Thank you for your interest in submitting comments to DOER in support of racial equity and minority economic participation in the 83C III solicitation for 1600 MW of offshore wind.   

Here is what you need to know: 

  • THE COMMENT WINDOW CLOSES AT 5:00 ON THURSDAY 2/25.   
  • Your comments need not be perfect nor exhaustive to make an impact.    
  • All the RFP documents are here.  The Redlined version is perhaps the most helpful.  The key parts we care about start on pg. 35 of that document, plus Appendix J. 
  • Keep in mind that your comments will be in the public domain, searchable by other stakeholders.   
  • Below, to get you started, is a draft letter that you can edit and make your own. 

Please reach out to any of the ELM staff if we can assist.  Veena Mohan can troubleshoot technical or logistical questions, Elizabeth Henry, Nancy Goodman and Susannah Hatch are available for questions on content and strategy. 

Thanks again, 

  • The ELM team 

  ________________________________________________________________________ 

Dear Dept. of Energy Resources,

We applaud the addition of new language regarding minority economic participation and environmental justice in the 1600MW 83C III offshore wind procurement.  We encourage you to build from this foundation and set significantly higher expectations for racial equity and minority economic participation.   

This is the largest such project in the Commonwealth’s history and represents a capital investment of between $4-5B.  The workers and companies engaged in this solicitation have a leg up to become the leaders of tomorrow’s offshore wind industry.  Your Administration projects that half of Massachusetts’ energy may come from offshore wind by 2050. This solicitation represents just the beginning of what will be tens of billions of dollars worth of economic activity and tens of thousands of jobs in the decades ahead.  Choices made today set the course for industry growth and workforce development for the years to come.  The Commonwealth should require comprehensive Diversity & Inclusion Plans to be included with developers’ submissions, and give significant weight to these Plans when evaluating the proposals. 

We encourage you to model this offshore wind solicitation on the Commonwealth’s successful case studies for racial inclusion and minority economic participation, namely the Massport Model and the Gaming Commission. Rather than set prescriptive criteria, DOER should create the conditions for healthy competition and ongoing accountability. The Massport and Gaming models succeeded because the state set a high bar and gave bidders the flexibility to harness their innovation, creativity and expertise.  

 

We urge DOER to:

  1. Evaluate proposals, in significant part, based on submitted plans for creating opportunities for minority and disadvantaged workers, businesses and investors. Among other features, this component of proposals should address:
    a. The respondent’s plan for training and workforce development, focused on minority and disadvantaged workers;
    b. The respondent’s plan to solicit business from minority and disadvantaged contractors; and;
    c. The respondent’s plan to solicit investment from minority and disadvantaged investors;
  2. Require bidders to cooperate with the state Supplier Diversity Office and other state agencies focused on minority and disadvantaged business creation and development;
  3. Require that bidders explain how their proposal will mitigate environmental harm and create economic opportunities in environmental justice communities; and
  4. Establish a process for the ongoing evaluation of commitments made in selected bids, including by requiring successful bidders to provide regular updates and statistics regarding their progress towards achieving or improving upon those commitments.

Thank you for your consideration.

Sincerely,

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