lueprint for action - frontier group · ing sonia hamel of the executive office of commonwealth...

MASSPIRG Education Fund / Clean Water Fund 1

A BLUEPRINTFOR ACTIONPolicy Options to Reduce Massachusetts’Contribution to Global Warming

MASSPIRG EDUCATION FUNDCLEAN WATER FUNDSpring 2004

Written by:Tony Dutzik, Elizabeth Ridlington and Frank Gorke, MASSPIRG Education Fund

Cindy Luppi, Clean Water Fund

With Contributions from the New England Climate Coalition Steering Committee:

Clean Water Fund: Brooke Suter (Ct.), Roger Smith (Ct.), Doug Bogen (N.H.), Jed Thorp(Mass.), Sheila Dormody (R.I.)

State PIRGs: Kate Strouse Canada (RIPIRG Education Fund), Colin Peppard (MASSPIRG Educa-tion Fund), Josh Irwin (NHPIRG Education Fund), Drew Hudson (Vermont Public Interest Re-search and Education Fund)

Natural Resources Council of Maine: Sue Jones, Mark Hays

Massachusetts Climate Action Network: Marc Breslow

2 A Blueprint for Action

Cover photo credits: Wind turbines in winter: DOE/NREL; Solar panels: DOE/NREL; Energy Star: DOE; Com-pact Fluorescent Bulbs: DOE/NREL; Toyota Prius: Paul Madsen.Design and Layout: Kathleen Krushas, To the Point Publications.


ACKNOWLEDGMENTSThe authors thank the members of the New England Climate Coalition steering committee, who investedsignificant time and energy in crafting this project and reviewing this report. Special thanks to Rob Sargent ofthe state PIRGs for his project leadership and Marc Breslow of the Massachusetts Climate Action Network andSeth Kaplan of Conservation Law Foundation for their incisive review. Thanks also to Susan Rakov, JasmineVasavada and Travis Madsen for their editorial and technical assistance, and Jane Wong of Public Interest GRFXin Philadelphia for her assistance in securing cover graphics.

The authors also wish to thank Bruce Biewald, Geoff Keith and Lucy Johnston of Synapse Energy Economicsfor providing technical review of this publication and making numerous editorial and other suggestions thathave improved the quality of the final product.

Finally, the authors thank those who were particularly helpful in obtaining information for this report, includ-ing Sonia Hamel of the Executive Office of Commonwealth Development, Eric Friedman of the Office of StateSustainability and Chuck Shulock of the California Air Resources Board.

MASSPIRG Education Fund, Clean Water Fund and the New England Climate Coalition express our mostsincere thanks to the Jessie B. Cox Charitable Trust, the Energy Foundation, the John Merck Fund, the PewCharitable Trusts and the Rockefeller Brothers Fund for their generous financial support of this project.

The authors alone bear responsibility for any factual errors. The recommendations are those of MASSPIRGEducation Fund and Clean Water Fund. The views expressed in this report are those of the authors and do notnecessarily reflect the views of our funders or those who provided editorial or technical review.

©2004 MASSPIRG Education Fund and Clean Water Fund

The Massachusetts Public Interest Research Group (MASSPIRG) Education Fund is a nonprofit, non-partisan 501(c)(3) statewide public interest organization working on consumer, environmental andgood government issues.

Clean Water Fund is a national environmental organization whose work features neighborhood-basedaction, and education programs which join citizens, businesses, and government for sensible solutionsensuring safe drinking water, pollution prevention, and resource conservation.

The New England Climate Coalition is a coalition of more than 160 state and local environmental,public health, civic and religious organizations concerned about the drastic effects of global warmingin the Northeast.

For additional copies of this report, send $20 (including shipping) to:New England Climate Coalitionc/o Center for Public Interest Research29 Temple PlaceBoston, MA 02111-1350

For more information about Clean Water Fund, visit www.cleanwater.org. For more information about theMASSPIRG Education Fund, visit www.masspirg.org. For more information about the New England ClimateCoalition, visit www.newenglandclimate.org.


TABLE OF CONTENTSEXECUTIVE SUMMARY ....................................................................... 6

INTRODUCTION ............................................................................. 10

GLOBAL WARMING AND MASSACHUSETTS ................................................ 11

Causes of Global Warming ............................................................................................... 11

Current Indications of Climate Change ............................................................................ 13

Potential Impacts of Global Warming ............................................................................... 13

Carbon Dioxide Emission Trends...................................................................................... 14

Regional and State Responses ............................................................................................ 16

GLOBAL WARMING STRATEGIES FOR MASSACHUSETTS .................................. 21

Reducing Emissions from the Transportation Sector ......................................................... 21

Strategy #1: Finalize and Implement the State’s Clean Cars Requirement ..................... 21

Strategy #2: Adopt California’s Limits on Vehicle Carbon Dioxide Emissions .............. 22

Strategy #3: Set Standards Requiring Low Rolling Resistance Replacement Tires ......... 23

Strategy #4: Implement a “Feebate” Program ............................................................... 24

Strategy #5: Implement Pay-As-You-Drive Automobile Insurance ................................ 25

Strategy #6: Reduce Growth in Vehicle Miles Traveled ................................................. 26

Combined Impact of the Transportation Strategies ...................................................... 28

Additional Transportation Strategies to Consider ......................................................... 28

Reducing Emissions from Homes, Business and Industry ................................................. 29

Strategy #7: Strengthen Residential and Commercial Building Energy Codes .............. 29

Strategy #8: Adopt Appliance Efficiency Standards ...................................................... 30

Strategy #9: Expand Energy Efficiency Programs ......................................................... 31

Combined Impact of the Residential, Commercial and Industrial Strategies ................ 33

Additional Residential, Commercial and Industrial Sector Strategies to Consider ........ 33

Reducing Emissions from Electricity Generation .............................................................. 34

Strategy #10: Enforce, Strengthen and Extend the Renewable Portfolio Standard ........ 34


Strategy #11: Support the Development of Solar Power ............................................... 36

Strategy #12: Finalize Power Plant Emission Standards for Carbon Dioxide as a

Foundation for a Regional, Electric-Sector Carbon Cap ............................................. 37

The Role of a Regional Carbon Cap in Reducing Electric-Sector Emissions ................. 38

Other Electric Sector Strategies to Consider ................................................................. 39

Public Sector and Other Strategies .................................................................................... 39

Strategy #13: Public Sector “Lead by Example” ............................................................ 39

Strategy #14: Develop and Implement a Global Warming Emissions Registry ............. 40

The Impact of the Strategies ............................................................................................. 41

Short- and Medium-Term Impacts ............................................................................... 41

Putting it in Perspective – Achieving the Long-Term Goal ........................................... 42

METHODOLOGY AND TECHNICAL DISCUSSION .......................................... 45

NOTES ...................................................................................... 53


Massachusetts could make major stridestoward reducing its emissions of globalwarming gases over the next several de-

cades by adopting a series of policy strategies to makethe state more energy efficient and reduce the use offossil fuels.

Adoption of the 14 policy strategies in this reportwould bring Massachusetts significantly closer tomeeting its short- and medium-term commitmentsunder a 2001 agreement signed by the six New En-gland governors and their peers in eastern Canada. Inthe process, the strategies would reduce the state’sconsumption of energy and position Massachusettsto make the technological shifts necessary to achievethe long-term goal of reducing Massachusetts’ emis-sions of global warming gases to levels that do nothave a harmful effect on the climate.

Global warming, caused by human-induced changesin the climate, is a major threat to Massachusetts’future.

• Since the beginning of the Industrial Age, atmo-spheric concentrations of carbon dioxide – the lead-ing global warming gas – have increased by 31percent, a rate of increase unprecedented in thelast 20,000 years. Global average temperatures in-creased by about 1˚ F during the 20th century, arate of increase unprecedented in the last 1,000years.

• The effects of global warming are beginning toappear in Massachusetts and worldwide. Averagetemperatures in Massachusetts have increased byabout 1˚ F since 1895, accompanied by changingprecipitation patterns and other shifts.

• Average temperatures in Massachusetts are pro-jected to increase by between 1˚ F and 10˚ F overthe next century, accompanied by increased pre-cipitation. The results of these changes could in-clude higher sea levels, degraded air quality,increased heat-related deaths, and the loss of Mas-sachusetts’ hardwood forest species.

Emissions of carbon dioxide – the leading globalwarming gas – are on the rise in Massachusetts.

• Between 1990 and 2000, Massachusetts’ directemissions of carbon dioxide from energy use (otherthan electricity) increased by approximately 7 per-cent. Electricity consumption within the state alsoincreased by about 14 percent.

• Based on adjusted regional energy use projectionsfrom the U.S. Energy Information Administration,Massachusetts’ direct (non-electric) emissions ofcarbon dioxide could increase by as much as 28percent over the next two decades, with much ofthe increase taking place in the transportation sec-tor. Electric sector emissions in New England canbe expected to increase by about 35 percent be-tween 2000 and 2020 if the region’s nuclear reac-tors close at the expiration of their operatinglicenses to protect the environment and publichealth and safety.

Massachusetts could significantly reduce its globalwarming emissions by adopting 14 policy strategiesand encouraging other New England states to dothe same.

The policies include:

1. Putting increasing numbers of hybrid-electric cars(and eventually zero-emitting cars such as hydro-gen fuel-cell vehicles) on Massachusetts’ roadsover the next two decades by finalizing and imple-menting the state’s clean cars requirement.

2. Adopting California’s forthcoming limits on ve-hicle carbon dioxide emissions.

3. Requiring the sale of low-rolling resistance re-placement tires that improve vehicle efficiencywithout negatively affecting safety.

4. Establishing a “feebate” program to reward thepurchase of more fuel-efficient vehicles.

EXECUTIVE SUMMARY


5. Requiring automobile insurers to offer pay-as-you-drive automobile insurance, in which in-surance rates are calculated by the mile,rewarding those who drive less, while potentiallyreducing accidents.

6. Adopting policies that would reduce growth invehicle miles traveled by cars and light truckson Massachusetts’ highways, such as measuresto reduce sprawling development and encour-age the use of transit and other transportationalternatives.

7. Adopting the latest commercial and residentialbuilding energy codes to improve the energy ef-ficiency of new construction.

8. Adopting appliance efficiency standards for aseries of residential and commercial products.

9. Reducing energy use by increasing funding forenergy efficiency programs supported by elec-tricity ratepayers and creating similar energy ef-ficiency programs for natural gas and heating oil.

10. Bolstering Massachusetts’ Renewable PortfolioStandard to require 10 percent of Massachusetts’electricity to come from new, clean, renewablesources by 2010 and 20 percent by 2020.

11. Dramatically expanding the installation of solarphotovoltaic systems on homes and businessesthrough direct incentives and new methods offinancing.

12. Limiting emissions of carbon dioxide from elec-tric power plants through adoption of strongstate and regional power-sector carbon caps.

Table ES-1. Projected Carbon Dioxide Emission Reductions fromPolicies (million metric tons carbon equivalent — MMTCE)

Policy 2010 2020

Clean Cars Requirement 0.03 0.19

Carbon Dioxide Tailpipe Standards 0.05 0.69

Low Rolling Resistance Tires 0.11 0.18

Feebate Program 0.06 0.29

Pay-As-You-Drive Automobile Insurance 0.39 0.45

Reduce Vehicle Miles Traveled 0.43 1.23

Residential and Commercial Building Codes 0.024-0.036 0.33

Appliance Efficiency Standards 0.18-0.39 0.52

Expanded Energy Efficiency Programs 0.54-0.77 1.25

Expanded Renewable Portfolio Standard 0.42-0.96 0.56

Solar Power Development 0.001-0.003 0.005

State and Regional Electric-Sector Carbon Caps See high end of range of above estimates

Public Sector “Lead By Example” Policies 0.04-0.05 0.06

Regional Global Warming Emission Registry Not estimated

Note: Savings from individual policies do not equal cumulative savings due to some overlap between the policies.


13. Reducing government sector emissions through“lead by example” measures, such as the purchaseof renewable power, increased energy efficiency,and the purchase of more efficient vehicles forstate fleets.

14. Creating a framework for future market-orientedand/or regulatory responses to global warmingthrough a regional global warming emission reg-istry.

Adoption of all 14 strategies would achieve signifi-cant reductions in global warming emissions whileimproving Massachusetts’ energy efficiency and spur-ring the development of renewable sources of energy.

• Reductions versus projected emission levels:Adoption of these 14 strategies would reduce Mas-sachusetts’ direct (non-electric) carbon dioxideemissions by about 16 percent below projectedlevels by 2020. Adoption of all strategies by all sixNew England states would reduce electric-sectoremissions by as much as 45 percent below pro-jected levels by 2020.

• Reductions versus regional goals: New England-wide adoption of all 14 strategies would bring the

region as much as 70 percent of the way to meet-ing the regional global warming emission reduc-tion goal for 2010 and as much as 60 percent ofthe way to meeting the goal for 2020 – even withthe retirement of several nuclear reactors that cur-rently provide low-global warming emission elec-tricity at high risk to the environment and publichealth. (See Fig. ES-1.)

• In addition, many of the strategies have benefitsthat extend beyond reducing global warming emis-sions by reducing emissions of other health-threat-ening pollutants, increasing Massachusetts’ energysecurity, and keeping jobs and dollars in the localeconomy instead of sending money out of statefor fossil fuel purchases.

Massachusetts should seize the opportunity to re-duce its emissions of global warming gases.

• Massachusetts should adopt the 14 measures inthis report and investigate other policy options toreduce global warming emissions, especially withregard to reducing vehicle-miles traveled, limit-ing suburban sprawl, and encouraging the devel-opment of non-fossil, non-nuclear sources ofenergy.

Fig. ES-1 New England Carbon Dioxide Emissions from All Sectors(MMTCE)

Note: High Reduction case assumes strong state and regional electric-sector carbon caps. Low Re-duction case assumes weak or no caps.

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With Adoption of 14Strategies - LowReduction CaseWith Adoption of 14Strategies - HighReduction CaseRegional Goal


• Massachusetts should continue to participate inregional efforts to reduce global warming gas emis-sions, particularly the efforts of the Council ofNew England Governors and Eastern CanadianPremiers and the northeastern states’ negotiationsto establish a regional, power-sector carbon cap.

• Massachusetts should commit to achieving thegovernors’ and premiers’ long-term global warm-ing emission reduction goal by 2050 and begin toplan for making the technological and otherchanges that will be needed to achieve that goal.

• Massachusetts can and should reduce its globalwarming emissions without increasing the use ofnuclear power or extending the life of the state’snuclear plants beyond their current operating li-censes.


INTRODUCTION

The path toward reducing the potential severity ofglobal warming must begin with a resolve to do ourshare. It is a challenge that Massachusetts has acceptedin the past, through the adoption of policies that limitcarbon dioxide emissions from power plants, spur thedevelopment of renewable sources of energy, and re-duce global warming emissions from automobiles.Through these and other actions, Massachusetts hasestablished itself as a leader – setting an example thatother states have followed.

Now, it is time for Massachusetts to lead once again.In 2001, the governors of the six New England statesand their peers in eastern Canada agreed to adopt aground-breaking commitment to reduce the region’semissions of the gases that cause global warming. Thesuccess of that commitment, however, depends on thedevelopment and implementation of effective poli-cies to reduce global warming emissions in each ofthe New England states.

This report presents 14 policy opportunities that en-able Massachusetts to achieve most of the reductionsin global warming emissions called for under the re-gional agreement. They are by no means the only stepsMassachusetts can or should take to reduce its contri-bution to global warming. But they represent a soundplatform for future global warming efforts and moveMassachusetts significantly closer to the cleaner, moreefficient, more sustainable and healthier future we allseek.

The opportunity for leadership exists. It is time forMassachusetts to act.

Global warming is a frightening problem. Theconsensus view of climate science holds thatglobal temperatures are increasing, that

human activities are the cause, and that further warm-ing of the planet is inevitable unless we significantlyreduce our emissions of gases that trap heat in theearth’s atmosphere.

The precise impacts that global warming will have onMassachusetts are unpredictable, but it is virtuallycertain that the climatic shifts brought about by warm-ing will leave forests, rivers, coastlines and disease andweather patterns far different than we have knownthem – and so too, the New England way of life.

While the effects of global warming are frightening,the solutions need not be. We now know how to makeappliances, automobiles, homes and buildings that useenergy more efficiently, reducing global warmingemissions from the combustion of fossil fuels. Renew-able energy sources such as wind and solar power arebecoming increasingly cost-competitive with tradi-tional forms of energy. And highly advanced new tech-nologies – such as fuel cells – show the potential tochange the means by which we create and use energyin fundamental ways.

We also know that the patterns of consumption andtravel that have been established over the last half-century in Massachusetts are not sustainable in thelong run – the traffic on our highways, the conges-tion on our electric lines, and our dwindling supplyof open spaces are constant reminders of the need tofind smarter ways for our commonwealth to grow.And events at home and abroad remind us of the needto find more secure and reliable sources of energy.


Global warming poses a clear danger to Mas-sachusetts’ future health, well-being andprosperity. Massachusetts contributes to glo-

bal warming primarily through the combustion offossil fuels, which emit carbon dioxide to the atmo-sphere. Massachusetts’ emissions of carbon dioxideand other global warming gases have increased overthe last decade and will likely continue to increase inthe absence of concerted action.

Causes of Global Warming

Global warming is caused by human exacerbation ofthe greenhouse effect. The greenhouse effect is a natu-ral phenomenon in which gases in the earth’s atmo-sphere, including water vapor and carbon dioxide, trapheat from the sun near the planet’s surface. The green-house effect is necessary for the survival of life; with-

out it, temperatures on earth would be too cold forhumans and other life forms to survive.

But human activities, particularly over the last cen-tury, have altered the composition of the atmospherein ways that intensify the greenhouse effect by trap-ping more of the sun’s heat near the earth’s surface.Since 1750, for example, the concentration of carbondioxide in the atmosphere has increased by 31 per-cent as a result of human activity. The current rate ofincrease in carbon dioxide concentrations is unprec-edented in the last 20,000 years.1 Concentrations ofother global warming gases have increased as well. (SeeFig. 1.)

As the composition of the atmosphere has changed,global temperatures have increased. Global averagetemperatures increased during the 20th century by

Fig. 1. Atmospheric Concentrations of Greenhouse Gases2

GLOBAL WARMING AND MASSACHUSETTS


about 1° F. In the context of the past 1,000 years,this amount of temperature change is unprec-edented, with 1990 to 2000 being the warmestdecade in the millennium. Fig. 2 shows tempera-ture trends for the past 1,000 years with a rela-tively recent upward spike. Temperatures in thepast 150 years have been measured; earlier tem-peratures are derived from proxy measures suchas tree rings, corals, and ice cores.

This warming trend cannot be explained by natu-ral variables – such as solar cycles or volcanic erup-tions – but it does correspond to models of climatechange based on human influence.3

Other Global Warming GasesSeveral gases other than carbon dioxide arecapable of exacerbating the greenhouse effectthat causes global warming. The other majorglobal warming gases are:

• Methane – Methane gas escapes from gar-bage landfills, is released during the extrac-tion of fossil fuels, and is emitted by livestockand some agricultural practices. It is the sec-ond-most important global warming gas inNew England in terms of its potential to ex-acerbate the greenhouse effect.

• Fluorocarbons – Used in refrigeration andother products, many fluorocarbons are ca-pable of inducing strong heat-trapping ef-fects when they are released to theatmosphere. Because they are generally emit-ted in small quantities, however, they areestimated to be responsible for only about 1percent of New England’s contribution to glo-bal warming.5

• Nitrous Oxide – Nitrous oxide is released inautomobile exhaust, through the use of ni-trogen fertilizers, and from human and ani-mal waste. Like fluorocarbons, nitrous oxideis a minor, yet significant, contributor to glo-bal warming.

• Sulfur Hexafluoride – Sulfur hexafluoride ismainly used as an insulator for electrical trans-mission and distribution equipment. It is anextremely powerful global warming gas, withmore than 20,000 times the heat-trappingpotential of carbon dioxide. However, it isreleased in only very small quantities and isresponsible for only a very small portion ofthe state’s contribution to global warming.

• Black Carbon – Black carbon, otherwiseknown as “soot,” is a product of the burningof fossil fuels, particularly coal and diesel fuel.Recent research has suggested that, becauseblack carbon absorbs sunlight in the atmo-sphere, it may be a major contributor to glo-bal warming, perhaps second in importanceonly to carbon dioxide. Research is continu-ing on the degree to which black carbon emis-sions contribute to global warming.

This report focuses mainly on emissions ofcarbon dioxide from energy use, since theseemissions are responsible for the majority ofMassachusetts’ contribution to globalwarming. Steps to reduce emissions of otherglobal warming gases should also be part ofthe state’s efforts to curb global climatechange.

Fig. 2. Northern Hemisphere Temperature Trends4


A Note on UnitsThere are several ways to communicatequantities of global warming emissions. Inthis report, we communicate emissions interms of “carbon equivalent” – in otherwords, the amount of carbon that would berequired to create a similar global warmingeffect. Other studies frequentlycommunicate emissions in terms of “carbondioxide equivalent.” To translate the lattermeasure to carbon equivalent, one cansimply multiply by 0.273.

Current Indications of

Climate Change

The first signs of global warming are beginning toappear, both in Massachusetts and around the world.Average temperatures have risen. Global average tem-peratures have increased by about 1° F in the pastcentury. In the same period, the average temperaturein Amherst has increased by 2° F.6 Statewide, averagetemperatures are estimated to have increased by 1° Fbetween 1895 and 1999.7

Precipitation patterns have changed. Precipitation hasincreased by 20 percent in some parts of Massachu-setts.8 Maine, New Hampshire, and Vermont haveexperienced a 15 percent decrease in snowfall.9 Inother parts of the world, such as Asia and Africa,droughts have been more frequent and severe, a changethat is consistent with models of climate change.10

Cold seasons have been shorter and extreme low tem-peratures less frequent. Since the late 1960s, North-ern Hemisphere snow cover has decreased by 10percent and the duration of ice cover on lakes andrivers has decreased by two weeks.11 Glaciers aroundthe world have been retreating.12

Oceans have risen as sea ice has melted. Average sealevels have risen 0.1 to 0.2 meters in the past cen-tury.13

Potential Impacts of

Global Warming

The earth’s climate system is extraordinarily complex,making the ultimate impacts of global warming in aparticular location – as well as the pace of change –difficult to predict. There is little doubt, however, thatglobal warming could lead to dramatic disruptions inthe world’s and Massachusetts’ economy, environ-ment, health and way of life.

Temperature increases in the past century have beenmodest compared to the increases projected for thenext 100 years. Global temperatures could rise by anadditional 2.5° F to 10.4° F over the period 1990 to2100.14 In Massachusetts, temperatures could increaseby 1° F to 10° F by 2100.15 Others estimate that a1.8° F increase in average temperature could occurNew England-wide as soon as 2030, with a 6° F to10° F increase over current average temperatures by2100.16 Such an increase in temperature would causea profound shift in Massachusetts’ environment; a 10°F increase in the average annual temperature in Bos-ton, for example, would leave the city with an averagetemperature similar to present-day Atlanta.17

Precipitation levels also could change. Massachusettscould experience an increase in precipitation of 10 to60 percent, with greater change in winter and lesschange in spring and summer.18

In any event, the impacts of such a shift in averagetemperature and precipitation would be severe.Among the potential impacts:19

• Longer and more severe smog seasons as highersummer temperatures facilitate the formation ofground-level ozone, resulting in additional threatsto respiratory health such as aggravated cases ofasthma.

• Increased spread of exotic pests and shifts in forestspecies – including the loss of hardwood forestsresponsible for Massachusetts’ vibrant fall foliagedisplays.

• Shifts in populations of fish, lobster and otheraquatic species due to changing water temperaturesand changes in the composition of coastal estuar-ies and wetlands.


• Increases in toxic algae blooms and “red tides,”resulting in fish kills and contamination of shell-fish.

• Declines in freshwater quality due to more severestorms, increased precipitation and intermittentdrought, potentially leading to increases in water-borne disease.

• Increased coastal flooding due to higher sea levels,with sea levels projected to rise by about 22 inchesnear Boston and by as much as 40 inches alongCape Cod over the next century.

• Increased spread of mosquito and tick-borne ill-nesses, such as Eastern equine encephalitis, ma-laria and dengue fever.

• Increased risk of heat-related illnesses and deaths– perhaps by as much as 50 percent, from 100 to150 annually.

• Disruption to traditional New England industriessuch as fall foliage-related tourism, maple syrupproduction and skiing.

The likelihood and severity of these potential impactsis difficult to predict. But this much is certain: cli-mate changes such as those predicted by the latest sci-entific research would have a dramatic, disruptiveeffect on Massachusetts’ environment, economy andpublic health – unless immediate action is taken tolimit our emissions of greenhouse gases such as car-bon dioxide.

Carbon Dioxide

Emission Trends

The vast majority of carbon dioxide emissions inMassachusetts result from the combustion of fossil

fuels. Fossil fuels are burned directly in homes, busi-nesses, vehicles and industrial facilities to produce heatand to power machinery. Individuals and businessesalso consume fossil fuels indirectly when they use elec-tricity, much of which is created through the com-bustion of coal, oil and natural gas in power plants.

New England’s economy is integrated across state lines,making it difficult in some cases to assign responsi-bility for carbon dioxide emissions to a particular state.For example, Massachusetts draws its electricity froma New England-wide electric grid, which is suppliedwith power from across the region and beyond.

As a result, in this report we will consider emissionsfrom energy end users and emissions from electricitygeneration differently. We will assess emissions fromresidential, commercial and industrial fuel combus-tion at the state level and emissions from electricitygenerators at the regional level.

Massachusetts’ Direct Emissions(Non-Electric)Carbon dioxide emissions from sources other thanelectricity generation increased in Massachusetts byapproximately 7 percent from 1990 to 2000 – from15.4 million metric tons carbon equivalent(MMTCE) to 16.4 MMTCE.20 (See Table 1.) Thisestimate does not include emissions from the use ofelectricity in any of the sectors. While emissions inthe residential, industrial and transportation sectorsincreased significantly during the decade, commer-cial emissions declined, due to the shift from higher-emitting petroleum to lower-emitting natural gas inmany commercial establishments and the lack of amajor increase in overall commercial energy use.

In 2000, the transportation sector was responsible forapproximately 53 percent of Massachusetts’ carbon

Table 1. Historic and Projected (Base Case) Massachusetts Non-ElectricCarbon Dioxide Emissions (MMTCE)21

1990 2000 2010 2020

Direct Emissions 15.4 16.4 18.6 20.9

Pct. Increase Over 1990 7% 21% 36%


dioxide emissions from sources other than electricitygeneration. The residential sector was responsible forabout 25 percent of direct emissions, with the com-mercial sector responsible for 11 percent and the in-dustrial sector for 11 percent. (See Fig. 3.)

The U.S. Energy Information Administration (EIA)has projected rates of increase in energy use in NewEngland from 2000 to 2020. Applying the EIA’s pro-jected New England rates of energy use increases (withan adjustment to reduce what appears to be an over-estimate of future transportation gasoline use) to Mas-sachusetts, and applying standard fuel-specificemission factors to those estimates, Massachusetts isprojected to experience a 28 percent increase in di-rect carbon dioxide emissions from energy use between2000 and 2020 in the absence of mitigating action.22

Between 2000 and 2010, emissions from these sourcescould increase by about 2.2 MMTCE, with a further2.4 MMTCE increase between 2010 and 2020. Most

Fig. 4. Massachusetts Projected (Base Case) Non-Electric Carbon DioxideEmissions, 2000-2020

Table 2. Historic and Projected (Base Case) Electric Sector CarbonDioxide Emissions in New England Without Nuclear Relicensing

(MMTCE)23

1990 2000 2010 2020

Electric Sector 12.0 12.6 13.8 17.0

Pct. Increase Over 1990 5% 15% 42%

Fig. 3. Massachusetts Direct(Non-Electric) 2000 Carbon

Emissions by Sector

Residential Use25%

Commercial Use11%

Industrial Use11%

Transportation Use53%

of the increase in emissions is projected to take placein the transportation sector. (See Fig. 4.)

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scheduled to expire before 2020. For environmentaland public health reasons, the relicensing of existingnuclear plants or the construction of new plants isnot an appropriate strategy to address global warm-ing. (See “The Dangers of Nuclear Power,” page 18.)Thus, in this report, we have adjusted the EIA pro-jections to reflect the closure of nuclear plants as theirlicenses expire and their replacement with additionalnew natural gas-fired generation. This assumptionresults in significant increases in projected emissionsof carbon dioxide versus a projection made based onEIA’s projected trends.

Without the relicensing of nuclear reactors, carbondioxide emissions from electricity generation in theregion can be expected to increase by approximately35 percent – or 4.4 MMTCE – between 2000 and2020.25 (See Fig. 5.)

Regional and State

Responses

The threat posed by global warming has provoked avariety of responses in Massachusetts and the NewEngland region. Despite a lack of leadership at thefederal level – as evidenced by the U.S. government’sunwillingness to support the Kyoto Protocol – regionalorganizations, governmental agencies, non-profits andsome business groups have made efforts to craft solu-tions that would reduce New England’s contributionto global warming.

Regional Electric Sector EmissionsCarbon dioxide emissions from the electric power sec-tor in New England increased by approximately 5percent – or 0.6 MMTCE – between 1990 and 2000.(See Table 2, previous page.) The relatively modest rateof growth is due largely to the shift from higher-pollut-ing coal and petroleum to less-polluting natural gas.

That shift had particularly profound effects in Mas-sachusetts. Carbon dioxide emissions from electricitygeneration within the state decreased significantlybetween 1990 and 2000 – from 7.0 MMTCE to 6.3MMTCE. The reductions were driven by fuel switch-ing from petroleum to natural gas, coupled with areduction in the amount of electricity generated withinthe state.

But reductions in in-state emissions from electricitygeneration – welcome though they may be – tell onlypart of the story. The consumption of electricity inMassachusetts increased by about 14 percent duringthe 1990s, while in-state generation of electricity de-clined slightly.24 Because the electric power used inMassachusetts comes from a regional electric grid, thisincrease in consumption likely resulted in higher car-bon dioxide emissions from sources outside of Mas-sachusetts.

EIA’s projections of future trends in energy use in NewEngland assume the continued operation of threenuclear power plants – including Massachusetts’ Pil-grim nuclear reactor – whose operating licenses are

Table 3. Summary of Historic and Projected Carbon Dioxide Emissions andRegional Goal (MMTCE)

1990 2000 2010 2020MASSACHUSETTS DIRECT CARBON DIOXIDE EMISSIONSHistoric/Projected Emissions 15.4 16.4 18.6 20.9Regional Goal 15.4 13.8Reductions From Projection Needed to Achieve Goal 3.2 7.1

NEW ENGLAND ELECTRIC SECTOR EMISSIONSHistoric/Projected Emissions 12.0 12.6 13.8 17.0Regional Goal 12.0 10.8Reductions From Projection Needed to Achieve Goal 1.8 6.2


Fig. 5. Projected (Base Case) Carbon Dioxide Emissions from ElectricGeneration in New England (MMTCE)26

New England/Eastern CanadaClimate Change Action PlanIn September 2001, the governors of the six NewEngland states, along with the premiers of the easternCanadian provinces, adopted a regional ClimateChange Action Plan that set specific goals for the re-duction of global warming emissions in the region.The governors’ and premiers’ action was based on ahistory of international cooperation within the regionto address environmental threats such as acid rain.

In the short term (by 2010), the plan calls for thereduction of global warming emissions in the regionto 1990 levels. The medium-term goal, to be achievedby 2020, is to reduce emissions to 10 percent below1990 levels. In the long run, the plan aims to achievereductions of the degree needed to minimize danger-ous threats to the climate. Scientists currently esti-mate that this will require reductions of 75 to 85percent below current emissions levels.33

The agreement acknowledged that not every jurisdic-tion or every economic sector has the same potentialto reduce its global warming emissions. However, inorder to achieve the goals of the plan, it was envi-sioned that each state and sector of the economy wouldstrive to make its share of the reductions.

The regional agreement also included a series of com-mitments for reductions in global warming emissions

from conservation activities and from the transporta-tion, electric and government sectors. Even if thesesector-specific commitments are fulfilled, however, a2003 New England Climate Coalition report esti-mated that the region’s emissions of global warminggases will still exceed the goals of the Climate ChangeAction Plan.34 (See Fig. 6, page 19.) To close the gapbetween the regional goals and the emission levels thatwould result from the sector-specific commitments,the Action Plan called upon states to develop theirown plans and policies to reduce global warmingemissions.

The Conference of New England Governors and East-ern Canadian Premiers (NEG/ECP) is continuingwork toward implementation of the plan, focusingspecifically on the development of an updated regionalgreenhouse gas inventory, the implementation of “leadby example” measures by state and provincial govern-ments, and the investigation of measures to reducetransportation sector emissions and improve energyefficiency.

Massachusetts Greenhouse GasEmission Reduction EffortsThe regional Climate Change Action Plan also calledupon each of the states to evaluate its current carbon

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The Dangers of Nuclear PowerFor the last several decades, New England hasrelied upon nuclear power for a significantshare of its electricity. However, between nowand 2026, the operating licenses of all of NewEngland’s operating nuclear reactors arescheduled to expire. For environmental andpublic health reasons, neither the relicensingof existing nuclear reactors beyond theiroriginal 40-year lifespans nor the constructionof new nuclear facilities should be consideredas a means to reduce global warmingemissions.

• Accident risk – In the short history ofnuclear power, the industry has experiencedtwo major accidents – at Three Mile Island andChernobyl – that endangered the health ofmillions of people. The Chernobyl accidentalone contaminated an area stretchingapproximately 48,000 square miles, with apopulation of 7 million. Even today, 18 yearsafter the accident, the region surrounding thereactor continues to suffer from highlyelevated rates of thyroid and breast cancerand long-term damage to the environment andagriculture.27

While the United States has thus far beenspared an accident of the scale of Chernobyl,there have been numerous “near-misses.” Forexample, in 2002, workers discovered afootball-sized cavity in the reactor vessel headof the Davis-Besse nuclear reactor in Ohio.Left undetected, the problem could haveeventually led to the leakage of coolant fromaround the reactor core.

• Terrorism and sabotage – The securityrecord of nuclear power plants is far fromreassuring. In tests at 11 nuclear reactors in2000 and 2001, mock intruders were capableof disabling enough equipment to causereactor damage at six plants.28 A 2003 GeneralAccounting Office report found significantweaknesses in the Nuclear RegulatoryCommission’s oversight of security atcommercial nuclear reactors.29

• Spent Fuel – Nuclear power productionresults in the creation of tons of spent fuel,which must be stored either on-site or in acentralized repository. Both options posesafety problems. Centralized waste repositoriesrequire the transport of high-level nuclearwaste across highways and rail lines withinproximity of populated areas. Once the wastearrives, it must be held safely for tens ofthousands of years without contaminating theenvironment or the public. On-site storageposes its own problems. Nearly all U.S. nuclearreactors store waste on site in water-filledpools at densities approaching those in reactorcores. Should coolant from the spent-fuelpools be lost, the fuel could ignite, spreadingradioactive material across a large area. Thecost of such a disaster, were it to occur, hasbeen estimated at 54,000-143,000 deaths fromcancer and evacuation costs of more than$100 billion.30

• Cost – Nuclear power has often proven to beexpensive in market terms, due to the highcost of building, maintaining anddecommissioning nuclear reactors. But lookingonly at market costs obscures the more than$100 billion spent by U.S. taxpayers forresearch and development, protection againstliability from accidents, and other subsidies fornuclear power.31 Without these subsidies, thenuclear industry likely could not have survived.

• Aging – Continued operation of nuclearreactors beyond their initial projected 40-yearlifespan could lead to unforeseen safetyproblems. In 2001, the Union of ConcernedScientists identified eight instances in just theprevious 17 months in which nuclear reactorswere forced to shut down due to age-relatedequipment failures.32

For these reasons and others, nuclear powershould remain “off the table” as a potentialmeans to reduce global warming emissions inNew England, and the region should advocatefor, and begin to plan for, the orderlyretirement of New England’s nuclear reactors.


dioxide emission levels and develop a plan for achiev-ing required global warming emission reductions.

Massachusetts began this process well before agreeingto the regional Climate Change Action Plan. In 1998,the state began preliminary planning for how to re-duce its emissions by convening a series of meetingswith citizens, interested organizations, and businesses.The participants worked in issue groups to brainstormsuggestions for how the state could reduce its emis-sions. Ideas ranged from the minute—substitution ofone product for another more carbon-intensive one—to the very broad, such as using more renewable en-ergy. Once the list had been compiled, the ExecutiveOffice of Environmental Affairs (now the Office ofCommonwealth Development) began to evaluate theoptions and narrow down the list of policies the stateshould pursue. The state’s final report, with a strongfocus on the strategies the state must implement andrecommendations on how to act quickly on them,will be released this year.

In addition to undertaking this broader planning pro-cess, Massachusetts has already implemented severalpolicies that will result in significant reductions inglobal warming emissions. Among the most impor-tant such policies are the state’s renewable portfoliostandard (RPS) for electricity generation, which willrequire 15 percent of the state’s electricity to comefrom new, clean renewable resources by 2020, andsystems benefit charges (SBCs) on electricity bills that

generate funding for energy efficiency and renewableenergy programs. Massachusetts is the first state inthe country to regulate carbon dioxide emissions frompower plants, though the rule specifying how coal andoil power plants must control their carbon dioxide,mercury, nitrogen oxides, and sulfur dioxide emissionsis still being implemented. The state has also longsought to reduce carbon emissions from vehicles bycommitting itself to adopting California’s zero-emis-sion vehicle (ZEV) requirements, which will lead tothe sale of cars that produce no direct emissions ofcarbon dioxide or other pollutants. Final regulationsimplementing recent changes to the ZEV programalso have yet to be adopted.

New England Climate CoalitionAction PrinciplesIn 2001, in response to the development of the re-gional Climate Change Action Plan, a coalition ofleading organizations from throughout New Englandworked together to articulate a set of principles toguide the region’s efforts toward achieving reductionsin global warming emissions. The New England Cli-mate Coalition’s 10 action principles have been en-dorsed by 160 environmental, public health, civic andreligious organizations in the six New England statesand Canada.

Fig. 6. Carbon Dioxide Emission Reductions in New England UnderImplementation of Regional Climate Change Action Plan35

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The principles are:

1) By 2010, reduce greenhouse gas emissions tolevels 10 percent below 1990 levels. The inter-national community has negotiated a treaty withbinding commitments on most of the industri-alized nations to reduce emissions to well below1990 levels. The U.S. has failed to sign onto thetreaty, but as the biggest emitter of heat-trappinggases, we must lead by reducing our emissionsby at least the same percentage as the other larg-est polluters.

2) The NEG-ECP’s long-term goal of reducinggreenhouse gas emissions by 75-85 percentshould be given a target date of 2050. This time-table is necessary to stem the increase of CO

2

concentrations and minimize global temperaturevariation.

3) Each consuming sector should be responsiblefor at least its proportionate share of the tar-geted emission reductions. Any changes to theseresponsibilities should be based on an explicit pro-cess, which justifies changes by the relative cost-effectiveness in each sector, and ensures that anyshortfalls in one sector are offset by greater re-ductions in another. (The sectors to be includedare transportation, industrial, commercial, insti-tutional, and residential. This recognizes that theelectricity sector targets will overlap.)

4) The region and each of the states should estab-lish a system of mandatory reporting of CO

2

and other greenhouse gas emissions by 2005.

5) Reducing emissions from the electricity sectoras a whole by 40 percent from current levels.Every state plan should include provisions for re-ducing CO

2 emissions from grandfathered power

plants. Increasing the use or output of nuclearpower is an unacceptable strategy for reducingelectricity sector greenhouse gas emissions.

6) The region and each of the states should set atarget of 10 percent of electricity consumptionfrom new, clean renewable sources by 2010, and20 percent of electricity consumption from new,clean renewable sources by 2020.

7) Every plan should include a target of increasingenergy efficiency in each sector by 20 percentby 2010. The plans should consider more effi-cient generation of power, strong efficiency andconservation measures and greater use of com-bined heat and power and micropower options.

8) The states should lead by example by:a. Purchasing 20 percent of state facility electric-

ity from clean, renewable sources by 2010.b. Greening the state fleet by establishing poli-

cies that require each vehicle purchased to bethe model that emits the least CO

2 and other

air pollutants per mile traveled, while fulfill-ing the intended state function; prohibit theuse of inefficient vehicles such as SUVs for non-essential purposes; and establish a schedule forreplacing all state vehicles with the most effi-cient models available.

c. Reducing state government’s energy use by 25percent overall by 2010.

9) Each plan should include long-term plans forcontrolling sprawl, which is one of the primaryfactors raising emissions from transportationand buildings. At a minimum, this should startby incorporating an assessment of CO

2 impacts

into the state environmental review process.

10) Each plan should recognize the economic de-velopment and job creation benefits of strate-gies to reduce greenhouse gas emissions. Andeach plan should also recognize the importanceof assisting displaced workers in making a suc-cessful transition to new employment.

The policy strategies that follow attempt to turn theseprinciples into a concrete plan of action. In some cases,the policy strategies achieve results that go beyondthose envisioned by the principles; in other cases, theyfall short, and additional actions will be needed. Buteach of the strategies will help to propel the state to-ward achievement of its overall global warming emis-sion reduction goals.


Reducing Emissions from

the Transportation Sector

The transportation sector poses the greatest challengefor Massachusetts as the state seeks to reduce its emis-sions of global warming gases. Not only is transporta-tion Massachusetts’ largest source of carbon dioxideemissions – responsible for about 39 percent of totalin-state emissions in 2000 – but it is also among thefastest-growing sources. Transportation-sector carbondioxide emissions increased by 11 percent in Massa-chusetts between 1990 and 2000, and could increaseby an additional 41 percent between 2000 and 2020if trends toward increasing vehicle travel continue.36

Light-duty vehicles are by far the largest source oftransportation-sector carbon dioxide emissions, re-sponsible for about two-thirds of transportation emis-sions in Massachusetts.37 Any strategy to deal withtransportation’s contribution to global warming, there-fore, must begin with addressing emissions from cars,light trucks and SUVs.

There are three ways to reduce emissions from motorvehicles: improve fuel economy, switch to low-car-bon fuels, or reduce vehicle travel. To achieve the kindsof reductions needed to meet Massachusetts’ commit-ments, the state will have to make progress in all threeareas.

Strategy #1: Finalize and Implementthe State’s Clean Cars RequirementPotential Savings: 0.03 MMTCE by 2010; 0.19MMTCE by 2020.38

The federal Clean Air Act allows states that fail tomeet clean air health standards to choose between twosets of emission standards for automobiles: those inplace at the federal level and the traditionally tougherstandards adopted by the state of California.

In 1990, California established a new type of emis-sion standard on vehicles sold in the state. In addi-tion to meeting strict tailpipe standards (contained inthe state’s Low Emission Vehicle – or LEV – rules), acertain percentage of vehicles sold in the state would

have to be “zero-emission vehicles” (ZEV). Over thedecade-plus since the adoption of the ZEV standard,the rules governing the program have evolved to re-flect changes in technology and to increase the op-tions available to automakers for meeting therequirement. The standards are scheduled to go intoeffect in California for the 2005 model year, and forthe 2007 model year in other states that have adoptedCalifornia standards.

Massachusetts has already adopted California’s emis-sion standards for automobiles. But recent changes tothe ZEV program rules in California require thatMassachusetts formally adopt the latest version of theprogram. Because the Clean Air Act requires statesadopting California standards to give manufacturerstwo years of lead time prior to enforcement, Massa-chusetts must adopt the new version of the programthis year in order to begin implementation in 2007.Otherwise, the standards will be delayed, meaning thatMassachusetts will miss the opportunity to place thou-sands of cleaner vehicles on the state’s highways.

While primarily a program for reducing smog-form-ing and toxic emissions from automobiles, the ZEVprogram’s “technology forcing” component will likelyreduce carbon dioxide emissions by requiring the in-troduction of significant numbers of “advanced tech-nology” vehicles (such as hybrid-electric vehicles) and,beginning in 2012, hydrogen fuel cell vehicles. Be-ginning in 2006 (which is when 2007 model year carswill go on sale), automakers will be required to sellthe equivalent of tens of thousands of hybrid vehiclesper year in Massachusetts, with the numbers increas-ing over time. Then, beginning in 2012, automakerswill be required to sell small numbers of hydrogenfuel-cell vehicles – again, with the numbers increas-ing over time. By 2020, about 12 percent of new light-duty vehicles sold in Massachusetts would be hybrids,while about 3 percent would be hydrogen fuel-cell orother vehicles with zero emissions.39

In the near term, the ZEV program will place tens ofthousands of hybrid-electric vehicles on Massachu-setts’ highways. Hybrids – such as the Toyota Priusand Honda Civic – use a small electric motor tocomplement the vehicle’s gasoline engine. The elec-tric motor allows the engine to be turned off at stop

GLOBAL WARMING STRATEGIES FOR MASSACHUSETTS


lights and helps to propel the vehicle. Hybrid systemsalso capture energy typically lost in braking and allowit to be used to help move the vehicle. The battery forthe electric motor is recharged through normal ve-hicle use, so the vehicle never needs to be rechargedfrom the electric grid.

Hybrid-electric vehicles have already proven popularwith drivers in Massachusetts and elsewhere. Hybrid-electric vehicle sales were expected to reach 40,000 inthe U.S. in 2003 and are expected to exceed 177,000by 2005.40 The 2004 Toyota Prius was recently namedMotor Trend magazine’s “Car of the Year” and one ofCar and Driver’s “10 Best Cars.”

By setting targets for the sale of hybrid and other ve-hicles that are likely to emit less carbon than conven-tional vehicles, the ZEV program encouragesautomakers to introduce more models of clean cars,giving Massachusetts residents broader choice of ve-hicles that are also highly efficient. In addition, theZEV programs in Massachusetts and other states willhelp automakers to achieve economies of scale in theproduction of hybrids, which would presumably beaccompanied by a decrease in price. In the meantime,federal tax incentives (which are scheduled to bephased out over the next several years) can help Mas-sachusetts consumers to afford hybrid vehicles, whichtypically cost about $3,000-$4,000 more than simi-lar models.

The future of hydrogen fuel cell vehicles is less cer-tain. Fuel cells use a chemical reaction involving hy-drogen to produce electricity, which is then used topower a vehicle. When pure hydrogen is used in afuel cell, the only byproducts are water and heat.

A limited number of fuel cell vehicles are currentlyon the road in demonstration projects. And while mostmajor automakers have stated that they are commit-ted to developing fuel cell vehicles, none has thus farcommitted to a firm timeline for widescale introduc-tion. More vexing, significant technological and mar-ket hurdles remain in the way of an effective systemfor generating, storing and distributing pure hydro-gen. Even if pure hydrogen can be used as a fuel, thepossibility exists that polluting and dangerous fuelssuch as coal and nuclear power could be used to gen-erate the hydrogen, creating new environmental and

public health threats. Thus, renewable sources of hy-drogen are central to a fuel cell future that deliversdramatic reductions in greenhouse gas emissions.

Despite these potential problems, fuel cells are inher-ently more efficient than traditional internal com-bustion engines and, ideally, could become anemission-free form of transportation for the future.Other technologies, such as battery-electric vehicles,are advancing as well, and could help fulfill the re-quirement for vehicles with no direct pollutant emis-sions, while natural gas and other clean alternative-fuelvehicles could also be used to meet program require-ments. Much as the original ZEV program in Cali-fornia sparked research into electric vehicles thateventually led to today’s hybrids, so too will the tech-nology-forcing aspects of the current ZEV programhasten the development of the next generation of au-tomotive technologies.

In its Greenhouse Gases, Regulated Emissions andEnergy Use in Transportation (GREET) model, theArgonne National Laboratory estimates that hybrid-electric passenger cars release approximately 47 per-cent less carbon dioxide per mile than conventionalvehicles. Fuel-cell passenger cars operating on hydro-gen derived from natural gas are projected to pro-duce about 62 percent less carbon dioxide thanconventional vehicles.41 Assuming the level of emis-sions in the GREET model, and that manufacturerscomply with the ZEV program in a similar way asthe California Air Resources Board expects them tocomply in California, Massachusetts can anticipateabout a 3 percent reduction in carbon dioxide emis-sions from light-duty vehicles by 2020 as a result ofadopting the ZEV program.42

Strategy #2: Adopt California’sLimits on Vehicle Carbon DioxideEmissionsPotential Savings (Including Savings from ZEVProgram): 0.05 MMTCE by 2010, 0.69 MMTCEby 2020 (estimated).In 2002, California built upon its long history of pio-neering efforts to clean up automobiles by enacting alaw directing the state to set standards for carbon di-


oxide emissions from motor vehicles. The so-calledPavley Law (named after the sponsor, AssemblywomanFran Pavley) was the first policy in the nation to regu-late carbon dioxide from automobiles.

Under the law, the California Air Resources Board isto propose limits that “achieve the maximum feasibleand cost effective reduction of greenhouse gas emis-sions from motor vehicles.” Limits on vehicle travel,new gasoline or vehicle taxes, or limitations on own-ership of SUVs or other light trucks cannot be im-posed to attain the new standards.43 The newstandards are to be proposed in 2005 and go into ef-fect in 2009.

The carbon dioxide emission standard adopted by theCalifornia Air Resources Board (CARB) pursuant tothe Pavley Law would be part of the package of auto-mobile emissions regulated by CARB, and other stateswould have the ability to adopt those standards. Inaddition, because of a 1990 state law that requiresMassachusetts to adopt the strongest automobile emis-sion standards available, the commonwealth is alreadycommitted to the implementation of the Pavley Law.

Assuming that the Pavley Law is implemented, onemust also make assumptions about the level of car-bon dioxide emission reductions that will result fromthe program, since regulations implementing the lawhave not yet been developed.

In estimating the benefits of the Pavley standards, weassume that the regulations will require a 30 percentreduction in average per-mile carbon dioxide emis-sions for both cars and light trucks, phased in over a10-year period. This estimate is similar to assump-tions made in the Connecticut climate change stake-holder process and by other analysts.44

Of course, the flexibility allowed by the Pavley lawcould result in emission standards that are either stron-ger or weaker than this “guesstimate.” Massachusettswill have the opportunity to make better estimates ofthe impact of the program when the California regu-lations are issued in 2005.

In the meantime, Massachusetts can lay the ground-work for implementation of the Pavley standards bymoving forward with adoption of the latest ZEV pro-

gram rules. The state should also encourage other NewEngland and northeastern states to follow Massachu-setts’ lead by adopting the strongest available auto-mobile emission standards. The emergence of aregional bloc of states in support of carbon dioxideemission standards will not only allow those states tomonitor the California process as it is taking place,but will also create leverage that can be used in secur-ing stronger strategies to reduce automotive carbonemissions at the federal level.

Strategy #3: Set Standards RequiringLow Rolling Resistance ReplacementTiresPotential Savings: 0.11 MMTCE by 2010; 0.18MMTCE by 2020.Automobile manufacturers typically include low roll-ing resistance (LRR) tires on their new vehicles in orderto meet federal corporate average fuel economy(CAFE) standards. However, LRR tires are generallynot available to consumers as replacements when origi-nal tires have worn out. As a result, vehicles with re-placement tires do not achieve the same fuel economyas vehicles with original tires.

The potential savings in fuel – and carbon dioxideemissions – are significant. A 2003 report conductedfor the California Energy Commission found thatLRR tires would improve the fuel economy of vehiclesoperating on replacement tires by about 3 percent,with the average driver replacing the tires on theirvehicles when the vehicles reach four, seven and 11years of age. The resulting fuel savings would pay offthe additional cost of the tires in about one year, thereport found, without compromising safety or tirelongevity.45

Several potential approaches exist to encouraging thesale and use of LRR tires – ranging from labeling cam-paigns (similar to the Energy Star program) to man-datory fuel efficiency standards for all light-duty tiressold in the state. A standards program that requiredthe sale of LRR tires beginning in 2005 in Massachu-setts – assuming the same tire replacement scheduleand per-vehicle emission reductions found in theCalifornia study – would ultimately reduce carbon


dioxide emissions from the light-duty fleet by about1.6 percent by 2010 and 2.3 percent by 2020, whilealso providing a net financial benefit to consumersthrough reduced gasoline costs.

Strategy #4: Implement a “Feebate”ProgramPotential Savings: 0.06 MMTCE by 2010; 0.29MMTCE by 2020.The federal fuel economy preemption limits the num-ber of policy tools available to states to reduce thefuel consumption – and carbon dioxide emissions –of passenger vehicles. One potential tool to reducethe global warming impact of motor vehicles is a pack-age of fees and rebates based on carbon dioxide emis-sions, commonly known as a “feebate.”

A feebate program would give financial incentives tocar buyers who purchase more efficient – and less car-bon-intensive – vehicles, and fund those incentivesthrough fees on purchasers of less efficient vehicles,making the program essentially revenue neutral. At adesignated point on the fuel economy scale – knownas the “zero point” – a vehicle would receive no rebateand pay no fee. The ideal zero point for a revenueneutral feebate program is usually thought to be theaverage fuel economy of all vehicles sold.

There are many potential variations of feebate pro-grams. Feebates can apply equally across all vehicleclasses, or can include separate “zero points” for carsand light trucks, or for vehicle subclasses (e.g. sub-compacts). Feebates can be structured to apply eitherto new vehicles or to both new and used vehicles.Feebate rates can be applied in a linear fashion – withrates increasing in direct proportion to carbon emis-sions – or be structured to specifically target vehiclesin the middle of the efficiency spectrum. Finally, therate of the feebate can vary, from a token charge tolevels that generate maximum fees/rebates in the rangeof several thousand dollars.

While no state currently has a feebate program in place(Maryland briefly adopted a program, but it was notimplemented due to a legal dispute with the federalgovernment over a separate labeling provision), RhodeIsland has engaged in detailed discussions of poten-tial feebate scenarios as part of its Greenhouse GasStakeholder Process, Connecticut endorsed a feebateprogram in its stakeholder process, and feebate legis-lation has been introduced in the Massachusetts Leg-islature for the last decade.

The impact of a feebate program depends largely onhow it is structured, but it also depends on the num-ber of vehicles covered by the program. A 1995 studyby researchers at Lawrence Berkeley National Labo-ratory found that the majority of the improvement infuel economy that would result from a feebate pro-gram would be generated by the response of manu-facturers – not the response of individual consumers.The study concluded that manufacturers would makemore fuel efficient vehicles to respond to the economicsignals from a feebate program, but that manufactur-ers likely would not respond if a feebate were adoptedby only a single state.47

The Federal CAFE PreemptionThe setting of federal corporate average fuel economy(CAFE) standards for cars and light trucks in 1975 was themost important policy move in U.S. history to improvethe fuel economy of light-duty vehicles. As a result ofCAFE standards, the miles-per-gallon fuel economy of carsand light trucks nearly doubled between the mid-1970sand the late 1980s.46

Unfortunately, CAFE standards have remained largelystagnant over the last decade; standards for cars have notincreased since 1990. Moreover, the federal law thatcreated the standards also bars states from adoptingregulations that are “related to fuel economy standards.”The language of the law explicitly bars states fromimposing fuel economy requirements on vehicles, but theuse of the phrase “related to” also casts legal shadows onother measures – from efficiency-based fees andincentives to limits on carbon dioxide emissions fromvehicles – that could be construed by some as “relatedto” fuel economy standards.

With the federal government resisting further significantincreases in CAFE standards, however, it may be up tostates such as Massachusetts to implement incentivesaimed at encouraging the purchase of vehicles thatproduce less carbon dioxide.


A feebate program adopted solely in Massachusettscould, therefore, have limited results. However, a re-gional program – implemented consistently across theNew England states – would not only bring a greaterlikelihood of manufacturer response, but would alsoease implementation of the program by reducing thepossibility of escaping the feebate by purchasing orregistering vehicles in neighboring states.

Based on analysis conducted for the California En-ergy Commission, a regionally adopted feebate pro-gram – applied linearly to all new vehicles and basedon carbon emissions – would reduce average carbondioxide emissions from new cars by approximately 8.2percent by 2020 and from light trucks by 8.4 per-cent.48 This estimate is far from certain, since theCalifornia study modeled the impact of a feebate sig-nificantly larger in dollar terms than that currentlybeing discussed in the New England states and be-cause California’s new vehicle market is approximatelythree times the size of New England’s. On the otherhand, the CEC report is based on somewhat optimis-tic assumptions about baseline increases in fueleconomy that would occur without a feebate. Assum-ing that the CEC’s assumed percentage emission re-ductions held true for a feebate assessed inMassachusetts, carbon dioxide emissions from thelight-duty vehicle fleet would be about 3.3 percentlower in 2020 than projected.

Strategy #5: Implement Pay-As-You-Drive Automobile InsuranceProjected Savings: 0.39 MMTCE by 2010; 0.45MMTCE by 2020.In a perfect market, the rates individuals pay for in-surance coverage would accurately reflect the risk theypose to themselves and others. Automobile insurersuse a host of measures – including vehicle model, driv-ing record, location and personal characteristics – toestimate the financial risk incurred by drivers.

One measure that is not frequently used with any ac-curacy is travel mileage. Common sense and academicresearch suggest that drivers who log more miles be-hind the wheel are more likely to get in an accidentthan those whose vehicles rarely leave the driveway.49

Many insurers do provide low-mileage discounts to

drivers, but these discounts are often small, and donot vary based on small variations in mileage. Forexample, a discount for vehicles that are driven lessthan 7,500 miles per year does little to encourage thosewho drive significantly more or less than 7,500 milesper year to alter their behavior. As a result, the systemfails to effectively encourage drivers to reduce theirrisk by driving less.

Requiring automobile insurers to offer mileage-basedinsurance is just one of many potential policies thatattempt to reallocate the upfront costs of driving. Highinitial cost barriers to vehicle ownership – such as in-surance, registration fees and sales taxes – may reducedriving somewhat by denying vehicles to those whocannot afford these costs. But for the bulk of the popu-lation that can afford (or has little choice but to af-ford) to own a vehicle, these high initial costs serve asan incentive to maximize the vehicle’s use. Per-milecharges operate in the opposite fashion, providing apowerful price signal for vehicle owners to minimizetheir driving and, in the process, minimize the coststhey impose on society in air pollution, highway main-tenance and accidents.

A pay-as-you-drive (PAYD) system of insurance inMassachusetts might work this way: vehicle insurancecould be split between those components in whichrisk is directly related to the ownership of a vehicle(comprehensive) and those in which risk is largelyrelated to driving (collision, liability). The formercould be charged to consumers on an annual basis, asis done currently. The latter types of insurance couldbe sold in chunks of mileage – for example, 5,000miles – or be sold annually, with the adjustment ofpremiums based on actual mileage taking place at theend of the year. Of critical importance to the successof the system would be the creation of accurate, con-venient methods of taking odometer readings andcommunicating them to the insurer.

A pay-as-you-drive system of insurance would havegreat benefits for Massachusetts – not only for reduc-ing global warming emissions but also for improvinghighway safety and reducing insurance claims. Becauseinsurers would still be permitted to adjust their per-mile rates based on other risk factors, mileage-basedinsurance would add additional costs for the worstdrivers, giving them a financial incentive to drive spar-ingly.


Most importantly, however, a mileage-based insurancesystem would reduce driving – particularly in a statewith high auto insurance rates such as Massachusetts.Converting the average collision and liability insur-ance policies to a per-mile basis in Massachusettswould lead to an average insurance charge of about10 cents per mile.50 (By contrast, a driver buying gaso-line at $1.50 per gallon for a 20 MPG car pays only7.5 cents per mile for fuel.)

If 80 percent of collision and liability insurance wereto be assessed by the mile, the impact on vehicle travelwould be significant. Research conducted by the U.S.EPA and updated by the Victoria Transport PolicyInstitute suggests that a per-mile charge of this mag-nitude (about 7.8 cents per mile in Massachusetts)would reduce vehicle-miles traveled by about 11.2percent, with carbon dioxide emissions from light-duty vehicles declining by roughly the same amount.51

Should one-half of Massachusetts drivers be coveredby the PAYD option, light-duty VMT – and, there-fore, light-duty vehicle carbon dioxide emissions –could be reduced by 5.6 percent.

While many insurers remain resistant to the adminis-trative changes that would be needed to implementmileage-based insurance, the concept is beginning tomake inroads. The Progressive auto insurance com-pany offered a pilot PAYD insurance system in Texasand other pilot programs are underway elsewhere. In2003, the Oregon Legislature adopted legislation toprovide a $100 per policy tax credit to insurers whooffer PAYD options.52

Massachusetts should choose to introduce the con-cept by requiring insurers to offer it as an alternativeto traditional insurance. If the concept proves suc-cessful, the state (or insurers) could then require li-ability and collision rates to be expressed incents-per-mile – thus maximizing the carbon dioxideemission reductions and other positive results of thepolicy.

Unlike other policies that use price signals to reducevehicle travel (such as an increased gas tax), mileage-based insurance has inherent aspects that make it anappealing policy option – regardless of its impact onglobal warming emissions. It ties the cost of insur-ance more closely to the actual risk incurred by driv-ing. As a result, it should be closely studied, andultimately implemented, in Massachusetts.

Policy Alternative: Pay-At-The-PumpInsuranceA close relative of pay-as-you-driveinsurance, pay-at-the-pump policies wouldrequire the state to collect a surcharge ongasoline sales that would then provideminimal insurance coverage to drivers.Drivers would still purchase additionalinsurance coverage in the traditional manner.

Pay-at-the-pump systems have fouradvantages. First, they do not requireverification of odometer readings. Second, asa global warming measure, they tie insurancecoverage to the amount of fuel used –encouraging both reductions in vehicle traveland the purchase of more efficient vehicles.Third, drivers of larger, less-fuel efficientvehicles (such as large SUVs) impose greatercosts when they get into accidents. Evidenceshows that SUVs and other large vehicles aremore likely to kill or severely injureoccupants of other vehicles in a collisionand that the sense of security provided bydriving in a large vehicle may lead to moredangerous driving behaviors.53 To the extentthis is true, pay-at-the-pump can put a priceon the additional risk these vehicles pose.Finally, pay-at-the-pump can generate a poolof funds to cover uninsured motorists,thereby reducing premiums for insuredmotorists who currently carry the financialburden of those who are not insured.

Strategy #6: Reduce Growth inVehicle Miles TraveledPotential savings: 0.43 MMTCE by 2010; 1.23MMTCE by 2020.The growth in vehicle-miles traveled over the last sev-eral decades has its roots in many societal changes –the redistribution of people and jobs away from cen-tral cities to the suburbs, the elimination of some masstransit opportunities, low gasoline prices, the increasedparticipation of women in the workforce, and resi-dential and commercial suburban sprawl.


Reversing this trend will be difficult, but success wouldbring benefits not only in reducing global warmingemissions but in easing traffic congestion, reducingpublic expenditures on highways, enhancing Massa-chusetts’ energy security, and reducing automotiveemissions of other pollutants that damage publichealth. It would be a reasonable goal for Massachu-setts to seek to reduce the growth rate in vehicle-milestraveled – projected by the Massachusetts HighwayDepartment to be approximately 1.4 percent annu-ally until 2020 – to the rate of population growth inthe state, projected by the U.S. Census Bureau to beapproximately 0.4 percent per year between 2005 and2020.54

The impact on vehicle-miles traveled of both transitimprovements and growth management policies hasbeen well documented. A variety of studies have docu-mented that doubling the residential density of a givenneighborhood reduces per-capita VMT by approxi-mately 20 to 38 percent. Increasing the density of tran-sit service has also been shown to reduce VMT.55

Because such effects are dependent on the character-istics of the community and the type of proposedpolicy or project, it is difficult to estimate the impactof any one statewide smart growth or transit strategy.Regardless, by adopting a package of “smart growth,”transit, and transportation demand management(TDM) policies, Massachusetts could encourage long-term shifts in development patterns and transporta-tion decisions that would reap benefits in reducedvehicle travel and global warming emissions.

Among the policies implemented in or considered byother states that could help achieve this goal are thefollowing:

• Directing state investments in transportation andother infrastructure toward designated growth ar-eas near existing population centers.

• Encouraging transit-oriented development nearstations to expand the range of services availableto commuters without having to use their vehicles(as proposed by Gov. Romney in December 2003).

• Encouraging location-efficient mortgages that al-low households living near transit services to bor-

row additional money because their reduced trans-portation expenses increase their disposable in-come. The “Take the T to Work” program, whichprovides no-down-payment mortgages for quali-fied applicants who regularly use the MBTA tran-sit system, is one such example.56

• Providing additional incentives to employers whoencourage telecommuting, establish car- and van-pool programs, provide transit subsidies, or other-wise promote transportation alternatives.

• Implementing congestion pricing on major high-ways (in which commuters traveling during con-gested periods pay a toll) thus reducing rush-hourtraffic and encouraging alternatives to single-pas-senger automobile use.

• Improving the geographic reach, quality and fre-quency of existing transit services, and working toachieve low fares that maximize the use of existingtransit infrastructure.

• Expanding bikeway networks and bike lanes, em-ploying “traffic calming” techniques in town cen-ter areas, requiring sidewalks in all newdevelopments, and other policies to improve thesafety and appeal of walking and bicycling.

• Promoting “infill” development and redevelop-ment in existing urban and suburban areas throughtransfers of development rights, brownfields rede-velopment incentives, urban development pro-grams, and other means.

Regardless of the specific policies involved, Massachu-setts must realize that land use and transportationpolicies are integrally related, and should be alignedto achieve the same goals of reducing automobile de-pendence, reducing development pressure on thestate’s remaining open spaces, and revitalizing urbanareas. By adopting a state goal for the management ofvehicle travel, and implementing that goal through aseries of locally appropriate policies, Massachusettscould go a long way toward meeting its global warm-ing emission reduction goals.


Combined Impact of theTransportation StrategiesImplementing the six strategies listed above wouldhave a significant impact on Massachusetts’ transpor-tation-sector carbon dioxide emissions by reducingvehicle-miles traveled and reducing the per-mile emis-sions of carbon dioxide from motor vehicles. Com-pared with a base case projection that assumes a 1.4percent per year increase in VMT and no significantimprovements in vehicle fuel economy, the actionslisted above would reduce transportation sector emis-sions by about 0.94 MMTCE by 2010 and 2.29MMTCE by 2020. At these levels, transportation-sec-tor emissions in Massachusetts in 2020 would be 2.23MMTCE higher than 1990 levels (excluding savingsfrom feebates).57

Achieving even this level of emission reductions willrequire swift action. Many of the transportation-sec-tor strategies (including feebates and the Pavley pro-gram) have a long lead time before they begin toproduce significant savings due to the fact that theyprimarily affect new vehicle purchases. Once sold, newvehicles typically remain on the road for 10-15 yearsor more. Thus, any delay in adoption of these mea-sures will result in more high-carbon vehicles travel-ing Massachusetts’ highways for years to come.

Finally, it is important to note the major role federaldecision-makers can play in reducing carbon dioxideemissions from transportation. An increase in the fed-eral CAFE standard to 40 MPG, applied to both carsand light trucks and phased in over time, would havea dramatic impact on carbon dioxide emissions –greater than any of the policy options listed above.58

Massachusetts cannot afford to wait for Washingtonto take action on CAFE, but the state should workwith federal officials to promote a CAFE increase andother changes in federal transportation policy to re-duce carbon dioxide emissions.

Additional Transportation Strategiesto ConsiderSome combination of other transportation-sectorstrategies will ultimately be necessary in Massachu-setts’ efforts to reduce global warming emissions.Among them are the following:

• Motor Fuel Taxes – Taxes on gasoline and othermotor fuels provide an incentive for individuals toreduce their driving and to purchase more efficientvehicles. Academic research shows that long-runfuel consumption is reduced by 3 to 10 percentfor every 10 percent increase in fuel price.59 Whilemotor fuels tax increases have traditionally beenunpopular with the public (and raise legitimateconcerns with regard to the impact on low-incomedrivers), novel variations on the policy are possible.For example, the revenue generated by higher gaso-line taxes could be used to reduce income or prop-erty taxes – thus preserving the tax increase’sincentive for fuel conservation while making it rev-enue neutral in the aggregate. Alternatively, fueltax increases could be dedicated to the expansionof transit services, incentives for the use of trans-portation alternatives, or incentives for the pur-chase of more fuel-efficient vehicles, in the samemanner as systems benefit charges on electricitybills are used to promote energy efficiency.

• Rail Improvements and Expansion – Massachu-setts’ network of operating and dormant rail corri-dors is a large potential resource for global warmingreduction. Rail can play two important roles: as asubstitute for car and air travel (particularly forflights within the Northeast region) and as a sub-stitute for air and highway freight delivery. Pas-senger rail operations release less than half theamount of carbon dioxide per passenger mile ofair travel.60 On the freight side, state officials shouldcontinue to consider modernization of the state’sfreight rail system, urge investments in intercon-nections with other regions, and improveintermodal connections. Rail improvements shouldreceive a high priority for funding at the state level,as they will become an increasingly important com-ponent of Massachusetts’ transportation systemover the next several decades.

• Limits on Highway Expansion – Congestion andsafety problems on Massachusetts’ highway net-work are growing, sparking proposals to add yetanother lane to highways around Boston. Theseproposed highway additions would be costly – bothin terms of the direct spending required of the state,and in terms of global warming emissions. Far fromalleviating congestion, expansion of major high-ways has been shown in various studies to pro-


mote increased vehicle travel, leading to more fueluse, more global warming emissions, and, eventu-ally, more traffic.61 Rather than expand the state’shighway capacity, transportation officials shouldadopt a policy that prioritizes roadway repairs andrelies on transportation demand management strat-egies – such as car- and van-pooling incentives,road pricing, and expansion of transportation al-ternatives for both personal and freight travel – tomeet the state’s long-term transportation needs.

• Limits on Diesel Pollution – Diesel fuel – usedpredominantly in large trucks, buses, and otherlarge vehicles and machinery – is a major source ofboth carbon dioxide and “black carbon,” whoserole in global warming some scientists believe maybe very significant. Diesel vehicles also producelarge amounts of particulates and other pollutantsthat endanger public health. Massachusetts hasseveral avenues open to it to reduce diesel emis-sions, including the adoption of standards for ul-tra-low sulfur diesel fuel, requirements for theretrofitting of existing diesel engines, the use ofalternative fuels (such as natural gas) in public tran-sit fleets, as is already beginning to be done by theMBTA, and measures to reduce the amount oftruck idling (such as the electrification of truckstops in the state and stricter enforcement of thestate’s anti-idling law).


Homes, Business and

Industry

The residential, commercial and industrial sectors areresponsible for about half of Massachusetts’ non-elec-tric emissions of carbon dioxide. There are, however,tremendous opportunities to improve the efficiencyof energy use in all three sectors.

Strategy #7: Strengthen Residentialand Commercial Building EnergyCodesPotential Savings: 0.024-0.036 MMTCE by 2010;0.33 MMTCE by 2020.62

Building codes were originally intended to ensure thesafety of new residential and commercial construc-tion. In recent years, however, building codes havebeen used to reduce the amount of energy wasted inheating, cooling and the use of electrical equipment.Massachusetts has included energy efficiency as a cri-terion in the development of building energy codessince at least the 1980s.63 The state must update thecodes at least once every five years and currently isconducting the next review.64 Currently, residential

Fig. 7. Projected Transportation Sector Carbon Dioxide Emissions(excluding savings from feebates)

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Emissions WithTransportationStrategies


construction in Massachusetts is guided by the 1995Model Energy Code (MEC) with energy-conserva-tion amendments added in 1998, while commercialconstruction is guided by the American Society ofHeating, Refrigerating and Air-Conditioning Engi-neers (ASHRAE) code 90.1-1999 and the 2001 In-ternational Energy Conservation Code (IECC).65

Model building energy codes are developed and up-dated at the national and international level. The In-ternational Code Council (ICC) is responsible fordevelopment of the International Energy Conserva-tion Code (IECC), the most recent version of whichwas published in 2003.

A 2001 study by the American Council for an En-ergy-Efficient Economy (ACEEE) estimated thathomes meeting the 2000 IECC code would use ap-proximately 15 percent less energy than homes notmeeting the code, with a further 20 percent energysavings from the adoption of future codes that wouldgo into effect after 2010.66 The U.S. Department ofEnergy estimates that the intensity of electricity usein New England commercial buildings would declineby approximately 10 percent if all states fully adoptedthe ASHRAE code 90.1-1999 versus the previousASHRAE code.67 ACEEE assumes a further 20 per-cent energy savings for all fuels in commercial build-ings from future updates to the code.68

Based on the assumptions of ACEEE and U.S. DOE,the adoption of updated building energy codes wouldreduce residential oil and gas use by approximately1.3 percent below base case projections by 2020, com-mercial oil and gas use by approximately 4 percent,and commercial electricity use by about 6.2 percent.These estimates are likely conservative, since they onlyattempt to quantify the impact of improved codes onnew construction. Applying codes to alterations andrenovations in residential and commercial structureswould result in even greater savings.

In estimating the carbon dioxide reductions thatwould result from improved building codes and othermeasures that reduce electricity use, a key factor isthe type of electricity generation that is assumed tobe affected by the reduction in consumption. Coal-and oil-fired power plants (particularly older plants)release significantly greater amounts of carbon diox-ide per unit of electricity produced than modern natu-

ral gas-fired power plants. Thus, the resulting emis-sion reductions are low if it is assumed that electricitysavings reduce the need for the construction of newgas-fired power plants, and high if they reduce theamount of power coming from older coal- and oil-fired plants.

In this report, where applicable, we present a range ofemission reductions based on these different assump-tions. The low end of the range is based on the as-sumption that electricity savings are first used to offsetany reduction in generation from nuclear plants thatwould be closed down upon expiration of their li-censes, with the remaining savings used to reduce theneed for gas-fired generation. The high end of therange is based on the assumption that savings are firstused to offset retired nuclear power, with the remain-der used to reduce coal-fired generation. It is likelythat the higher emission reduction estimate wouldonly be achieved under a strong state or regional capon electric-sector emissions. (See Strategy #12.)

It is important to note that the success or failure ofbuilding energy codes depends largely on the degreeto which they are enforced by local building officialsin the state’s cities and towns. With proper enforce-ment and training, upgraded building codes can ensurethat Massachusetts reaps the benefits of energy-efficientresidential and commercial construction.

Strategy #8: Adopt ApplianceEfficiency StandardsPotential Savings: 0.18-0.39 MMTCE by 2010; 0.52MMTCE by 2020.Household appliances and those used by business area major source of energy demand. Since the first stateappliance efficiency standards were adopted in themid-1970s (followed by federal standards beginningin the late 1980s), the energy efficiency of many com-mon appliances has been dramatically improved. Forexample, residential refrigerators complying with thelatest national standards consume less than one-thirdthe electricity annually of refrigerators manufacturedin the early 1970s.69

The federal appliance standards program has led togreat improvements in the efficiency of many appli-ances, but progress has slowed in recent years. Federal


standards have failed to keep up with advances in ef-ficiency technologies or have failed to take advantageof known efficiency opportunities. In addition, thefederal program does not cover some appliances withgreat potential for improved efficiency.

States are pre-empted from adopting their own effi-ciency standards for products covered by federal stan-dards, but there are two opportunities for states totake action. First, states may adopt efficiency stan-dards for products not specifically covered by the fed-eral program. In addition, states have the opportunityto apply for a waiver of federal pre-emption to applystronger standards to products currently covered byfederal standards.

An analysis conducted in 2002 by Northeast EnergyEfficiency Partnerships (NEEP) assessed the poten-tial energy savings that would result from the adop-

tion of improved efficiency standards for 15 commer-cial and residential products. (See Table 4.) UsingNEEP’s projections for total electricity savings, mov-ing forward with standards for all such products wouldreduce commercial-sector electricity use by about 2percent versus projection by 2020 and residential-sec-tor electricity consumption by about 15 percent.70

Appliance efficiency standards are also a win-win forMassachusetts’ environment and economy. The NEEPstudy estimated that adoption of the package of ap-pliance standards would bring Massachusetts approxi-mately $2.1 billion in net economic benefit by 2020.72

Massachusetts should move ahead with the adoptionof efficiency standards for appliances not covered byfederal rules, and apply for waivers of pre-emptionfor the others. In addition, the state should allow forthe expedited adoption of future appliance standards

for existing products and new productsmaking their way into the marketplace.

Strategy #9: Expand EnergyEfficiency ProgramsPotential Savings: 0.54-0.77 MMTCEby 2010; 1.25 MMTCE by 2020.One of the most promising opportuni-ties for reducing carbon dioxide emissionsin Massachusetts is through improvedenergy efficiency. Stronger residential andcommercial building codes and improvedappliance efficiency standards, while im-portant, are limited in their scope, leav-ing many existing buildings and sourcesof energy use untouched.

There are many barriers to the successfulintroduction of energy efficiency tech-nologies. Potential users may not knowabout the technologies or have an accu-rate way of computing the relative costsand benefits of adopting them. Evenwhen efficiency improvements are plainlyjustifiable in the long run, consumersmay resist adopting technologies thatcause an increase in the initial cost of pur-chasing a building or piece of equipment.In some cases, as with low-income indi-

Table 4. Products Covered Under ProposedEfficiency Standards71

Residential Products

Furnace fans

Torchiere light fixtures

Ceiling fans

Consumer electronics (standby power)

Central air conditioners and heat pumps

Commercial Products

Unit and duct heaters

Small packaged air conditioners and heat pumps

Beverage vending machines

Commercial refrigerators and freezers

Reach-in beverage merchandisers

Traffic signals

Exit signs

Commercial (coin-operated) clothes washers

Ice makers

Large packaged air conditioners


viduals, consumers may not be able to afford the ini-tial investment in energy efficiency, regardless of itslong-term benefits.

Traditionally, states have required electric utilities tomake investments in efficiency programs through therate-setting process. In the wake of electric industryrestructuring, however, some states have dropped ef-ficiency requirements, while others – including Mas-sachusetts – have created a new means of financingefficiency improvements through the assessment ofsystems benefit charges (SBCs) on consumers’ elec-tric bills.

The concept behind the SBC is that all electric con-sumers share in the benefits when any consumer im-proves his or her energy efficiency. These benefits areboth social (reduced global warming emissions andair pollution and improved long-run energy security)and purely economic (reduced need for expensive peakgeneration and ratepayer investments in transmissionand distribution systems).

While nearly half of all states (including all six NewEngland states) have adopted some form of SBC forelectric utilities, fewer have implemented SBCs fornatural gas, which is distributed through a regulatedsystem similar to electricity. Similarly, the potentialfor SBC-type programs for other fuels – such as pe-troleum – has not been fully explored.

Massachusetts established its system of SBCs throughelectric restructuring legislation adopted in 1997.73

SBCs are assessed in Massachusetts to support energyefficiency programs, the development of renewableenergy sources, and low-income assistance programs.We will discuss the SBC for renewable sources in moredetail later in this report.

The efficiency SBC is assessed to customers of inves-tor-owned utilities, but not to customers of munici-pal utilities, which serve 350,000 customers inMassachusetts.74 The efficiency SBC rate is 2.5 mills($0.0025) per kilowatt-hour. A slightly higher assess-ment rate in 2001 generated $122 million in efficiencyfunding.75 Massachusetts’ efficiency programs areoverseen by the state Division of Energy Resources(DOER). DOER reported that efficiency improve-ments made through the program in 2001 will saveapproximately 4,571 gigawatt-hours (GWh) of elec-tricity consumption over the lifetime of the measures

(a savings rate of about 2.3 kilowatt-hours annuallyper dollar spent, which will lead to lifetime economicsavings of about $332 million).76 SBC funds supporta wide variety of efficiency-related programs, rangingfrom research and development and public outreachto incentives for the purchase of energy efficient equip-ment for businesses.

Should Massachusetts double its SBC for efficiencyto 5 mills, the state could generate tens of millions ofadditional dollars for efficiency improvements. Evenassuming that efficiency savings from added SBC rev-enue would come at a substantially lower rate (giventhe decreasing availability of “low-hanging fruit” overtime), Massachusetts could still achieve carbon sav-ings of 0.40 MMTCE by 2020.

Cost-effective efficiency savings of this degree areclearly achievable. The American Council for an En-ergy-Efficient Economy (ACEEE) estimated in 2003that the cost-effective potential for efficiency savingsin Massachusetts within the next five years is approxi-mately 1,891 GWh.77

The impact of a gas and oil SBC program is moredifficult to predict, but it would be substantial. Basedon Vermont’s experience with a utility-based naturalgas conservation program, the Connecticut ClimateChange Stakeholder Dialogue estimated that the av-erage first-year cost of saving 1,000 cubic feet of natu-ral gas was $29.78 Assuming that a gas and oilSBC-type program applied to residential, commer-cial and industrial consumption in Massachusettswould achieve a savings rate 75 percent of that expe-rienced in Vermont, an SBC of 3.5 cents per 100,000BTU of energy consumed would reduce Massachu-setts’ carbon dioxide emissions by approximately 0.85MMTCE by 2020. An SBC at this rate would trans-late into a rate of about 3.5 cents per therm of naturalgas or 2.5 cents per gallon of distillate heating oil.

The near-term impacts of expanded residential, com-mercial and industrial energy efficiency programs mayrepresent just the tip of the iceberg of the potentialbenefits of an expanded SBC program. By fundingresearch and development into efficient new technolo-gies and practices and broadening public understand-ing of the potential benefits of energy efficiency, theseprograms can create new opportunities for cost-effec-tive energy savings in the years to come.


Combined Impact of the Residential,Commercial and IndustrialStrategiesAdoption of the three strategies listed above wouldreduce carbon dioxide emissions from electricity useand direct combustion of fossil fuels in homes, busi-nesses and industries by about 0.72-1.16 MMTCEin 2010 and 1.85-2.54 MMTCE in 2020. This esti-mate takes into account the fact that some equipmentcovered under proposed appliance standards could alsobe included in building codes by counting only sav-ings from appliances not covered by codes.

Additional Residential, Commercialand Industrial Sector Strategies toConsiderA number of other strategies are available to reduceenergy use in the residential, commercial and indus-trial sectors.

• Green Building Certification – State building en-ergy codes provide the minimum design standardsfor energy efficiency in buildings, but even greatersavings are available with good design and addi-tional upfront investment. Commercial buildingscertified to the U.S. Green Building Council’sLeadership in Energy & Environmental Design(LEED) standards achieve average energy savingsof 25 to 30 percent beyond the ASHRAE 90.1-1999 commercial code. While LEED-certifiedbuildings cost an average of 2 percent more to con-struct, they yield 20-year financial benefits of about10 times the construction premium.79 For residen-tial buildings, Home Energy Rating Systems(HERS) can be used to measure code complianceor to set thresholds for a “green home” designa-tion. In addition to making LEED certificationthe standard for new government construction,Massachusetts should also identify ways to rewardbuilders, businesses and home buyers who chooseto certify their buildings to green building stan-dards. Any program to promote green buildingsshould, however, also reinforce the state’s smartgrowth goals. A “green” commercial building sitedin such a way as to increase automobile travel mayhave a negligible – or even negative – net impacton global warming emissions.

• Energy-Efficient Mortgages/Pay-As-You-SavePrograms – Energy-efficient mortgages (EEMs)and pay-as-you-save (PAYS) programs are alterna-tive models for financing the installation of en-ergy-efficiency measures and distributed generationresources, primarily in the residential sector. EEMprograms generally allow homebuyers to assumelarger mortgages (sometimes on preferential terms)to finance energy efficiency improvements. PAYSprograms allow consumers to pay for energy-effi-cient equipment or distributed generation resources(such as solar panels, small wind systems or fuelcells) over time on their utility bills rather thanup-front. The charge remains on the utility billuntil the equipment is paid off, regardless of whois living in the residence at the time. PAYS systemsremove a major barrier from homeowners seekingto reduce energy demand: the prospect that theywill not reside at the home long enough to enjoythe benefits of their investments. State officialsshould work with utilities and mortgage lendersto encourage and publicize EEMs and with utili-ties to experiment with pilot PAYS systems for ef-ficiency and distributed generation.

• Cluster and Mixed Use Development – Smartgrowth policies are commonly thought to reduceglobal warming emissions by reducing the num-ber of automobile trips required to carry out dailyactivities. But they may also have the secondaryeffect of reducing energy use within the buildingsthemselves. Many smart growth or “new urbanist”projects involve the renovation of existing build-ings, construction of homes with less square foot-age than typical new suburban construction, or thecombination of commercial and residential usesin a more space-efficient fashion. More researchneeds to be done to quantify the energy impactsof such projects, but Massachusetts can spur theirdevelopment by encouraging municipalities todevelop zoning ordinances that allow, or provideincentives for, cluster and mixed-use developments.

• Combined Heat and Power and Distributed Gen-eration – New and improved technologies nowallow homeowners and businesses to generate theirown power. Combined heat and power (CHP)systems allow commercial and industrial facilitiesto use waste heat from heating and cooling sys-tems to generate electricity, or vice versa. CHP sys-


tems can vastly improve the efficiency of a facility’senergy production and use. Because CHP systemsgenerally rely on fossil fuels, they are less effectiveat reducing carbon dioxide emissions than arerenewable resources. Nonetheless, CHP should beencouraged, particularly for facilities for whichrenewable power does not make sense, by remov-ing market barriers and easing interconnection withthe electric grid. Similar incentives could promotethe use of clean distributed generation (DG) tech-nologies such as solar panels, small wind turbines,fuel cells, and small, high-efficiency turbines op-erating on natural gas or other low-carbon fuels.DG systems can reduce carbon dioxide emissionsin two ways: by providing a lower-carbon sourceof electricity than power from the grid, and byproviding that electricity closer to the point of use,reducing the amount of energy lost in transmis-sion from a central power station to the end user.In addition to removing barriers to DG deploy-ment, however, the state should adopt tight emis-sion standards to ensure that distributed generatorsoperating on diesel or other dirty fuels do not con-tribute to local air pollution problems.

• Solar-Ready Home Standards – Massachusettsshould revise its building codes to require that newhomes and commercial structures be built to al-low the easy installation of solar photovoltaic sys-tems.


Electricity Generation

In addition to efforts to conserve electricity, Massa-chusetts can also help to reduce carbon dioxide emis-sions from electricity use by working to make the NewEngland electric grid cleaner – specifically by encour-aging a shift away from carbon-intensive fuels such ascoal and oil and toward renewable energy sources suchas solar and wind. To achieve this goal, Massachusettsmust encourage the deployment of renewable energysources while simultaneously adopting policies to re-duce carbon dioxide emissions from fossil fuel gen-erators through a state or regional electric-sectorcarbon cap. Regional cooperation on this matter iscrucial, since generation capacity and renewable re-sources are not distributed evenly across the six NewEngland states.

Strategy #10: Enforce, Strengthenand Extend the Renewable PortfolioStandardPotential Savings: 0.42-0.96 MMTCE by 2010; 0.56MMTCE by 2020.Massachusetts is one of a number of states (along withMaine and Connecticut) that have adopted a renew-able portfolio standard (RPS) for electricity suppliedto the state’s customers. Essentially, an RPS requiresthat a certain portion of the power sold by utilities begenerated from renewable energy sources. The per-centage of renewable power increases over time, pro-viding a scheduled ramp-up to the provision of asignificant portion of the state’s power from renew-able sources.

Massachusetts adopted an RPS with the electric re-structuring law of 1997. The program sets a goal ofgenerating 4 percent of the state’s power from new(post-1997) renewable sources by 2009, with thetarget rising by one percent each year thereafter untilthe Division of Energy Resources ends the program.80

Eligible renewable sources include solar, wind, land-fill gas, fuel cells using renewable fuels, ocean ther-mal power, wave or tidal power, and low-emissionbiomass.81

Massachusetts and the rest of the region can be evenmore aggressive in the promotion of renewables. AnRPS that sets a target of 10 percent of the region’selectricity from new, clean, zero-net-carbon renewablesby 2010 and 20 percent by 2020 is achievable andwould result in a net reduction in carbon dioxideemissions from electric generation. For this to occur,the Massachusetts Department of Telecommunica-tions and Energy (DTE), the state utility regulator,must take it role in enforcing the provisions of theRPS seriously. Using its authority under state stat-utes, the DTE must recognize the fuel diversity ben-efits of the RPS and hold the utilities accountable forcomplying with the renewable energy requirement.

With these targets, Massachusetts would achieve sav-ings of 0.42-0.96 MMTCE by 2010 and 0.56MMTCE by 2020, with the higher near-term esti-mate based on adoption of a strong regional carboncap in which new renewable resources supplant gen-eration from coal-fired power plants. (See Strategy#12.) The 2020 savings estimate does not exhibit arange, since – regardless of the existence of a carbon


cap – the new renewables are assumed to first replacegeneration that had been provided by the Pilgrimnuclear reactor, whose license is scheduled to expirein 2012.

Under a regional RPS, applied to all power consump-tion in the region, the New England states would gen-erate more than 11,000 GWh of power from newrenewable sources by 2010, and 21,000 GWh by2020, over and above the amount of renewables thatwould already be deployed under the existing RPSsin Massachusetts and Maine and an older version ofthe RPS in Connecticut. Several forms of renewableenergy could be used to meet the RPS requirement,including wind power, solar power, landfill gas, andperhaps new technologies such as run-of-the-riverhydropower, if they are proven to be effective andenvironmentally benign.

Is such a level of renewable power production in NewEngland feasible? The U.S. Department of Energy’sOffice of Energy Efficiency and Renewable Energy(EERE) has calculated that New England has the po-tential to generate as much as 34,000 GWh per yearusing onshore wind resources alone.82 Technologicalimprovements in the future could allow the cost-ef-fective generation of additional power from wind. Thisestimate does not include the wind energy that couldbe harnessed by offshore wind turbines, which couldpotentially supply more electricity each year in NewEngland than the region currently consumes.83

In sum, fulfilling a 20 percent renewable portfoliostandard for New England would require the devel-opment of less than two-thirds of the region’s onshorewind potential under even the most conservative esti-mates and without factoring in the potential for tech-nological improvements to make wind power feasiblefor distributed applications and at lower wind speeds.Adding solar, landfill gas, and clean biomass (thatwhich does not contribute to toxic air emissions) tothe mix makes this task even more readily achievable.Massachusetts, for example, has already approved NewEngland landfill gas projects with a nameplate capac-ity of about 50 MW to qualify for the state’s RPS.84

Massachusetts has shown leadership with its adop-tion of an RPS, but adoption of consistent standardsacross New England would be beneficial. First, theregion should agree on a set of rules for inclusion underan RPS that emphasize truly clean, truly renewable

technologies. Polluting and environmentally damag-ing technologies, along with those that rely on non-renewable resources, should be excluded from use tofulfill RPS requirements. In some cases, difficult de-cisions will have to be made to preserve the spirit ofthe RPS. For example, stationary fuel cells that runon natural gas, while they may be environmentallybeneficial, should not receive credit under an RPS dueto their ultimate reliance on fossil fuels. Other incen-tives should be used to promote technologies, such ascombined heat-and-power, that improve efficiency butdo not draw on truly renewable resources.

The need for regional standards is particularly im-portant because any RPS is necessarily going to re-quire the purchase of credits from new renewablegeneration in other states. States vary greatly in theirpotential for successful renewables development, soit is only fitting that states get credit for the role theyplay in facilitating the development of renewables inneighboring states. Massachusetts’ RPS allows thefulfillment of requirements through the developmentof renewables in other New England states or evenoutside the region.

Massachusetts should commit to reaching the 10 per-cent goal for new renewables by 2010 and 20 percentby 2020. At the same time, the state should work withother New England states to support a similar, regionalrequirement, with tight and effective mechanisms fortracking, purchasing and trading renewable powercertificates. The state should also create mechanismsthat allow renewable energy developers to secure long-term contracts for the power they produce, therebyremoving one of the major barriers to constructingrenewable energy projects.

Strategy #11: Support theDevelopment of Solar PowerPotential Savings: 0.001-0.003 MMTCE by 2010;0.005 MMTCE by 2020.Solar power is currently a bit player in the generationof electricity in New England. Barring a technologi-cal breakthrough, it will likely remain a bit player forat least the next decade. But Massachusetts and otherNew England states can play a leading role in posi-tioning solar power to make a major contribution tothe region’s long-term global warming emission re-


duction goals. Solar photovoltaics (PV) have the po-tential to make a major contribution to a clean en-ergy future. Costs have already gone down by 75percent over the past 20 years.85 Massachusetts andother states must recognize the importance of earlyinvestments to reduce the ultimate cost of solar powerby front-loading support for solar installations to cre-ate greater economies of scale within the industry.

To generate funding for solar installations, the statecould consider increasing the systems benefit charge(SBC) for renewables, or creating an alternative sourceof new funding, such as a bond issue. Currently, cus-tomers of Massachusetts’ investor-owned utilities payan SBC of one-half of one mill ($0.0005) forrenewables. This generates approximately $25 millionper year for the state’s Renewable Energy Trust Fund.This funding allows the Massachusetts TechnologyCollaborative (which is supported by the state’srenewables SBC) to provide subsidies of up to $5,000per kW for the installation of solar PV capacity oncommercial buildings and in residential clusters. (TheTrust Fund, however, should streamline the bureau-cratic obstacles to obtaining these subsidies. The stateof New Jersey has a much less cumbersome systemwhich Massachusetts should consider replicating.)

A $4,000 per kW subsidy appears to be sufficient tomake solar power cost-competitive in New England inthe near term. A recent analysis found that a solar PVsystem for a commercial building in Massachusetts (in-cluding the subsidy) could cost as much as $11,000 perkW and still break even financially for the purchaser.Installed commercial PV systems in the U.S. range inprice from $7,000 to $12,000 per kW, making PV sys-tems largely cost-competitive (with subsidy) in Massa-chusetts.86 In addition, a $4,000 per kW subsidy wouldbe sufficient to push the residential breakeven cost ofsolar PV above $7,000 per kW, bringing residential so-lar to within the margins of competitiveness.87

A subsidy program of the kind described here, if fullyutilized, would result in the generation of about 21GWh of power from new solar installations in Mas-sachusetts by 2010 and 84 GWh by 2020 in Massa-chusetts. A comparable program across the regionwould generate 47 GWh by 2010 and 189 GWh by2020. Even with this ramp-up of solar power, less thanone percent of New England’s electricity would comefrom solar PV by 2020. And the new solar PV sys-tems would not even begin to tap New England’s

potential for solar PV development, with the equiva-lent of only about 40,000 New England homes bear-ing rooftop solar PV systems by 2020.88

These goals for solar development are conservativewhen compared to efforts in some other states andregions. New Jersey, for example, has adopted a state-wide goal of generating 120 GWh of power per yearfrom solar PV by 2008.89

While a solar program such as the one envisioned herewould have only a limited short- and medium-termimpact on carbon dioxide emissions in New England,the long-term impact is potentially great. The in-creased installation of solar PV systems would improvethe economics of solar power and begin to change theperception of solar systems from exotic curiosities toa day-to-day feature of life in many communities.With a long-term commitment to fund solar installa-tions in Massachusetts and throughout New England,manufacturers of PV systems would have a strongincentive to increase their production capacity, reduc-ing costs. The state and region would then be poisedfor a dramatic increase in solar installations in the2020-2050 period; precisely the time when the re-gion will be needing to make deep reductions in itsglobal warming emissions in keeping with the NewEngland governors’ long-term goal.

Solar PV is not the only technology that can be sup-ported through revenue from the renewable energySBC. SBC revenue can also be used to support re-search and development of new renewable technolo-gies and to hasten their deployment in themarketplace. As a result, this evaluation of solar merelyscratches the surface on the potential benefits of therenewables SBC.

Strategy #12: Finalize Power PlantEmission Standards for CarbonDioxide as a Foundation for aRegional, Electric-Sector Carbon CapPotential Savings: Included as high end of range ofestimates above.Massachusetts was the first state in the U.S. to limitcarbon dioxide emissions from power plants. Whilethe rules that will implement the limits have not yetbeen finalized, a group of 10 northeastern states has


launched discussions aimed toward establishing a re-gional cap on electric-sector carbon dioxide emissions.The initiative, known as the Regional Greenhouse GasInitiative (RGGI), parallels similar efforts in bothMassachusetts and New Hampshire as well as discus-sions of similar limits at the federal level.

The Massachusetts and RGGI processes provide anopportunity to build upon recent state proposals tolimit global warming emissions and shift from wide-spread reliance on polluting, carbon-intensive coal-and petroleum-fired generation and dangerous nuclearpower to the increasing use of renewable power, en-ergy efficiency, and other low- or zero-carbon formsof generation to meet the region’s electricity needs.

However, the promise of these efforts could easily belost if the level of the cap does not drive significantemission reductions. It could also lose public supportif the program makes the dangerous tradeoff of al-lowing nuclear power to get credit, subsidies or broadmarket advantage as a source of “clean” power. Amongthe important issues developers of carbon caps mustgrapple with are the following:

• Cap Levels – The program must establish a targetfor the level of carbon dioxide that can be emitted.An aggressive (i.e. low) cap is achievable and candrive large reductions in emissions.

Opportunities for reducing emissions from theelectric sector are numerous, including the pro-motion of energy efficiency in homes, businessesand industry; the retirement of old, inefficient fossilfuel-fired power plants; and the expansion of re-newable and clean distributed generation.

These initiatives are potentially mutually reinforc-ing. Reducing growth in electricity consumptionreduces the amount of new generating capacity thatmust be built to satisfy demand. Renewable anddistributed generation further reduces demand forfossil and nuclear generation. Together, thesechanges reduce the necessity to maintain existing,inefficient sources of generation and allow theirexpedited replacement with more efficient sources.

The Massachusetts carbon cap limitations are al-ready established for a set of older power plants,but the potential targets under the RGGI processwill be the focus of intense discussion. The New

England Climate Coalition recommends an over-all goal of reducing carbon dioxide emissions fromelectricity generation by 40 percent below currentlevels. The adoption of aggressive efficiency andrenewables programs by all six New England stateswould bring this goal within reach by 2020, withreductions of as much as 30 percent below currentlevels possible if energy efficiency improvementsand new renewables are used to reduce generationof electricity from the highest carbon-emittingsources. (See box below.)

• Nuclear Power and Offsets – A carbon cap-and-trade program should not be allowed to become abackdoor subsidy for nuclear power.

For environmental and public safety reasons, Mas-sachusetts and the New England states should bemoving toward a phase-out of nuclear generatingcapacity, beginning particularly with the retirementof existing nuclear reactors upon the expiration oftheir current operating licenses. Nuclear plants werenot designed to operate for longer than their cur-rent licenses. The expansion or maintenance ofnuclear generating capacity in New England orelsewhere should not be permitted to qualify as anoffset under any cap-and-trade program.

The use of offsets as a method of compliance withthe carbon cap also produces other potential prob-lems. Massachusetts’ rule for its electric sector car-bon dioxide emission cap requires that any offsetsprovide “real, surplus, verifiable, permanent andenforceable” emission reductions.90 Practicallyspeaking, designing offsets that meet these criteriais extraordinarily difficult. Demonstrating that anemission reduction is truly “surplus” requires ad-ministrators of a cap-and-trade program to assesswhat would have happened in the absence of a cap– for example, whether energy efficiency improve-ments used to generate offsets would have hap-pened anyway. Assessing permanence requiresfrequent verification that previous emission reduc-tions or sequestration activities remain in effect.

A sure way to avoid these problems is to draw theboundaries of any trading program very narrowly– including only those sources that emit carbondioxide, and only those within the region coveredby the program (in the case of RGGI, within the10-state region).


• Leakage – In theory, emission reductions thatwould be generated by a state or regional carboncap could be offset by increased emissions result-ing from power imported into Massachusetts orthe Northeast. To prevent this “leakage” of emis-sion reductions, the region must ensure a level play-ing field between electricity generated in theNortheast and imported electricity, perhaps by set-ting carbon dioxide emission standards for im-ported electricity. Another alternative is to expandthe cap to cover a broader geographic area, whilemaintaining strong provisions to ensure that thecap is enforced.

• Auctioning Credits – Another point of tensionrevolves around whether existing electricity gen-

erators in the Northeast would be required to buyemission credits at the outset of a carbon cap or begiven them for free. The free granting of emissioncredits to existing generators would act as a de factosubsidy to those plants, as well as grant those plantsan effective “right to pollute.” In addition, the auc-tioning of emissions credits could produce a sourceof income that could be returned to all residents,used to support efficiency and renewable power,or used for transition help for displaced workers.

The ongoing RGGI process, while important, shouldnot distract Massachusetts from completing therulemaking for the state’s own carbon dioxide limits.First, the state rule adopted in Massachusetts, if it isstrong, could become a positive example for other

Fig. 8. New England Projected Carbon DioxideEmissions from Electricity Generation (MMTCE)91

The Role of a Regional Carbon Cap in Reducing Electric-Sector EmissionsTo demonstrate the feasibility of a strong electric sector carbon cap without nuclear relicensing, estimateswere made of current and projected New England electricity use and carbon emissions based on the adoptionby all six New England states of the policies described in this report.

Were a carbon cap to be structured so as to use efficiency savings and new renewables from the policymeasures in this report to offset generation from coal-fired power plants first, then oil-fired plants, NewEngland could achieve up to a 29 percent reduction in electric sector carbon dioxide emissions by 2020

versus baseline 2001 levels. (See “HighReduction Case” in Fig. 8 below.) Bycontrast, using those efficiency savingsand new renewables to offset naturalgas-powered generation (forecast byEIA to make up virtually all of NewEngland’s new generating capacityafter 2009), would result in 2020reductions of only 3 percent versus2001 levels. (See Fig. 8, left.) Bothcases assume the retirement of NewEngland’s nuclear reactors at theexpiration of their current licenses.

Decisions regarding the level of aregional carbon cap will invariably takemany factors into account beyondachieving the maximum carbon dioxide

emission reductions. It is likely that emission reductions from a well-structured cap would fall somewherewithin the range of reductions estimated here. However, it is also possible that an aggressive regional effortto promote renewables could enable them to become economically competitive with other forms ofgeneration. Were that scenario to take place, the level of emission reductions possible under a carbon capwould be significantly greater.

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northeastern states to look to in the RGGI process.Second, while the commitment of the 10 states to theRGGI process appears sincere, there is no guarantee thatan agreement will be reached in a timely manner. Mas-sachusetts, by contrast, will require the achievement ofspecific reductions of carbon dioxide from the six olderpower plants covered under the rules by 2008.

Other Electric Sector Strategies toConsider• Green Power Option – The advent of retail com-

petition in electricity markets was to have broughtMassachusetts residents and businesses a variety ofchoices for supply of electricity – including thechoice to purchase power generated from renew-able resources. Companies in Massachusetts thatserve at least 40 percent of the state’s residents of-fer consumers electricity from renewable sources.92

The state could require all utilities serving Massa-chusetts consumers to offer a green power productmeeting minimum standards for renewable powergeneration. The standards should be set so thatgreen power products result in new renewable gen-eration over and above levels set in the state’s RPS.

Like the transportation sector, the electric sector is amajor source of global warming pollution in NewEngland. Unlike the transportation sector, however,Massachusetts and other New England states have anumber of mature, well-developed policy tools avail-able to both improve energy efficiency and facilitatethe shift to lower carbon sources of energy in the elec-tricity sector. As a result, the potential for savings inthe electric sector is disproportionately large and thestate and region should take full advantage of thatpotential.

Public Sector and

Other Strategies

Strategy #13: Public Sector “Lead byExample”Potential Savings: 0.04-0.05 MMTCE by 2010; 0.06MMTCE by 2020.Federal, state, and local governments are significantusers of energy in Massachusetts. State government

alone consumes about 1.2 percent of the state’s elec-tricity, along with large amounts of natural gas, heat-ing oil and motor fuel.93 But reducing energy use inthe government sector not only has a direct impacton global warming emissions; it also sets an examplefor the private sector as to what can be achieved andcreates markets for clean energy products.

The state of Massachusetts has already adopted somepolicies and practices that improve energy efficiencywithin state government and thus reduce thegovernment’s contribution to global warming. Thesepolicies include preferences for the purchase of envi-ronmentally preferable products and efficiency mea-sures for some state buildings.94

The state of Massachusetts should set a series of ag-gressive goals for the reduction of carbon dioxideemissions from state government. The state shouldendeavor to:

1) Reduce energy use in state facilities by 25% by2010.

The state government can achieve significant energysavings through a series of initiatives including:

Aggressive building retrofit programThe state should seek to retrofit at least half of allstate buildings for improved energy efficiency by 2010.A potential model for an expanded building retrofiteffort is the Building Energy Conservation Initiative(BECI) in New Hampshire, under which 1.2 millionsquare feet of office space have been retrofitted forefficiency improvements, saving an estimated 26 bil-lion BTU of site energy each year.95 Efficiency im-provements under the program are paid for from theprojected savings in energy costs resulting from theproject. Only projects that can be demonstrated to becost-effective can be undertaken through the program.

Adopt Green Building Standards for New State Build-ing ConstructionAs noted above, buildings certified to the Leadershipin Environmental & Energy Design (LEED) standardsachieve significant savings in energy use compared tobuildings certified to current building codes. The stateshould set achievement of LEED silver standards asthe goal for all new state buildings wherever feasible.

2) Improve the energy efficiency of the state vehiclefleet.


Massachusetts’ state government’s main fleet consistsof thousands of cars and light trucks. The state’s high-way division owns additional trucks and heavy equip-ment. Vehicles in all state and local government fleetsin Massachusetts consumed 34 million gallons of gaso-line in 2001, according to the Federal Highway Ad-ministration, representing over 1 percent of totalgasoline use in the state.96

To improve the energy efficiency of the state fleet,Massachusetts should require the purchase of the mostefficient vehicle that will serve the given governmen-tal purpose, within a reasonable cost premium. Thefuel economy spectrum in many classes of vehicles iswide – in the light-duty sector, the most fuel-efficientvehicle in each class in 2003 ranged from 13 percentto 140 percent more efficient than the average ve-hicle.97 Special efforts should be undertaken to pur-chase hybrid-electric vehicles, where available.

Second, Massachusetts should restrict the use of sportutility vehicles to those government functions in whichfour-wheel-drive and off-road capabilities are trulyrequired, as has been proposed by Gov. Romney.Doing so will likely not only reduce energy consump-tion, but will also save taxpayers money.

Finally, Massachusetts should implement a purchas-ing strategy for alternative-fuel vehicles that empha-sizes technologies that are inherently low-carbon. Thefederal Energy Policy Act (EPAct) of 1992 requires75 percent of applicable light-duty vehicles purchasedby state governments to operate on alternative fuels.Unfortunately, EPAct includes several perverse incen-tives and disincentives. For example, flexible-fuel ve-hicles that can operate on either gasoline or analternative fuel receive EPAct credit, even if they neveroperate on the alternative fuel. On the other hand,hybrid-electric vehicles are excluded from EPActcredit, despite their superior efficiency. Massachusettshas traditionally sought to maximize the carbon-re-duction potential of the EPAct requirements by pur-chasing dedicated, low-carbon, alternative-fuelvehicles such as electric and compressed natural gas(CNG) vehicles. The state should maintain this policyand work to expand refueling opportunities for alter-native-fuel vehicles. Meanwhile, Massachusetts andother New England states should urge revisions toEPAct that would enhance the program’s effectivenessas an emissions reduction tool.

3) Purchase 20 percent of the state’s electricity fromclean renewable sources by 2010 and 50 percent by2020.Enlisting Massachusetts state government as a pur-chaser of renewable electricity would provide yet an-other incentive for the development of wind, solarand other forms of renewable power in the state andregion. Government purchases of “green power”would be over and above the levels of renewable powerrequired by an enhanced Renewable Portfolio Stan-dard and should include the development of distrib-uted renewable resources on state buildings and land,such as rooftop solar systems, where appropriate.

4) Encourage public sector improvements outsideof state government.Municipal governments in Massachusetts are alsomajor consumers of energy. The state should use itsrole as a partial funder of school and other local con-struction projects to drive improvements in energyefficiency for those projects. Similarly, the state shouldhelp municipalities to develop market power in thepurchase of efficient vehicles and equipment.

Strategy #14: Develop andImplement a Global WarmingEmissions RegistryPotential Savings: Not estimated.A registry system for recording and tracking globalwarming emissions is a key piece of infrastructure inMassachusetts’ efforts to reduce its contribution toglobal warming. At present, Northeast States for Co-ordinated Air Use Management (NESCAUM) is de-veloping a registry system for the region that will likelybe operable by the end of 2005. Initially, the systemwill focus on recording emissions from the electricpower industry, but it could also be used as a way forentities to voluntarily record their baseline globalwarming emissions and reductions over time.

Massachusetts has already adopted regulations requir-ing older coal and oil-fired power plants to report theircarbon dioxide emissions. Unlike NESCAUM’s vol-untary registry, Massachusetts will require powerplants to report their emissions. The program’s de-tails have not yet been established, but likely will in-volve independent monitoring of emissions inaddition to self-reporting.


The impact of a registry system like NESCAUM’s(beyond its role in implementing an electric sectorcarbon cap) is difficult to determine, particularly inthe short run. However, once developed, a registrysystem could eventually be adapted to promote mar-ket-based (trading) and/or regulatory approaches tothe reduction of global warming emissions. Eventu-ally, entities responsible for large-scale emissions ofglobal warming emissions should be required to re-port their emissions to the registry.

The Impact of the

Strategies

Short- and Medium-Term ImpactsThe 14 strategies listed above would not be enough –on their own – to achieve the regional short- andmedium-term global warming gas reduction goalswithin Massachusetts. But, combined with other posi-tive strategies discussed by the New England gover-nors, other policy options suggested in this report,and action at the federal level in areas in which Mas-sachusetts’ freedom of action is limited, they can putthe state on a solid footing to achieve its goals.

We estimate that the strategies listed above would re-duce Massachusetts’ direct (non-electric) emissions of

carbon dioxide by 16 percent below projected levelsby 2020. Direct emissions would be about 12 per-cent above 1990 levels in 2010 and 15 percent above1990 levels in 2020. (See Fig. 9.)

Regionally, the combination of reduced electricityconsumption in the residential, commercial and in-dustrial sectors with the increased use of renewablesources of energy would result in a significant reduc-tion in carbon dioxide emissions from the electricitysector. The 14 strategies above would reduce carbondioxide emissions from power generation in NewEngland by about 2.1-4.8 MMTCE by 2010 and 4.3-7.7 MMTCE by 2020 versus projected levels.

Were all six New England states to adopt all 14 strat-egies, the region would take significant strides towardachieving the goals of the New England governors’and Eastern Canadian premiers’ climate change ac-tion plan. Total carbon emissions would be reducedby 18-23 percent versus projected levels by 2020, de-pending on the final level of any regional carbon cap.With a carbon cap that allowed the displacement ofhigh-carbon generation and the adoption of all 14strategies in all six states, carbon dioxide emissions in2010 would be about 7 percent above 1990 levels(compared to the regional goal of attaining 1990emissions levels by 2010). Emissions in 2020 wouldbe about 9 percent above 1990 levels (compared to

Fig. 9. Projected Non-Electric Carbon Dioxide Emissionsin Massachusetts (MMTCE)

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With Adoption of 14StrategiesRegional Goal


the regional goal of reducing emissions to 10 percentbelow 1990 levels by 2020).

The adoption of these 14 strategies by all New En-gland states, therefore, would bring the region about70 percent of the way to meeting the regional short-term carbon dioxide reduction goal and about 60 per-cent of the way to meeting the medium-term goal.The adoption of additional strategies identified in thisreport could help in closing the gap.

Putting it in Perspective – Achievingthe Long-Term Goal

Ultimately, Massachusetts’ efforts to reduce globalwarming emissions will be judged not by the state’sability to achieve interim goals, but by the speed withwhich the state can reduce – and eventually eliminate– its contribution to the degradation of the climate.Achieving the long-term reductions in emissions of75-85 percent that scientists believe will be needed toeliminate any harmful threat to the climate is the truetest by which the state’s efforts must be assessed, andshould remain the overarching goal.

The 14 strategies above not only move Massachusettsfar toward achievement of the short- and medium-term goals, but they also begin to lay the groundwork

for a deeper transition that will bring the long-termgoals within reach. In the transportation sector, swiftimplementation of a clean cars requirement will en-sure the placement of tens of thousands of high-effi-ciency and zero-emission vehicles on Massachusetts’roads, while focusing the research energy ofautomakers on the development of the next genera-tion of clean automobile technologies. The Pavleyprogram, if properly designed and implemented, willcreate the regulatory framework to ensure that all ve-hicles make the least possible impact on the climate.New buildings and appliances will have energy effi-ciency built in, while owners of existing buildings andappliances will be able to take advantage of energyefficiency programs to reduce their energy consump-tion. Wind power and other renewables will produceone-fifth of the electricity Massachusetts uses, whilesolar panels, fuel cells and other new technologies willbe market-ready and prepared to compete with tradi-tional fossil and nuclear electricity.

Even with these advances, Massachusetts will still facedifficult challenges. Our communities will have to bereshaped to rely less on individual cars and trucks totransport people and goods. Our economic systemwill have to reflect more fully the environmental andpublic health costs of the energy we use, and providethe capital needed to make the transition to cleanerand more efficient ways of living and doing business.Emissions of other global warming gases will have tobe reduced dramatically. And other states, regions and

Fig. 10. New England Projected Carbon Dioxide Emissions (MMTCE)

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Table 5. Carbon Dioxide Emission Reductions from Strategies and Additional ReductionsRequired to Meet Regional Goals (MMTCE)

1990 2000 2010 2020MASSACHUSETTS DIRECT CARBON DIOXIDE EMISSIONS

Historic/Projected Emissions 15.35 16.39 18.55 20.91

Regional Goal 15.35 13.82

Reductions Needed to Achieve Goal 3.20 7.09

Reductions from 14 Strategies 1.35 3.30

Additional Reductions Needed 1.85 3.79

NEW ENGLAND ELECTRIC SECTOR EMISSIONS

Historic/Projected Emissions 12.01 12.56 13.84 17.00

Regional Goal 12.01 10.81

Reductions Needed to Achieve Goal 1.83 6.19

Reductions from 14 Strategies (High/Low Case) 4.80/2.07 7.69/4.33

Additional Reductions Needed 0/0 0/1.86

nations far from Massachusetts will have to do theirshare as well.

Affecting these changes will require an unprecedentedamount of research, discussion, cooperation and po-litical will – as well as a commitment to achieve thelong-term goal within a reasonable time frame; forexample, by 2050. The early signs are positive: Mas-sachusetts and the other New England states are nowengaged in the discussion and study of global warm-ing, its impacts, and the means of addressing the prob-

lem in a way they have never been before. But thecritical test – implementation – lies ahead.

The strategies laid out in this report show the wayforward. By using existing technologies and reason-able public policy tools, Massachusetts can make largestrides toward reducing the state’s contribution to glo-bal warming in the near term, while in many casesimproving public health, economic well-being andenergy security, and providing a model of leadershipfor others to follow.


Emission-Reduction Strategies inConnecticut and Rhode IslandStakeholder groups in Connecticut and RhodeIsland have recommended emission-reductionpolicies for their states that achieve, or comeclose to achieving, the regional globalwarming emission reduction goals. Thestakeholder groups, which represent a broadrange of interests from government, businessand industry, the nonprofit sector andacademia, selected policies that they thoughtwould substantially reduce emissions withoutcreating unreasonable requirements for anysector.

Rhode Island: The combined results of the 49in-state policy options identified in RhodeIsland’s Greenhouse Gas Action Plan will allowthe state to meet the 2020 emissions-reduction target; further reductions can beachieved through recommended policies thatinvolve regional or national coordination. Thestrategies include:

• Implementing a fuel-efficiency feebate pro-gram: Purchasers of low efficiency vehicleswould pay a fee, while purchasers of moreefficient vehicles would receive a rebate.

• Improving the efficiency of buildings: A vari-ety of programs would be created to replaceexisting equipment in homes and businesseswith more energy efficient equipment and topromote the use of efficient combined heat-and-power.

• Encouraging smart growth: This would includeinitiatives to encourage the integration ofland-use zoning and transit planning to re-duce automobile trips by maximizingwalkability, improving bus services, and guid-ing growth along rail transit routes.

• Adopting a renewable energy standard: A mini-mum percentage of electricity sold in the statewould have to come from qualifying renew-able resources. The stakeholders estimated theimpact of a 20 percent by 2020 target, but didnot recommend specifics for the policy, andagreed that further assessment would beneeded.

Connecticut: The Connecticut Climate ChangeStakeholder Dialogue’s 55 policyrecommendations come close to achieving the2020 regional target. The Connecticut planrecommends:

• Adopting the California clean car standards:Strict emission standards for all new cars soldbeginning in model year 2007 would reduceemissions from the transportation sector.

• Creating a greenhouse gas feebate program: Pur-chasers of high greenhouse gas-emitting ve-hicles would pay a fee, while purchasers oflow emitting vehicles would receive a rebate.

• Improving efficiency in homes: This would de-crease energy use in houses by requiring build-ings to meet the most recent energy codes,expanding the rebates offered under the En-ergy Star Homes program, and providing fund-ing to double the number of houses servedunder the federal Weatherization AssistanceProgram.

• Adopting a renewable energy strategy: The statewould extend its existing renewable energystandard for electricity generation, require thatstate government and universities purchase apercentage of their electricity from zero-emis-sion renewables, and offer a tax credit for quali-fying renewable energy production.


General Assumptions andLimitationsThis report relies primarily on data and projectionsfrom the U.S. Energy Information Administration(EIA) to estimate past, present and future global warm-ing gas emissions in Massachusetts. Future emissiontrends in Massachusetts are generally based on EIA’sprojected rates of growth for New England as a whole.Massachusetts trends will differ, but the EIA growthprojections provide a reasonable approximation offuture trends, particularly given the regional contextof Massachusetts’ global warming emission reductionefforts.

EIA’s projections of future energy use – as publishedin the Annual Energy Outlook 2003 (AEO 2003) –are intended to reflect all federal, state and local legis-lation adopted as of September 1, 2002. Several policychanges adopted after that date will have an impacton carbon dioxide emissions in Massachusetts (includ-ing the recent increase in the CAFE standard for lighttrucks). We have not attempted to revise EIA’s assump-tions to reflect these changes.

This analysis focuses exclusively on emissions of car-bon dioxide from energy use in Massachusetts andNew England. The exclusion of other global warm-ing gases from this analysis is not intended to mini-mize their importance, but is the result of time andresource limitations.

This report also limits its scope of analysis to the sixNew England states. Several of the policies describedhere could have effects outside the region that wouldeither create additional carbon dioxide emissions orreduce emissions further than projected here. Becauseglobal warming is a global problem, it is important toconsider these potential spill-over effects when set-ting policy, but it is beyond the scope of this report todo so.

All fees, charges and other monetary values are in 2003dollars and are assumed to be indexed to inflation. Inother words, the systems benefit charge assessed onelectricity purchases in 2020 is assumed to have thesame buying power as a 5-mill charge would have in2003.

METHODOLOGY AND TECHNICAL DISCUSSION

Baseline Emission EstimatesBaseline estimates of carbon dioxide emissions fromenergy use for 1990 were based on energy consump-tion data from EIA, State Energy Data 2000 (SEDR2000). To calculate carbon dioxide emissions, energyuse for each fuel in each sector (in BTU) was multi-plied by carbon coefficients for 1990 as specified inEIA, Emissions of Greenhouse Gases in the United States2001, Appendix B.

Significant changes in EIA’s methodology for collect-ing and presenting data render some information inSEDR 2000 unreliable for estimating 2000 carbondioxide emissions, and require adjustments in the1990 data. Specifically, EIA has changed the sourcesof some of its energy use data and reallocated energyuse and emissions from non-utility producers of powerfrom the industrial to the electric sector.

There were several possible methods for obtaining state-specific energy use data for fuels and sectors in whichSEDR 2000 data are inaccurate. Our approach was toseek out the most recent available data from EIA’s fuel-specific reports or to follow EIA-specified methodolo-gies for adjusting data presented in SEDR 2000.

The 1990 figures for natural gas usage in each sectorwere adjusted upward by 2.3 percent, correspondingwith the upward revision in national natural gas usefigures as reported in EIA, Emissions of GreenhouseGases in the United States, 2001. The allocation of coaluse and emissions between the industrial and electricsectors was adjusted as described for 2000 data be-low.

The following sources and methods were used by fuel:

• Coal – For both 1990 and 2000, coal use andemissions were reallocated between the industrialand electric sectors based on the following method,adapted from EIA, Emissions of Greenhouse Gasesin the United States 2000, Appendix A:1) Total coal use for all sectors in BTU was ob-

tained from SEDR 2000.2) Residential and commercial coal use in BTU

was subtracted from the total, leaving totalindustrial and electric sector consumption.


3) Electric utility consumption was estimated bymultiplying utility consumption of coal inshort tons from EIA, Electric Power Annual2001, Consumption by State by the appropri-ate heat rate for Massachusetts, obtained fromEIA, SEDR 2000, Appendix B.

4) Consumption by non-utility power producerswas estimated by multiplying the remainingcoal consumption from the electric power sec-tor (from Electric Power Annual 2001) by theappropriate heat rate.

5) Estimated consumption by utility and non-utility power producers was summed to arriveat total electric energy use from coal. This fig-ure was then subtracted from the electric-plus-industrial consumption estimate to arrive atestimated consumption in the industrial sector.

• Natural Gas – Sector-specific natural gas consump-tion data for Massachusetts in million cubic feetwere obtained from EIA, Massachusetts Natural GasConsumption by End Use, downloaded fromt o n t o . e i a . d o e . g o v / d n a v / n g / n g _ c o n s _sum_sma_m_d.htm, updated 21 August 2003.Consumption data were converted to BTU valuesusing thermal conversion factors from SEDR 2000.

• Petroleum – Data for consumption of distillateand residual fuel by sector was obtained from EIA,Fuel Oil and Kerosene Sales 2001, and then con-verted to BTU values using heat rates from AEO2003, except for the use of petroleum in the elec-tric power sector, which was obtained from EIA,Electric Power Annual 2001 spreadsheets, Con-sumption by State. Estimated use of other petro-leum products was based on SEDR 2000.

Several additional assumptions were made:

• Carbon dioxide emissions due to electricity im-ported into New England were not included inthe emissions estimates, nor were “upstream” emis-sions resulting from the production or distribu-tion of fossil or nuclear fuels.

• Combustion of wood and other biomass was ex-cluded from the analysis per EIA, Emissions ofGreenhouse Gases in the United States 2001, Ap-pendix D. This exclusion is justified by EIA onthe grounds that wood and other biofuels obtaincarbon through atmospheric uptake and that their

combustion does not cause a net increase or de-crease in the overall carbon “budget.”

• Electricity generated from nuclear and hydroelec-tric sources was assumed to have a carbon coeffi-cient of zero.

• Carbon emissions from the non-combustion useof fossil fuels in the industrial and transportationsectors were derived from estimates of the non-fuel portion of fossil energy use and the carbonstorage factors for non-fuel use presented in U.S.EPA, Comparison of EPA State Inventory Summa-ries and State-Authored Inventories, downloadedfrom yosemite.epa.gov/oar/globalwarming.nsf/UniqueKeyLookup/JSIN5DTQKG/$File/pdfB-comparison1.pdf, 31 July 2003. To preserve thesimplicity of analysis and to attain consistency withfuture-year estimates, industrial consumption ofasphalt and road oil, kerosene, lubricants and otherpetroleum, and transportation consumption ofaviation gasoline and lubricants were classified as“other petroleum” and assigned a carbon coeffi-cient of 20 MMTCE per quad BTU for that por-tion that is consumed as fuel.

Known Discrepancies with OtherPublished EstimatesDue to variations in methodology, the adjustment ofenergy use figures over time, and inherent disagree-ment in the data presented in various EIA reports,the emissions estimates for 2000 presented here dif-fer somewhat from regional emission estimates de-rived from AEO 2003.

Because the estimates for this report were compiledusing a common methodology applied to all six NewEngland states, it is also possible to compare the re-gional total emissions estimate with estimates derivedfrom AEO 2003 and presented in the New EnglandClimate Coalition’s 2003 report, Global Warming inNew England. Estimated 2000 carbon dioxide emis-sions for the region based on the sources and meth-odology in this report are about 3 percent lower thanestimated emissions based on AEO 2003’s regionalenergy use figures – assuming the continued opera-tion of the region’s nuclear power plants in both cases.Specifically, the methodology of this report appears


to significantly underestimate emissions from petro-leum use in the commercial sector and natural gasuse in the industrial sector and to overestimate emis-sions from natural gas use in the commercial sectorwhen compared to estimates based on AEO 2003.These discrepancies are likely due to the use of vary-ing EIA reports for fuel use estimates. The expectedpublication of an updated version of SEDR in 2004should clear up these discrepancies and we encouragea revisiting of the data at that time.

Future Year ProjectionsProjections of energy use and carbon dioxide emis-sions for Massachusetts are based on applying the NewEngland year-to-year projected growth rates for eachfuel in each sector from AEO 2003 to the Massachu-setts baseline emissions estimate for 2000, with twoexceptions.

1) In the transportation sector, EIA’s estimates of ve-hicle travel increases are significantly higher thanprojections produced by the Massachusetts High-way Department and recent experience in the state.Instead of using EIA’s projected growth rates formotor gasoline use, we used a growth rate of 1.4percent per year, commensurate withMassHighway’s projections of vehicle miles trav-eled increases for 2002 to 2020, supplied by thedepartment in February 2003. This assumes noimprovement or deterioration in light-duty vehiclefuel economy in the aggregate between now and2020. While it is likely that EIA’s methodologyalso overstates emissions for diesel fuel use, we usedthe EIA assumptions because of the difficulty ofdisaggregating vehicular diesel fuel use from useby other transportation modes.

2) Unlike EIA, we assume that nuclear reactors inNew England are retired at the expiration of theircurrent operating licenses. Thus, the base case es-timate for power-sector energy use in Massachu-setts was adjusted by eliminating any nucleargeneration from the power-sector energy mix be-yond 2012 and replacing it with gas-fired genera-tion. The level of electric-sector natural gasconsumption needed to replace nuclear generationwas estimated by multiplying the amount ofnuclear energy consumption based on AEO 2003by the ratio of the calculated heat rate for natural

gas generation divided by the imputed heat ratefor nuclear generation, based on data from Supple-mentary Table 66 of AEO 2003. Heat rates werecalculated by dividing energy consumption for eachfuel by net generation for each fuel. This methodwill tend to slightly overstate energy use – andtherefore emissions – from natural gas, since it islikely that new natural gas-fired generation will bemore efficient than the average efficiency of allnatural gas plants in the region for any given year.

Carbon Dioxide Reductions fromElectricity Savings and RenewablesCarbon dioxide reductions for measures that reduceelectricity use or expand renewable resources weregenerally estimated based on the impact of the reduc-tions on the entire New England grid. For individualstrategies, a range of savings was projected based ontwo sets of assumptions:

• Low savings estimate – Based on the use of effi-ciency savings and renewables to first offset powerlost through the closure of in-state nuclear plantswhose licenses have expired, then to offset naturalgas generation on the New England grid, which isprojected by EIA in AEO 2003 to account for vir-tually all of New England’s new electric generat-ing capacity beyond 2009. The formulas used tocalculate these reductions are similar to those de-scribed above for the replacement of nuclear powerin the base case, with differences in heat ratesamong the fuels used to estimate the amount ofgenerating capacity that would be displaced. Thiscase is intended to replicate a scenario in whichefficiency and renewable savings are used to avoidthe need to construct new generating capacity,rather than retire less-efficient old generators.

• High savings estimate – Based on the use of effi-ciency savings and renewables to first offset powerlost through the closure of in-state nuclear plantswhose licenses have expired, then to offset genera-tion on the New England grid with the highestcarbon dioxide emissions, first coal, then petro-leum. The assumed offset of coal-fired generationmay not yield the maximum carbon reductionspossible under a regional carbon cap, since someoil-fired generating units in New England producegreater carbon dioxide emissions per unit of deliv-


ered electricity than coal-fired plants. The exami-nation of power plant-by-power plant data was,however, beyond the scope of this report. As a re-sult, the simplifying assumption to reduce coal-fired generation likely produces a conservativeestimate of the maximum potential benefits of anelectric-sector carbon cap.

The two estimates suggest the potential impact of anelectric-sector carbon cap, with greater savings aris-ing from a strong cap that creates pressure to retireold generation (the high savings estimate) and lessersavings arising from a weak cap or the absence of acap (the low savings estimate). In reality, it is likelythat both the high and low estimates are somewhatextreme – that is, that some old coal-fired generationwould be retired in the absence of a cap and that somesmall amount may remain even with a cap.

In addition, all electricity-related estimates assume thatNew England produces all the power it consumes andis neither a net importer nor a net exporter of electric-ity. The potential for “leakage” of emission reductions –in which public policies result in increased importationof high-emission electricity from elsewhere, thus lead-ing to greater emissions in the aggregate – is an impor-tant issue for policy-makers to address, but was beyondthe scope of this report to incorporate.

Transportation Sector StrategiesAll estimated reductions from transportation-sectorstrategies were derived by estimating the percentagereductions in light-duty vehicle motor gasoline usefrom the baseline arrived at by the methods above.Light-duty vehicle gasoline use was estimated bymultiplying the motor gasoline baseline by the per-centage of motor gasoline used by light-duty vehicles,derived from the supplementary tables to AEO 2003.

Percentage reductions were calculated by multiplyinggrams/mile emission factors for carbon dioxide, basedon a modified version of the Argonne NationalLaboratory’s GREET model, version 1.5a, by the pro-jected percentages of VMT driven by vehicles of vari-ous classes, types and ages, estimated as describedbelow. Estimates for light-duty carbon dioxide emis-sions were based on the following sources:

• Vehicle-miles traveled (VMT) percentages – VMTpercentages by vehicle class were derived by divid-ing projected national light-duty VMT for eachyear by the projected national light-duty vehiclestock as reported in supplementary tables to AEO2003. This average VMT/vehicle/year figure wasthen adjusted to reflect the slightly higher VMT/vehicle/year of passenger cars versus light trucks(based on a two-year average of VMT/vehicle de-rived from FHWA data) and multiplied by theprojected nationwide passenger car and truckstocks in AEO 2003. Light-duty truck VMT wasfurther divided into heavy and light categories bymultiplying the total truck VMT by vehicle stockpercentages contained in EPA, Fleet Characteriza-tion Data for MOBILE6, September 2001. Theprojected VMT for each vehicle class was then di-vided by the total light-duty VMT to arrive at thepercentage of total VMT traveled by vehicles ineach class in each year.

VMT were further disaggregated into VMT bymodel year and vehicle class for each year between2001 and 2020, based on estimates of VMT accu-mulation rates presented in EPA, Fleet Characteriza-tion Data for MOBILE6. No attempt was made tocustomize the national VMT percentages for Mas-sachusetts.

• Carbon dioxide emission factors – Grams-per-mileemission factors for each model year and class werebased on modifications to the GREET model, ver-sion 1.5a. For conventional gasoline vehicles, theonly modification to the model was the substitu-tion of “real-world” fleet average miles per gallon(MPG) estimates for each model year from 1970to 2020. For 1975 through 1999, real-world MPGwas calculated by multiplying EPA-rated MPG forcars and light trucks (as reported in EPA, LightDuty Automotive Technology and Fuel EconomyTrends, 1975 Through 2003, April 2003) by anadjustment factor of 0.8. For model years prior to1975, 1975 figures were used. For 2000-2020, newcar and truck on-road miles per gallon was basedon Supplementary Table 49 to AEO 2003.

Real-world MPG projections were then input intothe GREET model, producing grams-per-mile car-bon dioxide emission factors for vehicle operations.


Carbon dioxide emissions stemming from feed-stock and fuels were not included in this analysis.The resulting emission factors for vehicles greaterthan three years old were then divided by 0.97 toaccount for the loss of fuel economy resulting fromthe replacement of low-rolling resistance tires withless-efficient replacement tires.

For vehicles covered by the Zero Emission Vehicleprogram, vehicles sold to meet the program’s obli-gation for Advanced Technology Partial Zero-Emission Vehicle (AT-PZEV) credits were assumedto be hybrids, producing the same per-mile emis-sions as default hybrid vehicles in the GREETmodel, and vehicles sold to meet the obligationfor pure Zero Emission Vehicle (ZEV) credits wereassumed to be GREET model-default hydrogenfuel-cell vehicles. Because hydrogen fuel-cell ve-hicles emit no pollutants in vehicle operation, life-cycle carbon dioxide emissions were used. Thisassumption may result in a higher estimate for in-state carbon dioxide emissions from fuel-cell ve-hicles because it is unclear whether the conversionfrom natural gas to hydrogen would take place lo-cally (thus resulting in carbon dioxide emissions)or at an out-of-state location.

Zero-Emission Vehicle ProgramPercentages of conventional, AT-PZEV and ZEV ve-hicles that would be sold in Massachusetts under theZEV program were derived from projections of ve-hicle sales in California under the ZEV program inChuck Shulock, California Air Resources Board, TheCalifornia ZEV Program: Implementation Status, pre-sented at EVS-20, the 20th International Electric Ve-hicle Symposium and Exposition, November 2003.ZEV program implementation was assumed to be-gin in 2007. The sale of pure ZEVs was assumed tonot be required until 2012 per recent proposedchanges in the California ZEV rule. Estimates ofCalifornia sales may not translate accurately to Mas-sachusetts due to automakers’ accumulation ofbanked credits that can be used to reduce ZEV pro-gram obligations in the early years of the program inCalifornia.

To adjust for the presumed inclusion of earlier ZEVprogram requirements in AEO 2003 projections, sav-ings from the ZEV program were reduced by the es-

timated reductions of the previous (2001) version ofthe ZEV program, with estimated ZEV sales percent-ages derived from a spreadsheet supplied by CARBbased on the 2001 ZEV amendments, with all pureZEVs under the old scenario presumed to be full-function battery-electric vehicles.

California Vehicle Carbon Dioxide LimitsEmission factors for conventional vehicles (i.e. thosenot used to obtain ZEV or AT-PZEV credits) underthis scenario were assumed to be reduced by 30 per-cent between 2009 and 2019, with reductions takingplace in a linear fashion over that time period. Be-cause California has not yet proposed regulations forimplementing tailpipe carbon dioxide limits, it isimpossible to know whether ultimate reductions willbe greater or less than the 30 percent estimated hereand the estimated program benefits should be inter-preted with caution.

Low Rolling Resistance TiresSavings from the use of low rolling resistance replace-ment tires were estimated by reducing carbon diox-ide emission factors by 3 percent from baselineassumptions for vehicles reaching four, seven and 11years of age beginning in 2005, per California EnergyCommission, California Fuel-Efficient Tire Report,Volume II, January 2003. This estimate assumes thatthe tire stock will completely turn over; that is, thatLRR tires will supplant non-LRR replacement tiresin the marketplace through a state requirement. Otherpolicies to encourage, but not mandate, LRR tires willlikely produce reduced savings.

FeebatePotential savings from a feebate program are basedon estimated fuel economy improvements from aCalifornia state feebate program in ReducingCalifornia’s Petroleum Dependence (California EnergyCommission and California Air Resources Board, Fi-nal Staff Report, August 2003, Appendix C, Attach-ment B, B-251). Improvements in fuel economytranslate to a 4.2 percent reduction in carbon dioxideemissions per mile for new cars by 2010 and an 8.2percent reduction by 2020. For light trucks, estimatedreductions in carbon dioxide emission rates are 5 per-cent by 2010 and 8.4 percent by 2020. Improvements


in fuel economy are assumed to take place linearlybeginning in 2005. The impact of a feebate programin Massachusetts could be greater or less than the Cali-fornia program studied depending on the scope ofthe program and its design.

Pay-As-You-Drive Automobile InsuranceEstimates of the impact of PAYD insurance are basedon the assumption that 80 percent of collision andliability insurance payments in Massachusetts wouldbe transferred to a mileage-based system, with par-ticipation in the system increasing by 10 percent peryear from 2005 to 2010, and 50 percent of all light-duty drivers participating in the system from 2010 to2020. The average per-mile cost of insurance was com-puted by multiplying the average expenditure on col-lision and liability insurance in Massachusetts in 2001as reported in Facts and Statistics: The Rising Cost ofAuto Insurance (Insurance Information Institute,downloaded from www.iii.org/media/facts/statsbyissue/auto/content.print/, 29 October 2003) bythe number of light-duty vehicle registrations in Mas-sachusetts from FHWA, Highway Statistics 2001. Thistotal expenditure figure was then divided by light-duty VMT derived from adjusted FHWA figures toarrive at an average per-mile cost for liability and col-lision insurance. This per-mile cost was then multi-plied by 0.8 to account for any non-mileage relatedaspects of liability and collision coverage and to en-sure the conservatism of the estimate, yielding an av-erage per-mile charge of 7.8 cents. The estimatedreduction in VMT that would result from such acharge was obtained from Online TDM Encyclopedia:Pay-As-You-Drive Vehicle Insurance (Victoria TransportPolicy Institute, downloaded from www.vtpi.org/tdm/tdm79.htm, 3 December 2003). It was assumed thatthe decrease in VMT (11.2 percent) for drivers par-ticipating in the program would take place beginningimmediately upon program implementation in 2005.

VMT StabilizationVMT increases in this scenario are estimated to re-flect Massachusetts’ projected rate of populationgrowth between 2006 and 2020 per Projections of theTotal Population of States: 1995 to 2025, (U.S. Cen-sus Bureau, downloaded from www.census.gov/popu-lation/projections/state/stpjpop.txt, 12 December2003).

Combination of Transportation StrategiesCombined emission reduction estimates from thetransportation strategies were derived by multiplyingthe percentage of emissions remaining from each ofthe strategies by the percentage remaining from theother strategies. The impact of a feebate program isnot included in the combined policy case because it isdifficult to ascertain how such a program would in-teract with carbon dioxide tailpipe standards.

Other Transportation Assumptions

• We assume a “rebound effect” of 20 percent on allmeasures that improve fuel economy or reduce per-mile carbon dioxide emissions. The rebound ef-fect occurs when reduced per-mile costs of driving(such as would result from purchasing a vehiclewith better fuel economy) encourage drivers toincrease their VMT.

• We assume no mix shifting effects from any of theabove policies. In other words, we assume that thestrategies would not encourage individuals whowould have purchased a car to purchase a lighttruck, or vice versa. It is likely that at least somemix shifting would occur as a result of some of thepolicy strategies (for example, high feebate chargesencouraging individuals to shift from light trucksto cars), but we believe that the policies could beappropriately designed to ensure that any mix-shift-ing effects would serve to further reduce (ratherthan increase) carbon dioxide emissions.

Residential, Commercial andIndustrial Strategies

Building Energy CodesThe projected impact of residential energy codes wasderived by estimating the percentage of residentialenergy use that would take place in new homes underEIA projections and applying estimated percentagereductions in energy use that would take place underupdated codes. Revised codes were not assumed toaffect energy use in existing homes.

The proportion of projected residential energy usefrom new homes was derived by subtracting estimatedenergy use from homes in existence prior to 2004 from


total residential energy use for each year based on AEO2003 growth rates. Consumption of energy by sur-viving pre-code homes was calculated by assumingthat energy consumption per home remains stable overthe study period and that 0.4 percent of homes areretired each year, per EIA, Assumptions to AEO 2003.

Energy savings from updating Massachusetts’s residen-tial building code to 2000 IECC standards areassumed to be 15 percent below projected levels for2004-2010, based on Steven Nadel and HowardGeller, American Council for an Energy-EfficientEconomy (ACEEE), State Energy Policies: SavingMoney and Reducing Pollutant Emissions ThroughGreater Energy Efficiency, September 2001. Energysavings from future updates to residential buildingcodes were assumed to be 32 percent below currentprojections for 2011-2020, also based on ACEEE.Energy savings from residential building energy codeswere assumed to take place equally among the vari-ous fuels.

For commercial building codes, New England-spe-cific commercial building retirement percentages wereestimated by determining the approximate median ageof commercial floorspace in New England based ondata from EIA, 1999 Commercial Building EnergyConsumption Survey (CBECS), estimating a weighted-average “gamma” factor (which approximates the de-gree to which buildings are likely to retire at themedian age), and inputting the results into the equa-tion, Surviving Proportion=1/(1+(Building Age/MedianLifetime)Gamma as described in EIA, Model Documenta-tion Report: Commercial Sector Demand Module of theNational Energy Modeling System, March 2003.Baseline 2003 commercial energy demand was thenmultiplied by the percentage of surviving pre-codecommercial buildings to estimate the energy use frombuildings not covered by the code. For buildings cov-ered by the code, all savings between 2005 and 2010were assumed to be reflected in the baseline energyuse estimate derived from EIA projections. The adop-tion of future upgrades to commercial energy codeswas estimated to result in a 20 percent reduction inthe use of all fuels in new construction from 2011 to2020 per Nadel and Geller (ACEEE), State EnergyPolicies. No attempt was made to estimate the impactof commercial code revisions on energy use due torenovations of existing commercial space.

Appliance Efficiency StandardsEstimates of potential energy savings from applianceefficiency standards were based on Ned Raynolds andAndrew Delaski, Northeast Energy Efficiency Part-nerships, Energy Efficiency Standards: A Low-Cost, HighLeverage Policy for Northeast States, Summer 2002.Savings were assumed to begin in the adoption yearspecified in the NEEP report, with savings increasingin a linear fashion until 2020. We assume that stan-dards for all the products listed in the NEEP reportare adopted as described, including those subject tofederal preemption. Finally, we assume that additionalfuture efficiency standards would yield savings equiva-lent to 20 percent of the annual savings resulting fromthe above standards beginning in 2012.

Systems Benefit Charges for EfficiencyProjections of benefits from a 5-mill electric SBC forefficiency were computed based on the average kilo-watt-hour/dollar savings rates from five New EnglandSBC-supported programs for the most recent periodfor which data were available.98 (Maine was excludeddue to a recent transition in the program from utilityto state management.) Additional revenues generatedby the increased SBC were determined by subtract-ing the projected revenue from existing SBC programsfrom projected revenue from a 5-mill efficiency SBC,then multiplying the increased fee by projected elec-tricity use in Massachusetts. These revenues were thenmultiplied by the average kWh/$ savings rate, withthe savings reduced by 33 percent to reflect the likelyhigher marginal cost of additional kWh savings dueto the reduced availability of “low-hanging fruit” as aresult of the original SBC programs. This producedan estimate of annual electricity savings as a result ofefficiency programs due to the increased SBC. Futureyear savings from efficiency measures were assumedto be 90 percent of annual savings in the first throughfourth years after implementation of the measures,80 percent in years five through nine, 60 percent inyears 10-14 and 50 percent afterward. These estimatesare arbitrary, but yield maximum “lifetime” savingsof about 12 times annual savings by the end of thestudy period, a rate lower than most estimates of life-time savings from efficiency programs. Carbon diox-ide savings were then calculated as described in“Carbon Dioxide Reductions from Electricity Savingsand Renewables” above.


Savings resulting from the implementation of an oil/gas SBC-type program were estimated based on pro-jected BTU-per-dollar savings rates of a Vermont gasconservation program, as documented in Center forClean Air Policy, Connecticut Climate Change Stake-holder Dialogue: Recommendations to the Governor’sSteering Committee, January 2004. This savings ratewas then reduced by 25 percent to ensure the conser-vatism of the estimate. The rate of the charge was setat 3.5 cents per 100,000 BTU for natural gas anddistillate and residual oil used in the residential, com-mercial and industrial sectors, with the total BTUsavings estimated in a manner similar to savings fromthe 5-mill electric SBC. Carbon dioxide reductionswere then estimated by allocating the total BTU sav-ings from the charge proportionally among the threefuel types and then multiplying the result by the ap-propriate carbon coefficients.

Combined Policy CaseThe combined residential, commercial and industrialsector savings exclude savings resulting from appli-ance efficiency standards that may also be covered byenhanced building energy codes.

Electric Sector Strategies

Renewable Portfolio StandardThe impact of an RPS of 10 percent new renewablesby 2010 and 20 percent new renewables by 2020 wasestimated by multiplying projected electricity demandin Massachusetts by the percentage of the proposedRPS, which was assumed to be 2 percent of overallelectric demand in 2005, with the percentage increas-ing by 2 percent each year until 2010 and 1 percentper year between 2010 and 2020. New renewablegeneration resulting from the existing MassachusettsRPS was estimated separately and subtracted from thetotal under the assumption that it is already factoredinto EIA’s baseline energy projections. The currentMassachusetts RPS was assumed to remain in forcethrough 2020.

Solar ProgramFunding for the solar program was estimated basedon the amount of money that would be generated bya 0.15-mill earmark for solar programs in a renewablesSBC. This funding estimate was derived in a similar

manner as the estimated revenues from the SBC pro-grams above, taking into account energy savings fromother efficiency strategies in this report and assumingthat the renewables SBC is applied only to electricity.The amount of new solar capacity that would be cre-ated with that funding was estimated by assuming therate of subsidy needed to spark installation of solarPV systems. This figure was estimated at $4,000/kWfor 2005-2010, $3,000/kW for 2011-2015, and$2,000/kW for 2016-2020. The initial $4,000/kWfigure is based on the amount that would be requiredto increase the breakeven turnkey cost of residentialsolar to greater than $7,000/kW, per Christy Herig,Richard Perez, Susan Gouchoe, Rusty Haynes, TomHoff, Customer-Sited Photovoltaics: State Market Analy-sis, 2002. Figures for later years are conservative esti-mates based on the anticipated drop in prices for solarPV systems as estimated in U.S. Department of En-ergy and Electric Power Research Institute, Renew-able Energy Technology Characterizations, 1997, 4-5,and other sources. Electricity output from this newinstalled capacity was estimated based on operation ataverage 18 percent efficiency. All new solar capacity wasassumed to be distributed, with no line losses. One-halfof the new solar electricity was assumed to count to-ward fulfillment of RPS requirements, the other halfsurplus to offset fossil fuel-fired generation. This split isarbitrary, but would allow for the retirement of greentags for the new renewable capacity by individuals andinstitutions who choose not to redeem them or to ac-count for green power purchasing programs.

State Government Lead-By-ExampleEmissions savings from state government are basedon three categories of action. In each case, we assumedthat government does not grow, an approach thatmakes our savings estimates conservative.

Data on current state energy use was provided by EricFriedman, Office of State Sustainability. To calculatethe emissions savings from reducing energy use in statefacilities by 25 percent by 2020, we multiplied theenergy savings for each fuel by its carbon coefficient.

Savings from improving the efficiency of the state’svehicle fleet come from both gas and diesel savings.Data for state government transportation fuel use werenot available; thus we relied on the Federal HighwayAdministration’s figures for gas use by non-federal


governments—meaning our data represents fuel con-sumption by state, county, and local governments.Total statewide diesel use figures are from the samesource. We estimated non-federal public sector dieseluse by assuming that government diesel use is the sameportion of total diesel use as government gas use is oftotal gas use. Projected efficiency improvements as-sume that non-federal government vehicle fleetsachieve 20 percent more gallons per mile by 2012and 28.5 percent more gallons per mile by 2020. Weassumed that there would be no rebound effect ofincreased miles driven. Carbon savings were calcu-lated by multiplying the energy savings for each fuelby its carbon coefficient.

Carbon savings from having state government pur-chase 20 percent of its electricity from renewablesources by 2010 again relied on data provided by EricFriedman, Office of State Sustainability. The calcula-tions assume that the state already reduces its energyuse by 25 percent.

1. Working Group I, Intergovernmental Panel on ClimateChange, IPCC Third Assessment Report – Climate Change2001: Summary for Policy Makers, The Scientific Basis, 2001.

2. Ibid.

3. Ibid.

4. Ibid.

5. Based on 1990 figures from U.S. Environmental Pro-tection Agency, State GHG Inventories, downloaded fromyosemite.epa.gov/OAR/globalwarming.nsf/content/EmissionsStateGHGInventories.html, 7 July 2003.

6. U.S. Environmental Protection Agency, Global Warm-ing-State Impacts: Massachusetts, Office of Policy, Planning,and Evaluation, September 1997.

7. New England Regional Assessment Group, U.S. GlobalChange Research Program, Preparing for a Changing Cli-mate: The Potential Consequences of Climate Variability andChange. Foundation Report, September 2001.

8. See note 6.

9. See note 7.

10. See note 1.

11. Ibid.

12. Ibid.

13. Ibid.

14. Ibid.

15. See note 6.

16. See note 7.

17. Ibid.

18. See note 6.

19. Impacts from U.S. Environmental Protection Agency,Global Warming-State Impacts: Massachusetts, Office of Policy,Planning, and Evaluation, September 1997; New EnglandRegional Assessment Group, U.S. Global Change ResearchProgram, Preparing for a Changing Climate: The PotentialConsequences of Climate Variability and Change. FoundationReport, September 2001.

20. Based on 1990 fuel use data from U.S. Energy Infor-mation Administration, State Energy Data 2000, 151-156and 2000 fuel use data from State Energy Data 2000 andother EIA reports. See “Methodology and Technical Dis-cussion” for more information on sources and methods forcalculating carbon dioxide emissions from the fuel use data.

21. Historic emissions based on 1990 fuel use data fromU.S. Energy Information Administration, State Energy Data2000, 151-156 and 2000 fuel use data from State EnergyData 2000 and other EIA reports. Projected emissions basedon 2000 fuel use data multiplied by year-to-year projectedincreases for New England from U.S. Energy InformationAdministration, Annual Energy Outlook 2003, 9 January2003.

22. Estimated rate of increase in fuel use based on year-to-year increases for New England from U.S. Energy Informa-

NOTES


36. Increase from 1990 to 2000 is based on Massachu-setts-specific EIA fuel use data as described in “Methodol-ogy and Technical Discussion.” The estimated increase from2000 to 2020 is based on the projected growth rate in fueluse in New England from EIA, Annual Energy Outlook 2003,except for motor gasoline. The rate of growth in motor gaso-line use is based on the annual rate of growth in vehicletravel in Massachusetts projected by the Massachusetts High-way Department. MassHighway VMT projections wereobtained from Bob Frey, Manager of Statewide Planning,MassHighway, 7 February 2003.

37. To be more precise, motor gasoline combustion ac-counted for 74 percent of carbon dioxide emissions fromtransportation in Massachusetts in 2000, based on data fromEIA, State Energy Data Report 2000. About 92 percent ofmotor gasoline use in the transportation sector is used topower light-duty vehicles. (Source: EIA, Supplemental Tablesto Annual Energy Outlook 2003.)

38. Savings are over and above those from the previousversion of the ZEV program adopted by Massachusetts,which is assumed to be included in the EIA baseline energyuse estimates.

39. Based on a possible scenario for manufacturer compli-ance with the program in California in Chuck Shulock,California Air Resources Board, The California ZEV Pro-gram: Implementation Status, presented at EVS-20, the 20thInternational Electric Vehicle Symposium and Exposition,November 2003. The flexibility of the ZEV program meansthat manufacturers have many possible ways to comply withthe requirement; this scenario assumes that manufacturerstake full advantage of program provisions that allow themto substitute ultra-clean conventional gasoline vehicles andhybrids for “pure” zero-emission vehicles such as fuel-cellvehicles.

40. J.D. Power and Associates, J.D. Power and AssociatesReports: Anticipated Higher Costs for Hybrid Electric VehiclesAre Lowering Sales Expectations [press release], 27 October2003.

41. Based on default values from Michael Wang, ArgonneNational Laboratory, Greenhouse Gases, Regulated Emis-sions and Energy Use in Transportation (GREET) model,version 1.5a, 21 April 2001. Note: All figures for hybridsand conventional vehicles are based on emissions from ve-hicle operations (i.e. the tailpipe). Because hydrogen fuel-cell vehicles have no tailpipe emissions, fuel-cycle emissionswere used. The default energy efficiency of hybrid-electricvehicles in GREET 1.5 a is assumed to be 90 percent greaterthan gasoline-powered vehicles operating on conventionalgasoline, while the efficiency of fuel-cell vehicles is assumedto be 200 percent greater. A draft version of an updatedGREET model (GREET 1.6) assumes smaller efficiencyimprovements from the two technologies.

42. These results are similar to the 2.25 percent reductionin carbon dioxide emissions in Massachusetts under theLow-Emission Vehicle II/ZEV program in 2020 projectedby Northeast States for Coordinated Air Use Management(NESCAUM) in Emissions Benefits of Adopting the LEV IIProgram in the Northeast (draft report), May 2003.

43. California Assembly Bill 1493, adopted 29 July 2002.

44. The Center for Clean Air Policy assumed a 33 percentreduction in the Connecticut climate change stakeholder

tion Administration, Annual Energy Outlook 2003, 9 Janu-ary 2003.

23. Based on 1990 fuel use data from U.S. Energy Infor-mation Administration, State Energy Data 2000, 151-156and 2000 fuel use data from State Energy Data 2000 andother EIA reports. See “Methodology and Technical Dis-cussion” for more information on sources and methods forcalculating carbon dioxide emissions from the fuel use data.

24. 14 percent increase in consumption in Massachusettsbased on increase in sales of electric power from 1990 to2000 from U.S. Energy Information Administration, Elec-tric Power Annual 2001 spreadsheets, 1990 - 2001 Retail Salesof Electricity by State by Sector by Provider, March 2003.

25. Based on 2000 fuel use data from U.S. Energy Infor-mation Administration State Energy Data 2000 and otherEIA reports and year-to-year projected rates of increase inenergy consumption from EIA, Annual Energy Outlook2003, 9 January 2003.

26. See note 7.

27. Swiss Agency for Development and Cooperation,Chernobyl.info, downloaded 20 January 2004.

28. Union of Concerned Scientists, Nuclear Reactor Secu-rity, downloaded from www.ucsusa.org/clean_energy/nuclear_safety/page.cfm?pageID=176, 24 July 2003.

29. U.S. General Accounting Office, Nuclear RegulatoryCommission: Oversight of Security at Commercial NuclearPower Plants Needs to Be Strengthened, September 2003.

30. Robert Alvarez, Jan Beyea, et al, “Reducing the Haz-ards from Stored Spent Power-Reactor Fuel in the UnitedStates,” Science and Global Security, 2003, 11:1-51.

31. Cumulative subsidies for nuclear power over the pe-riod 1947-1999 have been estimated at $145.4 billion, basedon Marshall Goldberg, Renewable Energy Policy Project,Federal Energy Subsidies: Not All Technologies Are CreatedEqual, July 2000.

32. David Lochbaum, Union of Concerned Scientists, tes-timony before the Clean Air, Wetlands, Private Propertyand Nuclear Safety Subcommittee of the U.S. Senate Com-mittee on Environment and Public Works, 8 May 2001,downloaded from www.ucsusa.org/clean_energy/nuclear_safety/page.cfm?pageID=191.

33. Conference of New England Governors/Eastern Ca-nadian Premiers, Climate Change Action Plan 2001, August2001.

34. New England Climate Coalition, Global Warming inNew England, September 2003.

35. Ibid. Note: Projected base case emissions in this chartmay differ with projected New England emissions presentedelsewhere in this report due to changes in methodology andassumptions. Emission savings from sector-by-sector com-mitments in the regional plan are based on an optimisticinterpretation of the plan’s potential results, compared tothe conservative assumptions for the various policy optionsanalyzed in this report. In most cases, policies to imple-ment the plan’s commitments have not yet been formed orimplemented. The gap between the governors’ and premiers’regional commitments and the action plan goal thus repre-sents the minimum amount of additional carbon dioxidereductions the region must achieve.


process, the New York greenhouse gas task force assumed a36 percent reduction, and M.J. Bradley and Associates, in areport written for the Natural Resources Defense Council,assumed a 30 percent reduction. Sources: Center for CleanAir Policy, Connecticut Climate Change Stakeholder Dialogue:Recommendations to the Governor’s Steering Committee, Janu-ary 2004; M.J. Bradley and Associates, Survey and Evalua-tion of State-Level Activities and Programs Related to ClimateChange, 18 October 2002, prepared for the Natural Re-sources Defense Council Climate Center.

45. California Energy Commission, California State Fuel-Efficient Tire Report: Volume 2, January 2003.

46. U.S. Environmental Protection Agency, Light-DutyAutomotive Technology and Fuel Economy Trends: 1975Through 2003, April 2003.

47. U.S. Department of Energy, Office of Policy, Effects ofFeebates on Vehicle Fuel Economy, Carbon Dioxide Emissions,and Consumer Surplus, February 1995.

48. California Air Resources Board, Reducing California’sPetroleum Dependence, Final Staff Report, August 2003,Appendix C, Attachment B, B-251.

49. For a summary of data demonstrating the link betweenincreased vehicle travel and accident risk, see Victoria Trans-port Policy Institute, Online TDM Encyclopedia: Pay-As-You-Drive Vehicle Insurance, downloaded from www.vtpi.org/tdm/tdm79.htm, 4 December 2003.

50. Based on Insurance Information Institute, Facts andStatistics: The Rising Cost of Auto Insurance, downloaded fromwww.iii.org/media/facts/statsbyissue/auto/content.print/, 29October 2003

51. Victoria Transport Policy Institute, Online TDM Ency-clopedia, downloaded from www.vtpi.org/tdm/tdm79.htm,2 January 2004.

52. Ibid.

53. Michelle J. White, The “Arms Race” on American Roads:The Effect of SUVs and Pickup Trucks on Traffic Safety, [un-published].

54. VMT projection: Bob Frye, Massachusetts HighwayDepartment, 2 February 2003; population projection: U.S.Census Bureau, Projections of the Total Population of States:1995 to 2025, downloaded from www.census.gov/popula-tion/projections/state/stpjpop.txt, 12 December 2003.

55. See John W. Holtzclaw, Robert Clear, Hank Dittmar,David Goldstein and Peter Haas, “Location Efficiency:Neighborhood and Socio-Economic Characteristics Deter-mine Auto Ownership and Use – Studies in Chicago, LosAngeles and San Francisco,” Transportation Planning andTechnology, 2002, 25:1-27.

56. MassHousing, Take the “T” to Work Home MortgageProgram, downloaded from www.masshousing.com/, 12March 2004.

57. Note: These projections do not include the impact of afeebate program. It is very uncertain how a feebate pro-gram would interact with a program to set standards forcarbon dioxide emissions from vehicles. Presumably, afeebate program with a zero point that increases to matchthe average per-mile carbon emission level of the vehiclefleet would continue to provide an incentive for the pur-chase of more fuel efficient vehicles, and therefore lead tolower carbon emissions, but the degree of such an incentive

is difficult to discern based on the existing literature.

58. See Tony Dutzik, MASSPIRG Education Fund, Carsand Global Warming, April 2003.

59. See Congressional Budget Office, The Economic Costsof Fuel Economy Standards Versus a Gasoline Tax, December2003; Victoria Transport Policy Institute, “TransportationElasticities: How Prices and Other Factors Affect TravelBehavior,” Online TDM Encyclopedia, downloaded fromwww.vtpi.org/tdm/tdm12.htm, 11 March 2003.

60. Based on energy consumed in Amtrak passenger trainsin 1993 from Federal Railroad Administration, Energy,downloaded from www.fra.dot.gov/Content3.asp?P=977, 3February 2004.

61. For a list of readings on the potential of new highwaysto increase vehicle travel, see Robert Noland, Induced TravelBibliography, www.vtpi.org/induced_bib.htm, September2003.

62. Range of savings in 2010 estimate is based on two dif-fering assumptions as to the type of electricity generationthat would be displaced as a result of efficiency savings, withthe greater reductions based on the displacement of highercarbon-emitting generating capacity (as would result fromadoption of a strong regional carbon cap) and the lowerreductions based on the displacement of new generationfrom natural gas. See “Methodology and Technical Discus-sion” for more details.

63. Massachusetts Board of Building Regulations and Stan-dards, Commercial Energy Code (780 CMR, Ch 13), down-loaded from www.state.ma.us/bbrs/commercial_home_link.htm, 24 December 2003.

64. U.S. Department of Energy, DOE Status of State En-erg y Codes – Massachusetts, downloaded fromwww.energycodes .gov/ implement/ s ta te_codes /state_status.cfm?state_AB=MA, 24 December 2003.

65. Ibid.

66. Steven Nadel and Howard Geller, American Councilfor an Energy-Efficient Economy, Smart Energy Policies:Saving Money and Reducing Pollutant Emissions ThroughGreater Energy Efficiency, September 2001.

67. Based on quantitative and detailed textual analysis fromU.S. Department of Energy, Office of Energy Efficiencyand Renewable Energy, Commercial Determination, down-loaded from www.energycodes.gov/implement/determinations_com.stm, 17 November 2003.

68. See note 66.

69. Ned Raynolds and Andrew Delaski, Northeast EnergyEfficiency Partnerships, Energy Efficiency Standards: A Low-Cost, High Leverage Policy for Northeast States, Summer 2002.

70. These savings include energy savings that would resultfrom air conditioners meeting efficiency standards proposedduring the Clinton administration. The Bush administra-tion has attempted to weaken the proposed standards, butin January 2004, a federal appeals court overruled the deci-sion, allowing the more stringent standards to take effect.Should the court’s ruling be implemented, Massachusettswould gain the benefits of stronger air conditioner stan-dards without state action.

71. See note 69.

72. Ibid.


73. American Council for an Energy-Efficient Economy,Summary Table of Public Benefit Programs and Electric Util-ity Restructuring, May 2003.

74. Union of Concerned Scientists, State Public BenefitsFunding for Energy Efficiency, Renewables, and R&D, No-vember 2002; and Massachusetts Municipal Wholesale Elec-tric Company, Public Power In Massachusetts, January 1998.

75. Division of Energy Resources, 2001 Energy EfficiencyActivities, Summer 2003.

76. Ibid.

77. R. Neal Elliott, Anna Monis Shipley, Steven Nadel,Elizabeth Brown, American Council for an Energy-EfficientEconomy, ACEEE Estimates of Near-Term Electricity and GasSavings, 15 August 2003.

78. Center for Clean Air Policy, Connecticut Climate ChangeStakeholder Dialogue: Recommendations to the Governor’sSteering Committee, January 2004

79. Greg Kats, et al., The Costs and Financial Benefits ofGreen Buildings, A Report to California’s Sustainable Build-ing Task Force, October 2003.

80. MGL ch. 25A, sec. 11F; 225 CMR 14.00

81.225 CMR 14.05 (1)(a)

82. Energy Efficiency and Renewable Energy, U.S. Depart-ment of Energy, state by state Wind Resources estimates forall six New England states, downloaded fromwww.eere.energy.gov/state_energy, 23 November 2003.

83. Kevin J. Smith and George Hagerman, The Potentialfor Offshore Wind Energy Development in the United States,Proceedings of the 2nd International Workshop on Trans-mission Networks for Offshore Wind Farms, Royal Insti-tute of Technology, Stockholm, 2001.

84. Massachusetts Division of Energy Resources, RPS-Qualified New Renewable Generation Units, downloadedfrom www.state.ma.us/doer/rps/approved.htm, 5 Decem-ber 2003.

85. Photovoltaic Industry Statistics: Costs, Solarbuzz, down-loaded from www.solarbuzz.com, 30 June 2003.

86. Christy Herig, Richard Perez, Susan Gouchoe, TomHoff, PV in Commercial Buildings – Mapping the BreakevenTurn-key Value of Commercial PV Systems in the U.S., 2003.

87. Christy Herig, Richard Perez, Susan Gouchoe, RustyHaynes, Tom Hoff, Customer-Sited Photovoltaics: State Mar-ket Analysis, 2002.

88. Renewable Resource Data Center, PV Watts: ChangingSystem Parameters, downloaded from rredc.nrel.gov/solar/calculators/PVWATTS/version1/change.html, 24 Novem-ber 2003.

89. Michael Winka, New Jersey Board of Public Utilities,Renewable Energy for Reliability, Security and Affordability,presentation before the annual conference of the NationalAssociation of State Energy Officials, 14-17 September2003.

90. 301 CMR 7.00 Appendix B.

91. The spikes in emissions on this chart represent tempo-rary additional fossil fuel generation used to compensatefor the retirement of nuclear reactors upon license expira-tion in 2012 and 2015. This analysis also assumes that the

most-polluting plants (coal) are closed before cleaner sources(petroleum).

92. U.S. EPA, Green Power Partnership, How to Buy GreenPower: Massachusetts, October 2003; EERE, “MassachusettsUtilities Offer Green Power,” Green Power Network, down-loaded from www.eere.energy.gov/greenpower/0903_meco.shtml, 24 December 2003; and Energy Infor-mation Administration, State Electricity Profiles 2001, 92.

93. Electricity figure from comparison of data from EricFriedman, Office of State Sustainability, personal commu-nication, 13 November 2003, with 2000 figures from EIA,Electric Power Annual 2001.

94. Massachusetts Executive Office of Environmental Af-fairs, Climate Change Initiative, downloaded fromwww.s ta te .ma.us /env i r / sus ta inab le / in i t i a t ive s /initiatives_ghg.htm#OSD, 26 December 2003.

95. State of New Hampshire, Governor’s Office of Energyand Community Services, Building Energy ConservationInitiative Program, downloaded from www.nhecs.org/sept/beci.html, 2 December 2003.

96. Federal Highway Administration, Highway Statistics2001, Table MF-21, downloaded from www.fhwa.dot.gov/ohim/hs01/mf21.htm, 4 December 2003.

97. U.S. Environmental Protection Agency, Light-DutyAutomotive Technology and Fuel Economy Trends: 1975Through 2003, April 2003.

98. (Connecticut) Energy Conservation ManagementBoard, Energy Efficiency: Investing in Connecticut’s Future,31 January 2003; (Massachusetts) Massachusetts Office ofConsumer Affairs and Business Regulation, 2001 EnergyEfficiency Activities: A Report by the Division of Energy Re-sources, Summer 2003; (New Hampshire) Connecticut Val-ley Electric Company, Granite State Electric Company, NewHampshire Electric Cooperative, Public Service Companyof New Hampshire, Unitil Energy Systems, New Hamp-shire Core Efficiency Programs: Quarterly Report, June 1-De-cember 31, 2002, 13 February 2003 (savings estimate basedon lifetime savings of efficiency measures in second half of2002 divided by 15); (Rhode Island) Narragansett ElectricCompany, Residential Energy Efficiency Programs andNarragansett Electric Company, Design 2000plus EnergyInitiatives/Small Business Services; PowerPoint presentationsbefore the Rhode Island Greenhouse Gas Stakeholder Pro-cess, Buildings and Facilities Working Group, 29 Novem-ber 2001, downloaded from righg.raabassociates.org/events.asp?type=grp&event=Buildings%20and%20Facilities;(Vermont) Efficiency Vermont, 2004 Annual Plan, 31 Oc-tober 2003 and Efficiency Vermont, The Power of Ideas:Efficiency Vermont 2002 Annual Report. Annual energy sav-ings and spending figures based on the most recent year ofdata available.

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