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Technical Comment 2022

LDC Independent Consultant Report Pathways Analysis

A technical comment on the gas utilities' independent consultant pathways analysis.

Michael J. Walsh

Jonathan Seth Krones (Coauthor of the attached renewable-fuels working paper)

Michael J. Walsh submitted these independent comments and alternative proposals to Massachusetts D.P.U. 20-80 on May 6, 2022. The submission examines the Department’s role in the thermal transition, critiques the gas utilities’ consultant study and proposals, and proposes an approach to regulatory oversight.

The 47-page submission includes three working papers:

  • Challenges Associated with the Use of Renewable Fuels for Large-Scale Building Decarbonization, by Michael Jay Walsh and Jonathan Seth Krones.
  • Assessment of Proposed Hybrid Heating Strategies, by Michael Jay Walsh.
  • Estimated Electrification-Driven Utility Changes in Customers and Sales in Massachusetts, by Michael Jay Walsh.

Walsh filed this submission as an independent researcher and consultant. It is separate from his later work for the Massachusetts Office of the Attorney General. His October 14, 2022 final comment followed this submission.