AEG Boston Task Force Proposed Equity Matrix Evaluation for ESMPs - Working Document

	A	B	C	D	E	G	H
1	AEG Boston 23Q3 Task Force Proposed Equity Matrix Evaluation Criteria
2	Please add rows to capture your individual feedback! In Columns C, D, E. Does the ESMP address this guiding question? (Yes/Partially/No) In Columns F-G - Please leave feedback/notes and your name In Column H - Please include your recommendation and identification of key metrics that can be included in the recommendation
3	Guiding Question		EDC ESMP			Areas of Concern + Comments	Recommendations + Proposed Metrics
4	Guiding Question		Eversource	National Grid	Unitil	Areas of Concern + Comments	Recommendations + Proposed Metrics
5	1	Does the ESMP include plain language to communicate the impacts and outcomes of the ESMPs?		Partially			Language access plan?
6	1	Does the ESMP include plain language to communicate the impacts and outcomes of the ESMPs?	No	Partially		As a frequent stakeholder in these types of proceedings I understand what they mean by utility constraints / primary and secondary sources etc. Eversource uses a higher degree of technical language then the National Grid plan.
7	2	Does the ESMP include maps and visuals that are easy for community members to understand the local impact of proposed solutions?		Partially		We have a map on NGRID page 24 focusing on the need for system upgrades which is good.	Electric quality (geographic disaggregation of outage frequency/
8	2	Does the ESMP include maps and visuals that are easy for community members to understand the local impact of proposed solutions?	Partially	Partially		Eversource example P104 - map should at minimum include town names if being used for external stakeholder/community audiences Utilities provide different types of maps from different tools. Understanding the local impacts of existing issues and future solutions could be a good application of interactive GIS tools/layers.	Consistency between maps in terms of legends and town names. Consider community and residential stakeholders and how they may wish information delivered (would a more interactive GIS tool be helpful or not utilized?)
9	3	Do the ESMPs provide and guarantee opportunities for local communities to engage and provide meaningful input?				For National Grid - focusing on procedural and distributional equity and conveniently ignoring recognition justice is very deceptive. The disregard of people and their concerns should have been addressed on the onset by an acknowledgement . An honest stakeholder engagement process begins with acknowledgement of past harms. page 45 would have a nice place to highlight that. I live in a national grid territory - I do not remember a meeting or even material from the company eliciting my feedback despite the claim of a robust stakeholder engagement process on page 57- neither have my neighbors. That makes me uncomfortable with the promises of engagement in the Fall of 2023. National Grid cannot gain trust when it continues to use language such as the page 104 - that implies they already have support. Lowell has a sustainability committee - Grid should have or should build relationships with such stakeholders to say the least. Who did they engage if they did not engage such a basic group?	Metrics- acces and capacity to pay for a technical expert the communities choose that can serve as their advisor because grid mod is very technical and information assymetry may short charge communities. Who pays for it is a question ? How and where notices for informational meetings for new grid facilities and at what stage, utilities should not give construction notices without community engagement first. Language access plans? Representativeness and inclusiveness - for example in a place like Lowell not having the Asian community of African immigrants in the stakeholder groups will not be representative of those who live in the City and i believe this is different for each community in the Commonwealth.
10	3	Do the ESMPs provide and guarantee opportunities for local communities to engage and provide meaningful input?	No	No	No	This ESMP does not benefit from any opportunity for robust stakeholder feedback. Concern that the community advisory WG is focused too narrowly on siting AFTER decisions have been made. Need more intention around community engagement at the forecasting stage. NGRID identifies a list of stakeholders they have engaged with in "Appendix A" but I could not locate this.	All utilities identify the communities in each subregion of their system. Can the Utilities identify specific town and community outreach over the last (2?) years that have helped inform these plans. Can they identify a target and specific plan for current and future ESMP cycles?
11	4	Do the ESMPs address disparity of wealth and environmental justice in the Commonwealth and provide measurable relief in the form of economic benefits to communities that have or will be disproportionately impacted ?	No	Partially		NO METRICS The NGRID ESMP identifies: "increased economic acticity on the order of $1.4 billion and create an additional 11,000 jobs throughout the Commonwealth by 2030" Investments incremental to $240M in state and local property taxes EJC focused workforce development program Pages 390-393 provide a descriptive and comprehensive list of investments ngrid is making in workforce development. See page 395 for new " future" programs and funding requests The Eversource ESMP includes: Same benefit analysis $1,4billion, 11,000 jobs by 2030 Unitil ESMP: Benefit analysis identifies $163M/incremenal $32M and 250 additional jobs Identifies affordability as an objective Identifies union workforce needs for infrastructure/communication needs met by local workforce This section does describe how Unitil isaddressing "barriers" for new workforce entrants (p179+)
12	4	Do the ESMPs address disparity of wealth and environmental justice in the Commonwealth and provide measurable relief in the form of economic benefits to communities that have or will be disproportionately impacted ?	No	No	No	Thinking about National Grid key outcomes missed affordability as an outcome- energy poverty in Massachusetts is real and not having affordability on page 11 as an outcome is a problem for me. There are three metrics that should govern grid modernization 1) Affordability 2) Resilience 3) environmental impact. Hiding affordability in those 5 outcomes is a travesty of justice. Some States actually go further and identify "equity' as an outcome I think affordability as a metric must be part of the ESMP's. (Wambui)	Proposed metrics = energy burdens should not be more than 6% of a residents annual income especially in EJ communities. Affordability can also be measured with the peak demand reduction of the system load factor. Will this ESMP investments focus on minimizing over all costs? Since Massachusetts utilities have failed in reducing energy costs should they use a third party in tracking affordability especially since they have mentioned time varying rates which can be very detrimental to LMI households- if they do then they should measure enrollments in demand response , opt-in's in time varying rates as well as the utilities own action plan to educate and work with consumers - Massachusetts has done a poor job in demand response programs for LMI's households so there must be consumer protections if time varying rates become the major "rate design "element. Workforce in building the new grid should be local and diverse. Ha ha call me crazy- how about reparation of electricity cost burden shouldered by energy burdened communities (stats for Boston exist), Community Benefit Agreements -to get at economic benefits CBA's exist nationwide.
13	5	Do the ESMPs address disparity of wealth and environmental justice in the Commonwealth and provide measurable relief in the form of health benefits to communities that have or will be disproportionately impacted ?				We need to define what Health means.
14	5	Do the ESMPs address disparity of wealth and environmental justice in the Commonwealth and provide measurable relief in the form of health benefits to communities that have or will be disproportionately impacted ?	No	No	No	NO METRICS National Grid's ESMP identifies "up to $4.7B in health benefits" (not clear where that analysis is supported) "environmental and climate benefits that will lead to improved health benefits and outcomes. Benefits will be realized at local and state scales through emissions reductions, improvements in building air quality, and through positive climate impacts that will occur within and beyond the state’s borders. " Focus on outdoor ambient air quality - what about indoor? p9/Table 4 - Table of "Investments Leading to Improved Health" (Metering, EE, Clean Tarnsportation, NWAs, Reslient Neighborhoods, Time-Varying Rates" Eversource ESMP: Identifies the creation of a "Equity and EJ team" to progress "frameworks and mindset developed bu the Eversource Pro-Equity Advisory Team" Reference to a specific project in an EJ community which has associated health ebenefits "here is ample literature on outages disproportionately impacting environmental justice communities.9 In its IIJA application, see section 12.2, the Company proposed to deploy a microgrid in the environmental justice community of Pittsfield which would be backed by battery storage systems. In this proposal, the community would decide which critical facilities need to be protected by the microgrid in case of an outage." Unitil ESMP: Does not identify health as a key objective
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