Midyear Update on State Renewable Energy Programs

Written on: August 3, 2025 by Joe Uglietto

We’re a few months removed from last year’s cold Winter and just a few months away from what we all hope will be another one. The mixed economic outlook combined with increased energy usage this past Winter has put serious pressure on policy makers to avoid legislation or regulations that increase the cost of energy for their constituents. As a result, States are scrambling to find ways to provide relief, and the introduction of programs that would increase costs have become political hot potatoes. We shouldn’t expect this dynamic to last forever, but it has altered the landscape. Here’s where State renewable energy programs stand around New England and the Northeast.

Update on Reporting Regulations
Vermont
30 V.S.A. §8124(b)(1) requires that each entity selling fuel into or in Vermont register annually with the Commission. The deadline to register was in early 2024. All entities that sell heating fuel in or into Vermont must register annually with the Commission and report their total fuel sales of heating oil, biodiesel, propane, kerosene and natural gas.

In a controversial move, the Vermont Public Utility Commission (PUC) issued a ruling in late May 2025 that stated, “The Commission cannot take further action on the Clean Heat Standard.” In regards to the Fuel Dealer Registry, the commission stated that existing law (30 V.S.A. § 8124(b)(1) requires dealers to file and for the PUC to collect information on June 30 every year. However, there are no plans to do so and no effort to enforce compliance. According to the ruling: “Absent a legislatively approved Clean Heat Standard, the Commission will not process fuel dealer registrations, update its website of fuel dealer registrants, or enforce against non-registration.”

Massachusetts
310 CMR 7.71 requires companies selling and distributing heating fuels to homes and businesses in Massachusetts, including suppliers of natural gas, fuel oil and propane, to register with the State and report their fuel sales quarterly. It also implements a reporting requirement for all fuel storage facilities in Massachusetts. The registration deadline for all companies and storage facilities was Jan. 31, 2025. All companies were required to report their Q1 2025 fuel sales by June 2, 2025. This reporting requirement will continue each quarter and will ensure that the Massachusetts Dept. of Environmental Protection (MA DEP) has all the data it requires to implement a Clean Heat Standard in the future.

New York
New York Codes, Rules & Regulations (NYCRR) introduced Part 253, Mandatory Greenhouse Gas (GHG) Reporting Program. Similar to MA and VT, this reporting regulation will require all fuel dealers in New York to report the gallons sold to the State. This program will require reporting annually, rather than quarterly as in MA and VT, but will also require third-party verification of gallons by a New York Dept. of Environmental Conservation (DEC) accredited auditor. The first reporting deadline is at least two years away.

Update on Market-Based Decarbonization Programs
Massachusetts
The MA DEP has yet to release the draft regulation of its Clean Heat Standard (CHS). The Draft Framework was published in April 2024, and the MA DEP indicated that the draft regulation would be published by the end of this past Winter. While the release of the draft regulation has been delayed, there has not been a formal announcement that the program would be delayed past its indicated implementation date of Jan. 1, 2026. It seems likely that the MA CHS will be delayed, but that is not a certainty, and we will await further information from the MA DEP. Additionally, Massachusetts is considering a Low Carbon Fuel Standard for transportation fuels.

Vermont
The Vermont Climate Council has been preparing draft recommendations for reducing GHG emissions within the State. These recommendations, which are scheduled to be drafted this Summer, will include a recommendation that Vermont join a regional Cap & Invest program, which doesn’t currently exist. The Council has also indicated that a CHS is not off the table. While the Council has previously recommended that a CHS not be adopted, they include in their recommendations that a modified CHS could be an option. It is anticipated that the revised Vermont Climate Action Plan will be released by the time this article is published.

New York
The New York Cap & Invest program (NYCI) is in development. This economy-wide cap on emissions will impact all fuel dealers. Cost concerns and significant consumer pushback has delayed its development, but it appears that the State will move forward with the program despite the opposition. Additionally, New York is considering a Clean Fuel Standard for transportation fuels. A Clean Fuel Standard, which would mirror the California Low Carbon Fuel Standard, could run in conjunction with a Cap & Invest program. A Clean Heat Standard could also run in conjunction with a Cap & Invest program and this scenario is entirely plausible given New York’s current political landscape.

Rhode Island
Rhode Island introduced legislation for a CHS for the second year in a row in 2025. While this legislation will likely not be passed this year, there is a potential that a CHS could come to Rhode Island and other States in the near future if it is implemented in Massachusetts.

There are rumblings in other States as well; Maryland, New Jersey and even Pennsylvania may consider modified versions of the CHS we’re likely to see in New England; time will tell.

Right now, some of the wind has been taken out of the sails of the States trying to adopt wide-ranging decarbonization programs. However, the goal of decarbonization still remains front and center for these States. Just as it has become politically treacherous for policy makers to plow ahead with no consideration for the impact on energy costs, so is it politically untenable for these same policy makers to give up on decarbonization altogether.

I expect that the next few months will give us substantial insight into where we’re headed for 2026 and beyond. Stay tuned. ICM


Renewable Energy Insights is a regular column by Joe Uglietto, President of Diversified Energy Specialists, with a focus on emissions reductions & renewable energy innovation. DiversifiedEnergySpecialists.com