also proposes to force these mostly small family businesses to convert at least 3 % of their customers to electric heat each year .
Such a requirement constitutes an egregious and unconstitutional restraint of trade . This proposal renders our members in the Commonwealth no longer competitive , dramatically impedes interstate commerce , and constitutes a clear violation of both the Dormant Commerce and Due Process Clauses of the U . S . Constitution .
The proposal will harm regional energy security and reliability . Forcing all 770,000 homes in the Commonwealth that rely on liquid heating fuel and propane to convert entirely to electric heat pumps will significantly jeopardize regional energy security and reliability . ISO-NE and other utility organizations have repeatedly cautioned that widespread building electrification will result in grid imbalances because policy-driven fossil fuel and nuclear plant retirements are outpacing plans for replacement generation from renewable ( e . g ., solar and wind ) energy sources and demand response .
Additionally , as use of electricity increases , so does increased peaking problems of ISO-NE . Favoring electric cold-climate heat pumps not only puts increase peaking burdens on the electric grid , and as temperatures decline below freezing to subzero temperatures , the decreasing efficiency / temperature curve in these systems will create a new spiking peak in electrical demand resulting in increasing consumer costs and undermining grid reliability . It also exposes our economy to possible attacks by foreign adversaries and terrorists and make our grid particularly exposed during the coldest days of winter . Consider that in 2016 , Burlington Electric in Vermont was targeted by a Russian cyberattack operation known as “ Grizzly Steppe ,” exposing both potential vulnerabilities of the region ’ s grid and an interest on the part of U . S . adversaries to attack it .
Furthermore , it is a fact that ASHPs simply do not provide adequate warmth and comfort during the coldest days of winter . In fact , most homes that install electric heat pumps as a whole-home heat source often require the legacy furnace or boiler to be retained as a backup . This is particularly true in states like Massachusetts that regularly experience prolonged cold periods . A backup liquid or gas heating system will be needed to alleviate a potential shortfall of the available low ambient temperature due to inefficiencies of the heat pump system .
Retaining such systems will ensure
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