Massachusetts has some of the strongest climate laws in the nation. The Next Generation Roadmap Act, signed into law in 2021, requires the Commonwealth to reduce our greenhouse gas emissions by at least 50% by 2030, a mere eight years away. This is both a monumental task and an imperative one. Reaching that target will set us on a trajectory to net zero emissions by 2050. 

In August 2022, Governor Baker signed An Act Driving Clean Energy and Offshore Wind prioritizing offshore wind, transportation electrification, building decarbonization, and economic inclusion. 

These laws must now be implemented, and we need to hold our elected and appointed officials accountable for reaching our mandated greenhouse gas reductions. 

To make sure we are on track, we will be monitoring deadlines included in these laws as well as additional climate plans and executive orders to determine if we are meeting our goals or lagging behind. 

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To reach our greenhouse gas (GHG) emission reduction mandates, we must address the building sector which contributes about a third of the overall GHG emissions in the Commonwealth, second only to transportation. The Clean Heat Commission was established to advise the Administration on strategies and policies to achieve deep emissions reductions from the combustion of heating fuels in the Commonwealth.

Naming of members to the Commission was delayed until January 2022.
Read the Commission on Clean Heat Final Report issued on November 30, 2022.

The Department of Public Utilities (DPU) website has been updated to include these criteria as part of its mission statement: The DPU seeks to promote safety, security, reliability of service, affordability, equity, and greenhouse gas emission reductions.

The number of balancing factors the DPU can consider alongside greenhouse gas (GHG) emission reductions (e.g., customer costs and reliability) may mean that we won’t see significantly different decisions from the DPU.

For instance, overall the recently filed three-year energy efficiency plans submitted to the DPU by the utilities were excellent. However, advocates were disappointed that in the final plans approved by the DPU, the agency restored fossil fuel incentives that had been reduced and altered performance incentives which appear in conflict with their new mission to ensure equity and the reduction of GHG emissions. In one bright spot, the DPU strengthened the plan by requiring utilities to prioritize weatherization prior to heat pump installation for all customer classes, not just moderate-income ratepayers.

As we transition away from fossil fuels, it is imperative that natural gas distribution companies rethink their products and business model. In June 2020, the Attorney General called on the DPU to open an investigation into the future of the natural gas industry “to develop a nation-leading regulatory and policy roadmap to guide the evolution of the gas distribution industry companies, provide ratepayer protection, and allow the Commonwealth to move into its net-zero GHG emissions energy future.”

The DPU has turned over responsibility for this investigation to the gas distribution companies. Advocates are closely watching this process. Decisions and policymaking that come out of this proceeding will be consequential and indicate how seriously the DPU is taking their expanded mission. More information about this docket can be found at The Future of Gas and ByNumber (state.ma.us. 20-80 is the docket number.

Five gas utilities filed decarbonization plans on March 18, 2022.

Monitoring of DPU actions will be ongoing.

The Council consists of 9 members appointed by the governor. The Roadmap Act requires that the Energy and Environmental Affairs Secretary consult with the Council before making any substantial adoptions, revisions, or amendments to regulations related to the definition of environmental justice population as defined in the Act.

Members of the EJ Council were finally appointed a full year after the deadline called for in the Roadmap Act. The Executive Office of Energy and Environmental Affairs has developed a website that includes information about members of the EJ Council along with meeting notices, materials and minutes.

The Roadmap Act established carbon emission targets for MLPs. These targets include 50% carbon free energy sales in 2030, 75% in 2040, and 100% in 2050.

Two organizations that work with MLPs, the Massachusetts Municipal Wholesale Electricity Company (MMWEC) and Energy New England (ENE) are helping them develop greenhouse gas emission standards.

MMWEC has assisted its 20 municipal light members in developing individualized 2050 roadmap plans for their power portfolios to ensure they stay on track with the Commonwealth’s climate goals.

MMWEC reports that nine of their members have already exceeded the 2030 goal of 50% carbon-free energy sales. An additional seven members have exceeded 40% carbon-free as of 2021, and therefore are on track to exceed 50% by 2030.

While this is good progress, it is worth noting that much of this progress is achieved using non-emitting sources (e.g., nuclear and old hydro) rather than clean energy (e.g., wind, solar, geothermal).

MLPs will need to file annual reports with DOER on their progress. The Massachusetts Climate Action Network published a report on MLPs and GHG emission reductions in spring 2022.

The Board of Building Regulation and Standards (BBRS) is responsible for monitoring the state building code and retains full authority over the base building energy codes. In 2008, the Green Communities Act required the BBRS to develop a municipal opt-in stretch code for communities that wanted to go above and beyond the base building code and require higher energy efficiency standards for new buildings. To date, 299 municipalities in the Commonwealth have adopted the stretch code. Multiple communities are now seeking a net zero building code that provides them with the tools they need to reach ambitious climate goals for buildings in their cities and towns. The Roadmap Act calls on the Department of Energy Resources (DOER) in consultation with the BBRS to develop a municipal opt-in “specialized” stretch energy code.

EEA Secretary Theoharides set the reduction goals for the Mass Save programs at 504,000 metric tons and 341 metric tons of carbon emissions reduction for the electric and gas plans respectively.

The Roadmap Act requires that Massachusetts Environmental Policy Act (MEPA) Office incorporate environmental justice principles and considerations into both its public process and analysis of project impacts.

Interim regulations went into effect Jan. 1, 2022.

Phase 2 regulations are being developed with a draft anticipated in the fall of 2022 and final regulations being promulgated in early 2023.

The MA Environmental Justice (EJ) table submitted extensive comments and recommendations on the proposed changes. Some issues the EJ table raised will be considered during phase two of regulation development. The new regulations include requirements for project proponents to engage with affected communities prior to filing with MEPA and public health considerations were included in some provisions of the new regulations. In addition, a more streamlined process for ecologically beneficial projects was included.

Energy and Environmental Affairs conducted public meetings on Oct 14 and October 15, 2021 and April 14 and April 15, 2022.

View recordings of these meetings.

The Department of Revenue released guidance on property tax exemptions for solar powered, wind powered, fuel cell powered, and energy storage systems.

The initial $12 million has been transferred. MassCEC is undertaking a workforce needs analysis to understand the current clean energy workforce and gaps, future projected clean energy workforce and gaps, and workforce development best practices related to Women and Minority Owned Businesses, environmental justice populations, and current and projected fossil fuel workforce and opportunities for transition.

To date, MassCEC has provided $4.5 million in planning and implementation grants to Women and Minority Owned Businesses. This effort has supported 50 existing firms and helped create another two dozen.

MassCEC has also begun to work directly with regional employment training programs within environmental justice communities to develop programs for job training and placement in the clean energy economy.

The Roadmap Act also specifically called for MassCEC to administer a heat pump market development program to fund and offer training to expand the markets for space and water heating using efficient heat pump technology. This will be part of the MassCEC work detailed above.

Appliance standards are one of the single most effective energy saving policies we can take and are key to meeting our climate goals. The Department of Energy Resources (DOER) has set new regulations and released a full list of covered products.

The new appliance standards now in place will reduce greenhouse gas emissions and save consumers money. The Appliance Standards Awareness Project estimates that in 2025 alone, the new standards will save consumers and businesses over $100 million and cut carbon dioxide emissions by 113,000 metric tons, an amount equivalent to taking 24,000 cars off the road.

Energy and Environmental Affairs held public meetings to present and gather feedback on:

  • Proposed emissions limits and sector specific sublimits for 2025 and 2030.
  • Proposed goals for reducing emissions from and increasing carbon sequestration on natural and working lands (NWL)
  • Proposed policy portfolio that aims to achieve these emission limits, sublimits, and NWL goals.

The Global Warming Solutions Act (GWSA) required a 25% reduction of greenhouse gas emissions below the 1990 baseline level from all sectors of the economy by 2020.

Meeting this goal is key to determining whether the state is on track to achieving the more ambitious emissions reduction targets established by the Roadmap Act. The state did exceed the target, but the data may not be representative as some of the reductions likely can be attributed to the economic slowdown during the COVID-19 pandemic.

It is known that emissions reductions in the electric sector were the primary contributors to statewide reductions through 2020. To meet future targets, major emissions reductions in the transportation and building sector are needed and progress in these sectors to date has been limited.

The original Global Warming Solutions Act of 2008 (GWSA) set emissions limits every ten years while the Roadmap Act has reduced the time frame to five-year intervals. This change will ensure the state is on track and provide a mechanism to make mid-course corrections in a timely manner. The sector specific sublimits require policymakers to think through the variety of trade-offs required to meet the overall five-year targets and provide guidance for state policy.

The 2050 net-zero target of the Roadmap Act is dependent on emissions reductions made this decade. Unless major progress is made by 2030, it is unlikely that future targets are achievable.

In December 2020, the administration released the interim 2030 Clean Energy and Climate Plan (CECP). This interim plan was issued prior to the enactment of the Roadmap legislation and targeted a 45% emissions reduction. A redrafted final plan was released in June 2022. This plan complies with the Roadmap Act and its targets of a 50% reduction in GHG emissions reduction by 2030 and net zero carbon by 2050.

This Environmental Justice Council is directed to review the environmental justice definition every five years.

Now that the EJ Council has been appointed, they are learning about the history of the EJ definition and discussing if updates or changes are needed.

Five public hearings took place in early March 2022 to receive public comment on two straw proposals.

On September 23rd, the Massachusetts Department of Energy Resources (DOER) released final code language for its Stretch Energy Code and Specialized Municipal Opt-in Code.

The electric companies are required to submit their first plan for review by the Council by September 1, 2023, and thereafter once every 5 years. The council is required to consist of the following members: Commissioner of Energy Resources or designee (chair), ED of MassCEC, and 13 additional members including: 1 representative of middle-income and low-income residential consumers, 1 representative from a local agency administering low-income weatherization, 1 environmental advocate, 1 representative of an EJ community organization, 1 representative of a large/transmission-scale renewable energy industry, 1 representative of small/distribution-scale renewable energy industry, 1 representative of the energy storage industry, 1 representative of the EV industry, 1 representative of the building electrification industry, 1 representative of municipal or regional interests, 1 with technical and engineering expertise interconnecting clean energy, 1 representative of businesses, and 1 member from each electric company.

The GSEP Working Group was convened in spring 2023 and held its first meeting in April. Additional information on working group meetings and materials can be found on the DPU website. 

The Clean Heat Commission released its final report on November 30th, 2022.

In summer 2023, the updates to the MOR-EV program required by the 2022 climate and clean energy law became official. Income-qualified individuals can now participate in the “MOR-EV+” program which offers additional rebates for low-income buyers and includes used EV purchases in program eligibility.

A detailed explanation of the updates to the program can be found here

In summer 2023, the updates to the MOR-EV program required by the 2022 climate and clean energy law became official. A detailed explanation of the updates to the program can be found here.

A dashboard for dealerships to enroll in the Department’s point-of-sale rebate program is now live. Visit mor-ev.org more information.

Detailed program usage data is available on the MOR-EV website. You can find a full breakdown of rebate usage and program statistics here

In summer 2023, the updates to the MOR-EV program required by the 2022 climate and clean energy law became official. A detailed explanation of the updates to the program can be found here

The Director of Marine Fisheries and the Director of Coastal Zone Management will serve as co-chairs of the Commission. The Governor appoints the 16 members of the Commission, all of whom are to be from specifically designated organizations and institutions. 

The commission will address subjects including the responsible development of offshore energy projects, mitigation and support strategies to ensure the long-term sustainability of fisheries in the commonwealth, the creation of a comprehensive infrastructure to enable effective dialogue between fishing industry stakeholders and those involved in the development of marine-based energy generation and transmission projects including, but not limited to, the offshore generation and transmission.  

The Commission shall meet 4x/year and produce an annual report.  The Commission will expire in August 2030.

MassCEC offers a detailed webpage for consumers providing information on electric vehicles using data sourced from the Green Energy Consumers Alliance. You can visit it here. 

The purpose of the program will be to develop and expand offshore wind industry-related employment opportunities in the commonwealth and to promote renewable energy-related economic development in the commonwealth by supporting and stimulating manufacturing and related supply chain capacity in the offshore wind industry. 
 
The 2022 clean energy law directs the Department of Revenue to create a tax incentive program for qualifying businesses, funded through a $35 million annual transfer. The law also creates an Offshore Wind Industry Investment Trust Fund to collect and distribute additional support for workforce development, manufacturing, infrastructure, and research. 

The program will  provide workforce training, educational and professional development, job placement, startup opportunities and grants to certified minority-owned and women-owned small businesses; other businesses or communities underrepresented in the clean energy workforce or industry; individuals residing in environmental justice or low-income communities; current and former workers from the fossil fuel industry; and federally recognized and state acknowledged tribes within the commonwealth.

The purpose of the program will be to promote participation in the commonwealth’s energy efficiency, clean energy, and clean heating and cooling industries and promote access to employment opportunities in clean energy, clean transportation, electrification, and energy efficiency.  

In July 2023, MassCEC released a clean energy workforce needs assessment to help inform this effort. The report identified a workforce need of 38,100 additional jobs by 2030 (or 37% growth) and made additional findings on the critical sectors, regional differences, and equity considerations needed to enable a just transition to a net-zero economy.

Environmental Justice (EJ) advocates have been pushing for cumulative impact analysis in permitting and siting decisions for years. Inclusion of this provision in the Roadmap Act is critical in addressing the disproportionate exposure of certain communities to public health and environmental hazards from one or multiple facilities. This provision means that a proposed project in an EJ community will not be evaluated in isolation. By examining cumulative impacts, regulators will have a more comprehensive understanding of all environmental and health risks already facing certain communities and can more effectively address these issues.

See the draft Cumulative Impact Analysis guidance.

Read about the proposed amendments.

 

The Department of Energy Resources (DOER) released its final language for an updated stretch code and a new specialized opt-in stretch code on September 27, 2022. See the guidance and model language.

A straw proposal was expected in fall of 2021 but was delayed and finally released in February 2022  

299 communities have adopted the stretch code since it was first available in 2009. Some communities want to go further in their efforts to transition to clean energy and eliminate fossil fuel combustion to the extent possible in new buildings and major renovations. The Roadmap Act required DOER to develop a definition of a net zero building and a net zero building performance standard. The final specialized energy stretch code, while it includes many good updates, would still allow fossil fuel heating as long as pre-electrification measures (e.g., wiring) are taken and rooftop solar is installed if feasible. Many advocates were disappointed that fossil fuel hookups are still allowed in new construction but the legislature attempted to move the ball by including a 10 community pilot in An Act Driving Clean Energy and Offshore Wind that was signed into law on August 11, 2022.

In January 2023, the Executive Office of Energy and Environmental Affairs finalized amendments to the regulations governing Environmental Impact Reviews under the Massachusetts Environmental Policy Act (MEPA) that included a number of updates required by the 2050 Next-Generation Roadmap Law, including public health analysis requirements and environmental justice definitional updates. 

In December 2022, DOER decided to move ahead in coordination with the state of Maine in setting up contracts for the King Pine onshore wind project and transmission. Massachusetts would procure 400 megawatts (MW) of electricity, or 40% of the wind farm’s power – enough to power 180,000 homes.

After a process including public hearings, the Executive Office of Energy and Environmental Affairs has released the Clean Energy and Climate Plan for 2050.

Read the Clean Energy and Climate Plan for 2050.

See the public hearing presentation.

Gas companies have submitted applications to the Department, which has begun the review and approval process. National Grid announced the approval of its pilot project in September 2022.

The list shall include workforce needs and shortages in each region and recommendations on courses and programming in public schools that can help prepare students for the jobs of the future.  The list will be made available to public schools and posted on the agency website.

See State-Level Employment Projections for Four Clean Energy Technologies in 2025 and 2030 here. MA figures can be found on page 87.

The department of elementary and secondary education shall submit an annual report on the progress of the pilot program including: (i) the number of public school students participating in the pilot seeking certifications for high-demand occupations in the offshore wind industry; (ii) the number of students participating who are low-income, English language learners and students with disabilities; (iii) the specific types of certifications earned by students, including the number of each certification earned; and (iv) recommendations on how to bring high-skill, high-demand credentialing programs to scale statewide, including any necessary funding considerations.

MassDOT has hired a consultant to conduct an analysis of the electrification needs of regional transit authorities, but a final report with recommendations has not yet been released. 

The Governor is in the process of finalizing appointments to the commission, and meetings are expected to commence in the coming months. 

The practice of siting solar projects on agricultural lands raises a number of issues that deserve study.  We need to examine questions about using prime agricultural lands for non-agricultural uses, when and how that can be done most responsibly; we know we need to site a significant amount of new solar projects to meet our climate mandates, and we also know that hosting solar projects can be a new revenue stream for farmers who often are operating on the margins.  

The Clean Energy Transmission Group was appointed and began meeting in July 2023. Meeting notes and additional materials can be found on the working group’s webpage. 

A solicitation can be coordinated or issued jointly with other New England states. We expect the RFP to be issued on May 7, 2023. This procurement in May 2023 would be MA’s fourth offshore wind procurement. Statute requires these procurements to reach a total of 5,600 MW by June 30, 2027. 

The Roadmap Act adds new language that requires that all quarterly and annual reports must, for the first time, quantify the degree to which the activities undertaken “contribute to meeting any and all GHG emission limits and sublimits imposed by statute or regulation.” The first annual report on the first year of the 2022-2024 Energy Efficiency Plan will be due by June 1, 2023.

Energy and Environmental Affairs must hold three public hearings.

The 2025 and 2030 Clean Energy and Climate Plan calls for 200,000 electric vehicles to be on the road by 2025 along with 15,000 charging stations and 900,000 EVs on the road by 2030. 

This section specifically authorizes the combined heat pump/solar/storage initiative that  the Cape Light Compact has been developing and would like to be added to the Mass Save program.   The DPU has now approved a pilot project under this law. 

Any electric distribution company or municipal aggregator with a certified efficiency plan may submit proposed low- and moderate-income whole building efficiency, electrification and greenhouse gas emission reduction offerings to a limited number of participants within the low- and moderate-income customer groups to the department of public utilities for review.

Utilities shall file a report with analysis of  the benefits of the Cape Light Program referenced with July 1, 2023 deadline.

The department of energy resources shall establish a demonstration project in which cities and towns may adopt and amend general or zoning ordinances or by-laws that require new building construction or major renovation projects to be fossil fuel-free, and enforce restrictions and prohibitions on new building construction and major renovation projects that are not fossil fuel-free. 

This includes through the withholding or conditioning of building permits; provided, that said restrictions and prohibitions shall not apply to research laboratories for scientific or medical research, or to hospitals or medical offices regulated by the department of public health as a health care facility. 

The department shall approve not more than 10 applications for participation in the demonstration project under this section. No city or town shall apply for acceptance into the demonstration project until it has received local approval and has submitted a home rule petition to the general court.

Draft regulations were released by the Department and referred to the Joint Committee on Telecommunications, Utilities, and Energy in May. The Committee issued its report on the regulations in June, taking no formal position, and the final regulations are set to go into effect unchanged by July 14, 2023. More information on the program can be found here. 

The proposals shall not include additional demand charges. The proposals shall include a separate opt-in residential time-of-use rate for electric vehicle owners or lessees. In evaluating proposals for approval, the department shall consider the effect of the proposal on: (i) energy conservation; (ii) optimal and efficient use of a distribution company’s facilities and resources; (iii) benefits to transmission and distribution systems; (iv) equitable rates for electric consumers; and (v) greenhouse gas emissions reductions. The proposals shall ensure equitable participation by all electric vehicle owners and lessees.

The Electric Vehicle Infrastructure Coordinating Council released its initial assessment and report to the Legislature in August 2023, which can be found here. The EVICC continues to meet regularly, and information can be found on its webpage. 

The council is charged with assessing and reporting on strategies and plans needed to deploy electric vehicle charging infrastructure that will establish an equitable, interconnected, accessible and reliable electric vehicle charging network. The deployment plan shall facilitate: (i) compliance with the mandated greenhouse gas emissions limits and sublimits with an emphasis on compliance with the emissions limits and sublimits set for 2025 and 2030; (ii) attainment of the mandated numerical benchmarks for electric vehicles and electric vehicle charging stations; (iii) cessation, by December 31, 2035, of in-state sales of non-zero-emission vehicles; and (iv) advancement of access to, and affordability of, electric vehicle charging and fueling.  The council shall hold at least 3 public hearings in geographically diverse areas of the commonwealth.

These plans will aim to: (i) improve grid reliability, communications and resiliency; (ii) enable increased, timely adoption of renewable energy and distributed energy resources; (iii) promote energy storage and electrification technologies necessary to decarbonize the environment and economy; (iv) prepare for future climate-driven impacts on the transmission and distribution systems; (v) accommodate increased transportation electrification, increased building electrification and other potential future demands on distribution and, where applicable, transmission systems; and (vi) minimize or mitigate impacts on the ratepayers of the commonwealth, thereby helping the commonwealth realize its statewide greenhouse gas emissions limits and sublimits.  

The Department of Energy Resources released an updated offshore wind solicitation for proposals between 200MW and 2400MW, up to 3600MW in total, in August 2023. More information can be found here. 

See April 1, 2023 item.

“Mid-duration” energy storage is defined as a storage system that is capable of dispatching energy at its full rated capacity for a period of 4-10 hours. “Long-duration” energy storage is defined as a storage system that is capable of dispatching energy at its full rated capacity for a period of more than 10 hours. 

In October and November 2022, DOER and MassCEC held office hours and invited written comments to receive input from interested stakeholders on the potential scope of the study. MassCEC announced plans to issue a Request for Proposals for consultants in December 2022.

In December 2023, DOER and MassCEC released a study entitled “Charging Forward: Improve Grid Reliability via Energy Storage.” The study included recommendations intended to lower the barriers for energy storage deployment and use; improve the siting process; increase resiliency across the Commonwealth, particularly for environmental justice (EJ) and low- and moderate-income communities; and spur the commercialization of storage technologies. The agencies also released a report to the Legislature detailing these findings and recommendations, as required by the 2022 climate law, which can be read here. 

Named working group members include the American Society of Civil Engineers, the Associated Industries of Massachusetts, Inc., the Massachusetts Taxpayers Foundation, Inc., the National Consumer Law Center, Inc., the Acadia Center, and the Northeast Clean Energy Council, Inc. 

The Governor is required to appoint 6 additional members including: 1 person from the offshore wind industry; 1 person from the solar industry; 1 economist with knowledge of electrical transmission, distribution, generation, and power supply; 1 representative of municipal interests or a regional public entity; and 2 representatives of investor-owned utilities. 

In December 2023, the Clean Energy Transmission Working Group released a final report containing its findings and recommendations to the Legislature. You can read the report in full here. 

Following completion of the assessment, the department of public health, in consultation with the Massachusetts School Building Authority, the department of elementary and secondary education, and the department of energy resources, shall develop, and report on, methods, best practices, and standards for achieving green and healthy school strategies for the students of the commonwealth. Methods, best practices, and standards may involve, but shall not be limited to: (i) increasing energy efficiency, increasing electrification, and shifting to fossil-free fuels; (ii) efficiently using resources, including, but not limited to, low flow water fixtures; (iii) improving water and air quality, ventilation, and air circulation systems; (iv) maintaining thermal comfort, humidity, and temperature controls; and (v) taking other actions the department may determine.

Undaunted K12: UndauntedK12 is working to ensure national, state, and local climate and education leaders place America’s K-12 schools at the center of efforts to equitably decarbonize our infrastructure and create the clean energy workforce of the future. 

A solicitation can be coordinated or issued jointly with other New England states. This procurement in May 2023 would be MA’s fourth offshore wind procurement. Statute requires these procurements to reach a total of 5,600 MW by June 30, 2027. 

The report shall also analyze impacts on: housing production, if any; housing affordability, if any, including electric bills, heating bills and other operating costs; housing affordability for persons of low and moderate income, if any, including electric bills, heating bills and other operating costs; and any other matters set forth by the department after consultation with municipalities and with individuals, organizations and institutions knowledgeable about issues of housing and emissions reductions. The report shall also include recommendations for the continuation or termination of the demonstration project. 

A solicitation can be coordinated or issued jointly with other New England states. This procurement in May 2023 would be MA’s fourth offshore wind procurement. Statute requires these procurements to reach a total of 5,600 MW by June 30, 2027. 

The solicitation can be coordinated or issued jointly with other New England states and must take place every 24 months.  

The Department of Energy Resources (DOER) released a 1,600 megawatt (MW) offshore wind request for proposals (RFP) on May 7, 2021, to add to the 1,600 MW of offshore wind that had already been procured in 2018 and 2019.

In December 2021, DOER announced the winning bids – Commonwealth Wind, a 1,200 MW project from Avangrid Renewables, and another 400 MW from Mayflower Wind to add to their previously awarded contract. Contracts will be finalized in the spring of 2022. Once this solicitation is complete, the Commonwealth will have 2,400 MW of offshore wind requirements remaining, and DOER is required to conduct solicitations every 18 months.