Energy efficiency is, and will continue to be, a core pathway for buildings to decarbonize as the City of Boston develops a Building Emissions Performance Standard for existing buildings and a Net Zero Buildings Standard for new construction, and the  State Legislature develops economy-wide emission reduction targets to be followed by sector-specific targets at a later date. Although energy efficiency is one of many pathways for buildings to reach these goals – others include renewable energy, offsets, carbon pricing, and alternative compliance payments – efficiency as a core decarbonization strategy features prominently in all policies under development.

Many A Better City buildings have been working diligently to increase efficiency within their buildings for years. A key energy efficiency motivator has been the Commercial and Industrial (C&I) incentives provided through the Mass Save program as part of the utilities’ Three-Year Energy Efficiency Plans that are monitored by the Massachusetts Energy Efficiency Advisory Council (EEAC). A Better City and the Green Ribbon Commission’s (GRC’s) Commercial and Health Care Working Groups develop C&I recommendations for inclusion in the utility’s Three-Year Energy Efficiency Plans and track the progress towards achieving the goals throughout the course of each three-year cycle.

Currently, we are in the 2019-2021 three-year plan cycle and have just conducted an analysis of the utility’s progress to date. In a nutshell, progress towards achieving C&I savings targets is lagging behind the necessary pace to meet the 2019-2021 Three-Year Plan goals. The planning process for the 2022-2024 Three-Year Plan has already started with a series of workshops and listening sessions that provide opportunities for stakeholder engagement and public comment.

Initial comments have been developed based on discussions internally with A Better City’s staff, EEAC councilors, and consultants, and with feedback from A Better City’s Energy and Environment Advisors and the GRC’s Commercial Real Estate Working Group. These comments were submitted at the November 17th Listening Session on behalf of A Better City, and the GRC Commercial and Health Care Working Groups. We expect to submit additional detailed comments upon release of the draft Three-Year Plans in 2021 and will seek additional feedback from members at that point. Given the increasing prominence of energy efficiency in achieving carbon neutrality goals at both the city- and state level, we have identified the following areas of priority for the 2022-2024 Energy Efficiency Plan:

  1. Explore greater alignment of EEAC and GWSA priorities. We strongly encourage EEAC to assess: 1) the 2050 Decarbonization Roadmap study that identifies deep decarbonization pathways, to be released in December 2020; and 2) the key priority actions recommended by the GWSA Implementation Advisory Committee (IAC) Working Groups for inclusion in the 2030 Clean Energy and Climate Plan, also to be released in December 2020. We encourage exploration of the best ways to align both near- and long-term priorities for Mass Save with these pathways.

  2. Develop enhanced retrofit offerings for pursuing deeper energy reductions and electrification. The programs should be structured to ensure that short-term energy efficiency measures contribute to—and do not undermine—the pursuit of deeper energy retrofits that have the potential to provide greater long-term energy, emissions, and resiliency benefits to C&I buildings. Stronger measures are necessary to capture the limited opportunities between now and 2050 for building owners to replace HVAC systems and as such, we recommend increased incentives for electrification of thermal loads in buildings and the early retirement of HVAC systems as part of deeper energy retrofits.

  3. Continue to expand equitable training and workforce development efforts through Mass Save and streamline the application processes. We recommend increased trainings to ensure that facilities managers and building operators can meet and exceed expected energy performance in buildings. We encourage expanded training in Building Operator Certifications, new trainings in HVAC controls, and additional trainings that enable customers to fully leverage Mass Save’s offerings. As programs are expanded for training and workforce development, we also encourage the emphasis on equitable workforce development in underserved and environmental justice communities. More streamlined application processes for these programs will also encourage key individuals to participate in these programs.

  4. Incorporate resilience considerations and additional non-energy benefits into efficiency programs. We urge better integration and the updating of health benefits and avoided health care costs from energy efficiency which have historically been undervalued. We also urge the inclusion of a study of the potential benefits of integrating energy efficiency with improved resiliency in building retrofits, with the goal of establishing potential programs for inclusion in the 2025-2027 plan.

  5. Enhancing communication and coordination across and within key C&I segments. We strongly recommend establishing C&I working group(s) to increase access and engagement between utilities and key C&I market segments. This will enable more targeted and effective outreach, facilitate the refinement of strategies for market engagement, provide deeper understanding of and opportunities to engage with key Mass Save program offerings, and will be an avenue for the delivery of utility biannual progress reports.

For further information, please contact Yve Torrie:

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