3 Year Energy Efficiency Planning
November 17, 2023
A Better City hosted a working session with members on November 8th to discuss draft recommendations for the 2025-2027 Three Year Energy Efficiency Plans that included an analysis of progress to date on the 2022-2024 Three Year Energy Efficiency Plan. As a result of listening to monthly Energy Efficiency Advisory Council (EEAC) meetings, attending C&I dedicated stakeholder sessions, reviewing the recommendations of the EEAC consultants, and most importantly through the working session input and conversations with members, A Better City sent preliminary comments and recommendations for the 2025-2027 Three Year Energy Efficiency Plan to the EEAC on November 14th. These comments were also provided on behalf of the Boston Green Ribbon Commission’s Commercial Real Estate and Health Care Working Groups.
For those less familiar with the 3-year energy efficiency planning process, in 2008, as part of the Green Communities Act, the EEAC was established to oversee the development, implementation and evaluation of the 3-Year Energy Efficiency Plans for MA investor-owned utilities and municipal aggregators (referred to as program administrators). The energy efficiency plans are required every 3 years and must maximize the economic benefits for residents and businesses through energy efficiency programs that we know as Mass Save. Also, the plans must achieve the Commonwealth’s energy, climate, and environmental goals. The Commercial and Industrial (C&I) sector has a representative sitting on the EEAC to be the C&I voice within the Council.
In summary, A Better City’s preliminary recommendations were to:
- Streamline and Standardize the Processes for Custom HVAC Projects. A Better City members have noted that control setbacks and other HVAC control strategies and optimization approaches have the potential to save significant amounts of energy and emissions, especially from fossil fuel use, and that they can be implemented in the near-term, at relatively modest capital outlay. But these Custom HVAC projects take much longer to move through the Program Administrator’s review process and approvals are often delayed. We have therefore recommended that this process be streamlined and standardized with final incentives being flexible based on observed savings, relative to an established baseline.
- Support Existing Building Commissioning. A Better City members support the Program Administrators undertaking an effort to provide a high-volume of existing Building Commissioning studies to medium and large customers over the duration of the upcoming Three-Year Plan, and that these services be provided at no cost to qualifying customers.
- Support Expanding Access to the Deep Energy Retrofit Pathway. A Better City members recommend allowing longer timelines in the Deep Energy Retrofit Pathway as the current window of three years to achieve a 40% reduction in GHG emissions is extremely aggressive given the planning and construction timeline for most large C&I customers. Instead, we recommend that at a minimum, the time horizon be extended to 5 years.
- Not Link Weatherization and Heat Electrification. A current EEAC proposal suggests that incentives for heat pumps be tied to weatherization requirements. Although A Better City members appreciate the spirit of the proposal and recognize that a properly weatherized building can facilitate the optimal sizing and operation of heat pump systems, they note that investing in heat pump systems represents a significant investment, while weatherization of large C&I buildings are major projects in their own right that typically involve significant capital outlay. They are concerned that tying heat electrification incentives to whether a building is weatherized could discourage heat pump adoption where it otherwise might have occurred.
- Formalize the C&I Working Group as an EEAC Working Group. The C&I Working Group, established in the 2022-2024 Three Year Energy Efficiency Plan, has been meeting to discuss the issues that C&I customers face when participating in the programs and pathways offered under Mass Save. However, we recently learned that the C&I working group is not formally part of the EEAC. As the C&I Working Group represents a diverse spectrum of C&I customers, we recommend formalizing it as an EEAC Working Group so that issues relevant to the sector can be discussed in greater detail at EEAC meetings, and recommendations from it can be included in EEAC recommendations.
For any questions, please contact Yve Torrie.