The Environmental Markets Association (“EMA”) appreciates the opportunity to provide its responses to the set of questions the Massachusetts Department of Energy Resources (“DOER”) recently posted regarding the design and development of the Clean Peak Energy Portfolio Standard (“CPS”) that was established pursuant to the enactment of Chapter 227 pf the Acts of 2018. While there is no shortage of challenges associated with creating such a complex and comprehensive program, EMA is very excited about the prospects for the CPS and believes DOER has the opportunity to design a market-based mechanism that will serve as the template for many other states that are interested in pursuing similar clean energy objectives. We appreciate DOER’s inclusive approach to this important undertaking and look forward to participating in this process to assist the Commonwealth in meeting its economic and environmental sustainability policy objectives in the most efficient and cost-effective manner possible.

The EMA is a US-based trade association representing companies that have interests in the trading, legislation, and regulation of environmental markets. EMA was founded in 1997 as a 501(c)(6) not-for-profit organization. The members have decades of extensive, first-hand experience with market instruments related to federal and regional cap-and-trade programs in sulfur dioxide (“SO2”), nitrogen oxide (“NOx”), renewable fuels (“RINs”), and greenhouse gas emissions (carbon allowances and offsets), as well as state- driven renewable energy certificate (“REC”) programs. EMA’s diverse member group represents a wide variety of participants in the clean energy markets, from utilities and electricity suppliers to renewable energy project developers and investors. Our members have extensive operational experience with renewable portfolio standards (“RPS”) compliance, REC trading, and renewable energy investment and, collectively, have significantly contributed to the aggregate economic investment to achieve the Commonwealth’s RPS. The EMA has a vested interest in the continued success of comprehensive and inclusive market-based mechanisms and RPS programs, including the CPS. Relying on our broad-based membership and their cumulative experience in these programs, we believe that EMA can provide a unique perspective as it relates to DOER’s Policy Deliberative.

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