Summary of PA’s draft 2025-2027 Energy Efficiency Plan as it Relates to ABC’s November recommendations

Written by: Yve Torrie, Director of Climate, Energy and Resilience

June 14, 2024

In November of 2023, after soliciting feedback in a facilitated discussion with its membership, A Better City submitted recommendations to the Massachusetts Program Administrators (PAs) via the Energy Efficiency Advisory Council (EEAC) public comment process. A Better City had also been coordinating closely with the Commercial & Industrial Working Group (C&IWG) and the HVAC taskforce to identify and implement improvements to the PAs’ current processes and procedures for project development.

As required by regulation, the PAs submitted the draft of the 2025-2027 Energy Efficiency Plan to the EEAC for comment and further refinement prior to the issuance of a council resolution regarding the plan in June of 2024. A Better City has reviewed the plan with an eye toward how and to what degree the PAs addressed the recommendations made last year.

For ease of reference, here are links to the relevant documents on the EEAC website:

ABC’s recommendations consisted of five main points—they are listed below with a summary of their treatment in the Draft Plan.

  • Advocating 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.
    • The PAs address this in their plan under Enhancement #1 under Existing Buildings and outline several improvements:
    • Currently conducting a statewide procurement for technical assistance services “to help ensure more consistent delivery” and to “minimize duplicative efforts.”
    • Expanding the number of “custom express” savings estimation tools which establish the specific data points which are needed to produce estimates of programmatic savings.
    • Establishing consistent, statewide pre- and post-inspection requirements to balance program rigor and customer burden.
  • Many of these improvements represent ongoing collaboration and engagement with customers, vendors, evaluators, and PAs, working together to make meaningful changes to the “custom” process, especially regarding HVAC projects. A Better City will continue to engage with the C&IWG, the HVAC taskforce, and others to advocate for greater transparency and standardization to increase participation and savings.
  • Increasing the availability of, and funding for, existing building commissioning (EBCx) studies and
    • The EEAC specifically recommended that the PAs undertake 2,200 EBCx The PAs proposed completing less than half that number (1,000) during the upcoming plan term. A Better City continues to encourage the PA’s to be flexible based on uptake as the offering gets underway.
  • Extending the time horizon for achieving the goals outlined in the Deep Energy Retrofit pathway from three years to five
    • The PAs proposed extending the achievement timeline to five years.
  • Incentives for the electrification of heat should not be predicated on the co- implementation of weatherization 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.
  • The PAs do not appear to have explicitly tied the availability of incentives for heat pump and other heat electrification equipment to simultaneous or sequential upgrades to the thermal performance of the building envelope.
  • Formalization of the C&I Working Group 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.
  • While the formalization of the C&IWG is beyond the scope of the PAs to implement alone, they do commit to forming a working group to improve collaboration of the PAs’ engineering staff on projects in split electric/gas territories.
  • ABC 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.

 

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