Energy Efficiency Plan 2022-2024

Written by Yve Torrie, Director of Climate, Energy, & Resilience

From Q4 2020 through October 2021, A Better City and the Boston Green Ribbon Commission’s Commercial Real Estate (CREWG) and Health Care Working Group (HCWG) have been engaging with the Massachusetts Energy Efficiency Advisory Council (EEAC) and Massachusetts Program Administrators (PAs) as the 2022-2024 Three-Year Energy Efficiency Plan (Three-Year Plan) was under development. Two drafts of the Three-Year Plan were released in April and early October for public comment prior to the November 1, 2021 filing with the Department of Public Utilities.

Through participation in relevant stakeholder workshops in late 2020/early 2021 and ongoing EEAC meetings, as well as internal working group meetings, we developed a set of key recommendations for the Three-Year Plan based on key member interests and progress made to-date on the 2019-2021 plan. Representatives from A Better City, CREWG, HCWH, as well as the Commercial & Industrial Councilor, advocated for these recommendations through written comment and public comments delivered across EEAC meetings in 2021, as well as through direct meetings with EEAC councilors and representatives of the PAs.

Many of these recommendations were adopted in the Three-Year Plan. These recommendations, as well as the degree to which they were adopted in the final submitted plan, are summarized in the table below. Note that DPU is not expected to rule on the Three-Year Plans until January 2022 at the earliest. Final spending amounts and programmatic proposals may be changed or rejected.

For reference, the final submitted plan can be accessed here



Enhance communication and coordination across and within key C&I segments
  • We proposed the establishment of a formal C&I working group to increase access and engagement between PAs and stakeholders from key C&I market segments, to be facilitated by DOER. The goal of this working group would be to facilitate more frequent engagement between the PAs and key stakeholders and institutional organizations, enabling more targeted and effective outreach; facilitating the refinement of strategies for market engagement; and providing deeper understanding of and opportunities to engage with key Mass Save program offerings, particularly for small- and mid-sized organizations.
  • The PAs and DOER agreed to convene a C&I working group, which shall meet four times a year during the 2022-2024 term, to be co-led by the PAs and the DOER. The key focus of this group will be direct engagement with customers and contractors who have experience with the programs. The charter of the C&I working group will be developed jointly by DOER and the PAs, with input from the working group.
  • See page 144 for additional information
Develop enhanced retrofit offerings for pursuing deeper energy reductions and electrification
  • We endorsed the Consultant Team’s recommendation to increase promotion of electrification systems and program offerings in C&I buildings and the establishment of separate targets for C&I electrification.
  • We endorsed the Consultant Team’s recommendation to undertake a Deep Energy Retrofit pilot to pursue cost-effective deep energy retrofits across envelope, HVAC, and other efficiency improvements through whole building approaches.
  • We proposed streamlined engineering review and the establishment of more consistent and transparent parameters for program review to reduce project delays and bottlenecking.
  • We requested that the PAs explore opportunities to implement incentives for tenant space submetering as part of participation in Continuous Energy Improvement (CEI) or Equipment and Systems Performance Optimization (ESPO).
  • The PAs proposed to increase support for electrification of existing buildings, which includes supporting gas-to-electric conversions in the Municipal, University, School and Hospital (MUSH) market as well as broadening pathways for program participation (i.e. upstream, downstream, and custom). This included establishing targets for electrifying over 50 million square footage of C&I buildings.
  • The PAs proposed to design and implement a deep energy retrofit offering, including significant technical and financial assistance to support systematic forethought and intentionality that leads to impactful investments that can drive adoption at scale.
  • The PAs proposed to reorient C&I HVAC incentives to provide more flexible delivery channels through “harmonization” of midstream, downstream, prescriptive, and custom pathways, though did not specifically mention improvements for engineering review.
  • See pages 151-153 for additional information.
Continue to expand equitable training and workforce development efforts through Mass Save and streamline the application processes
  • We endorsed the Consultant team’s recommendation to deliver additional targeted trainings for emerging and critical technologies (e.g. established technologies such as building automation systems, heat pumps, HVAC controls as well as emerging technologies) and to expand Building Operator Certification trainings.
  • We recommended broadening program-oriented trainings to increase understanding of available pathways to leveraging Mass Save programs and funding.
  • We endorsed the EEAC Equity Working Group’s recommendations to broaden and diversify the energy efficiency workforce through increased outreach and collaboration with vocational and technical schools and increased funding for apprenticeships, internships, and job placements.
  • The PAs proposed to continue expanding previous technical trainings to encompass more technologies and to establish a partnership with Northwest Energy Efficiency Council to increase access to no-cost BOC resources and trainings.
  • The PAs proposed continuing partnership with UMass Amherst for technical training sessions for end-users to enable them to better understand opportunities for efficiency and taking advantage of Mass Save programs.
  • The PAs proposed a Clean Energy Pathways internship program to increase the supply of qualified HVAC workers and building operators, improve diversity in the workforce, and increase program participation in traditionally hard-to-reach communities, with a goal of training and placing approximately 120 individuals in energy efficiency-related careers.
  • See pages 141-142 for additional information.
Study the incorporation of resilience considerations and additional non-energy benefits into efficiency programs
  • We recommended that the PAs study the potential benefits of integrating energy efficiency with improved resiliency in building retrofits, with the goal of establishing a program offering that could support integrated efficiency and resiliency offerings
  • The PAs make no mention of resiliency from the perspective of energy efficiency in the Three-Year Plan.
  • Notably, we made the same recommendation in the 2019-2021 Three-Year Planning process, though similarly, the PAs did not address this then either.
Assess incentives and impacts for combined heat and power
  • We endorsed the Consultant team’s recommendation to reassess incentives for gas-fueled CHP with the recommendation to closely review energy-intensive market segments that do not have suitable alternative technologies that provide similar benefits to CHP for exemptions from any CHP incentive rollbacks.
  • We proposed that the PAs also assess the potential for biogas to serve new and existing CHP systems and options for enhancing incentive support for biogas-powered CHP systems.
  • Pending the assessment and evaluation of CHP programs, the PAs propose to phase out CHP incentives in the 2022-2024 plan for systems that will lead to an increase in 2030 emissions.
Develop an incentive structure for electric and micro mobility vehicles
  • We recommended that the PAs develop a program to support installation of electric vehicle infrastructure outside of active demand management programs as well as incentives for the purchase of micro-mobility vehicles.
  • Within the framework of active demand management, we propose that the PAs explore opportunities to support vehicle-to-grid technologies to enhance grid management and renewables integration.
  • The PAs only proposed to explore EV charging management within active demand management within C&I (page 172-173).
Support greater alignment between Energy Efficiency planning and GWSA mandates
  • We proposed that the EEAC and PAs explore how best to align near- and long-term priorities for Mass Save with deeper decarbonization pathways needed to achieve state climate targets.
  • In light of the passage of S.9, the PAs were required to integrate carbon reduction targets into the Three-Year Plan. As such, many steps, including stepdown of incentives for many fossil fuel equipment types, substantial increases in electrification support, and first-time support for gas-to-electric conversion may be considered steps towards greater alignment of the energy efficiency framework with broader climate mitigation goals.


Please reach out to Yve Torrie with any questions or comments.


Comments (0)

Allowed tags: <b><i><br>Add a new comment: