Comments Regarding the Advancing Massachusetts Power Straw Proposal

Clean Energy Group (CEG) submitted comments to the Massachusetts Department of Energy Resources (DOER) in response to DOER’s request for stakeholder feedback regarding the Advancing Massachusetts Power (AMP) straw proposal. In these comments, CEG recommends that the DOER AMP program include equitable battery-based virtual power plants. This would fall into the Community Resilience category of the AMP grant program.

CEG points to an existing program model in Massachusetts, the Cape & Vineyard Electrification Offering (CVEO), which combines behind-the-meter electrification, solar, battery storage, and efficiency in a VPP format, allowing Cape & Vineyard Electric Cooperative to dispatch aggregated behind-the-meter resources for peak demand reduction services. Importantly, the program has a strong equity focus, and yet achieves positive net benefits for ratepayers. CEG profiled this program in a March 2025 report, available here.