Speak out on Boston’s draft CCE plan!

The City of Boston wants public comments on its draft plan for Community Choice Energy (CCE). You can submit written comments until 5pm on Friday, May 17.

Please consider taking 15 minutes this week to send a short comment on the plan. Email david.musselman@boston.gov with “City of Boston’s Aggregation Plan” in the subject line.

In particular, we encourage you to comment on this section of the plan, which leaves open the possibility that Boston might look outside of New England for its renewable energy:

“The City will require that the RECs [Renewable Energy Certificates] either be created and recorded in the New England Power Pool [NEPOOL] Generation Information System or be certified by a third party such as Green-e.” (page 16)

Put simply, buying RECs is a way of paying for renewable energy. The “either…or be certified by a third party such as Green-e” in this sentence indicates that Boston is not committed to buying all its green energy from generators within our region (i.e. only those recorded by NEPOOL). We are concerned about this lack of commitment.

We see several advantages to keeping Boston’s electricity dollars within New England as much as possible. By supporting the local renewables industry, we encourage the development of more green generators in our own region. This will create jobs locally. It will also hopefully enable the retirement of some older, carbon-burning generators, which will reduce not only the greenhouse gas emissions that cause climate change, but also other types of pollution that threaten local public health. Additionally, the City Council’s authorization for CCE specified that the renewable content should come from our region.

Some may argue that the retirement of carbon-fired plants in other states is still a win for us, since greenhouse gases produced anywhere affect climate globally. What complicates this issue is the fact that the environmental effectiveness of green energy purchases vary from state to state. The strength of a state’s energy regulations and other market conditions affects the value – both environmental and financial — of its RECs. If, to save money, Boston were to buy from a state where green energy purchases do not stimulate new development or shutter dirty plants, Boston might claim to be “green” without effecting much change. This is called “greenwashing.”

If local renewables ever become so expensive as to make it impossible to offer any additional renewable content in Boston’s default CCE rate and still keep prices comparable with Eversource’s, only then would we want the City to consider purchases from outside New England. In that event, we would want the City to ensure that any out-of-region RECs we buy would be effective in stimulating further development of green energy generators.

For more details on how RECs work, we recommend this short video from the EPA or this essay from journalist David Roberts. Roberts specifically discusses the difference between Green-e RECs and RECs sourced from generators in our region.

For more about NEPOOL, see nepoolgis.com/about.

For an example of “greenwashing,” consider this short video from Cascade Policy Institute.

bnef-recs-regions

An illustration of the relative higher value of RECs generated in New England, compared to other regions. Image source: https://www.vox.com/2015/11/9/9696820/renewable-energy-certificates.

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