The first phase of the regulations is focused only on reporting issues. It will address
- Reporting Requirements
- Third-Party Data Verification Requirements
- Preservation of Records
The rationale for this narrow focus is that the City wants these regulations in place promptly, in time for reporting in Q2 2022.
The “informal” public comment period on the draft regulations will remain open until January 14. Comments can be provided here. The Air Pollution Control Commission will later hold a “formal” public comment period at a time TBD.
The “Regulations Development” outline does not provide a timeline for Phase II of the regulations. That’s where the meat of the regulations will be set forth. Phase II will include provisions governing the standard emissions factors; alternative compliance mechanisms; how to establish either hardship emission limits or compliance timelines; and exemptions.
It’s not exactly profound to note that there’s a lot to do to get to net zero. BERDO is just one small piece, even if it’s an important piece for Boston. I do want to pose one question, though. Do we need a rigorous set of GHG emission limits for buildings and also a separate ordinance banning use of natural gas in new buildings? If we’re going to the trouble of establishing stringent emissions limits that will ratchet down to zero, why do we need that prohibition?
In any case, stay tuned. I’m tempted to advise stakeholders to fasten seatbelts, because it’s going to be a bumpy ride. However, it’s the holiday season and we all desperately need reasons for optimism, so instead I’ll just say Get Ready. (And if that doesn’t make you smile, then Jack, You’re Dead!)