By Radina Valova
The Energy Efficiency for All New York (“EEFA NY”) coalition strongly supports the New York Public Service Commission’s (“PSC”) recent adoption of aggressive energy efficiency and beneficial electrification programs through its New Efficiency: New York process, as well as new efficiency spending and programs as part of Consolidated Edison’s 2019 rate case. Energy efficiency is critical to achieving New York’s ambitious climate goals, and is an essential tool in the affordability toolbox for low- and moderate-income (LMI) New Yorkers and affordable multifamily housing (AMF).
EEFA NY has been a strong advocate for well-designed efficiency programs, supported by robust outreach and education, to inform affordable multifamily residents, property managers, and building owners of the efficiency resources and funding available to them. The PSC’s Order Authorizing Utility Energy Efficiency and Building Electrification Portfolios Through 2025 (the “Efficiency and Electrification Order”) is an important step in developing programs that provide meaningful efficiency solutions and options for AMF residents and building owners and operators.
The New Efficiency: New York program has as its primary goal the achievement of annual efficiency savings of 3% for electricity and 1.3% for gas – goals that match or exceed the targets set by the majority of states in the U.S. The PSC has allocated a total of $1.99 billion in ratepayer funds from 2019-2025 toward electric and gas efficiency programs and electrified heating investments (in addition to previously authorized programs totaling another $1 billion). Under the Efficiency and Electrification Order, $892 million will go toward electric efficiency investments, $552 million toward gas efficiency, and $454 million toward heat pumps.
These investments are anticipated to achieve 35.8 TBtu of incremental energy savings, on top of efficiency programs that have already been authorized, and to result in $13 billion in gross bill savings to participants, $6 billion in gross lifetime utility system benefits, and $1.7 billion in societal carbon reduction benefits.
One of the most important elements of the New Efficiency: New York program is that it allocates at least 20% of incremental funding—representing $253 million for 2021-2025—to LMI efficiency programs. Furthermore, the PSC directed that 40% of the LMI budget be spent on multifamily buildings (on a statewide basis, recognizing that there are more multifamily buildings in some utility territories than others). EEFA NY strongly supports the PSC’s focus on providing targeted financial support for ramped-up efficiency in the affordable multifamily sector, and this is a critical start on that path.
Our work is not yet done. The LMI Portfolio, which the utilities and the New York State Research and Development Authority (“NYSERDA”) will jointly develop, with stakeholder feedback, will have to address a number of important implementation issues.
As we have previously noted, targeted funding must be accompanied by robust customer identification, education, outreach, referral, and enrollment programs, not just for individual customers, but for affordable multifamily property owners and managers as well. LMI programs must also explicitly include efficiency support for in-unit and common areas in multifamily buildings. In addition, the PSC correctly notes that the utilities’ “current portfolios do not sufficiently target building envelope improvements” (Efficiency and Electrification Order at p. 45). Multifamily efficiency programs must include whole-building measures.
EEFA NY strongly supports the PSC’s recognition that in developing programs and implementation plans, the utilities and NYSERDA must work with all relevant stakeholders, including customers and market participants, as part of the Performance Management and Improvement Process mandated in the Order. That process – and all additional stakeholder participation – should include benchmarks for incorporating stakeholder feedback into program design and implementation in a way that has a direct and meaningful impact on program design.
EEFA NY also appreciates the PSC’s instruction to the utilities to design their gas efficiency incentive programs to maximize gas efficiency. Increasing gas efficiency for existing gas customers is critical to promoting greater affordability and environmental benefits. At the same time, in regard to new customers seeking energy services for cooking, heating, or hot water, the utilities must prioritize renewable alternatives to the greatest extent possible.
In addition to the measures it approved as part of the Efficiency and Electrification Order, the PSC approved several important funding and programmatic provisions as part of Con Edison’s 2019 rate case, including: granting Con Edison full flexibility to allocate funds between its electric and gas LMI efficiency programs; making its gas efficiency programs available to interruptible customers—an important measure that can increase efficiency access to a subset of customers who haven’t previously been able to take advantage of energy efficiency programs; and a commitment by Con Edison to help owners/developers of LMI projects obtain financing by funding studies of efficiency project potential and by providing the customer with a commitment letter for the utility incentives for which they are eligible. While not all EEFA NY members support the Con Edison Joint Proposal or the Commission’s order of approval due to concerns that it is not, as a whole in the public interest, EEFA NY recognizes the importance of robust utility energy efficiency programs.
EEFA NY is pleased to be part of New York’s ongoing effort to address climate change and the disparate impact energy decisions have had on disadvantaged and low income communities. We are pleased that the recent PSC decisions direct resources to affordable multifamily housing and look forward to working with all parties to implement and strengthen the provisions supporting safe, comfortable and efficient housing for all.
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