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New York state’s Energy Efficiency for All Coalition responds to plans by Governor Cuomo and the Public Service Commission to expand energy efficiency programs for low-income families

As the state’s leading coalition of energy efficiency and affordable housing advocates, New York Energy Efficiency for All (EEFA NY) applauds Governor Cuomo and the New York Public Service Commission (PSC) for their leadership in combating climate change and promoting energy efficiency for all New Yorkers.  We are thankful that they acknowledge the unique barriers that low-income people face–especially those who live in multifamily housing–as families seek to share in the benefits of energy efficiency and the clean energy economy.

On December 13th, Governor Andrew Cuomo announced that the PSC approved two major initiatives: By 2025, the Commission hopes to advance clean energy storage technologies that will power over a million homes. The Commission’s actions will also more than double New York’s targets for energy efficiency, reducing energy consumption by the equivalent of powering 1.8 million homes. These expanded efficiency targets will create as many as 50,000 new jobs, save customers an estimated $15 billion dollars on their energy bills and provide important non-energy benefits such as healthier, more comfortable homes.

By ensuring that, at minimum, 20 percent of the newly authorized spending on energy efficiency will be used to help low and moderate income New Yorkers, the PSC has helped assure that the state’s neediest families are not left behind by this new initiative. Since 4 in 10 low-income residents live in dwellings with more than five apartments, we are thrilled to see the Commission suggest that these resources should focus on multi-family housing. We support additional funding for multi-family programs where feasible and appropriate.

Another bright spot in the December 13th announcement is that it highlights the need for financing to help owners make efficiency upgrades both within apartments and building-wide. Owners of affordable, multi-family buildings often rely on razor-thin operating margins to fund repairs and renovations. Typically, it’s only when owners seek to refinance their mortgages that money could become available for major improvements like whole-building retrofits. The PSC order points to the possibility of aligning program dollars with these refinancing cycles to help support building upgrades, as well as between cycles to pay for smaller and in-unit updates.

EEFA NY also agrees that the Commission’s initiative will create good-paying jobs in the energy efficiency sector. Our hope is that the initiative, as well as the workforce development programs at the New York State Energy Research and Development Authority (NYSERDA) will provide robust job-training opportunities for low-income residents, so that they can become equal partners in building our clean energy economy.

While the PSC order is a much needed acceleration of energy efficiency in the state, our coalition has some concerns about the timeline for its implementation. Utilities have until March 31, 2019 to submit their joint plan for targets and budgets, as well as a framework for low and moderate income programs. These will be followed by a 60-day public comment before being adopted by the Commission. Then, the utilities and NYSERDA will submit a low and moderate income plan, set for implementation in 2020. Our view is that utilities and energy efficiency service providers are ready now, especially given the many stakeholder forums and proceedings that have already identified recommendations for this sector. Providers of affordable housing and their tenants need relief today.

We are also concerned that the Commission assigns NYSERDA a significant role in developing and delivering inclusive energy efficiency programs. While NYSERDA has, and should remain, an active partner in providing low income energy efficiency, utilities know their regions and their markets best. Utilities should therefore be encouraged, if not required, to develop and implement their own programs.

Thankfully, the order allows for a less stringent approach for determining what is cost effective for low and moderate income efficiency programs, which will, in turn, allow for more flexibility in their planning and implementation. This is helpful, given that the current approach used by the utilities does not adequately account for the non-energy benefits of efficiency such as health and safety. We continue to support explorations of how to quantify and include non-energy benefits of efficiency in program planning.  

Ultimately, we believe that the PSC’s announcement is a win for New York state. EEFA NY looks forward to working closely with NYSERDA and the utilities as they implement Governor Cuomo’s ambitious clean energy goals, helping to make sure that the benefits of energy efficiency are enjoyed by all.