Updated Energy Efficiency Priorities In The Next Three-Year Energy Efficiency Plan


At the Energy Efficiency Advisory Council’s (EEAC) Listening Session on November 17th, 2020, initial Commercial and Industrial (C&I) comments for the next three year energy efficiency plan (2022-2024) were submitted on behalf of A Better City, and the Green Ribbon Commission’s Commercial and Health Care Working Groups. Since that time, the EEAC Consultant Team have presented their recommendations, and there has been a robust public engagement and workshop process that commenced in the last quarter of 2020. In addition, we hosted a focus group with interested members about our draft comments on February 12th, 2021, and received invaluable feedback.

This resulted in an update to our C&I comments that were presented in both written form and verbally at the EEAC’s monthly meeting on February 24th. There are seven key recommendations:

  1. Enhance communication between the C&I sector and Program Administrators (PAs): With progress towards achieving C&I savings targets lagging behind the necessary pace to meet the 2019-2021 Three-Year Plan goals, we consider establishing stronger channels for engagement between PA’s and key C&I market actors to be critical to meeting future goals.
  2. Develop enhanced retrofit offerings for pursuing deeper energy reductions and electrification: In order to set the C&I sector on the path to achieving long-term decarbonization goals, it is imperative that the 2022-2024 Three Year Plan offerings support building owners in achieving the deeper energy and emissions reductions that will be necessary to meet state climate mandates, including: the decarbonization strategies detailed in EEA’s Draft Interim Clean Energy & Climate Plan for 2030; updates to the state building code and stretch code scheduled for the end of 2022 under the 10th building code edition; a potential specialized opt-in stretch energy code as detailed in the latest version of S.9., the “Climate Bill”; and the City of Boston’s proposed update to the Building Energy Reporting and Disclosure Ordinance (BERDO) that includes a building emissions performance standard, and a Zero Net Carbon Standard for new construction.
  3. Continue to expand equitable training and workforce development through Mass Save: We recommend a significant increase in the amount of investment in workforce development to account for a greater proportion of total Mass Save spending (e.g. from <0.2% to 1-2% of total spending). We also acknowledge the contributions provided by the Equity Working Group for Workforce Development to ensure that increased spending drives equitable workforce development and investment in underserved and environmental justice communities. Equitable workforce development opportunities will not only serve to meet future building energy service needs but will also support equitable growth in the context of economic recovery from the COVID-19 pandemic.
  4. Study the incorporation of resilience considerations and other non-energy benefits into efficiency programs: We recommend a study of the potential benefits of integrating energy efficiency with improved resiliency in building retrofits, with the goal of establishing potential programs to implement in the second and third years of the 2022-2024 plan. We also support the proposed expansion of behind-the-meter storage targets outlined in recommendations for the Active Demand Reduction (ADR) program. Finally, we recommend finding ways to better integrate updated valuations of avoided health impacts and healthcare cost containment benefits from energy efficiency.
  5. Assess incentives and impacts for combined heat and power: We support the broader alignment of the Commonwealth’s energy efficiency programs with its climate targets and the need to phase out fossil fuel combustion in buildings. However, we believe that deeper exploration is needed on the impact of phasing out CHP incentives on the limited C&I market segments that can still benefit from CHP’s energy and non-energy benefits, as well as the present lack of available alternative technologies and fuels that can meet these specific needs.
  6. Develop an incentive structure for EV and micro mobility vehicles: We recommend developing a program to incentivize electric vehicle (EV) infrastructure in conjunction with or separate from Active Demand Management. We also recommend incentives be provided for EV-ready infrastructure in situations when immediate implementation is not possible.
  7. Support greater alignment between Energy Efficiency Planning and the Global Warming Solutions Act (GWSA): We recommend the energy efficiency planning process aligns with the GWSA so the planning process builds on the 2050 Decarbonization Roadmap and draft Clean Energy & Climate Plan released at the end of 2020.

We expect to submit updated comments upon release of the EEAC’s draft Three-Year Plans in April 2021.

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