 per ton. If 

we are able to achieve our goal of reducing disposal by 2 million tons per year by 2020, that 

would result in annual avoided disposal costs of $120-$160 million. Plastics diversion alone 

constitutes some $8 million to $11 million of the total $120 million to $160 million in annual 

avoided disposal costs.

Implementation issues: Public hearings have been held on the Commonwealth's Draft 2010-

2020 Solid Waste Master Plan: A Pathway to Zero Waste.

76 All public comments have been 

received and are being reviewed.

 

74 Based only on reduced disposal costs.

75 http://www.mass.gov/dep/public/press/0710swmp.htm

76 http://www.mass.gov/dep/recycle/priorities/dswmpu01.htm#swmp

Expanded Policy
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

80

Cros s-c u t t ing 

Po l i c ie s

Introduction

Several policies do not fit neatly into the 

categories of buildings, electricity supply, 

transportation or non-energy emissions.

These are state actions that drive clean 

energy adoption across all of these domains.

The Massachusetts Environmental Policy Act 

(MEPA) Office, which conducts the 

environmental review process for all large 

development projects, requires proponents 

to assess the environmental impact of a 

project and analyze alternatives in an effort 

to avoid, minimize and mitigate damage.

This necessarily includes the buildings, 

energy supply, and transportation impacts of 

a project. The state’s Leading By Example 

program, established by Governor Patrick, 

requires state agencies to reduce energy 

costs and lower emissions in state buildings, 

in vehicle fleets, and through green 

procurement. The Green Communities 

Division of DOER works closely with 

municipalities to help cities and towns lower 

their energy costs and adopt energy efficient 

technologies, add renewables to their energy 

mix, and make their fleets more fuel 

efficient. Though not, for the purposes of the

Massachusetts Clean Energy and Climate 

Plan for 2020, discrete policies with their 

own measurable impacts on GHG emissions, 

they contribute to (and their impacts are 

accounted for within) numerous other

initiatives contained in this Plan. 

Finally, the Global Warming Solutions Act 

itself requires all state agencies, 

departments, boards, commissions and 

authorities to consider climate change 

impacts, such as GHG emissions, when they 

issue permits, licenses and other 

administrative approvals. 
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

81

MEPA GHG POLICY AND PROTOCOL

Policy summary: MEPA requires that all major projects proposed in the Commonwealth that 

have state involvement (in the form of state permits, land transfers or financial assistance, for 

example) undertake an assessment of project impacts and alternatives in an effort to avoid, 

minimize and mitigate damage to the environment to the maximum extent feasible. Building on 

this general requirement, the MEPA GHG Policy requires that certain projects undergoing review 

by the MEPA office quantify their GHG emissions and identify measures to avoid, minimize, and 

mitigate such emissions. In addition to quantifying project-related GHG emissions, the MEPA GHG 

Policy also requires proponents to evaluate project alternatives that may result in lower GHG 

emissions and to quantify the impact of proposed mitigation in terms of emissions and energy 

savings. The MEPA GHG Policy is primarily applied to commercial and residential real estate 

development projects, but also applies to industrial and energy generation projects.

Clean energy economy impacts: By requiring project proponents to evaluate all feasible 

measures to reduce their GHG emissions, such as energy efficiency upgrades, fuel switching, 

incorporation of renewable energy measures and reduction of vehicle miles traveled, the MEPA 

GHG Policy supports the development of industries and jobs to supply these technologies. In 

addition, the avoided fuel and electricity use due to enhanced efficiency of projects cuts the longterm operational costs of the projects.

Rationale: The principal purpose of the MEPA GHG Policy is to require project proponents to 

undertake a thorough analysis of a proposed project’s primary sources of GHG emissions at an 

early stage of project planning and to examine all feasible alternatives that may have lower GHG 

emissions potential. By conducting this early-stage impacts and alternatives analysis, project 

proponents can integrate directly into project planning sustainable design considerations that will 

allow the project to achieve GHG emissions reductions in the most economical manner. 

Policy design and issues: For the majority of projects subject to the MEPA GHG Policy, the 

Policy requires comparison of emissions associated with the proposed project design to the 

emissions that would result from construction of an identical building code-compliant project. In 

this way, the MEPA GHG Policy is closely related to issues surrounding the adoption of Advanced 

Building Energy Codes and other energy efficiency improvements for buildings. Similarly, where 

the MEPA GHG Policy encourages adoption of renewable energy components, it is closely related 

to issues involved in the implementation of incentives for generating renewable energy. The 

MEPA GHG Policy also aims to reduce vehicle miles traveled in coordination with other state 

policies.

GHG impact: To date, more than 90 projects have been at least partially reviewed in

accordance with the MEPA GHG policy, and 32 projects have completed MEPA review with a 

finding that their GHG analysis adequately complied with the MEPA GHG Policy. Projects that have 

completed review have achieved an average reduction of 19.5 percent in stationary-source GHGs 

below an equivalent code-compliant project. Mobile source GHG reductions have ranged from 

zero to 25 percent, with an average of 5.8 percent. In total, the MEPA GHG Policy has resulted in 

commitments to reduce GHG emissions by over 70,000 tons per year to date. However, it is likely 

that a portion of these reductions, and many of the potential future reductions under the MEPA 

Expanded Policy
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

82

Policy, may be duplicative of the reductions achieved by other state policies designed to increase 

efficiency, encourage renewable energy generation, and reduce vehicle miles traveled. 

Costs: The upfront costs of incorporating GHG reduction measures will vary widely depending 

upon the project. Because the MEPA GHG Policy does not mandate a specified level of reductions, 

but rather asks project proponents to adopt ―feasible‖ measures, measures that are considered 

infeasible from a cost perspective are eliminated from consideration.

Experience in other states: The MEPA GHG Policy is a nation-leading policy. Other states, 

including California and New York, have adopted similar policies, and the White House Council on 

Environmental Quality, which oversees implementation of the National Environmental Policy Act 

(NEPA) by federal agencies, has also released a draft policy concerning consideration of GHG 

emissions as part of the NEPA review of individual projects.

Legal authority: The Global Warming Solutions Act specifically amended the MEPA statute to 

provide that:

In considering and issuing permits, licenses and other administrative approvals and decisions, the 

respective agency, department, board, commission or authority shall also consider reasonably 

foreseeable climate change impacts, including additional GHG emissions, and effects, such as 

predicted sea level rise. See M.G.L. c. 30, §61.

Therefore, implementation of the MEPA GHG Policy is mandatory under the MEPA statute.

Implementation issues: The MEPA GHG Policy has become a routine part of the environmental 

impact review process. For real estate development projects, the assessment and review of a 

project’s GHG analysis has become generally accepted by the regulated industry and the public.
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

83

LEADING BY EXAMPLE 

Policy summary: The Leading by Example (LBE) Program, established in April 2007 by Governor 

Patrick’s Executive Order (EO) No. 484, works to lower costs and reduce environmental impacts 

at all Executive Branch agencies, as well as the 29 public institutions of higher education and 

several quasi-public authorities. The program oversees efforts to reduce energy use at the state’s 

70 million square feet of buildings and fuel use among the thousands of light and heavy duty 

vehicles, expand recycling programs, reduce water consumption, promote environmentally 

preferable purchasing, facilitate the construction of high performance state buildings, and reduce 

carbon emissions across state government. EO 484 sets the following targets for state 

government: 25 percent reduction from a 2002 baseline in GHG emissions by 2012, 40 percent 

by 2020, and 80 percent by 2050; 20 percent reduction from a 2004 baseline in energy use 

intensity by 2012 and 35 percent by 2020; and an increase in consumption of renewable 

electricity to 15 percent of total electric use by 2012 and 30 percent by 2020. The EO also 

established a ―Massachusetts LEED Plus‖ building standard for new construction and major 

renovation projects that requires all state government projects to achieve LEED certification and 

perform 20 percent better than the Massachusetts energy code. 

The LBE Program is overseen by EEA and Administration and Finance, working collaboratively 

with state agencies such as the DOER (clean energy policies and project implementation), 

Division of Capital Asset Management (construction and energy projects) and Operational 

Services Division (procurement) to track state government energy use and GHG emissions, 

oversee the funding and implementation of dozens of clean energy projects annually, and provide 

technical assistance and training for dozens of agencies and hundreds of staff each year. 

Despite the advances made by the LBE program, there is currently no single entity charged with 

managing and procuring low-cost, clean energy across all public agencies, authorities, and 

facilities. The Administration has proposed and will continue to work toward the development of a 

Common-wealth Energy Solutions program, which will end the separate decision-making by 

multiple agencies and provide an opportunity for a comprehensive, integrated strategy from 

procurement (taking advantage of economies of scale) to continuous monitoring and 

management of energy performance.

Clean energy economy impacts: Leading by Example efforts that include broad and comprehensive energy efficiency projects, as well as small and large-scale renewable project installations, will continue to create significant numbers of clean energy jobs in the construction and retrofit markets. Additionally, these efforts will result in a stabilization and potential reduction of 

state government energy costs, and will continue to reduce the amount of foreign oil used in 

public buildings. 

Rationale: With approximately 70 million square feet of buildings, state government operations 

result in significant amounts of fuel consumption annually, including approximately 900 million 

kWh of electricity, 50 million therms of natural gas, 15 million gallons of fuel oil and more than

million gallons of diesel fuel and gasoline. This consumption results in over 800,000 tons of GHG

emissions and expenditures exceeding $220 million. Given this large impact, there is clearly a 

huge opportunity to reduce energy usage and associated carbon emissions. Such efforts will also 

demonstrate to other institutions and the private sector that large-scale energy reduction and 

renewable energy efforts are both feasible and fiscally desirable.

Expanded Policy
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

84

Design issues: Although significant clean energy programs are underway at state facilities, efforts to sustain such programs at the current scale once federal stimulus dollars are no longer 

present are needed. Also, efforts to streamline and simplify bidding and construction timelines 

have taken place, but more work will most likely be needed to ensure that projects are undertaken and completed in a timely fashion. 

GHG impact: GHG emission impacts are directly related to energy reduction and renewable 

energy efforts at state facilities. If the 2012 targets in EO 484 are met, this would result in a 

reduction of approximately 200,000 metric tons of GHGs. 

Other benefits: Additional benefits include reduced energy costs for Massachusetts taxpayers. 

The installation of new equipment also minimizes facility maintenance costs and needs, and 

improves comfort for the thousands of employees, residents, and visitors who work or live in, or 

visit, state facilities. LBE projects also provide important piloting for new technologies and system 

management initiatives that could be adopted by other institutions and cities and town, as well as 

the private sector. 

Costs: Although exact costs are unknown, it is anticipated that over $200 million worth of clean 

energy projects will be implemented by 2012. Project costs will, for the most part, be funded 

through the Massachusetts Clean Energy Investment Program (CEIP), a newly developed 

program that is designed to provide low-rate bond financing paid for out of project savings. This 

program results in a positive cash flow early in the project and overall simple paybacks of between 10 and 20 years. Additional financing through 2012 and thereafter will be targeted through 

3rd party financing, forward capacity market payments, Renewable Energy Credits, utility 

incentives, and, where available, renewable energy rebates. 

Equity issues: There are no known equity issues.

Experience in other states: Many other states have undertaken ―leading by example‖ efforts, 

including California, Colorado, Illinois, Indiana, New York, North California, Pennsylvania, and 

Utah. Success has varied, but all efforts recognize the impact to the state budget of reducing 

energy costs, as well as how such efforts are critical to the success of statewide clean energy 

goals, where applicable. 

Legal authority: EO 484 provides the legal authority to those entities overseen by the Governor. 

Other independent entities, such as the MWRA, MassPort, and the Massachusetts Convention 

Center Authority, frequently participate on a voluntary basis in the LBE Program and undertake 

similar efforts, but they are not subject to the specific targets in the order. 

Implementation issues: Successful implementation is dependent upon state resources, 

including financial and staffing. LBE staff will continue to work with key agencies, in particular the 

Division of Capital Asset Management and Executive Office for Administration and Finance, to ensure that such resources are available.

Uncertainty: Given the success of past efforts, current use of federal ARRA funding, and the 

ongoing collaboration between key agencies, it is likely that a significant number of clean energy 

projects will be initiated and completed over the next several years. However, meeting the energy 

and GHG emission reduction targets will depend on the extent to which energy reductions are 

sufficient to overcome new construction and expansion of services — particularly at the public 

institutions of higher education, which have seen a significant increase in enrollment and hours of 

operation. Additionally, ensuring that adequate funding exists to implement large-scale projects is 

critical to meeting the targets. 
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

85

GREEN COMMUNITIES DIVISION

Policy summary: Created by the Green Communities Act of 2008, the Green Communities 

Division of the DOER is intended to help municipalities become more sustainable, control rising 

energy costs, and incubate the clean energy technologies and practices that will put 

Massachusetts cities and towns — and the Commonwealth as a whole — at the center of the 21st 

century clean energy economy. Envisioned as a way to encourage municipalities to make greener 

energy decisions, the Division is mandated to offer grant and loan opportunities to municipalities 

in order to be designated as ―Green Communities.‖ 

Clean energy economy impacts: The five required criteria to be designated a Green 

Community help municipal governments to reduce their own energy costs, and those of local 

residents and businesses; and help to achieve siting of wind, solar, and other renewable energy 

installations. 

Rationale: Municipal governments are substantial consumers of fossil-fuel energy, primarily for 

buildings and secondarily from vehicles. The Energy Reduction Plan along with the Fuel Efficient 

Vehicle Policy required for designation as a Green Community results in municipalities reducing 

their energy consumption from municipal operations by a minimum of 20 percent. Through 

zoning they can have a major impact on the ability of renewable energy facilities to find suitable 

locations. And by deciding to adopt the ―stretch‖ energy code (see Buildings) — another 

requirement for Green Communities designation — they significantly improve the energy 

efficiency of new construction and major renovations. 

Policy design and issues: The Division provides technical assistance to communities to help 

them qualify for Green Community designation and state grants. To become Green Communities, 

municipalities must meet five criteria: 

Adopt a local zoning bylaw or ordinance that allows "as-of-right-siting" of renewable and/or 

alternative energy R&D facilities, manufacturing facilities or generation units;

Adopt an expedited permitting process related to the as-of-right facilities;

Establish a municipal energy use baseline and establishing a program designed to reduce use 

by 20 percent within five years;

Purchase only fuel-efficient vehicles for municipal use, whenever such vehicles are 

commercially available and practicable; and

Require all new residential construction over 3,000 square feet and all new commercial and 

industrial real estate construction to reduce lifecycle energy costs (such as adoption the 

Stretch Code).

The Green Communities Act allows funding of up to $10 million per year for the designation and 

grant program from the proceeds of Regional Greenhouse Gas Initiative (RGGI) allowance 

auctions and other sources. The Green Communities Division also serves all Massachusetts cities 

and towns as a one-stop shop for energy efficiency and renewable energy opportunities, helping 

them understand all the state programs at their disposal and providing streamlined delivery of 

those programs. 

Existing Policy
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

86

To achieve the goal of serving all 351 cities and towns in Massachusetts, the Green Communities 

Division offers a number of programs and services in addition to its signature Green Communities 

Grant Program. Other services include an energy assessment program in collaboration with the 

investor-owned utilities, technical assistance with energy savings performance contracting, 

stimulus grant programs and support, an online energy information system for tracking energy 

consumption and making decisions about how to reduce consumption, webinars and guidance 

documents and tools, a website and listserv for disseminating information and four Regional 

Coordinators to provide direct support to cities and towns.

GHG impact: GHG emissions are directly related to energy reduction and renewable energy 

efforts in municipalities. The first 35 Green Communities committed to reducing their energy 

consumption by 822,000 MMBTUs in five years. The newest 18 committed to a reduction of 

592,000 MMBTUs over five years.

Other benefits: Additional benefits include reduced energy costs and a lower burden on 

Massachusetts taxpayers. Projects funded through the Green Communities Division can pilot new 

technologies and system management. In addition, the work done by municipalities to become 

designated as a Green Community requires buy-in of its residents, with meeting many of the 

criteria requiring a Town Meeting vote. This has resulted in a major grassroots movement to 

educate the larger citizenry on the benefits of reducing energy consumption and creating clean, 

renewable energy projects.

Costs: Up to $10 million per year, funded through the proceeds of Regional Greenhouse Gas 

Initiative (RGGI) emissions allowance auctions (see Electricity) and other sources.

Equity issues: There are no known equity issues. Grants are based on a $125,000 base for 

each designated Green Community, plus additional amounts tied to per capita income and 

population, and for municipalities that provide as-of-right siting for renewable energy generation.

There are 53 designated communities from the Berkshires to Cape Cod, ranging in population 

from 990 to 621,000 residents.

Experience in other states: We are aware of no similar programs in other states. The Green 

Communities Division is believed to be the first of its kind in the nation.

Legal authority: The Green Communities Act of 2008 created the Division and the designation 

and grant program and authorized funding for it. The Board of Building Regulation and Standards 

approved the Stretch Code as an option for municipalities to adopt. 

Implementation issues: As of December 2010, 53 communities had attained designation as 

Green Communities, thereby qualifying for funding from the Division. In addition, as of December 

2010, 64 cities and towns had passed the Stretch Code. 

Uncertainty: The Green Communities Division and Grant program are new and have created 

considerable excitement among Massachusetts cities and towns. It will be important in going 

forward to continue engaging municipalities in a manner that maintains that excitement. In 

addition, proceeds from the RGGI auctions, the main source of funding for the Division, are 

difficult to predict.
Massachusetts Clean Energy and Climate Plan for 2020

II. An Integrated Portfolio of Policies

87

CONSIDERATION OF GHG EMISSIONS IN STATE PERMITTING, LICENSING &

ADMINISTRATIVE APPROVALS

Policy Summary and Rationale: Section 7 of the Global Warming Solutions Act states, ―In 

considering and issuing permits, licenses and other administrative approvals and decisions, the 

respective agency, department, board, commission or authority shall also consider reasonably 

foreseeable climate change impacts, including additional GHG emissions...‖ in the context of 

environmental review. The body of landmark energy legislation that has been passed in the last 

four years established new expectations for how we manage energy, plan transportation, build 

our buildings, and generate and distribute electricity. The official approvals by state agencies, 

departments, boards, commissions and authorities often have implications for clean energy 

adoption and GHG emissions. EEA, in collaboration with other state and quasi-public agencies, 

will develop a plan to implement this requirement in selected agency actions.

New Policy
Massachusetts Clean Energy and Climate Plan for 2020

III. Implementing the Global Warming Solutions Act

88

III. Implementing the Global Warming 

Solutions Act 

Se t t ing t he 2 0 2 0 

L im i t

Section 4. (a) The secretary shall adopt the 

2020 statewide GHG emissions...which shall 

be between 10 per cent and 25 per cent 

below the 1990 emissions level ... (Global 

Warming Solutions Act of 2008; M.G.L. 

Chapter 21N) 

Setting the statewide GHG emissions limit for 

2020 was based on two years of analysis and 

public comment, and followed a process set 

forth in the Act.

In March 2009, the Executive Office of 

Energy and Environmental Affairs (EEA) 

established the Climate Protection and Green 

Economy Advisory Committee to provide 

input on the 2020 limit and measures to 

reduce GHG emissions in accordance with 

the Global Warming Solutions Act (GWSA).

As required by the GWSA, the Advisory 

Committee included members representing 

the following sectors: commercial, industrial 

and manufacturing; transportation; lowincome consumers; energy generation and 

distribution; environmental protection; 

energy efficiency and renewable energy; 

local government; and academic institutions. 

Advisory committee meetings were held 

throughout 2009 and 2010 and 

subcommittees were set up to examine 

technical aspects of possible policies.

In parallel and integrated with the activities 

of the Advisory Committee, EEA convened a 

technical working group consisting of staff 

from EEA, the Department of Environmental 

Protection (MassDEP), the DOER, the 

Department of Transportation (MassDOT), 

and the Executive Office of Housing and 

Economic Development (EOHED). This team 

spearheaded the technical analysis.

Overseen by this state agency technical 

working group, most of the analytical work 

was undertaken by a team of consultants, 

led by Eastern Research Group (ERG) and 

including several other firms with extensive 

expertise in specific sectors — Cambridge 

Systematics, Inc. on transportation, Synapse 

Energy Economics on electricity supply and 

energy use in buildings, and Abt Associates 

on the non-energy emissions sources. A 

variety of specialized models and data 

sources were used by the consultants for the 

various sector analyses. All the supporting 

data was then entered into the LEAP (longrange energy alternatives planning) model of 

Stockholm Environment Institute–U.S., 

another member of our consulting team. 

LEAP provides a convenient and 

sophisticated tool for integrating all the 

sectors and for running various policy 

scenarios. It was used both for the 2020 

analysis and for development of hypothetical 

scenarios to reach the long-range 2050 

reduction mandate. Finally, additional 

analysis of scenarios for shifting the motor 

vehicle fleet to lower-carbon alternatives to 

petroleum fuel was conducted by Ventana 

Associates, using system dynamics 

modeling.

The first step in the analysis was to 

determine what Massachusetts 1990 

emissions level was and what the predicted 

―Business as Usual‖ (BAU) emissions 

trajectory to 2020 would be. MassDEP issued 

its Statewide Greenhouse Gas Emissions 

Level: 1990 Baseline and 2020 BAU
Massachusetts Clean Energy and Climate Plan for 2020

III. Implementing the Global Warming Solutions Act

89

Projection77 on July 1, 2009. The primary 

finding of this report was that, despite yearto-year variation, the trend line of GHG 

emissions has been relatively stable since 

1990 and is predicted to remain relatively 

stable through 2020. Even though there has 

been robust economic growth in 

Massachusetts since 1990, GHG emissions 

have remained stable because the fuel mix in 

electricity generation shifted toward natural 

gas (which is less carbon-intensive than coal 

or oil), the Massachusetts economy shifted 

toward services, and the limited energy 

efficiency programs in place during that 

period moderated growth in energy use. The 

BAU estimate for 2020 is essentially a 

straight-line extrapolation of the 1990-2008 

stable trend. This approach was chosen 

because the 1990-2008 period included both 

recessions and economic booms, and the 

underlying trends of that period are likely to 

continue, whereas attempts to create a more 

dynamic model of GHG trends in the future 

would unavoidably involve making a wide 

range of untested assumptions. 

The next step in the analysis was to 

determine the expected GHG reductions by 

2020 that would result from the policies and 

programs implemented or initiated since the 

beginning of the Patrick-Murray 

Administration, not including new policies 

that would be implemented under authority 

of the GWSA. In April 2010, Eastern 

Research Group submitted a report to the 

Advisory Committee, Initial Estimates of 

Emissions Reductions from Existing Policies 

Related to Reducing Greenhouse Gas 

Emissions. This report found that the energy 

efficiency, renewable energy, and 

transportation measures required by the 

Green Communities Act, the Advanced 

 

77 Statewide Greenhouse Gas Emissions Level: 1990 

Baseline and 2020 Business As Usual Projection, 

Massachusetts Dept. of Environmental Protection, July 

1, 2009.

Biofuels Act, various state government 

executive actions, and the federal 

government would result in emissions being 

reduced to approximately 18 percent below 

1990 levels by 2020 — roughly the midpoint 

of the 10 percent to 25 percent range 

required by the GWSA. 

Following that report, EEA issued a Draft 

Climate Implementation Plan: A framework 

for meeting the 2020 and 2050 goals of the 

Global Warming Solutions Act. In the 

Implementation Plan, Secretary Bowles 

signaled his intention to set a 2020 

emissions reduction requirement of 18 

percent to 25 percent below 1990 levels and, 

for the final plan to achieve this limit, to give 

greatest consideration to those measures 

that show potential for significant energy 

cost savings and/or job creation.

In May 2010, Eastern Research Group 

submitted an additional report, CostEffective Greenhouse Gas Mitigation in 

Massachusetts: An Analysis of 2020 

Potential. For this report, the consultants 

were asked to consider what additional GHG 

reductions would be technically feasible with 

cost-effective policies beyond those already 

in place. This report showed that it would be 

technically feasible to reduce emissions by 

up to 35 percent below 1990 levels by 2020 

with additional policies that are costeffective. 

Both the draft implementation plan and the 

analysis of 2020 potential were used to focus 

a series of eight public hearings that were 

held in June 2010, as required by the Act.

Nearly 200 individuals and organizations 

provided oral or written comment on the 

2020 emissions reduction requirement and 

on policy measures to meet the requirement.

The vast majority of commenters called for 

the Secretary to set the GHG limit at 25 

percent below 1990 levels, the maximum 

allowed under the statute. A range of 

suggestions also pointed to a variety of 
Massachusetts Clean Energy and Climate Plan for 2020

III. Implementing the Global Warming Solutions Act

90

different policy mechanisms that EEA should 

analyze in preparing the final implementation 

plan.

Following the hearings, EEA further consulted 

with the Climate Protection and Green 

Economy Advisory Committee and tasked the 

Advisory Committee’s technical 

subcommittees, technical staff at EEA 

agencies, MassDOT, EOHED and other state 

agencies, and third-party consultants with 

analyzing a wide range of actions, policies, 

regulations, and legislation that could 

achieve additional clean energy gains and 

emissions reduction by 2020 and beyond.

The Secretary then directed the technical 

teams to conduct in-depth analyses of those 

additional measures that satisfy criteria of 

cost-effectiveness while reducing GHG 

emissions. These in-depth analyses focused 

on GHG reduction potential; cost; clean 

energy economy impacts (cost of living, 

number and quality of jobs, reduced 

spending on fuel imports, etc.); 

implementation and design issues; 

experience in other states or jurisdictions; 

other co-benefits; equity issues; and 

uncertainties.

0%

5%

10%

15%

20%

25%

30%

35%

40%

% Reduction Below 1990 Statewide Emissions

by 2020

Projected Emission Reduction Range

Range 

allowed 

by GWSA

Maximum reduction projected

Minimum reduction projected

Figure 8. Projected emission reduction range 

below 1990 by 2020. The range results from 

uncertainties in Business as Usual (BAU) 

emissions, policy designs, and impacts of 

individual policies. 

Table 2 (on page 91) displays the portfolio of 

policies incorporated in the Massachusetts

Clean Energy and Climate Plan for 2020, and 

the associated potential contribution to GHG 

reduction below 1990 levels by 2020 for 

each policy. In aggregate, these policies, 

which include measures put in place since 

2007 and new initiatives proposed in this 

Plan, are projected to achieve emissions 

reductions in the range of 18 percent to 33 

percent by 2020 (see Figure 8). The lower 

end of this range represents a scenario in 

which Business as Usual (BAU) emissions are 

higher than projected and actual emission 

reductions from the policies as implemented 

are at the low end of estimates. The higher 

end of the range represents a scenario in 

which BAU emissions are lower than 

projected and implementation success is 

relatively high. A mid-range estimate for the 

portfolio of policies results in GHG emissions 

approximately 27 percent below 1990 levels 

by 2020.
Massachusetts Clean Energy and Climate Plan for 2020

III. Implementing the Global Warming Solutions Act

91

Table 2. The Portfolio of Policies

middle estimate 

% reduction 

below 1990

Buildings 9.8%

All cost-effective energy efficiency/RGGI 7.1%

Advanced building energy codes 1.6%

Building energy rating and labeling ---

―Deep‖ energy efficiency improvements for buildings 0.2%

Expanding energy efficiency programs to C/I heating oil 0.1%

Developing a mature market for solar thermal water/space heating 0.1%

Tree retention and planting to reduce heating and cooling loads 0.1%

Federal appliance and product standards 0.6%

Electricity 7.7%

Expanded Renewable Portfolio Standard (RPS) 1.2%

More stringent EPA power plant rules 1.2%

Clean energy imports 5.4%

Clean energy performance standard (CPS) ---

Transportation 7.6%

Federal and California vehicle efficiency and GHG standards 2.6%

Federal emissions and fuel efficiency standards for medium and heavyduty vehicles 0.3%

Federal renewable fuel standard and regional low carbon fuel standard 1.6%

Clean car consumer incentives 0.5%

Pay As You Drive (PAYD) auto insurance (pilot program, possible 

expansion later) 1.1%

Sustainable Development Principles 0.1%

GreenDOT 1.2%

Smart growth policy package 0.4%

Non-Energy Emissions 2.0%

Reducing GHG emissions from motor vehicle air conditioning 0.3%

Stationary equipment refrigerant management 1.3%

Reducing SF6 emissions from gas-insulated switchgear 0.2%

Reducing GHG emissions from plastics 0.3%

Cross-cutting Policies ---

MEPA GHG policy and protocol ---

Leading by Example ---

Green Communities Division ---

Consideration of GHG emissions in State permitting, licensing and 

administrative approvals ---

Overall reductions versus 1990 (adjusted for uncertainty in Business as Usual (BAU) 

emissions, policy designs, and impacts of individual policies)

High BAU emissions and low policy impacts 18%

Middle BAU emissions and policy impacts 27%

Low BAU emissions and high policy impacts 33%

Note: the overall reduction is adjusted for overlap among policies, so is smaller than the sum of the 

individual policies. Individual lines may not sum to subtotals due to rounding. 
Massachusetts Clean Energy and Climate Plan for 2020

III. Implementing the Global Warming Solutions Act

92

60

65

70

75

80

85

90

95

100

1990 1995 2000 2005 2010 2015 2020

Million tons GHG 

Clean Energy and Climate Portfolio Impacts vs. 

Business as Usual

Buildings (-9.8%)

Electricity

Supply (-7.7%)

Transportation 

(-7.6%)

Non-Energy

(-2.0%)

Business as Usual

25% below 1990

Figure 9. Emissions reductions by sector for the portfolio of policies, at the mid-range estimate of 

27 percent below 1990 levels by 2020. 

Based on these analyses, input from the 

Advisory Committee, and full consideration 

of the public comments received, EEA 

Secretary Ian Bowles determined that a 

responsible and achievable GHG emissions 

reduction limit for 2020 that maximizes 

opportunities to realize energy cost savings, 

increase energy independence, and promote 

growth in clean energy jobs in Massachusetts 

is 25 percent — the high end of the range for 

2020 authorized by GWSA, but the middle of 

the range of possible outcomes for the 

policies incorporated in this Plan. 

In setting this limit, the Secretary took into 

account the statutory mandate of 80 percent 

reduction by 2050, which led him to set the 

2020 limit as high as is practical. He also did 

so based on his understanding that the 

portfolio of measures outlined in the 

Integrated Portfolio section of this Plan, 

discounted for uncertainty and potential 

implementation constraints, provides enough 

flexibility and redundancy for the 

Commonwealth to achieve the 2020 

reduction limit of 25 percent.
Massachusetts Clean Energy and Climate Plan for 2020

III. Implementing the Global Warming Solutions Act

93

Pu t t ing t he P la n 

in to A c t ion

In 2011, state agencies responsible for each 

new measure will complete program 

development and consultative processes with 

stakeholders, in order to create an 

implementation plan for each policy outlined 

in this Plan. Given the portfolio nature of the 

policies included in the Plan, there will 

naturally be a diversity of processes to move 

each policy forward. For example, some 

require pilot programs (such as the Pay As 

You Drive pilot program that is dependent on 

Federal Highway funding). Others require 

expansion of existing programs (such as 

energy efficiency). Still others may require 

legislation even as administrative actions 

move them forward (such as the expansion 

of renewable energy credits from electricity 

to include thermal energy). 

As part of continued policy development, 

more detailed cost and benefit information 

will be analyzed and used to design 

programs to maximize a cost-effective 

transition to an equitable clean energy 

future, which includes well-distributed green 

jobs and business growth, as well as GHG 

gas reduction.

In order to monitor progress in implementing 

the Plan, the Climate Protection and Green 

Economy Advisory Committee will remain in 

existence, and the Secretary of EEA will 

present an annual progress report to the 

Committee by December 31 of each year. In 

preparation for that annual report, all 

responsible agencies (EEA agencies, 

MassDOT, EOHED, and others) will report to 

the EEA Secretary by October 31 of each 

year on their progress toward 

implementation. The Secretary will, in turn, 

compile a complete report for the Climate 

Protection and Green Economy Advisory 

Committee. The first full progress review 

required by the Act will be in 2015.

Engaging Citizens to Realize our Clean 

Energy Future: Individuals, Cities & Towns, 

and Regional Planning Agencies

Throughout the development of this Plan, 

there has been ongoing interest on the part 

of the Advisory Committee and the public 

concerning the need for continued citizen 

engagement in reaching the clean energy 

and climate goals set forth in the Global 

Warming Solution Act.

During the course of eight public hearings 

held across the state and in written 

comments, EEA learned of many projects 

and activities that Massachusetts citizens, 

non-governmental organizations (NGOs), 

universities, business groups, and 

municipalities are engaged in to reduce GHG

emissions and work toward a clean energy 

future. EEA and the Commonwealth’s

agencies recognize the value of these efforts 

and commit to work together and support 

them as we collectively strive to implement 

this Plan. 

Individuals are already making clean energy 

decisions such as making their homes more 

energy efficient, and are eager for 

information about how they can do so where 

they work, shop and play.

As of December 2010, 53 communities had 

attained designation as Green Communities, 

becoming eligible for funding to go greener 

as a result; and 64 communities have 

adopted the ―stretch code,‖ a local-option 

building code that sets a standard of 20 

percent to 30 percent more energy efficient 

than the Commonwealth’s recently adopted 

statewide code. Earlier this year, the city of 

Boston adopted a wide-ranging climate 

action plan that was developed through 

extensive community engagement. In 

addition, a variety of independent climate 

and energy initiatives at the municipal level 

are developing practices and information that 

state agencies can learn from and support.
Massachusetts Clean Energy and Climate Plan for 2020

III. Implementing the Global Warming Solutions Act

94

Regional planning organizations, in 

particular, are valuable partners for the state 

to work with in crafting solutions tailored to 

the unique challenges and opportunities of 

their regions. Some already have 

sustainability and/or smart growth programs 

that result in GHG reduction. For example, 

the Pioneer Valley Planning Commission and 

Franklin Regional Council of Governments 

recently released a clean energy plan that 

charts a path toward greater energy 

independence and the use of cleaner and 

more efficient energy in the Valley. The 

process of creating and now implementing 

the plan has been a prime example of state, 

regional and local government collaboration, 

and engagement of citizens, nongovernmental organizations (NGOs) and the 

private sector. 

NGOs of all types are making effective use of 

their community roots to raise consciousness 

about the risks of climate change and the 

opportunities for a clean energy future.

College and university students are 

informed, organized and eager to help shape 

their energy and climate future; these 

students gave impassioned testimony at 

every public hearing.

As the Commonwealth agencies responsible 

for implementing parts of this Plan develop 

their programs, they will look for 

opportunities to work with and support these 

ongoing efforts. Most state agencies have a 

local presence and networks that can 

facilitate coordination with local groups; for 

example, MassDEP has four regional offices 

and DOER has a Green Communities 

coordinator located in each of them.

MassDOT also has regional offices as well as 

established relationships with regional 

planning organizations and regional transit 

authorities. Pilots and demonstration projects 

conducted as agencies develop their 

respective programs under this Plan will 

provide excellent opportunities to involve 

local groups in state initiatives.

The work of individuals, municipalities, 

universities, business organizations, NGOs, 

and regional planning organizations will be 

essential to the Commonwealth’s success in 

implementing this Plan and making the 

transition to a clean energy economy.
Massachusetts Clean Energy and Climate Plan for 2020

IV. Beyond 2020: The Road to 80 Percent Lower Emissions in 2050

95

IV. Beyond 2020: The Road to 80 

Percent Lower Emissions in 2050 

S ce nar ios for a 

C lea n E nergy 

F u t ure

The clean energy economy of 2050 will be 

very different than the fossil fuel dominated 

economy of today. With many of the policies 

embodied in this report in place, 2050 would 

find a Massachusetts where energy costs are 

less volatile and comprise a smaller part of 

budgets. Businesses, households, 

municipalities and institutions are better able 

to manage their energy needs. Renewable 

and alternative sources of energy have 

largely displaced fossil-based sources, and a 

smart grid and advanced technology store 

and release to the grid as needed the 

electricity generated during the night by 

massive wind farms off the coast of the 

Northeast. Both small and large-scale solar 

installations are ubiquitous across the state.

In this scenario, global geopolitics has 

dramatically changed also, and United States 

foreign policy is no longer influenced by the 

politics of petroleum, natural gas, and coal.

National security has been strengthened by 

an economy driven by homegrown sources of 

energy that no longer depend on fossil fuel 

from unstable regions or from countries that 

do not share the interests of the U.S.

By 2050, the clean energy cluster in 

Massachusetts has matured, much as the 

biotechnology and health care sectors 

matured in the early part of the 21st century.

Small entrepreneurial companies and multinationals, R&D, manufacturing and service 

companies make up a varied and dynamic 

clean energy economic landscape. 

Massachusetts plays a dominant role in the 

global market for technologies in offshore 

wind, solar PV and thermal, electricity 

storage and energy management.

Massachusetts architects and engineers are 

leaders internationally in green building 

design and building energy management.

Massachusetts companies that have 

pioneered battery technology have robust 

partnerships with American, European, 

Indian and Chinese car and truck 

manufacturers.

And, by 2050, GHG emissions will, by law, be 

80 percent less than what they were in 1990, 

and the air will be cleaner.

Even as we chart the course through 2020, it 

is critical to plan for the path to 2050.

Getting to this clean energy future will 

require significant innovation in policy, 

technology and business practices. Unlike 

the 2020 limit, which can be met with 

actions that we take here in Massachusetts, 

reaching 80 percent reductions below 1990 

emission levels, as required by the Global 

Warming Solutions Act, will mean broad 

changes that are beyond the reach of 

Massachusetts alone. Between 2010 and 

2050, much will change — in the economy, 

in federal regulation, and in technology —

that will make possible GHG emission 

reductions that would be unthinkable today.

With the nation-leading requirements of the 

GWSA, Massachusetts should — and must —

stay ahead of the curve. But as it reaches for 

the more ambitious mandates of 2030, 2040, 

and 2050 required by the GWSA, 

Massachusetts can only build on changes 

percolating throughout the U.S. economy, 

not strike out entirely on its own. 

But in imagining — and planning for — a 

path to the mandated GHG emissions 

reduction of 80 percent in 2050, it is 

important to ask now: How do we get there?
Massachusetts Clean Energy and Climate Plan for 2020

IV. Beyond 2020: The Road to 80 Percent Lower Emissions in 2050

96

It helps to consider the sources of GHG 

emissions in Massachusetts. As Figure 10

shows, the vast majority of our state’s 

emissions come from energy use. Burning 

carbon intensive fuels for transportation, in 

buildings, and for electricity generation 

accounted for about 92 percent of statewide 

GHG emissions in 2007. The rest of the 

emissions — a scant 8 percent — were from 

activities other than fuel combustion, such as 

wastewater treatment and agriculture (both 

of which emit methane and other GHGs).

Broadly speaking, it is possible to lower GHG 

emissions from energy use in three ways:

Efficiency — Finding means to deliver the 

same services (e.g., miles traveled by 

passenger vehicles, indoor air temperature) 

using less energy. Examples include 

weatherizing buildings so they consume less 

energy to provide comfortable indoor spaces, 

and higher fuel efficiency standards for 

passenger vehicles and light trucks so that

less fuel is combusted for every mile 

traveled.

Conservation — Making lifestyle choices 

that lower energy use even in the absence of 

efficiency improvements. An example is 

reducing non-essential driving.

Cleaner energy sources — Substituting 

low carbon energy sources for the carbon 

intensive fuels we use today. An example is 

generating electricity from wind or solar 

energy instead of from fossil fuels.

The first two of these approaches target 

energy demand, while the third focuses on 

energy supply.

This chapter explores how these approaches 

could be combined with cuts in non-energy 

emissions to hit the 2050 target required for 

Massachusetts. It presents the results of 

scenario modeling of the state’s energy 

system and economy, conducted to assess 

conditions that would allow achievement of 

the 2050 limit. The first part characterizes 

the modeling process and explains how the 

two scenarios presented here were devised.

A summary of the scenarios and their 

emissions and energy projections follows, 

along with implications for Massachusetts 

clean energy and climate policy. The chapter 

goes on to review policies which will either 

have small impacts by 2020 or may not be 

needed to reach the 2020 emissions limit, 

but are critical to achieving the 2050 limit. 

Energy 

Use

NonEnergy 

Sources

7.6 (8%)

84.8 (92%)

Figure 10. Massachusetts GHG Emissions in 

2007 (MMTCO2e and %)
Massachusetts Clean Energy and Climate Plan for 2020

IV. Beyond 2020: The Road to 80 Percent Lower Emissions in 2050

97

Scenario Modeling: Purpose 

and Process

In order to understand the challenges and 

opportunities of meeting the 80 percent by 

2050 goal, the EEA began by modeling 

scenarios of statewide energy use and GHG 

emissions. The scenarios comprised all 

modes of transportation, residential and 

commercial buildings, electricity generation, 

and numerous other factors.

Assisted by technical consultants, EEA used 

the scenarios to project potential futures for 

Massachusetts that would allow attainment 

of the 2050 goal. In this sense, the scenarios 

were not so much predictions or forecasts as 

thought experiments: they showed possible 

ways to cut GHG emissions under various 

conditions. A central consideration in crafting 

the scenarios was that they be plausible. To 

that end, the modeling team limited itself to 

technology that is currently available or 

expected to emerge shortly. The team also 

consulted published scientific and technical 

literature and other government and 

academic modeling projects for insights into 

plausibility.

After experimenting with several scenarios, 

the modeling team developed two that 

achieved the 80 percent target (within a 

reasonable margin of error): one stressing 

electrification and clean electricity supply; 

and another prioritizing efficiency and 

conservation measures. The next sections 

describe these scenarios. The team also 

determined that the target could be 

attainable in a scenario of substituting low 

carbon biofuels for fossil fuels. However, as 

such a scenario is basically equivalent to the 

electrification scenario — replacing clean 

electricity with clean biofuels — it is not 

treated here.
Massachusetts Clean Energy and Climate Plan for 2020

IV. Beyond 2020: The Road to 80 Percent Lower Emissions in 2050

98

Scenario Descriptions: Narratives and Assumptions

SCENARIO 1 — ELECTRIFICATION: A RESIDENT’S VIEW

Houses are better insulated and ventilated than they were 40 years ago. Many houses look 

like those from the Massachusetts 2010 Zero Energy Challenge — there are a number in 

your neighborhood. Increasingly, homeowners are turning to electric heat pumps for space 

and water heating. The cost of these systems has been dropping for a number of years, 

and it’s now standard practice to include them in new houses. Solar hot water and 

residential photovoltaic (PV) installations are also commonplace. You rented out your 

rooftop to a solar PV company last year, cutting your electricity bill in half.

You still drive to work each day, but you do it in a highly efficient electric car. When you 

take public transportation, you’re generally in an electric vehicle as well — whether a train, 

bus, or subway. You hardly see any petroleum-powered vehicles anymore, except for 

airplanes and some trucks. But even those use a 40 percent biofuel blend.

Most commercial buildings are more energy efficient than they were in 2010; a significant 

fraction look like the advanced green buildings of that era. Just as in houses, electric heat 

pumps, solar hot water, and PV arrays are increasingly the norm in commercial buildings.

You work in an industrial setting — at a advanced battery manufacturer that supplies 

batteries for the new fleets of cars, minvans, and trucks that are coming out of Detroit —

and business is booming. Gross state product has more than doubled since 2010, while 

industry’s fraction of it is unchanged. Meanwhile, the energy intensity of industrial 

operations has been falling, and many firms have retooled their processes around electric 

power (instead of fossil fuels). Your employer recently replaced most of the equipment on 

the shop floor with new high-efficiency models, improving productivity and cutting 

operating expenses.

The electrification scenario meets the challenge of the 2050 goal by pairing widespread 

electrification in transportation, buildings, and industry (i.e., switching from fossil fuels to 

electricity) with an extremely clean electricity supply. These changes are backed up by 

energy efficiency gains throughout the economy and progress toward reducing non-energy 

GHG emissions. Table 3 lists the major assumptions defining the electrification scenario. 

The narrative in the sidebar describes what you might experience if you were a resident of 

Massachusetts in 2050.
Massachusetts Clean Energy and Climate Plan for 2020

IV. Beyond 2020: The Road to 80 Percent Lower Emissions in 2050

99

Table 3. Electrification Scenario

Sector Assumption

Statewide

The population of Massachusetts grows to 7.6 million people by 2050 

(about 18% higher than today).

Gross state product (GSP) grows to $930 billion (2008$) by 2050 

(approximately 150% higher than today). This increase is based on the 

historical rate of per capita income growth in Massachusetts.

Transportation

By 2050, 90% of light duty vehicles are pure electric, 5% are plug-in 

electric, and 5% are hybrids.

By 2050, passenger and freight vehicle efficiency improves substantially.

For example, holding vehicle size constant, the energy intensity of hybrid 

gasoline cars (energy required per mile traveled) falls about 31% between 

now and 2050.

By 2050, transit service doubles and number of people per vehicle 

increases 20% from today’s levels.

By 2050, commuter rail and intercity rail in Massachusetts are completely 

electric; 90% of buses are electric.

By 2050, 40% of commercial aircraft and road freight miles are powered 

by biofuel that produces 70% fewer GHG emissions than burning gasoline.

Growth in annual commercial air travel miles stops in 2020.

Residential 

and 

Commercial 

Buildings

By 2050, only 16% of houses have the same energy use profile as a typical 

house today; 40% match the energy performance of today’s advanced 

green houses. New and upgraded houses mainly use electric heat pumps 

for space and water heating.

By 2050, only 20% of commercial buildings have the same energy use 

profile as a typical commercial building today; 40% match the energy 

performance of today’s advanced green commercial buildings. New and 

upgraded buildings mainly use electric heat pumps for space and water 

heating.

Industry

Rising at the same rate as GSP, industrial output in Massachusetts grows 

to $162 billion (2008$) by 2050.

40% of industrial energy comes from electricity in 2050.

Between now and 2050, industrial energy intensity (energy required per $ 

of output) decreases 2% per year on average.

Electricity 

Generation

By 2050, 100% of the electricity consumed in Massachusetts comes from 

near zero carbon sources: renewables, pre-2000 nuclear facilities, and a 

small amount of biomass, and this constitutes 112% of what total 

Massachusetts electricity use was in 2007, or 9 times the amount of lowcarbon supply in 2007. The state no longer uses any electricity from 

natural gas, coal, or oil.
Massachusetts Clean Energy and Climate Plan for 2020

IV. Beyond 2020: The Road to 80 Percent Lower Emissions in 2050

100

Scenario Descriptions: Narratives and Assumptions

SCENARIO 2 — EFFICIENCY AND CONSERVATION SCENARIO: A RESIDENT’S VIEW

Every house in the state uses less energy per square foot than a typical house did 40 years 

ago. Improved lighting, insulation, appliances, and heating and cooling systems are 

universal. Houses remaining from 2010 have been equipped with these enhancements (to 

a greater or lesser degree), and new houses include them as a matter of course. Nearly 

half of all houses meet efficiency standards only attained by the best ―green‖ prototypes in 

2010. Yours is one of them: when you bought it 10 years ago, you had a deep energy 

improvement performed before moving in. The contractor installed an electric heat pump 

for heating and cooling, solar hot water collectors, and a PV array, among other 

improvements. Residents statewide are increasingly choosing these technologies to meet 

household energy needs. They’re also opting for markedly smaller homes, prompting a 

reduction in the size of new houses and conversions of large dwellings into multi-family 

residences.

For several decades, the trend in passenger vehicles has been toward more efficient cars.

Light trucks have fallen out of favor except with tradespeople who need them for work, as 

have SUVs except for those who need true off-road capability, with the number on the 

road dropping 75 percent since 2010. Drivers are carpooling more, and everyone thinks 

twice about single-purpose drives to the store or the mall. You still have that hybrid, but 

your spouse made the switch to an electric car a few years ago, and you take the electric 

when you travel together. More and more, you use public transportation when you can. It 

helps that transit service is more widespread and frequent than it used to be. You don’t 

travel by plane as much as you once did, either; for short and middle distance trips, you 

go by high-speed train or your car, and you take long trips less often.

Like everyone you know, you work in a building that’s substantially more energy efficient 

than commercial buildings were in 2010. Half of today’s buildings would have been 

considered advanced green buildings in 2010, and many use electric heat pumps instead of 

fossil fuels.

Industrial output in Massachusetts has more than doubled since 2010, while the energy 

intensity of industrial production has fallen by almost two thirds. Enterprises requiring a 

skilled, educated workforce continue to locate in the state, contributing to steady economic 

growth.

The efficiency and conservation scenario achieves the 2050 goal through a combination of 

maximal efficiency gains in all sectors and consumer choices favoring energy efficiency and 

conservation. Complementing these developments are some fuel switching toward 

electricity, a significant (but not total) de-carbonization of the electricity supply, and cuts 

in non-energy emissions. Table 4 shows the principal assumptions underpinning the 

efficiency and conservation scenario, and the sidebar provides a parallel narrative — what 

you might experience under this scenario if you were a resident of Massachusetts in 2050.
Massachusetts Clean Energy and Climate Plan for 2020

IV. Beyond 2020: The Road to 80 Percent Lower Emissions in 2050

101

Table 4. Efficiency and Conservation Scenario

Sector Assumption

Statewide

The population of Massachusetts grows to 7.6 million people by 2050 

(about 18% higher than today).

Gross state product (GSP) grows to $930 billion (2008$) by 2050 

(approximately 150% higher than today). This increase is based on the 

historical rate of per capita income growth in Massachusetts.

Transportation

By 2050, 60% of light duty vehicles are pure electric, 20% are plug-in 

electric, and 20% are hybrids.

By 2050, passenger and freight vehicle efficiency improves even more 

than in scenario 1, with (for example) the energy intensity of hybrid 

gasoline cars falling about 36% between now and 2050.

Consumer preferences shift toward more efficient cars. By 2050, 

technologies allow cars to use one third less energy than it otherwise 

would have.

Apart from those who need special functions, consumers shift away from 

light trucks and passenger vehicles built on light truck chassis (SUVs).

By 2050, the share of trucks in the light duty vehicle fleet drops to 10 

percent (from around 40 percent today).

By 2050, utilization of cars and light trucks rises to 2.0 people/vehicle 

(compared to 1.6 today).

By 2050, less non-essential driving causes the total number of miles 

traveled in light duty vehicles to be 15% lower than it would otherwise 

have been.

By 2050, transit service increases 2.5 times and ratio of people-pervehicle rises 30% from today’s levels.

By 2050, 40% of commercial aircraft and road freight miles are powered 

by biofuel that produces 70% fewer GHG emissions than gasoline.

Annual commercial air travel miles drop 50% between 2010 and 2050 as 

regional and intercity rail increases.

Residential 

and 

Commercial 

Buildings

By 2050, no houses have the energy use profile of a typical house 

today; 45% match the energy performance of today’s advanced green 

houses. New and upgraded houses mainly use electric heat pumps for 

space and water heating.

By 2050, only 5% of commercial buildings have the energy use profile of 

a typical commercial building today; 50% match the energy performance 

of today’s advanced green commercial buildings. New and upgraded 

buildings mainly use electric heat pumps for space and water heating.

In residential buildings, average square footage per household is about 

22% lower in 2050 than today.

Industry

Rising at the same rate as GSP, industrial output in Massachusetts grows 

to $162 billion (2008$) by 2050.

Between now and 2050, industrial energy intensity decreases 2.5% per 

year on average.

Electricity 

Generation

By 2050, about 80% of the electricity consumed in Massachusetts comes 

from near zero carbon sources: renewables, pre-2000 nuclear facilities, 

and a small amount of biomass used in high efficiency combined-heatand-power applications. The low-carbon power is about five times the 

amount used in Massachusetts in 2007 (about half the amount of lowcarbon power needed in the electrification scenario). The remainder is 

from natural gas generation. 
Massachusetts Clean Energy and Climate Plan for 2020

IV. Beyond 2020: The Road to 80 Percent Lower Emissions in 2050

102

Scenario Results

In both the electrification and efficiency and 

conservation scenarios, Massachusetts 

reaches the 80 percent target by 2050.

Given the first two assumptions in Tables 1 

and 2 — of rising population and real income

— this achievement is remarkable.

Significant changes in infrastructure, 

technology, and consumer choices pave the 

way to the 80 percent reduction. Figure 11

depicts projected statewide GHG emissions 

under the scenarios, as well as historic 

emissions and a business-as-usual 

trajectory.

Figure 11. Historic and Projected Massachusetts GHG Emissions

The two scenarios have important 

commonalities, such as improvements in 

vehicle and building efficiency, shifts away 

from fossil fuels in transportation and 

buildings, and deployment of low carbon 

electricity generation. But they differ in how 

they combine demand- and supply-side 

approaches to reducing GHG emissions from 

energy use. In the electrification scenario, 

low-carbon supply rises greatly, to 112

percent of total Massachusetts electric 

consumption in 2007, or providing nine times 

the amount of low-carbon supply that 

Massachusetts consumed in 2007. In the 

efficiency and conservation scenario, the 

low-carbon supply only has to rise to about 

five times the 2007 amount. 

6.7

63.8

36.8

0

10

20

30

40

50

60

70

2007 2050 -

Electrification

2050 -

Efficiency & 

Conservation

Thousand GWh

Figure 12. Supply of Near-Zero Carbon Electricity
Massachusetts Clean Energy and Climate Plan for 2020

IV. Beyond 2020: The Road to 80 Percent Lower Emissions in 2050

103

In the efficiency and conservation scenario, 

enhanced efficiency measures and consumer 

choices produce lower transportation and 

buildings emissions than in the electrification 

scenario, notwithstanding some continued 

reliance on fossil fuels. These incremental 

gains make feasible a somewhat more 

carbon intensive energy supply. Figure 13

shows that the efficiency and conservation 

scenario allows for more emissions from 

electricity generation, whereas more nonemitting electricity sources are needed for 

the electrification scenario. Both scenarios 

require dramatic reductions in energy use, 

but the electrification scenario allows for 

somewhat greater electricity generation 

(from clean sources) even compared with 

today, while the efficiency and conservation 

scenario requires less energy use (and 

electricity generation) overall. 

Figure 13. Emissions by sector in two scenarios.

The transportation and buildings sectors are 

by far the largest end users of energy in 

Massachusetts. Both scenarios count on 

considerable gains in building energy 

efficiency by 2050. These gains go further in 

the efficiency and conservation scenario, 

especially for existing houses — more of 

them are upgraded with energy saving 

measures and high efficiency mechanical 

systems. For residential buildings that exist 

in 2010, the electrification scenario assumes 

that energy demand per square foot is cut in 

half by 2050, while in the efficiency and 

conservation scenario it is cut by two-thirds. 

Homes that are built between 2010 and 2050 

use even less energy, about 50 percent as 

much per square foot as existing buildings in 

the efficiency/conservation scenario. 

There are three ways that transportation 

emissions can be reduced — reducing VMT, 

improving fuel efficiency, and reducing the 

carbon content of vehicle fuel. To achieve an 

80 percent emissions reduction, all of these 

must achieve large gains relative to Business 

as Usual (BAU). In the 

electrification scenario, 

where vehicles are running 

almost entirely on lowcarbon power, VMT for cars 

and light trucks is able to 

grow from 51 billion miles to 

58 billion, while in the 

efficiency and conservation 

scenario it decreases to 48 

billion miles, and the share 

of light trucks in the fleet 

drops steeply. Vehicle 

efficiency improves greatly in 

both scenarios, but more so 

in the efficiency and 

conservation scenario. 

Conversely, carbon 

emissions per unit of fuel are only about half 

as large in the electrification scenario, at 114 

grams of CO2 per kwh of energy input, as 

they are in the efficiency and conservation 

scenario (at 217 grams CO2 per kwh).
Massachusetts Clean Energy and Climate Plan for 2020

IV. Beyond 2020: The Road to 80 Percent Lower Emissions in 2050

104

Policy Directions to be Developed in Coming Years

As the scenarios show, reducing emissions 

by 80 percent in 2050 depends on dramatic 

changes in energy and transportation 

systems. Some of the policy changes that 

are critical to reaching the 2050 reduction 

requirement are included in the 2020 policies 

discussed earlier in this Plan. But the GHG 

reductions shown are relatively small, 

because these policies need long lead times 

for development and their impacts grow over 

time, becoming more significant after 2020. 

In addition, further new policies will be 

needed that are not necessary to reach the 

2020 target, but are essential to reaching 

the 2050 mandate. Below we briefly review 

both sets of policy possibilities. 

Policies in 2020 Plan that have 

relatively small impacts in 

2020 but are critical for 2050

Buildings — As the scenarios show, on 

average energy use must drop by at least 42

percent for existing buildings in the 

electrification scenario and by 69 percent in 

the efficiency/conservation scenario by 2050. 

To accomplish this, policies to achieve much 

deeper reductions in energy use than result 

from the current utility programs will be 

needed. For new buildings, this can result 

largely from code requirements, while for 

existing buildings it is likely that other forms 

of incentives and regulatory requirements 

will be needed. Because buildings are so 

long-lasting, investments that are made in 

2011 and beyond are likely to yield GHG 

savings for a century or more, while 

inefficiencies that are not rectified will 

produce excess emissions for decades. Four 

of the proposed policies to address this have 

been discussed in detail earlier in this Plan, 

but are worth re-emphasizing in their 

importance for 2050.

Building rating and labeling — At present, 

the likely energy use of existing buildings, 

both commercial and residential, is largely 

unknown to prospective purchasers and 

tenants. As a result, the built-in efficiency of 

a building (as distinct from occupant 

behavior) has little value in the marketplace. 

Rating the energy performance of buildings 

relative to an objective standard for others of 

the same size and type will make it possible 

for sales and rental prices to take energy use 

into account, giving owners an incentive to 

improve performance for resale value. In 

addition, rating and labeling are 

prerequisites to instituting performance 

requirements, which will become necessary 

over time in order to reduce the average 

consumption of existing buildings.

Building codes — To achieve the dramatic 

reductions in energy use that is needed for 

new buildings, building additions, and major 

renovations of existing buildings, continual 

updating of building codes is the most costeffective policy. This will require conversion 

of traditional ―prescriptive‖ codes, which 

dictate specific measures, to performancebased standards, and tightening over time of 

the energy requirements. Technological 

development, experience within the industry, 

and increases in the real cost of energy, 

along with an eventual price of carbon, 

should make such tightening cost effective. 

Recent trends and projections for the next 

few years in the IECC and American Society 

of Heating, Refrigerating and AirConditioning Engineers, Inc. (ASHRAE)

standards show that continual improvement 

in codes is feasible. Again, because buildings 

are so long-lasting, it is essential that 

improvements in the shells of new buildings 

(insulation and air sealing) be ramped up as 

quickly as possible. 
Massachusetts Clean Energy and Climate Plan for 2020

IV. Beyond 2020: The Road to 80 Percent Lower Emissions in 2050

105

Deep energy improvements — Today, 

utility-administered efficiency programs 

provide incentives for ―moderate‖ retrofits of 

existing buildings, such as installing 

insulation in attics and in exterior wall 

cavities, purchasing compact fluorescent 

light bulbs and high-efficiency commercial 

light fixtures, and more efficient appliances. 

Achieving nearly universal adoption of such 

items should be sufficient to reach the 2020 

GHG target, but not for 2050. ―Deeper‖ 

retrofits, including such items as rigid 

insulation on the exterior walls of buildings 

under new siding, triple-glazed windows, LED 

lighting, and renewable heating systems, will 

all be needed. 

Tree retention and planting — Because 

trees grow slowly, planting done in the next 

decade will have small benefits by 2020, but 

will contribute greatly to the 2050 target by 

reducing cooling and heating loads in 

buildings. In addition, though it is not 

counted in this Plan due to data limitations, 

planting more trees will result in greater 

sequestration of GHGs.

Transportation — to reduce transportation 

emissions on the order of 80 percent, all 

three of the primary drivers of emissions will 

have to be addressed — vehicle efficiency 

(including driving habits), miles driven, and 

carbon content of vehicle fuel. The measures 

below are some of the methods for 

influencing these three areas. 

Smart Growth — To achieve the GHG 

target, VMT for light vehicles (cars and light 

trucks) must be reduced by 15 percent in the 

efficiency/conservation scenario versus the 

business-as-usual scenario. One of the 

primary influences on VMT is development 

pattern, with sprawling business and housing 

development increasing the amount of nondiscretionary driving. This impact can be 

reduced through smart growth, which 

concentrates development in and around 

existing cities and in more compact areas 

with mixed residential, shopping, and 

employment uses to reduce transportation 

needs. Because development in 

Massachusetts is occurring slowly, the 

savings from smart growth are relatively 

small in 2020 but will be much greater in 

2050. Without new development taking place 

primarily in smart growth fashion, however, 

it will not be possible to reach the necessary 

emissions reduction from transportation. 

Low Carbon Fuel Standard (LCFS) — To 

achieve the 80 percent reduction limit, the 

average carbon content of vehicle fuel falls 

by 54 percent in the electrification scenario 

and by 12 percent in the efficiency /

conservation scenario. This will require the 

conversion of a majority of motor vehicles 

from petroleum to other fuel sources, such 

as electricity or biofuels. The 2020 Plan 

anticipates that introduction of a LCFS will 

mandate a 5 percent reduction in the 

average carbon content of light vehicle fuel, 

contributing modestly to the 2020 limit. But 

for 2050 the LCFS must become far stricter, 

and be supported by other policies necessary 

for the LCFS to succeed (such as 

development of fueling infrastructure). 
Massachusetts Clean Energy and Climate Plan for 2020

IV. Beyond 2020: The Road to 80 Percent Lower Emissions in 2050

106

Policies not in the 2020 Plan 

that are needed for 2050

Beyond the measures described above and 

earlier in this Plan, the 2050 scenarios make 

clear that additional measures will be 

necessary to achieve an 80 percent GHG 

reduction at that time: 

Decarbonizing the electricity supply — In 

both scenarios for 2050, the vast majority of 

electricity supply must be low-carbon (70 or 

80 percent lower than the average emissions 

from the New England grid at present). Less 

of this supply is needed in the 

efficiency/lifestyle scenario than in the 

electrification scenario. The resources to 

achieve this shift are theoretically available, 

if not entirely in Massachusetts (given our 

small size and limited supply of renewable 

resources), then in imports from the region 

and beyond. The current RPS requires that 

the state’s distribution utilities supply 15 

percent of their power from qualifying 

renewable sources by 2020. For 2050 we will 

need far more resources from both RPSeligible and non-RPS qualified sources. Part 

of this we expect will be obtained from 

offshore wind resources, which are ample in 

federal waters off Massachusetts. Part will 

come from non-RPS sources such as 

Canadian hydro and wind power. To ensure 

that sufficient supplies are available, new 

policy mechanisms will need to be developed 

that go beyond the RPS, such as the Clean 

Energy Performance Standard discussed 

earlier in this Plan. 

Converting motor vehicles from 

petroleum to other fuels — The LCFS is 

the state’s primary policy mechanism for 

encouraging a shift from petroleum to lowcarbon vehicle fuels. However, there is 

evidence that the LCFS may not by itself be 

sufficient to cause this shift without 

complementary policies to induce consumers 

to shift to alternative fuels.78 At least in part, 

this result stems from the difficulty in 

simultaneously developing alternative fuel 

sources, the infrastructure to distribute the 

fuels, and the vehicles that can utilize them. 

For example, converting a substantial portion 

of vehicle fuel to electricity requires that 

electric charging stations be installed at 

homes and businesses and at public 

locations, that auto manufacturers produce a 

variety of plug-in hybrid and all-electric 

vehicles, and that consumers purchase these 

vehicles in large numbers at a premium to 

conventional vehicles (at least in the early 

years). Substantial incentives for fueling 

infrastructure and for consumers to purchase 

the vehicles may be necessary. 

 

78 Based on results of system dynamics modeling 

conducted by Ventana Systems, Inc. on behalf of the 

state’s CPGEA planning team. 
Massachusetts Clean Energy and Climate Plan for 2020

V. Appendix

Page 107

V. Appendix

Methodology for Estimating Policy 

Impacts on Employment in 2020

State government policies affect employment 

in several ways. First, employment in a 

particular industry whose development is 

affected can be raised or lowered. Second, 

every industry buys goods and services from 

other industries, thus ―indirectly‖ creating 

employment. And third, both employees and 

owners spend their incomes, creating 

―induced‖ employment. The size of 

employment changes depends greatly on 

what portion of an industry’s income, and of 

household incomes, are spent within a state 

(or other geographic area being considered), 

and the capital- or labor-intensity of an 

industry, with labor-intensive ones generally 

yielding larger employment gains. 

For purposes of this Plan, we have examined 

changes in the demand for the products of 

various industries, mainly those involved in 

energy production and consumption and in 

transportation. In general, the 

Commonwealth’s and the federal 

government’s energy and climate policies are 

designed to shift spending away from fossil 

fuels and toward energy efficiency and 

renewable energy, causing shifts in spending 

among industries. For example, federal fuel 

efficiency/vehicle CO2 standards cause an 

increase in the cost of manufacturing autos, 

but the reduction in spending on gasoline 

and diesel fuel is several times larger than 

the higher manufacturing costs. Incomes of 

Massachusetts households rise by the 

difference between their savings on fuel and 

their extra spending on new vehicles, and, 

when they spend this money in 

Massachusetts, employment in 

Massachusetts rises. Income for auto 

manufacturers rises, but, since there are no 

auto plants in Massachusetts, almost all of 

this goes out of state, except for the small 

fraction gained by auto dealers. Income to 

the petroleum industry falls greatly, but this 

impact is primarily felt out of the state and 

out of the country, except for the reduced 

income to retailers. On balance, we estimate 

that in 2020 federal efficiency standards for 

light, medium, and heavy-duty vehicles will 

raise employment in Massachusetts by 7,000 

jobs, driven by fuel savings that no longer go 

outside the Commonwealth, but that can 

now be spent in Massachusetts. 

A similar procedure has been used for most 

of the major policies included in this Plan, 

wherever it was possible to make reliable 

estimates of the impact of a policy on energy 

production and consumption, and, as a 

result, on the incomes and expenses of 

various industries and on households. The 

first step in each case is to estimate the 

dollar value of changes in energy usage, and 

the amounts of higher or lower spending that 

will occur in each industry. To convert these 

to employment changes, several different 

models can be used; we have utilized the 

RIMS (Regional Input-Output Multiplier 

System) of the Bureau of Economic Analysis 

(BEA) in the U.S. Department of Commerce. 

Specifically, the RIMS Type II multipliers 

provide an estimate of the number of jobs in 

Massachusetts that result from an increase in 

spending of $1 million on an industry located 

in the Commonwealth — due to ―direct‖ jobs 

within the industry itself, ―indirect‖ jobs at 

suppliers to the industry, and ―induced‖ jobs 

from spending by employees of the industry. 

The multipliers must be adjusted for the 

degree to which spending on an industry, or 

by an industry, goes out of the state — such 

as purchases of fuel or equipment from 

outside the Commonwealth.

When energy costs, such as electricity bills, 

fall, this is a gain to the incomes of both 
Massachusetts Clean Energy and Climate Plan for 2020

V. Appendix

Page 108

households and businesses. To estimate the 

resulting employment changes, we need to 

know how much of the savings goes to 

households and to each type of business, 

and how each spend their money. The split 

between households and businesses can be 

obtained from the state’s electric utilities. 

Then, for households, we have used the 

Consumer Expenditure Survey of the U.S. 

Bureau of Labor Statistics as the basis for 

how families will spend their energy savings. 

Combining this with the employment 

multipliers for each industry, we have 

constructed an employment multiplier for 

household spending. For businesses, we 

have used BEA data on the share of 

Massachusetts Gross Domestic Product 

coming from each industry, in combination 

with BEA multiplier data that shows the 

percentage of each industry’s spending that 

goes to utility costs. These two data sources, 

then combined with the overall employment 

multipliers for each industry, give us an 

estimate of what the employment change 

will be in Massachusetts for a change of $1 

million in business spending on electricity 

bills. 

This procedure was used for those policies 

where the dominant change was a reduction 

in fossil fuel spending, and the changes to 

other industries in Massachusetts could be 

predicted with some reliability — which 

includes federal and state vehicle efficiency 

policies, policies to affect vehicle miles 

traveled, utility-administered buildings 

efficiency policies, building codes, and 

federal appliance/product efficiency 

standards. However, for renewable energy 

policies, more of the employment impact 

comes from growth in the renewable energy 

industries themselves, including equipment 

and fuel supplies. For these, we lack 

Massachusetts-specific studies on the likely 

development of relevant businesses within 

the Commonwealth by 2020 — such as 

manufacturing of solar photovoltaic panels or 

wind turbines, or conversion of biomass into 

cellulosic biofuels. We have therefore utilized 

national-level studies of employment 

changes due to increased reliance on 

renewable energy (primarily electricity), 

some of which have provided state-by-state 

estimates. However, such studies have not, 

in general, predicted the degree to which 

renewable energy industries will develop to 

differing degrees within different states. 

These studies usually provide results based 

either on the current status of the industries 

by state, or simply based on the overall size 

of a state’s economy. For this reason, in our 

results shown in this Plan, we have given a 

broad range for possible employment in 

2020 from renewable energy industries. 

In most cases, policies as they existed prior 

to 2008 are considered part of the BAU trend 

for GHG emissions — for example a portion 

of savings from building codes and federal 

appliance standards. Only the post-2008 

expansion of programs or creation of new 

programs are counted as causing reductions 

from the BAU in GHG. Consequently, energy 

savings, and the resulting jobs, deriving from 

pre-2008 policies have in most cases not 

been counted here. However, the 

Massachusetts DPU requires DOER to report 

on the impacts of all efficiency spending,

including the level that existed prior to 2008. 

In order to be consistent with the figures 

reported to the DPU, the employment figures 

shown here are based on all efficiency 

spending.

Sources for transportation and buildings 

efficiency estimates: RIMS II multipliers 

for Massachusetts, Bureau of Economic 

Analysis, U.S. Department of Commerce, 

December 2010; Consumer Expenditure 

Survey 2009, Northeast states, U.S. Bureau 

of Labor Statistics; Gross Domestic Product 

by Industry for Massachusetts 2009, Bureau

of Economic Analysis, U.S. Department of 

Commerce.
Massachusetts Clean Energy and Climate Plan for 2020

V. Appendix

Page 109

Sources for renewable energy 

estimates: "Economic Impacts of Extending 

Federal Solar Tax Credits," Navigant 

Consulting, Burlington, MA, Sept. 15, 2008; 

"Wind Turbine Development: Location of 

Manufacturing Activity," George Sterzinger 

and Matt Svrcek, Renewable Energy Policy 

Project, Sept. 2004; "Solar PV Development: 

Location of Economic Activity," George 

Sterzinger and Matt Svrcek, Renewable 

Energy Policy Project, January 2005; "The 

Economic Benefits of Investing in Clean 

Energy," Robert Pollin et al, Political 

Economy Research Institute and Center for 

American Progress, June 2009; "Putting 

Renewables to Work: How Many Jobs Can 

the Clean Energy Industry Generate?," 

Daniel M. Kammen et al, Renewable and 

Appropriate Energy Laboratory, Goldman 

School of Public Policy, University of 

California - Berkeley, April 13, 2004 

(corrected 1/31/2006). 
Massachusetts Clean Energy and Climate Plan for 2020

VI. Reference

Page 110

VI. References

Akbari, H. (2002) ―Shade trees reduce building energy use and CO2 emissions from power plants.‖ 

Environmental Pollution 116: S119-S126

American Automobile Association. (March 2008) Crashes vs. Congestion, What’s the Cost to Society?

Bordoff, Jason E., and Pascal J. Noel. (July 2008) Pay-As-You-Drive Auto Insurance: A Simple Way to 

Reduce Driving-Related Harms and Increase Equity. The Hamilton Project, The Brookings Institution.

Brown, Marilyn A., Frank Southworth, and Therese K. Stovall. (June 2005). Towards a Climate-Friendly Built 

Environment. Prepared for the Pew Center on Global Climate Change. Published online at: 

http://www.pewclimate.org/docUploads/Buildings_FINAL.pdf

Burchell, Robert W., William R. Dolphin, and Catherine C. Galley. (2000) Impact Assessment of the New 

Jersey State Development and Redevelopment Plan. New Jersey: Rutgers University for Urban Policy 

Research.

Burchell, R.W. and S. Mukherji (2003) ―Conventional Development Versus Managed Growth: The Costs of 

Sprawl.‖ American Journal of Public Health 93(9):1534-1540.

California Environmental Protection Agency Air Resources Board. (May 2008) Clearinghouse of Technological 

Options for Reducing Anthropogenic Non-CO2 GHG Emissions from All Sectors, Chapter 4 - High-GWP Gases.

Published online at: http://www.arb.ca.gov/research/apr/past/05-328.pdf and 

http://www.arb.ca.gov/cc/non-co2-clearinghouse/non-co2-clearinghouse.htm

California Environmental Protection Agency Air Resources Board. ―HFC Emission Reduction Measures for 

Mobile Air Conditioning — Low Emission Vehicle (LEV III), MAC Effort.‖ Published online, retrieved Dec. 8, 

2010 from http://www.arb.ca.gov/cc/hfc-mac/mvac-gwp/mvac-gwp.htm

California Environmental Protection Agency Air Resources Board, ―Global Warming Potential Refrigerants.‖ 

Published online, retrieved Dec. 8, 2010 from 

http://www.arb.ca.gov/regact/2009/gwprmp09/gwprmp09.htm

California Environmental Protection Agency Air Resources Board, ―SF6 Gas Insulated Switchgear.‖ Published 

online, retrieved Dec. 8, 2010 from http://www.arb.ca.gov/regact/2010/sf6elec/sf6elec.htm

California Environmental Protection Agency Air Resources Board, ―California Electricity Sector and Particle 

Accelerator Sulfur Hexaflouride (SF6) Survey.‖ Published online, retrieved Dec. 8, 2010 from 

http://www.arb.ca.gov/cc/sf6elec/survey/sf6survey.doc

California Environmental Protection Agency Air Resources Board. (Dec. 2008). Climate Change Scoping Plan, 

A Framework for Change. Published online at: 

http://www.arb.ca.gov/cc/scopingplan/document/adopted_scoping_plan.pdf

California Environmental Protection Agency Air Resources Board, Research Division. (October 2009) HighGlobal Warming Potential Stationary Source Refrigerant Management Program Published online at: 

http://www.arb.ca.gov/regact/2009/gwprmp09/isorref.pdf

Cambridge Systematics, Inc. (2009) Moving Cooler: An Analysis of Transportation Strategies for Reducing 

Greenhouse Gas Emissions. Washington, D.C., Urban Land Institute.

Center for Climate Strategies. ―Home Page.‖ Published online, retrieved Dec. 8, 2010 from 

http://www.climatestrategies.us/
Massachusetts Clean Energy and Climate Plan for 2020

VI. Reference

Page 111

Clean Edge. (April 2010) A Future of Innovation and Growth: Advancing Massachusetts’ Clean Energy 

Leadership. MassCEC.

Comerica. (May 2010) Auto Affordability Index. Published online at:

http://www.comerica.com/Comerica_Content/Corporate_Communications/Docs/Auto%20Affordability%20In

dex/Auto_Affordability_Index_Q12010.pdf

Commonwealth of Massachusetts. ―Governor Deval Patrick: Energy and the Environment.‖ Published online, 

retrieved on October 27, 2010 from 

http://www.mass.gov/?pageID=gov3utilities&sid=Agov3&U=energyandenvironment

Commonwealth of Massachusetts. (Spring 2008) Advanced Biofuels Task Force Report. Page 20. Published 

online at: http://www.mass.gov/Agov3/docs/biofuels.pdf

Commonwealth of Massachusetts. (July 2008) Clean Energy Biofuels Act, Chapter 206 of the Acts of 2008.

Published online at: http://www.malegislature.gov/Laws/SessionLaws/Acts/2008/Chapter206

Commonwealth of Massachusetts. Massachusetts General Law Chapter 111, Section 142 K ―Motor Vehicle 

Emission Standards; Late Models.‖ Published online at: 

http://www.malegislature.gov/Laws/GeneralLaws/PartI/TitleXVI/Chapter111/Section142K

Commonwealth of Massachusetts, Department of Environmental Protection. (July 1, 2010) News Release: 

―Patrick-Murray Administration Releases Draft Solid Waste Master Plan for 2010-2020.‖ Published online at: 

http://www.mass.gov/dep/public/press/0710swmp.htm

Commonwealth of Massachusetts, Department of Environmental Protection. ―Waste and Recycling —

Priorities and Results.‖ Published online, retrieved on Dec. 8, 2010 from 

http://www.mass.gov/dep/recycle/priorities/dswmpu01.htm#swmp

Commonwealth of Massachusetts, Department of Public Health. (2009) Maximizing our Efforts: The 

Massachusetts State Injury Prevention Plan. Published online at: 

www.mass.gov/Eeohhs2/docs/dph/com_health/injury/injury_prevention_plan.pdf

http://www.mass.gov/Eeohhs2/docs/dph/com_health/injury/injury_prevention_plan.doc

Commonwealth of Massachusetts, Department of Transportation — Highway Division. ―Average Crash 

Rates.‖ Published online, retrieved on Dec. 14, 2010 from 

http://www.mhd.state.ma.us/default.asp?pgid=content/traffic/crashrate&sid=about

Commonwealth of Massachusetts, Executive Office of Energy and Environmental Affairs. (October 28, 2010)

News Release: ―Patrick-Murray Administration Highlights Growth of Solar Industry with Visit to Solar 

Inverter Manufacturer.‖ Published online at: 

http://www.mass.gov/?pageID=eoeeapressrelease&L=1&L0=Home&sid=Eoeea&b=pressrelease&f=101028_

pr_solar&csid=Eoeea

Ewing, Reid, Keith Bartholomew, Steve Winkelman, Jerry Walters and Don Chen, with Barbara McCann and 

David Goldberg. (2008) Growing Cooler: The Evidence on Urban Development and Climate Change. 

Washington, D.C.: Urban Land Institute.

Eastern Research Group (2010) Final Report to the Climate Protection and Green Economy Advisory 

Committee.

Ferreira, Jr., Joseph, and Eric Minikel. (November 2010) Pay-As-You-Drive Auto Insurance In 

Massachusetts: A Risk Assessment And Report On Consumer, Industry And Environmental Benefits. 

Commissioned by Conservation Law Foundation & Environmental Insurance Agency.
Massachusetts Clean Energy and Climate Plan for 2020

VI. Reference

Page 112

Gelman, Emmaia, Editor. (May 2009) Green Jobs/Green Homes New York: Expanding home energy 

efficiency and creating good jobs in a clean energy economy. Center for Working Families, Green Jobs New 

York and Center for American Progress. Page 5. Published online at: 

http://www.americanprogress.org/issues/2009/05/pdf/ghgjny_v10.pdf

Global Insight, Inc., (2007) Massachusetts Clean Energy Census. Massachusetts Technology Collaborative.

Published online at: http://www.cleanenergycouncil.org/files/Clean-Energy-Census-Report-2007.pdf

Goulder, L.H, M. R. Jacobsen, and A.A. van Benthem. (2009) ―Impacts of State-Level Limits on Greenhouse 

Gases per Mile In the Presence of National CAFE Standards.‖ Published online at: 

http://www.stanford.edu/~goulder/Pavley-CAFE%20Paper%20%28Goulder-Jacobsenvan%20Benthem%29.pdf

Grossman, Richard and Gail Daneker. (1979) Energy, Jobs and the Economy. Boston, MA: Alyson 

Publications.

H.C. Planning Consultants, Inc., and Planimetrics, LLP. (1999) .The Cost of Suburban Sprawl and Urban 

Decay in Rhode Island. Providence, RI: Grow Smart Rhode Island.

Huang, Y.J., H. Akbari, H Taha, and A.H. Rosenfeld. (1987) ―The Potential of Vegetation in Reducing 

Summer Cooling Loads in Residential Buildings.‖ Journal of Climate and Applied Meteorology. 26:1103-1116.

Intergovernmental Panel on Climate Change. (2005) Safeguarding the Ozone Layer and the Global Climate 

System: Issues Related to Hydrofluorocarbons and Perfluorocarbons. Published online at: 

http://books.google.com/books?id=Qf0MVNcQKmQC&printsec=frontcover&dq=Safeguarding+the+Ozone+L

ayer+and+the+Global+Climate+System:+Issues+Related+to+Hydrofluorocarbons+and+Perfluorocarbons&

source=bl&ots=5tP0u2fN9q&sig=cvbgcIUYRYSdi7h0RzraQDGM_U&hl=en&ei=wd0HTdh9wfrwBr6fge0G&sa=X&oi=book_result&ct=result&resnum=

5&ved=0CC0Q6AEwBA#v=onepage&q&f=false

The International Council on Clean Transportation (April 2010). Best Practices for Feebate Program Design 

and Implementation.

Iowa Department of Transportation, Transportation and Engineering Division. (1995) Miles, Vehicle Miles, 

Accidents and Accident Rates in Iowa By Road System, 1989-1993. 

Kammen, Daniel M., et.al. (April 2004; corrected January 2006) ―Putting Renewables to Work: How Many 

Jobs Can the Clean Energy Industry Generate?‖ Renewable and Appropriate Energy Laboratory, Goldman 

School of Public Policy, University of California — Berkeley. 

Katz, Bruce. ―Smart Growth Saves Money.‖ The Detroit News. Published on April 13, 2003, retrieved Dec. 7, 

2010 from http://www.brookings.edu/opinions/2003/0413metropolitanpolicy_katz.aspx?p=1

Konopacki, S. and H. Akbari. (2002) ―Energy Savings for Heat-Island Reduction Strategies in Chicago and 

Houston‖ (including updates for Baton Rouge, Sacramento, and Salt Lake City. Lawrence Berkeley National 

Laboratory LBNL-49638.

Konopaki, S. and H. Akbari. (2001) ―Energy Impacts of Heat Island Reduction Strategies in Toronto, 

Canada.‖ Lawrence Berkeley National Laboratory.

Litman, Todd. (June 2008). ―Distance Based Vehicle Insurance Feasibility, Costs and Benefits.‖ Victoria 

Transport Policy Institute.
Massachusetts Clean Energy and Climate Plan for 2020

VI. Reference

Page 113

McPherson, E.G., and J.R. Simpson. (1999) ―Carbon dioxide reduction through urban forestry: Guidelines 

for professional and volunteer tree planters.‖ Gen. Tech. Rep. PSW-GTR-171. Albany, CA: Pacific Southwest 

Research Station, Forest Service, US Dept. of Agriculture.

McPherson, E.G. and Rountree, R.A. (1993) ―Energy conservation potential of urban tree planting.‖ Journal 

of Arboriculture 19(6):321-331.

Minnesota Department of Transportation. (March 2006) ―Mileage-Based User Fee Demonstration Project: 

Potential Public Policy Implications of Pay-As-You-Drive Leasing and Insurance Products.‖

Mullan, Jeffrey B. (2010) MassDOT Policy Directive on GreenDOT. Massachusetts Department of 

Transportation.

Navigant Consulting. (September 2008) ―Economic Impacts of Extending Federal Solar Tax Credits.‖

Prepared for the Solar Energy Research and Education Foundation.

Nowak, D.J. (1994) ―Air pollution removal by Chicago's urban forest.‖ Chicago's Urban Forest Ecosystem: 

Results of the Chicago Urban Forest Climate Project. USDA Forest Service General Technical Report NE- 186. 

McPherson, E.G., Nowak, D.J., Rountree, R.A.(Eds.), pp. 63-81.

O’Connor, John T., and Marc Breslow et. al, (January 1997) The Massachusetts Green Jobs Report: How to 

Create 100,000 Jobs While Cleaning the Environment. GreenWorks. Table 2, page 16.

Oregon Department of Transportation. (November 2007) Oregon’s Mileage Fee Concept and Road User Fee 

Pilot Program Final Report.

Pollin, Robert, et.al. (September 2008) Green Recovery: A Program to Create Good Jobs and Start Building 

a Low-Carbon Economy. Political Economy Research Institute and Center for American Progress. Page 10.

Pollin, Robert, et.al. (June 2009) The Economic Benefits of Investing in Clean Energy. Political Economy 

Research Institute and Center for American Progress.

Riverside Public Utilities. ―Tree Power.‖ Published online, retrieved on Dec. 7, 2010 from 

http://www.riversideca.gov/UTILITIES/resi-treepower.asp

Sacramento Municipal Utility Department. ―Free Shade Trees.‖ Published online, retrieved on Dec. 7, 2010 

from http://www.smud.org/en/residential/trees/Pages/index.aspx

Sacramento Tree Foundation. ―Sacramento Shade.‖ Published online, retrieved on Dec. 7, 2010 from 

http://www.sactree.com/doc.aspx?25

Sterzinger, George and Matt Svrcek. (January 2005) Solar PV Development: Location of Economic Activity. 

Renewable Energy Policy Project.

Sterzinger, George and Jerry Stevens. (August 2007) Component Manufacturing: Massachusetts’s Future in 

the Renewable Energy Industry. Renewable Energy Policy Project. 

Sterzinger, George and Matt Svrcek. (September 2004) Wind Turbine Development: Location of 

Manufacturing Activity. Renewable Energy Policy Project.

Texas Transportation Institute. (2009) Urban Mobility Report.

Trees Forever. ―Home Page‖ Published online, retrieved on Dec. 7, 2010 from http://www.treesforever.org/
Massachusetts Clean Energy and Climate Plan for 2020

VI. Reference

Page 114

United States of America, 110th Congress. (January 2007). The Energy Independence and Security Act of 

2007. Published online at: http://frwebgate.access.gpo.gov/cgibin/getdoc.cgi?dbname=110_cong_bills&docid=f:h6enr.txt.pdf

United States of America, 110th Congress (September 2008). The Energy Improvement and Extension Act 

of 2008. Published online at: http://www.gpo.gov/fdsys/pkg/BILLS-110hr6049eas/pdf/BILLS110hr6049eas.pdf

United States Bureau of Labor Statistics. (2009) Consumer Expenditure Survey 2009.

United States Census Bureau. ―2007 Economic Census.‖ Published online, retrieved on Dec. 8, 2010 from 

http://www.census.gov/econ/census07/

United States Department of Commerce, Bureau of Economic Analysis. (2009) Gross Domestic Product by 

Industry for Massachusetts 2009.

United States Department of Commerce, Bureau of Economic Analysis. (Dec. 2010) RIMS II (Regional InputOutput Multiplier System) multipliers for Massachusetts 2007.

United States Department of Transportation Office of the Secretary of Transportation (February 5, 2008) 

Memorandum to Secretarial Officers Modal Administrators, ―Re: Treatment of the Economic Value of a 

Statistical Life in Departmental Analysis.‖

United States Department of Transportation; Research and Innovative Technology Administration Bureau of 

Transportation Statistics. ―Table 1-17: New and Used Passenger Cars Sales and Leases.‖ Published online, 

retrieved Dec. 14, 2010 from 

http://www.bts.gov/publications/national_transportation_statistics/html/table_01_17.html

United States Department of Transportation; Research and Innovative Technology Administration Bureau of 

Transportation Statistics. ―Table 2-1: Highway Traffic Fatalities and Fatality Rates 2008.‖ Published online, 

retrieved Dec. 14, 2010 from 

http://www.bts.gov/publications/state_transportation_statistics/state_transportation_statistics_2009/html/t

able_02_01.html

United States Department of Transportation Federal Highway Administration. (2006) ―Highway Performance 

Monitoring System Background Data.‖

United States Department of Transportation Federal Highway Administration. ―Highway Statistics: Table 

VM-2 — Functional System Travel 2008 1/Annual Vehicle Miles.‖ Published online at: 

http://www.fhwa.dot.gov/policyinformation/statistics/2008/vm2.cfm

United States Environmental Protection Agency. ―GreenChill Advanced Refrigeration Partnership.‖ Published 

online, retrieved Dec. 8, 2010 from http://www.epa.gov/ozone/partnerships/greenchill/

United States Environmental Protection Agency. ―GreenChill Store Certification Program.‖ Published online, 

retrieved Dec. 8, 2010 from http://www.epa.gov/ozone/partnerships/greenchill/certcenter.html

United States Environmental Protection Agency. ―Climate Change — Regulatory Initiatives, Subpart DD —

Use of Electric Transmission and Distribution Equipment.‖ Published online, retrieved Dec. 8, 2010 from 

http://www.epa.gov/climatechange/emissions/subpart/dd.html

United States Environmental Protection Agency. ―SF6 Emission Reduction Partnership for Electric Power 

Systems.‖ Published online, retrieved Dec. 8, 2010 from http://www.epa.gov/electricpower-sf6/
Massachusetts Clean Energy and Climate Plan for 2020

VI. Reference

Page 115

United States Environmental Protection Agency. (April 2010) Final Rulemaking to Establish Light-Duty 

Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards, Regulatory 

Impact Analysis, EPA-420-R-10-009. Published online at: 

http://www.epa.gov/otaq/climate/regulations/420r10009.pdf

United States Environmental Protection Agency. (2006) Global Mitigation of Non-CO2 Greenhouse Gases EPA 

Report 430-R-06-005. Published online at: 

http://www.epa.gov/climatechange/economics/downloads/GlobalMitigationFullReport.pdf

United States Environmental Protection Agency and Department of Transportation National Highway Traffic 

Safety Administration. (October 2010). ―EPA and NHTSA Propose First-Ever Program to Reduce Greenhouse 

Gas Emissions and Improve Fuel Efficiency of Medium- and Heavy-Duty Vehicles: Regulatory 

Announcement‖ Report No. EPA-420-F-10-901. Published online at: 

http://www.epa.gov/oms/climate/regulations/420f10901.pdf

Vickrey. Automobile Accidents, Tort Law, Externalities and Insurance: An Economist’s Critique. Law and 

Contemporary Problems 33: 464–87, 1968.