Draft 2025-2027 Three Year Energy Efficiency Plan and How it Relates to a Better City’s November 2024 Recommendations
October 18, 2024
Written by: Yve Torrie, Director of Climate, Energy and Resilience, and Grayson Bryant, Senior Associate, Cadmus
In April 2024, the Massachusetts Program Administrators (PAs) submitted the draft of the 2025-2027 Three-Year Energy Efficiency and Decarbonization Plan to the Energy Efficiency Advisory Council (EEAC) for comment and further refinement. EEAC councilors and the Council Consulting Team held multiple focused working sessions to propose and discuss the adoption of enhancements and modifications to the draft plan, resulting in the issuance of a council resolution proposing specific recommendations in June 2024. The PAs followed up with a detailed memo and supporting spreadsheet in August 2024 which detailed each recommendation and the degree to which it was incorporated into their final draft plan.
The PAs will formally file the 2025-2027 Three Year Plan with the Department of Public Utilities at the end of October and on October 23, at its monthly meeting, the EEAC adopted a resolution that recommends approval by the Department.
A Better City has been engaged throughout the development process, attending the initial workshops which began over a year ago, soliciting feedback from its members, and submitting recommendations to the EEAC in November 2023. A Better City staff also sit on the Commercial & Industrial Working Group (C&IWG) and the HVAC taskforce where they have identified improvements to the PAs current processes and procedures for project development.
A Better City has reviewed the plan with an eye toward how and to what degree the PAs have addressed A Better City’s recommendations made last year, continuing to advocate for changes that will benefit its members and the Commonwealth.
A link to the final draft of the Three-year Plan as it was provided to the EEAC by the PAs on September 25th is available here: https://ma-eeac.org/wp-content/uploads/FINAL-MA-2025-2027-Plan-09-25-24-v2.pdf. Note that the Commercial & Industrial Sector begins at pg. 158 of the PDF.
Additional documents, including earlier drafts and EEAC resolutions, are available at the EEAC website here: https://ma-eeac.org/plans-updates/
A Better City’s Recommendations
ABC’s recommendations and main points of focus have centered on five main issues—they are listed below with a summary of how they have been addressed in the final plan.
- Streamlining the Custom HVAC Process
A Better City supports electrification of the Commonwealth’s building stock and acknowledges that electrifying existing buildings and systems pose unique technical and economic challenges. For buildings which have been constructed and are occupied, changes to the HVAC controls represent one of the largest opportunities for savings and for the reduction of emissions from fossil fuels. A Better City has consistently advocated for a more streamlined and standardized process for “custom” HVAC projects, which represent the project type and pathway most frequently pursued by the large commercial entities that comprise A Better City’s membership.
A Better City helped spearhead a response to customer concerns and facilitated collaboration between facility engineers, technical assistance providers, and the PAs technical staff to develop a more transparent, structured, and standardized approach to document the existing conditions associated with HVAC controls improvements and upgrades, facilitating the PA commitment of incentives and accelerating project timelines.
A Better City will continue to engage with the C&IWG, the HVAC taskforce, and other stakeholders to assess progress in incorporating these changes into standard practice.
- Existing Building Retro-commissioning
In a similar vein to Custom HVAC, A Better City has advocated for a more formalized, better funded, and more accessible approach to Existing Building Retro-commissioning (“EBCx”) as an important avenue for improving the operational efficiency of the Commonwealth’s existing building stock.
The PAs intend to develop a pool of qualified service providers who are specifically trained in the technical requirements of the new pathway and propose providing significant financial support to customers undertaking EBCx investigations. The 150-300 assessments budgeted by the PAs falls short of the 2,200 recommended by the EEAC and Consulting team. A Better City acknowledges the commitment to roll out this new pathway and encourages the PAs to expand enrollments based on interest and results as the offering gets underway.
- Deep Energy Retrofits
A Better City recommended extending the time horizon for achieving the goals outlined in the Deep Energy Retrofit pathway from three years to five years. The PAs agreed with this modification, committed to it earlier in the year, and have incorporated it into their final, proposed Plan.
- Separate Electrification Incentives from Weatherization
A Better City recommended that incentives for the electrification of heat should not be predicated on the co-implementation of weatherization measures or building shell upgrades. A Better City and its members understand and appreciate the rationale under which such suggestions have been made, especially in the context of the residential sector. However, for commercial buildings, many of which have long term capital plans and numerous tenants, such prerequisites for electrification incentives could have a chilling effect on the very projects that the PAs and the Commonwealth are trying to promote. In the final version of the Plan, the PAs agreed with A Better City and rejected the recommendation to tie electrification incentives to weatherization efforts.
- Commercial & Industrial Working Group (C&IWG)
A Better City recommended the formalization of the C&IWG as an official body of the EEAC—analogous to the Equity Working Group—to provide a forum for addressing programmatic and process issues related to the delivery of energy efficiency and electrification services to the sector. The formalization of the C&IWG is beyond the scope of the PAs to implement alone, and they do not specifically address this recommendation in the Plan. However, they do commit to engaging a working group to improve collaboration of the PAs’ engineering staff on projects in split electric/gas territories.
A Better City will continue to work with EEAC councilors and DOER to advocate for the formalization of the C&IWG and other forums for collaborative engagement with the PAs on issues specific to the C&I sector.
