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HBRAMA submits comments on Draft Regulations for Fossil Fuel Ban

By March 20, 2023November 28th, 2023No Comments

The Department of Energy Resources (DOER) recently closed the comment period on draft regulations for the 10-Community Fossil Fuel Demonstration Project that will allow certain communities to ban all new future fossil fuel infrastructure. The ban would apply to all newly constructed buildings and major renovations to existing buildings.

The Home Builders and Remodelers Association of Massachusetts submitted two letters of comments to the Department of Energy Resources on draft regulations. The HBRAMA’s comments were included in a letter sent various affordable housing organizations, as well as in a letter from the Massachusetts Coalition for Sustainable Energy (MCSE) of which it is a member.

In its comments, the HBRAMA urged the DOER to take steps to provide affordable housing and mixed-income housing providers with flexibility and support to build fossil fuel free buildings without creating financial hardships for residents or contributing to the loss of affordable housing. Among the suggestions made to the DOER, were the following:

  • Provide funding and technical assistance for affordable housing projects already in progress;
  • Define “major renovations” to ensure that fossil free standards will only apply to projects whose scope of work includes replacing mechanical and electrical systems;
  • Create complementary financial and technical assistance programs to support affordable housing providers in adopting high-efficiency, all-electric construction in new and existing affordable housing;
  • Create a lower utility rate design for low- and moderate-income residents and affordable housing providers that will see an increase in their utility bills because of the switch from gas to electricity;
  • Ensure that individual projects located in these communities do not get saddled with exorbitant infrastructure upgrade costs or delayed permitting issues.

In the letter from MCSE, the HBRAMA urged the DOER to be explicit in requiring that communities seeking to participate in the project clearly demonstrate to the department the plans, methods and forms they will use to satisfy compliance reporting requirements relative to emission impacts, building and operating costs, and housing affordability.

The 10 communities that are considered likely to seek participation in the demonstration project are:

  • Cambridge
  • Newton
  • Brookline
  • Lexington
  • Arlington
  • Concord
  • Lincoln
  • Acton
  • Aquinnah
  • West Tisbury

The DOER is expected to finalize the regulations for the Demonstration Project shortly.

Copies of the letters can be found here and here.