3 Year Energy Efficiency Plan

The 3 Year Energy Efficiency Plan (2019-2021) is drafted up by the Energy Efficiency Advisory Council (EEAC), which includes representatives from the efficiency Program Administrators (PAs – aka, the utility companies), environmental and community leaders and is chaired by the Department of Energy Resources (DOER). Energy Efficiency Plans are approved by the Department of Public Utilities (DPU) once the Draft is finalized. These plans are central to maintaining Massachusetts’ nation-leading status on energy efficiency savings, meeting the state’s climate goals, and capturing available benefits for all consumers.

Comments on the draft must be submitted to the Councilors by
October 10 to ma-eeac@mass.gov.


2019-2021 Three-Year Energy Efficiency Plan September 2018


Ask that the EEAC vote NO on the Draft unless these issues are addressed or included:

  •  Enhanced incentives offered for gas conversion are not acceptable. Energy Efficiency dollars should be invested in ways that drive conversion to beneficial electrification, NOT conversion from oil/propane to gas.
  • Beneficial electrification should be a core feature of the plan, allowing fuel switching to high-efficiency electric heating, hot water and cooking.Among other solutions, one means to driving conversion to electrification could be to extend the Solar Access pilot program statewide to allow customers to access incentives for adding high-efficiency cold weather heat pumps and the solar panels to run them. This program allows households to drastically cut or eliminate their need for fossil fuels, helping drive compliance with the Global Warming Solutions Act (GWSA). It also requires customers to have a Mass Save Energy Audit, which is the key to accessing many incentives for boosting energy efficiency.

    Beneficial electrification should be a priority focus for cases where starting new energy systems from scratch becomes necessary, as in the homes and businesses affected by the Columbia Gas system failure in the Merrimack Valley, or in any new construction or renovation where replacement of energy systems is required.
    See comments on including community partners in outreach implementation below.

  • Expansion of linguistic services – Expansion of linguistic services in the MassSave phone center are a step forward, but also need to include French / French Creole speakers, the third largest language bloc in Massachusetts.
    See comments on including community partners in outreach implementation below. 
  • Incentives for landlords & renters – Aside from continuation of the 90% incentive for landlords, the current draft of the Energy Efficiency Plan does not clearly outline incentives for renters and landlords. What provisions are there for renters whose landlords are reluctant to participate? How can landlords be incentivised to participate even if their renters pay their own utility bills?
  • Outreach for energy efficiency and energy conversion programs needs to be partnered with trusted community groups. Community aid organizations have a first-hand knowledge of the barriers that low income, communities of color and non-english-speaking residents may face and can help bridge the gap, making benefits of existing programs accessible and implementable for a significantly larger portion of the population.
  • Failure to account for Global Warming Solutions Act (GWSA) compliance does not make sense. Efficiency is our cheapest resource. Exhausting all cost-effective efficiency (squeezing all we can out of energy efficiency) means we’ll be less reliant on more expensive means of achieving compliance with the Global Warming Solutions Act. The 3YP should reflect MA-only value for carbon avoidance/GWSA compliance identified in the DOER study ($35/ton).
  • Performance incentives – more money paid to the Program Administrators (PAs) for achieving lower goals is unacceptable. The plan, as drafted, proposes increased performance incentives, but delivers significantly less in total benefits without explanation as to why.
  • Data transparency – Data transparency is essential to decision making by the Council and accountability to the public, who are paying for these programs through their utility bills. The basic questions of where the dollars are going, how being used, and are they being efficiently used need to be readily answerable.


» Notes from Sept. 24 webinar on the 3 Year Plan Draft, hosted by Green Energy Consumers Alliance
» Notes from Green Justice Coalition

Questions? Contact Eugenia Gibbons, Clean Energy Programs Director, Green Energy Consumers Alliance, eugenia@greenenergyconsumers.org, 617-524-3950 x 141

»» Public comments already filed on the 3 Year Energy Efficiency Plan Draft

**This list of talking points has been compiled from recommendations from
Green Energy Consumers Alliance, Acadia Center, Green Justice Coalition, No Fracked Gas in Mass and Berkshire Environmental Action Team.

(Tiny URL for this page: tinyurl.com/EEPlanDraft)