Comments for the MA Energy Efficiency Advisory Council!

The 3-year plan for the Massachusetts Energy Advisory Council is in its final stages of approval and written comments will be welcome until October 10.

Public comment can be submitted by presenting in person at a monthly EEAC meeting or by emailing a PDF version of comments, including name and organization of the commenter. Email ma-eeac@mass.gov with the comments! 

Here are 2 groups of draft talking points that you can use, of course feel free to add your own issues and concerns.

Green Justice Coalition talking points:

  • We have been advocating for almost the same policies for ten years and have seen little progress despite the plans always including our issues in name.  Just saying that there is outreach and that you are trying is no longer enough for this group and hopefully for the Councilors who have indicated this year and in year's past that the PAs have not done enough.
  • Our main issue is that the PAs want expanded performance incentives.  We are not completely opposed to that, as long as the new metric and the performance incentives are tied to their service of moderate-income, environmental justice, and renter communities.  
  • We again request that the PAs and this council work on making Mass Save data publicly available, so ratepayers can understand how much they are paying and what the money is going towards.  This program takes money from every community and even after 10 years, we have no idea if that money is going back to every community, not municipality. Granular data is needed to know the distributional effects of the program and how it affects low and moderate income areas.  
  • We are thankful for the inclusion of multiple languages on the website and marketing materials, but still have strong concerns about accessibility of the phone lines and services that Mass Save offers.  We want to ensure that when our constituents call Mass Save that they are not only presented with English options.

In addition, there are a number of environmental and economic concerns with the plan and there are talking points regarding the overall proposal by the Program Administrators (who are the Investor Owned Utilities):

  • We would like higher overall savings targets in the plan.  The proposed targets are insufficient to meet all cost effective savings and do not fully take into account the consultants' recommendations.  We strongly urge the council and the PAs to adopt a higher savings goal that is in line with the consultants' recommendations.
  • We are extremely concerned with Mass Save funds being used for oil-to-gas conversions.  The emissions performance metric as well as apparent self-dealing is not an acceptable use of ratepayer funding for utility companies.  We are concerned that the utilities are trying to expand their customer base with Energy Efficiency money that should be going towards strategic electrification and efficiency measures.  We believe that converting from oil to gas does not achieve the greenhouse gas emissions reductions that are statutorily required in the Mass Save program.
  • This plan does not account for the Global Warming Solutions Act.  This program had the ability to help us meet our aggregate emissions targets for 2020 but sadly has never reached the standard set for them by statute which is all cost effective savings.  
  • We reiterate that we are extremely disappointed by the PAs asking for higher performance incentives without showing more savings.  It is unacceptable to our community and to the ratepayer to charge us more money for less savings. We believe the performance incentive proposed by the PAs/utilities is disingenuous and shows that they do not have the ratepayer's best interest at heart.

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