Three-Year Energy Efficiency Plan

Three-Year Energy Efficiency Plan
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 1 of 274
2013-2015
Massachusetts
Joint Statewide Three-Year
Electric and Gas Energy Efficiency Plan
November 2, 2012
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 2 of 274
Prologue: .................................................................................................................................. 1
I.
EXECUTIVE SUMMARY.................................................................................................... 6
A.
Introduction ..........................................................................................................................6
B.
Core Goals for 2013-2015 .......................................................................................................6
C.
A Retrospective – Past and Current Achievements ..................................................................8
D.
The Future – Achievements to Come ....................................................................................10
1.
2.
3.
E.
Statewide Electric Summary: ....................................................................................................................12
Statewide Gas Targets Summary: .............................................................................................................13
Term Sheets ..............................................................................................................................................14
Significant Updates & Highlights ...........................................................................................15
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
F.
Bold New Initiative Targeting Economically Challenged Neighborhoods.................................................15
Continuing Focus on Segmentation ..........................................................................................................15
Public Education .......................................................................................................................................16
Enhanced Integration of Gas and Electric Energy Efficiency Services Plan ..............................................17
Program Consolidation .............................................................................................................................17
Budget/Savings Goals: Comparison to 2010-2012 ..................................................................................18
Innovation and Best Practices ..................................................................................................................18
Reducing Administrative Burdens/Streamlining Processes ......................................................................20
Incorporating RCS in Three-Year Plan.......................................................................................................21
Engaging Third Party Stakeholders ...........................................................................................................21
Updates Since July 2, 2012 and September 19, 2012 Draft Plans ............................................................22
Overview of the Key Aspects of the Plan ...............................................................................23
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
Savings and Core Benefits ........................................................................................................................23
Program Budgets ......................................................................................................................................26
Cost Effectiveness .....................................................................................................................................29
Progress Toward Green Communities Act Requirements and Goals .......................................................29
Programs...................................................................................................................................................30
Evaluation, Monitoring and Verification ..................................................................................................30
Cost Recovery and Performance Incentives .............................................................................................30
Mid-Term Modifications ...........................................................................................................................31
Economic Development and Job Growth .................................................................................................32
Conclusion ................................................................................................................................................32
G. Council Priorities, Sense of the Council, Council Action Plans and Individual Councilor
Comments ...................................................................................................................................33
1.
2.
3.
4.
5.
II.
Council Priorities .......................................................................................................................................33
Sense of the Council Regarding the Three-Year Plans (2013-2015) .........................................................36
Action Plans for the Three-Year Plans ......................................................................................................39
Individual Councilor Comments Draft Plans .............................................................................................51
Council Resolution of July 23, 2012 ..........................................................................................................51
PROCEDURAL BACKGROUND ......................................................................................58
A.
The Green Communities Act .................................................................................................58
B.
D.P.U. 08-50-A .....................................................................................................................59
C.
D.P.U. 08-50-B .....................................................................................................................59
D.
D.P.U. 08-50-C .....................................................................................................................60
i
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 3 of 274
E.
Initial Three-Year Plans - D.P.U. 09-116 to D.P.U. 09-128 .......................................................60
F.
D.P.U. 10-106 .......................................................................................................................61
G.
D.P.U. 11-120 .......................................................................................................................61
H.
2010 Annual Reports, D.P.U. 11-63 through D.P.U. 11-73, D.P.U. 11-126................................63
I.
2011 Annual Reports, D.P.U. 12-51 through D.P.U. 12-61 ......................................................64
J.
2011 Energy Efficiency Mid-Term Modifications, D.P.U. 10-140 through 10-150 ..................... 64
K.
2012 Energy Efficiency Mid-Term Modifications, D.P.U. 11-106 through D.P.U. 11-116 .......... 65
L.
D.P.U. 08-50-D .....................................................................................................................66
III.
THE THREE-YEAR PLAN ................................................................................................68
A.
Core Benefits and Cost-Effectiveness ....................................................................................68
1.
2.
3.
4.
a.
b.
5.
a.
b.
B.
Energy and Demand Savings.....................................................................................................................68
Environmental Benefits ............................................................................................................................69
Net Benefits and Cost-Effectiveness.........................................................................................................70
Gas and Electric Program Integration and Coordination ..........................................................................72
Focus on Seamless Delivery .................................................................................................................72
Ongoing Work of Management Committees.......................................................................................73
Additional Benefits ...................................................................................................................................74
Reduction in Peak Load........................................................................................................................74
Economic Development and Job Growth/Retention ...........................................................................74
i.
New England Clean Energy Foundation Study ................................................................................74
ii.
Contribution to Clean Energy Economy ..........................................................................................75
Progress towards Green Communities Act Requirements and Goals ......................................75
1.
Acquisition and Assessment of All Available Cost-Effective Energy Efficiency and Demand Reduction
Resources ...........................................................................................................................................................75
a.
Experience in Field ...............................................................................................................................76
b.
Point 380 Market Characterization ......................................................................................................76
c.
Synapse Assessment ............................................................................................................................76
d.
Review of EM&V Results ......................................................................................................................77
e.
Appreciative Inquiry Summit ...............................................................................................................77
f.
Council Meetings .................................................................................................................................78
g.
Consultant Assessment ........................................................................................................................78
h.
Re-Assessment of Savings Goals following June, July, August, and September Council Meetings .....80
2.
Key Factors, Challenges and Market Barriers ...........................................................................................82
a.
Market Barriers ....................................................................................................................................82
b.
Policy Issues .........................................................................................................................................84
c.
Assessing Technical Potential ..............................................................................................................84
3.
Allocation of Funds for Low-Income Programs and Education ................................................................85
4.
Minimizing Administrative Cost................................................................................................................85
5.
Competitive Procurement Process ...........................................................................................................88
6.
Demand Response ....................................................................................................................................88
C.
Funding Sources & Financing Initiatives ................................................................................89
1.
2.
3.
4.
5.
System Benefit Charge (electric only).......................................................................................................89
Forward Capacity Market (“FCM”) Proceeds (electric only).....................................................................89
Regional Greenhouse Gas Initiative Proceeds (electric only) ...................................................................90
Energy Efficiency Reconciliation Factor (“EERF”) (electric only) ..............................................................91
Carryover Information ..............................................................................................................................91
ii
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 4 of 274
6.
7.
D.
Outside Funding Levels .............................................................................................................................91
Financing Initiatives ..................................................................................................................................91
Summary of Budgets, Savings, and Benefits ..........................................................................92
1.
2.
3.
4.
5.
6.
E.
Cost Drivers ..............................................................................................................................................93
Process to Determine Goals .....................................................................................................................98
Common Assumptions..............................................................................................................................99
Unique Service Areas - Drivers of Appropriate Savings Variations among PAs ......................................100
Electric Statewide Budget, Annual Savings, Lifetime Savings, and Benefits ...........................................103
Gas Statewide Budget, Annual Savings, Lifetime Savings, and Benefits ................................................104
Bill Impacts ........................................................................................................................ 105
F.
Statewide Programs ........................................................................................................... 107
1.
2.
3.
4.
5.
6.
a.
b.
c.
d.
G.
Strategic Overview of Residential, Low-Income, and C&I Programs and Program Consolidation .........107
Consistent Messaging .............................................................................................................................107
Same Delivery Mechanism for Gas and Electric .....................................................................................108
Review of New Technologies ..................................................................................................................108
Long-term Goals .....................................................................................................................................109
Program Descriptions .............................................................................................................................110
Residential Program & Core Initiative Descriptions ...........................................................................110
Residential General Initiatives ...........................................................................................................166
i.
Efficient Neighborhoods+ .............................................................................................................166
Low-Income Program Descriptions ....................................................................................................168
C&I Program Descriptions ..................................................................................................................188
Pilots & Hard-to-Measure Efforts........................................................................................ 221
1.
2.
H.
Pilots .......................................................................................................................................................221
Hard-to-Measure Efforts ........................................................................................................................221
a.
Residential Research and Development (“R&D”) ..............................................................................221
Public Education and Marketing Activities .......................................................................... 222
1.
2.
3.
I.
Marketing Plan Overview .......................................................................................................................222
Community Engagement ........................................................................................................................228
Schools/Education Program ...................................................................................................................231
Evaluation, Monitoring & Verification ................................................................................ 233
1.
2.
3.
4.
5.
6.
7.
8.
Introduction ............................................................................................................................................233
EM&V Enhancements .............................................................................................................................233
EM&V Resolution....................................................................................................................................234
Descriptions of Research Areas ..............................................................................................................237
Transition to Statewide Plan ..................................................................................................................238
Evaluation Budgets .................................................................................................................................238
Types of Evaluation Functions ................................................................................................................239
Specific Evaluation and Monitoring Activities for 2013-2015 ................................................................239
J.
Technical Reference Manual .............................................................................................. 242
K.
Performance Incentives...................................................................................................... 243
L.
Cost Recovery .................................................................................................................... 253
1.
a.
b.
2.
3.
Overview .................................................................................................................................................253
Mechanisms Specific to Electric Program Administrators .................................................................253
Mechanisms Specific to Gas Program Administrators .......................................................................254
Calculation of EERF .................................................................................................................................255
Department Proceedings in D.P.U. 11-120 (Phase II) .............................................................................255
iii
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 5 of 274
4.
Residential Conservation Services Surcharge .........................................................................................256
M.
Mid-Term Modifications..................................................................................................... 256
N.
Database Issues ................................................................................................................. 258
O.
Effect of Investigation D.P.U. 11-120 on Three-Year Plans ................................................... 260
1.
Phase I ....................................................................................................................................................261
a.
CO2 Compliance Costs .......................................................................................................................261
b.
Savings ...............................................................................................................................................261
2.
Phase II ...................................................................................................................................................261
P.
All Cost-Effective Energy Efficiency and GHG Emissions Reductions ..................................... 262
1.
2.
3.
Summary.................................................................................................................................................262
GCA .........................................................................................................................................................262
GWSA/CECP ............................................................................................................................................263
Q.
An Integrated NSTAR Electric /WMECo Three-Year Energy Efficiency Plan ........................... 266
R.
The Special Inclusion of Blackstone..................................................................................... 269
IV.
APPENDICES .............................................................................................................270
A.
Glossary............................................................................................................................. 270
B.
Narrative Overview of D.P.U. 08-50 Tables ......................................................................... 274
C.
Statewide D.P.U. 08-50 Tables ............................................................................................ 276
D.
State by State Comparison of Energy Efficiency Savings Requirements ................................ 277
E.
Counselor Comment Matrix ............................................................................................... 278
F.
Report on Appreciative Inquiry Summit .............................................................................. 279
G.
Maps of Service Areas ........................................................................................................ 280
H.
Unique Service Area Presentations ..................................................................................... 281
I.
Sample Marketing Materials .............................................................................................. 282
J.
Performance Incentive Models ........................................................................................... 283
K.
Performance Metrics ......................................................................................................... 284
L.
Database Materials ............................................................................................................ 285
M.
Participant Definitions ....................................................................................................... 286
N.
Technical Reference Manual .............................................................................................. 291
O.
2011 Avoided Cost Study .................................................................................................... 292
P.
Evaluation Studies ............................................................................................................. 293
Q.
Bibliography ...................................................................................................................... 294
R.
Term Sheets 10/29/12 ....................................................................................................... 295
iv
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 6 of 274
2013-2015 MASSACHUSETTS JOINT STATEWIDE THREE-YEAR
ELECTRIC & GAS ENERGY EFFICIENCY PLAN
Prologue:
THE BIG PICTURE:
AGGRESSIVE SAVINGS, STREAMLINED COSTS, AND INNOVATION
пѓ� The PAs are proposing the most aggressive savings goals for an integrated gas and
electric statewide energy efficiency program anywhere in the nation.
Escalating electric target of 2.5 percent, 2.55 percent, and 2.6 percent of retail sales
compares with California target of approximately 1 percent.
Annual Savings Target (Electric)
Annual Savings Target (Electric)
2.50%
2.25%
2.20%
1.90%
2.00%
1.70%
1.50%
1.50%
1.00%
NSTAR, Western Massachusetts Electric Company, and National Grid electric savings
levels each exceed 2.5 percent. The Council’s escalating gas target is 1.10 percent, 1.12
percent, and 1.15 percent of retail sales. National Grid Gas and NSTAR Gas have
adopted savings targets that meet or exceed this level on a three-year basis. All gas PAs
have significantly increased savings goals from July 2, 2012 and September 19, 2012
proposals, even with the challenges of new evaluation results. Electric and gas savings,
statewide and for each PA, exceed goals set forth in the October 29, 2012 Term Sheets.
1
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 7 of 274
Annual savings set at consistently high levels over the three years of the Plan, with level
costs, as shown below:
Total Electric Annual Savings
1,200,000
$0.447 $0.403 $0.401 $0.407
$0.381
1,000,000
$0.344
800,000
$0.500
$0.400
$0.300
600,000
$0.200
400,000
$0.100
200,000
-
$/Annual kWh
Annual MWh Savings
1,400,000
$2010 2011 2012 2013
(Actual) (Actual) (MTM)
Residential
Low-Income
2014
C&I
2015
Cost per kWh
Total Gas Annual Savings
$7.43
25,000,000
$5.56
$6.41
$7.15 $7.22
$5.58
$8.00
$7.00
$6.00
20,000,000
$5.00
15,000,000
$4.00
$3.00
10,000,000
$2.00
5,000,000
$/Annual Therm
Annual Therm Savings
30,000,000
$1.00
-
$2010 2011 2012 2013
(Actual) (Actual) (MTM)
Residential
Low-Income
C&I
2014
2015
Cost per annual therm
пѓ� To achieve these challenging savings levels in light of: (1) new codes and standards
requirements for more efficient equipment, and (2) evaluation results, the Program
Administrators will ramp up production and reach more customers, with more
equipment installed and services provided.
пѓ� These savings targets and costs factor in CHP project availability and EM&V studies
showing decreased net savings in certain programs (in particular on the gas side), and
challenges posed by increasing efficiency baselines (especially EISA lighting standards).
To maintain savings, PAs must consistently do more.
пѓ� Results to date demonstrate that the PAs have prudently expended customer funds and
have been able to deliver savings at historic levels below projected costs; this
commitment to cost-efficiency will continue in 2013-2015.
2
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 8 of 274
TERM SHEETS
пѓ� PAs, DOER, and the Attorney General have come to an overall agreement in principle on
core 2013-2015 items, including budgets, savings, and benefits and performance
incentives. These agreements reflect intensive discussions that concluded on October 29,
2012.
пѓ� The Plan is consistent with the Term Sheets and reflects the consensus positions.
пѓ� The full Council is expected to act in support of the Term Sheets on November 5, 2012.
NEW BREAKOUT INNOVATIONS FOR 2013-2015
пѓ� Efficient Neighborhoods+: The PAs are proposing this bold new initiative to serve
lower income and working-class communities that incorporates extensive public
feedback and targets economically challenged neighborhoods and will explore target
communities such as the Commonwealth’s “Gateway Cities” and Green Communities.
пѓ� The PAs will drive the lighting revolution they have led: new technologies, more
savings, better lighting quality, more satisfied customers.
пѓ� State-of-the-art new approaches target the healthcare sector, office space and
municipalities: multi-year MOUs, new technologies, Office of the Future efforts, a new
approach across the Commonwealth to serve and proactively engage with cities and
towns, including Green Communities, and an effort that is focused on wastewater and
drinking water treatment facilities in collaboration with DEP.
пѓ� Public education: a new commitment to schools, developing curricula and driving a
culture of sustainability based upon suggestions from stakeholders.
� Enhanced use of market segmentation studies and sector-focused “Go-to-Market”
approaches.
CONTINUATION OF AREAS OF EXCELLENCE
� A commitment to Massachusetts’ outstanding EM&V: continuation of the successful
EMC, ensuring confidence in results, learning from experience. Over $69 million
budgeted for EM&V activities in accordance with the Term Sheets.
пѓ� Sharing of best practices and adoption of new technologies: the C&IMC, RMC, LowIncome Best Practices Group, Statewide Marketing Committee, and MTAC; each group
integrated across gas and electric PAs – no state matches the effort and cooperation of the
Massachusetts Program Administrators.
пѓ� Cohesive and extensive marketing and outreach efforts including extensive community
engagement and creative new campaigns.
пѓ� Continued sensitivity to customer bill impacts and sustainability.
3
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 9 of 274
BENEFITS ACROSS THE BOARD
пѓ� Over $8.92 Billion in economic benefits for customers.
пѓ� Environmental benefits, as a legacy for future generations, comparable to taking
approximately 403,407 cars off the road or eliminating the output of a 470 MW power
plant for one year.
пѓ� Important job creation benefits- ongoing research is indicating that each million dollars
spent on residential weatherization supports 12 direct in-the-field full time jobs and,
according to the 2012 Massachusetts Clean Energy Industry Report, energy efficiency
has been adding jobs to the Commonwealth at a 10 percent growth rate since 2011.
пѓ� Robust BCRs of 3.69 (electric) and 1.81 (gas).
пѓ� Improved quality of life for our most vulnerable low-income customers as a result of the
historic partnership between LEAN and the PAs.
UPDATES SINCE JULY 2, 2012 AND SEPTEMBER 19, 2012 DRAFT PLANS
� All PAs have increased savings in response to the Council’s requests and are at or above
PA-specific and statewide levels set forth in the Term Sheets.
пѓ� Each PA has focused on increasing savings and reducing costs, with the understanding
the budgets, savings, and performance incentives are interlinked.
� The PAs, DOER, the Attorney General, and the Council’s Consultants have engaged in
good faith negotiations on goals and costs, sharing detailed analytics both statewide and
PA-specific and have eliminated previous gaps.
пѓ� Statewide electric increases savings by 102,108 MWh and decreases costs over $73.7
million notwithstanding the significantly increased savings from July values. The costs
savings are even higher, $118 million, if July costs are applied to the increased savings
levels presented today.
пѓ� Statewide gas increases savings approximately 8% in both lifetime and annual savings as
compared with the July 2, 2012 filing.
пѓ� Gas costs have decreased as compared to the September 19, 2012 draft, and are at levels
supported in the Term Sheet.
пѓ� Cost drivers and variances tables (electric and gas) indicate decreasing expenditures on
PP&A (proportionate), and that increased budget dollars are flowing to customers in the
form of incentives and technical assistance, as well as increased expenditures
(proportionate) for EM&V
пѓ� While some differences in BCRs remain at the initiative level, there has been much
increased convergence. When BCRs are analyzed at the portfolio level, particularly on
the gas side, they are notably in alignment:
2013 BCRs
GRAND TOTAL
CMA
1.95
NGRID
1.77
NSTAR UNITIL
1.78
1.72
4
NEG
1.85
BERKSHIRE
2.05
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 10 of 274
пѓ� PAs have reinforced commitment to deep savings and comprehensiveness.
пѓ� PAs have focused on streamlining the participation experience in all sectors and making
efforts more customer-focused:
пЃ¶ PAs are seeking to address unique needs by segments of customer base
пЃ¶ Emphasis has remained on gas/electric integration.
пѓ� Proposed savings targets are on favorable trajectory to support CECP objectives.
пѓ� Program design enhancements detailed below in response to Council and stakeholder
suggestions.
THANKS: MANY HANDS PULLING ON THE OARS
пѓ� The PAs have received constructive input from Councilors, government officials,
stakeholders, energy experts and consultants, and participants in the groundbreaking
Appreciative Inquiry Summit and Energy Expos. This Plan has benefited from extensive
input.
пѓ� The PAs appreciate their team: every PA contributes, every PA leads, and every PA
learns.
пѓ� The PAs are committed to continuous improvement.
improved over time.
5
Even the best efforts can be
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 11 of 274
I.
EXECUTIVE SUMMARY
A.
Introduction
The gas and electric distribution companies and municipal aggregator (“Program
Administrators” or “PAs”) 1 are pleased to submit this 2013-2015 three-year energy efficiency
plan (the “Plan”) in accordance with Green Communities Act (“GCA”). 2 The objective of the
Program Administrators is to set aggressive, sustainable goals for the next three years through a
sustained and integrated statewide energy efficiency effort that (1) captures all available costeffective energy efficiency, (2) maximizes net economic benefits, (3) achieves energy, capacity,
climate and environmental goals, and (4) considers both short-term customer bill impacts and
longer-term benefits expected from proposed efforts. The Plan is intended to be viewed as an
integrated and interrelated whole, whose various and interconnected parts will work together as a
package over the next three years to provide innovative energy efficiency services, deliver on
PAs’ savings goals, maintain the Commonwealth’s first-in-the-nation energy efficiency status
and advance the Commonwealth’s energy efficiency policy objectives and clean energy and
climate plan goals.
Based on the goals set forth in this Plan, the Program Administrators expect that the net
present economic value of the benefits to be achieved under the Plan is greater than $8.92 billion
statewide over the three years. The Plan marks the most aggressive integrated gas and electric
savings effort undertaken in the nation and keeps Massachusetts at the forefront of leadership in
energy efficiency. Importantly, today the Program Administrators are filing one, single
integrated gas and electric Plan, as opposed to two separate three-year Plans as was done with
the initial Plan for effect in 2010-2012. This achievement reflects the remarkable working
relationship among Program Administrators, which includes sharing of ideas and best practices
and is a critical component of the Program Administrators’ successful delivery of energy
efficiency to date.
B.
Core Goals for 2013-2015
In the 2013-2015 Plan, the Program Administrators seek to build on the lessons learned
from the initial Three-Year Plan, including both its successes and challenges, and are refining the
Plan to best achieve the Commonwealth’s energy efficiency goals. The 2010-2012 Three-Year
Plan laid the foundation for continuing growth in energy efficiency efforts in the
Commonwealth, and the PAs propose to continue to build on these efforts in 2013-2015. The
Program Administrators will pursue all available cost-effective energy efficiency, subject to
reasonable short-term customer bill impacts, as mandated by the Green Communities Act, and
will seek to maximize benefits to the Commonwealth and its citizens.
1
Bay State Gas Company d/b/a Columbia Gas of Massachusetts, The Berkshire Gas Company, Blackstone
Gas Company, Boston Gas Company and Colonial Gas Company each d/b/a National Grid, Cape Light
Compact, Fitchburg Gas & Electric Light Company d/b/a Unitil, Massachusetts Electric Company and
Nantucket Electric Company each d/b/a National Grid, New England Gas Company, NSTAR Electric
Company and NSTAR Gas Company, and Western Massachusetts Electric Company.
2
An Act Relative to Green Communities, Acts of 2008, chapter 169, section 11.
6
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 12 of 274
The 2013-2015 Plan is focused on both short-term and longer-term goals that include
creating greater awareness of available energy efficiency services, improving the customer
experience for program participants, focusing on education-based initiatives in schools as a way
to help to create a culture of sustainability in the state, training for trade allies in support of
infrastructure development, and continuing to ensure that efforts remain dynamic, incorporating
evolving measures and services and responding to findings from program evaluation efforts.
Proposed efforts are anticipated to result in historic levels of savings, while taking into account
the challenges of achieving these results at a time when incremental savings for many actions are
reduced due to improved codes and standards. For example, NSTAR Electric estimates that if
savings in the third year of this plan (2015) were calculated consistent with how savings are
calculated in 2012, the anticipated savings would be approximately 2.9% of its sales in 2015. In
addition, the Plan also takes into account the impact of low energy costs, particularly low natural
gas costs, which create longer payback periods for consumers considering energy efficiency
investments.
Another key goal of the 2013-2015 Plan is to address the Council Priorities set forth in
the Council’s Resolution of February 14, 2012 (see Section I.G of this Plan). The PAs are
setting aggressive but sustainable goals that will capture all available cost-effective energy
efficiency over the next three years. The PAs are also combining multiple core initiatives into
fewer programs in order to allow for fluidity of resources, to reduce customer confusion, and to
seek deeper savings in all sectors. Consistent with the GCA and their public service obligation,
the PAs will seek to improve the cost efficiency of program delivery and pursue available
funding and financing options to maximize benefits. The PAs are also committed to consistently
addressing market barriers, including accessibility and affordability, as well as any tenantlandlord or unique service territory barriers, through their programs, initiatives, community
engagement efforts, and hard-to-measure programs. Specifically, the PAs are currently
implementing an initiative to study possible solutions to pre-weatherization barriers, and will
apply these lessons learned to 2013-2015. For reporting purposes, PAs will continue to explore
data management and analytics that provide benefits to the PAs and multiple stakeholders;
active, continuing discussions on data matters are ongoing, as is discussed in more detail in
Section III.N.
The PAs have made significant progress integrating gas and electric energy efficiency
services and commit in this Plan to further progress in both the residential and non-residential
sectors. In addition, customer outreach efforts continue to rely on consistent messaging and
seamless delivery in all sectors.
An additional PA objective for the 2013-2015 Plan is to implement the Plan as one threeyear plan rather than three one-year plans where practicable, which will provide greater
flexibility and allow the PAs to build upon lessons learned and best practices developed
throughout the course of the Plan. This will also allow for a better, more efficient use of
resources for PAs, regulators, and other stakeholders. The PAs remain committed to
coordination and cooperation with each other and with other stakeholders in order to identify and
share best practices, including seeking out information on the customer experience for both
planning and implementation purposes.
7
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 13 of 274
C.
A Retrospective – Past and Current Achievements
In the proposed Plan, the PAs build on the detailed 2010-2012 three-year plan by
continuing elements that worked, discontinuing elements that did not, moving forward with the
lessons learned, and implementing new innovations and strategies to seek even greater levels of
success in 2013-2015. There is a solid foundation of programs from which to build, informed by
sharing best practices, a commitment to efforts that evolve dynamically in response to market
changes, evaluation findings, and the introduction of new measures and services within
programs. These leading efforts have been recognized both within the Commonwealth and
nationally, including the receipt of awards and honors, such as the following:
Year
2010
Award
US Environmental
Protection Agency
Reason
ENERGY STARВ® Homes
Leadership in Housing Award
2010
US Environmental
Protection Agency
2010
US Environmental
Protection Agency
2010
2010
National Energy
Education
Development Project
(“NEED”)
NEED
ENERGY STARВ® Award for
Sustained Excellence for
Energy Efficiency Program
Delivery
ENERGY STARВ® Award for
Sustained Excellence for
Energy Efficiency Program
Delivery
National and State Senior Level
School of the Year
2010
NEED
2010
NEED
2010
Publicity Club of New
England Bell Ringer
Awards
Platts 2010 Global
Energy Awards
2010
2011
Mayors Climate
Protection Center
Awarded to
Joint Management
Committee (“JMC”)
(New Homes working
group)
National Grid
Northeast Energy
Efficiency Partnerships
(“NEEP”) (with electric
PAs recognized)
Sandwich High School
and Cape Light Compact
(“CLC”)
National and State Elementary
Eastham Elementary
Level School of the Year
School and CLC
Finalist
State Middle School of the Year Cape Cod Lighthouse
Charter School and CLC
State Senior Level School
Nauset Regional High
Finalist
School and CLC
Publicity Club of New England National Grid
Bell Ringer Awards
Energy Efficiency Program of
the Year Energy Supplier,
Finalist for Home Energy
Reports Program
Honorable Mention - Best
Practices 2011 Climate Award
8
National Grid
City of New Bedford
(New Bedford
Community Retrofit
Program)
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 14 of 274
Year
2011
2011
2011
2011
Award
US Environmental
Protection Agency
Association of Energy
Services Professionals
American Council for
an Energy-Efficient
Economy
US Environmental
Protection Agency
Reason
ENERGY STARВ® for Homes
Leadership in Housing Award
Outstanding Achievement in
Marketing and Communications
Massachusetts ranked number
one in the nation for energy
efficiency
ENERGY STARВ® Award for
Excellence in ENERGY
STARВ® Promotion
ENERGY STARВ® Award for
Sustained Excellence for
Energy Efficiency Program
Delivery
Best Energy Efficiency/
Demand Response Project of
the Year, Home Energy Reports
Program
Best Business Ad
National and State Special
Project of the Year
2011
US Environmental
Protection Agency
2011
PowerGrid
International Award
2011
2011
ESource
NEED
2011
NEED
2011
NEED
2011
NEED
National Senior Level Rookie
School of the Year
State Elementary School of the
Year and National Finalist
State Senior Rookie Finalist
2011
NEED
State Senior School Finalist
2011
Interstate Renewable
Energy Council
MA Association of
Science Teachers
American Council for
an Energy-Efficient
Economy
US Environmental
Protection Agency
Renewable Energy Innovation
Award
Science Educator of the YearBarnstable County
Massachusetts ranked number
one in the nation for energy
efficiency
ENERGY STARВ® Award for
Sustained Excellence for
Energy Efficiency Program
Delivery
ENERGY STARВ® for Homes
Leadership in Housing Award
2011
2012
2012
2012
US Environmental
Protection Agency
9
Awarded to
JMC
Mass Save Statewide
Commonwealth of
Massachusetts
National Grid
NEEP (with electric PAs
recognized)
National Grid
Mass Save Statewide
Harwich Community
Learning Center and
CLC
Boston Latin and
NSTAR
Eastham Elementary
School and CLC
Cape Cod Academy and
CLC
Nauset Regional High
School and CLC
CLC Energy Education
Programs
CLC Education Staff
Commonwealth of
Massachusetts
Northeast Retail Products
Initiative
JMC
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 15 of 274
Year
2012
Award
US Environmental
Protection Agency
2012
AESP
2012
National Energy
Solutions Center
National Energy
Solutions Center
2012
Reason
ENERGY STARВ® Award for
Sustained Excellence in Energy
Efficiency Program Delivery
Outstanding Achievement in
Residential Program Design &
Implementation
Award for Partnership with
Smith College
Award for partnership with
Mary Immaculate Nursing and
Restorative Center
ENERGY STARВ® Award for
Excellence in ENERGY
STARВ® Promotion
2012 Planet Protector Award
2012
US Environmental
Protection Agency
2012
“e” inc.
2012
NEED
2012
NEED
2012
NEED
2012
NEED
State Senior Finalist
2012
NEED
State Junior School of the Year
2012
NEED
2012
NEED
2012
Tools of Change peer
selection panel
State and National Elementary
School of the Year
State Elementary Rookie of the
Year
Smart Home Energy
Monitoring Pilot Designated a
Landmark Case Study
D.
Senior Level Rookie of the
Year National and State
Senior Level Finalist - National
& State
National and State Special
Projects of the Year
Awarded to
JMC
NSTAR’s Community
Based Outreach Initiative
Columbia Gas of
Massachusetts
Columbia Gas of
Massachusetts
National Grid
NSTAR Electric Residential Education
Acton Boxborough High
School & NSTAR
Boston Latin School &
NSTAR
Harwich Community
Learning Center and
CLC
Sandwich High School
and CLC
Bourne Middle School
and CLC
Eastham Elementary
School and CLC
Forestdale School and
CLC
Cape Light Compact
The Future – Achievements to Come
In this section, the Program Administrators are pleased to provide statewide summaries
of certain key aspects of the targets for their three-year energy efficiency plan for 2013-2015. 3
3
Note that the PAs utilized the same single-page summary format adopted by the Energy Efficiency
Advisory Council (the “Council”) with respect to their initial 2010-2012 gas and electric plans.
10
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 16 of 274
The first summary table addresses statewide electric savings and budget targets, and the second
summary table addresses statewide gas savings and budget targets.
The Program Administrators have worked collaboratively together and with the Council,
the Council’s consultants (“Consultants”), and other multiple and diverse stakeholders, to
develop these statewide targets and their individual PA-specific proposals. The proposals reflect
feedback and suggestions on the Program Administrators’ short form 2013-2015 submission of
April 30, 2012 and detailed Plan filings of July 2, 2012 and September 19, 2012, as well as ideas
brought forward in the Program Administrators’ ground-breaking Appreciative Inquiry process,
suggestions presented by various stakeholders at Council meetings, and in informal discussions
with stakeholders. As detailed in Section I.D.3 below, this Plan also executes upon the October
29, 2012 Electric Term Sheet: 2013 – 2015 Plan (“Electric Term Sheet”) and Gas Term Sheet:
2013 – 2015 Plan (“Gas Term Sheet”) (together, the “Term Sheets”) that set forth key areas of
agreement in principle among the PAs, the Department of Energy Resources (“DOER”), and the
Office of the Attorney General (“Attorney General”) on core terms for 2013-2015 energy
efficiency efforts.
As a result of stakeholder input, today’s Plan calls for, among other things, a bold new
initiative, Efficient Neighborhoods+. This core initiative targets economically challenged
neighborhoods throughout the Commonwealth, and will explore target communities such as the
City of Boston and the Commonwealth’s “Gateway Cities” 4 and Green Communities. The Plan
also sets forth creative new approaches to working with municipalities, a new focus on the
healthcare sector, and plans to tailor available services to the unique needs of other key sectors
where significant savings are likely including but not limited to drinking water and wastewater
treatment facilities and grocery stores.
The Plan maintains and enhances the Program Administrators’ nationally recognized
commercial and industrial (“C&I”) and residential efforts, and the enormously successful and
pioneering partnership with the Commonwealth’s Low-Income Service Provider/Weatherization
Assistance Program (“WAP”) Network. The proposals to be implemented benefit all customer
sectors over the three-year period 2013-2015, resulting in long term economic and environmental
benefits for Massachusetts residents and businesses, and should result in the Commonwealth
continuing its nation-leading energy efficiency programming.
4
The following communities have been designated as Gateway Cities: Barnstable, Brockton, Chelsea,
Chicopee, Everett, Fall River, Fitchburg, Haverhill, Holyoke, Lawrence, Leominster, Lowell, Lynn,
Malden, Methuen, New Bedford, Pittsfield, Quincy, Revere, Salem, Springfield, Taunton, Westfield, and
Worcester.
11
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 17 of 274
1.
Statewide Electric Summary:
2013
2014
2015
Total
2013-2015
Statewide Council Savings Target as % of Retail
2.5%
2.55%
2.6%
2.55%
Energy Sales
PA Proposed Savings Goals as % of Retail
2.5%
2.55%
2.6%
2.55%
Energy Sales
Council Target Annual Energy Savings in GWh
1,194
1,235
1,273
3,702
PA Proposed Annual Energy Savings in GWh
1,195
1,236
1,275
3,706
Performance Incentive at Design ($ million)
$25.8
$26.7
$27.5
$80.0
Threshold to Begin Earning Incentives
75%
75%
80%
75%-80%
Performance Incentive Cap
125%
125%
125%
125%
$479.10
$499.37
$516.53
$1,495.0
Program Budget ($ million) per Term Sheet
$481.32
$495.66
$518.72
$1495.70
PA Proposed Program Budget ($ million)
$0.401
$0.404
$0.406
$0.4037
Cost Per Annual kWh Saved per Term Sheet
$0.403
$0.401
$0.407
$0.4036
PA Proposed Cost Per Annual kWh Saved
$0.0366
$0.0374
$0.0374
$0.0371
PA Proposed Cost Per Lifetime kWh
 Flexibility provided for PA savings goals to be lower or higher than the savings target, but with the
statewide savings targets (set forth in GWh above) remaining the same. Cape Light Compact and
Unitil have variances from the statewide targets because of the unique characteristics of their
service areas as has been historically recognized by the Council and found appropriate for 20132015 in the Term Sheet. National Grid, NSTAR, and Western Massachusetts Electric Company
are proposing savings goals in excess of the escalating 2.5 percent target.
 Incentive pool is allocated to individual PAs based on the dollar benefits and dollar net benefits
target each year.
 Incentive mechanism provides higher incentives for the higher savings targets. Performance
incentive threshold for National Grid and NSTAR/WMECo is based on the 2.50%, 2.55%, and
2.6% thresholds in applicable years where savings goals are in excess of these targets.
 Incentive pool of $80.0 million is the maximum pool at the target savings level for the three years.
 Performance Incentives three component approach is based upon 2011-2012 approach, with
limited performance metrics component.
 Program cost to achieve is materially less than 2012 MTM costs and earlier draft 2013-2015
filings.
 Program consolidation per Residential Management Committee and C&I Management Committee
recommendation.
 For cost-effectiveness, the PAs used the 2011 Avoided Energy Supply Cost and current NonEnergy Impacts studies, with updates on certain NEIs based upon best current information.
 PAs to perform defined follow-up study on 2011 Avoided Energy Supply Cost Study (e.g.,
confirming DRIPE) based upon Term Sheets.
 Targets and proposals may require adjustments in the event of new legislation, opt-out pilot
participation by largest customers, new municipal aggregators, material new EM&V results, or
any material regulatory changes.
12
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 18 of 274
2.
Statewide Gas Targets Summary:
2013
2014
2015
Total
2013-2015
Statewide Council Savings Target as % of
1.10%
1.12%
1.15%
1.12%
Retail Energy Sales
PA Proposed Savings Goals as % of Retail
1.07%
1.13%
1.14%
1.11%
Energy Sales per Term Sheet
Annual Energy Savings Goals (therms) per
23,000,000 24,250,000 24,750,000 72,000,000
Term Sheet
PA Proposed Annual Energy Savings (therms) 22,661,039 24,401,130 24,949,014 72,011,183
$5.1
$5.4
$5.5
$16.0
Performance Incentive at Design ($ million)
Threshold to Begin Earning Incentives
75%
75%
80%
75%-80%
Performance Incentive Cap
125%
125%
125%
125%
$169
$175
$181
$525
Program Budgets ($ million) per Term Sheet
$168
$175
$180
$523
PA Proposed Program Budgets ($ million)
$7.348
$7.216
$7.313
$7.292
Cost Per Annual Therm Saved per Term Sheet
$7.433
$7.154
$7.218
$7.264
PA Proposed Cost Per Annual Therm Saved
$0.554
$0.558
$0.560
$0.557
PA Proposed Cost Per Lifetime Therm
 Flexibility provided for PA savings goals to be lower or higher than the savings target, but with the
statewide savings targets (set forth in therms above) remaining the same. All gas PAs have
significantly increased savings goals from earlier draft Plan levels and savings goals for all PAs,
tailored to service area characteristics, are found appropriate for 2013-2015 in the Term Sheet.
Unitil (gas and electric), Berkshire and New England Gas will conduct studies of remaining
potential in 2014 for use in the next three-year plan per Term Sheet.
 Goals reflect savings reductions based upon most recent EM&V findings.
 Incentive pool is allocated to individual PAs based on the dollar benefits and dollar net benefits
target each year.
 Incentive mechanism provides higher incentives for the higher savings targets. Performance
incentive threshold for National Grid and NSTAR is based on the 1.10%, 1.12%, and 1.15%
savings targets, in applicable years when their savings goals are in excess of these savings targets.
 Incentive pool of $16.0 million is the maximum pool at the target savings level for the three years.
 Performance Incentives three component approach is based upon 2011-2012 approach, with
limited performance metrics component.
 Program cost to achieve assumes continued low gas costs in 2013-2015, requiring some increased
incentives to meet aggressive savings targets, as well as reduced savings levels based upon most
recent EM&V results.
 Program consolidation per Residential Management Committee and C&I Management Committee
recommendation.
 For cost-effectiveness, the PAs used the 2011 Avoided Energy Supply Cost and current NEIs
studies, with updates on certain NEIs based upon best current information.
 Targets and proposals may require adjustments in the event of new legislation, opt-out pilot
participation by largest customers, new municipal aggregators, material new EM&V results, or
any material regulatory changes.
13
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 19 of 274
3.
Term Sheets
On October 29, 2012, the Term Sheets were finalized after extensive and diligent
discussions and negotiations. The term sheets set forth the overall agreement in principle among
the PAs, the DOER, and the Attorney General with respect to savings, budgets, benefits and
performance incentives for 2013-2015. See Section IV, Appendix R and November 1, 2012
letter from Mark Sylvia, Chair of the Energy Efficiency Advisory Council (the “November 1
Letter”) to the Department of Public Utilities (“Department”), which letter is filed by each of the
PAs as a part of its individual Plan. As noted in the November 1 Letter, DOER anticipates a vote
on the Term Sheets at a Council meeting on November 5, 2012, stating:
At that Council meeting, we anticipate a vote on a Council Resolution to approve
the terms governing the aforementioned agreement in principle. Shortly
thereafter, a subsequent meeting of the Council will be convened to render a more
detailed assessment of the contents of the EEIPs, whose publication is currently in
production, and accordingly has not been reviewed by the Council in final form.
It is our desire, consistent with the spirit of M.G.L. c.25, В§ 21 (d)(l), to provide
our assessment of the final EEIPs by way of a second Council Resolution, giving
commentary on any unresolved issues that we might identify in the EEIPs
submitted to the Department by the PAs on November 2, 2012, reflecting the twoday extension granted by the Department in recognition of the storm.
In this Plan, the PAs have included each of the provisions of the Term Sheets and have
sought in good faith to clearly support each of the items in the Term Sheets. The following table
illustrates how the PAs have incorporated key quantitative elements of the Term Sheets into this
Plan. 5
Electric PA Total Annual Energy Savings Goals (MWh)
Gas PA Total Annual Energy Savings Goals (Therms)
Benefits ($, million) - Electric and Gas Combined
Benefits ($, million) - Electric
Benefits ($, million) - Gas
Budget ($, million) - Electric and Gas Combined
Budget ($, million) - Electric
Budget ($, million) - Gas
Cost per Annual kWh Saved - Electric
Cost per Annual Therm Saved - Gas
5
Term Sheet
Provision
3,702,844
72,000,000
$8,770
$7,500
$1,270
$2,020
$1,495
$525
$0.4037
$7.292
Three-Year
Plan Provision
3,705,368
72,011,183
$8,922
$7,638
$1,284
$2,018.8
$1,495.7
$523.1
$0.4036
$7.264
The Term Sheets provide that: “Final numbers may be slightly higher or lower than these values, but all
within a reasonable, non-material bandwidth.” Any variances noted above, in the PAs’ view, are within
this bandwidth, and indeed with respect to almost every single metric/goal under the Term Sheets, the PAs
have actually exceeded the rigorous standards adopted in the Term Sheets.
14
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 20 of 274
In sum, the PAs are proposing more overall savings at a lower overall cost and with more
benefits than in the very aggressive Term Sheets. Where limited individual items are outside the
levels in the Term Sheets, they are within the reasonable bandwidth contemplated in the Term
Sheets.
In addition to budgets, savings, and benefits, the PAs have also reflected the other,
qualitative provisions of the Term Sheets in this Plan, including agreements related to the Clean
Energy and Climate Plan, flexibility for PAs, performance incentives, support for the Mass Save
mark, and commitment to perform a new DRIPE study.
The PAs express their appreciation of the diligent efforts devoted to finalizing the Term
Sheets by DOER and the Attorney General, as well as the Council’s consultants.
E.
Significant Updates & Highlights
1.
Bold New Initiative Targeting Economically Challenged Neighborhoods
The Program Administrators are proposing a bold new initiative targeting economically
challenged neighborhoods in cities throughout Massachusetts, and will explore target
communities such as Boston and cities identified as “Gateway Cities” by the Commonwealth and
Green Communities. This new initiative, Efficient Neighborhoods+ is described in further detail
in Section III.F.6.b.i below. The Program Administrators have developed this initiative based on
feedback and suggestions at Council meetings, including the Council meeting of January 10,
2012, and at the Appreciative Inquiry Summit, as well as informal discussions with members of
the Council (“Councilors”) and stakeholders, especially those Councilors who have raised
particular concerns with respect to low to moderate income customers. The initiative, which will
be refined over a review period as described in Section III.F.6.b.i, is aimed at providing energy
efficiency services in neighborhoods that contain high portions of economically challenged
customers, including lower income and lower middle class families. The initiative calls for
neighborhood-focused outreach, including special incentive structures, and engagement with
community representatives and local government agencies. By utilizing a neighborhood
approach that is developed based upon the Commonwealth’s Gateway Cities program, the PAs
will be able to target economically-challenged customers that have been a core priority for the
Council and stakeholders. It is also expected that these targeted neighborhoods will include lowincome qualified/eligible consumers. Thus, the Program Administrators plan to include the
Low-income Energy Affordability Network (“LEAN”) in the initiative design and
implementation phases to ensure a fully integrated cross-sector approach. The Program
Administrators will also seek input from other interested parties as they finalize the design of this
new initiative.
2.
Continuing Focus on Segmentation
The PAs will continue to refine their go-to-market approach that is based on segmenting
their non-residential customer base by industry type, identifying common messaging, barriers,
opportunities, decision making processes and other unique attributes, thereby allowing for
greater penetration into the market. These efforts continue to be actively tested and refined
across the spectrum of C&I customers. For example:
15
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 21 of 274
•
As set forth in section III.F.6.d below, as part of their C&I effort, the Program
Administrators have a customized approach to the healthcare sector, which is one of the
core economic drivers in Massachusetts. The PAs have had a great deal of success in
tailoring efforts to this important sector, along with multi-year agreements focused on
both electric and gas energy efficiency opportunities with some of the largest hospitals in
the Commonwealth. Building on this success, the PAs will continue to focus on this
important sector in 2013-2015. Of special importance is the PAs’ new engagement with
the Fraunhofer Center for Sustainable Energy Systems CSE, located in Cambridge,
Massachusetts. Fraunhofer will be supporting the effort to identify and address
opportunities for efficient equipment specific to the healthcare industry. The expected
results from this effort include equipment selection criteria and operating opportunities,
as well as engagement with manufacturers to provide additional focus on energy in this
key sector.
•
While engaging with customers from the commercial real estate sector, the PAs have
found several factors affecting efficiency investments. These factors include some of the
unique characteristics of the tenant/landlord relationship, primarily through varying lease
structures as well as differences in owner operated or third party operated buildings. In
addition, the owner’s long or short term philosophy for the asset also impacts these
decisions. The PAs continue to engage with several large property managers and are
actively testing various structures to address some of these barriers. Results from these
efforts will be available by the second quarter of 2013 and will be used to further refine
the PAs’ go to market strategies for engaging with this important sector.
•
The municipal sector also has unique attributes affecting its decisions on efficiency
investments. Cities and towns are generally resource constrained, requiring financial
assistance to both identify energy efficiency opportunities and to deploy identified
measures and practices that lead to energy savings. In addition, the plan/specification
process for municipal decision making can be challenging to the design/build nature of
efficiency. The PAs address these challenges by engaging communities at the highest
levels and providing assistance on several fronts, including technical assistance and turnkey implementation services. There have been significant successes with large cities
leveraging the Memorandum of Understanding (“MOU”)/ Strategic Energy Management
Plan (“SEMP”) process. The PAs have also engaged a number of communities to
develop a streamlined approach more appropriate and scalable for smaller towns.
Specifically, National Grid and NSTAR will implement a dedicated track for municipal
customers within the C&I Retrofit Program in 2013 and will share experiences with other
PAs for review for potential broader implementation.
3.
Public Education
The PAs have been at the forefront of creating a “culture of sustainability” in
Massachusetts. The Program Administrators have hosted, after extensive planning, two major
forums: the Appreciative Inquiry Summit at Gillette Stadium of May 15-16, and the Energy
Expo at the Intercontinental Hotel on June 2, 2012. Over 600 stakeholders and efficiency
16
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 22 of 274
experts participated in these events. At these events, the PAs were able to obtain notable, highprofile speakers, including Governor Patrick, John Fernandez, Massachusetts Eye and Ear
Infirmary CEO and president, and two of the top 10 “Most Influential Bostonians” as recognized
in Boston Magazine: John Fish, chairman and CEO of Suffolk Construction and Anne M.
Finucane, Global Strategy and Marketing officer at Bank of America. All of these influential
speakers emphasized the importance of energy efficiency and attention to issues of sustainability,
and the PAs are grateful for their participation. Energy efficiency is closer to the forefront of the
public’s consciousness and as a result, it has become clear, based upon comments from multiple
stakeholders in events such as the Appreciative Inquiry Summit, that an enhanced public
education initiative regarding energy efficiency enjoys broad support. In today’s filing, in
Section III.H.3, the Program Administrators outline their approach to exploring and developing
state-of-the-art energy efficiency curricula and training, not only for school-aged children, but
also in community colleges, vocational schools, and other educational opportunities. Such a
commitment to public education is squarely consistent with G.L. c. 25, В§ 21(b)(2), which
endorses public education efforts.
4.
Enhanced Integration of Gas and Electric Energy Efficiency Services Plan
The Program Administrators continue to refine their program designs to reflect the
enhanced integration of gas and electric efforts. Regular communication and interaction with
each other allows the Program Administrators to share best practices and lessons learned, and the
ability to provide gas and electric information to customers in an integrated manner in order to
promote comprehensive installations. The PAs have developed effective strategies and made
significant progress in integrated program delivery during the initial three-year plan of 20102013. Based upon anecdotal information from Councilors and some of the findings in the
Synapse study presented to the Council on April 10, 2012, the Program Administrators are
continuing to analyze ways in which to streamline further the customer experience and make it
more seamless. The PAs are committed to seeking further synergies to provide customers with a
streamlined experience, where electric and gas opportunities are provided to customers
simultaneously. The filing of one integrated joint electric and gas statewide Plan for 2013-2015
reflects the commitment and success of the Program Administrators in embracing seamless
program delivery for customers. One specific area for particular focus of integrated efforts will
be wastewater facilities, which the Program Administrators are already targeting with the
assistance of the Department of Environmental Protection (“DEP”), which has identified several
potential facilities that can benefit from efficiency measures. The Program Administrators note
their appreciation of the active engagement of DEP and DOER on wastewater facilities efforts.
5.
Program Consolidation
In their 2012 MTM filings, the Program Administrators proposed to consolidate the LowIncome Single Family Retrofit and Low-Income Multi-Family Retrofit Programs into a single
Low-Income Retrofit Program, noting the expected benefits of increasing flexibility to meet
customer needs. 6 The Program Administrators plan to further consolidate efforts in both the
6
Throughout the 2013-2015 Plan, the residential low-income sector will remain a separate budget sector and
retain the consolidated program categories the Program Administrators proposed in their 2012 Mid-Term
Modification filings.
17
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 23 of 274
residential and C&I sectors. 7 Residential sector programs will be consolidated into two primary
categories: Whole House and Products. Similarly, the Program Administrators also plan to
consolidate the C&I sector programs into two primary categories: New Construction and
Retrofit. The primary purpose and benefit of this consolidation is greater implementation
flexibility to address shifts in market conditions and consumer demand and reduced customer
confusion. For purposes of transparency, and to satisfy the priority placed by the Council on
more discrete data, the Program Administrators will continue to track and report spending and
savings associated with each core initiative within each program, but overall program level
reporting will be done in the aggregate.
6.
Budget/Savings Goals: Comparison to 2010-2012
For electric Program Administrators, the proposed three-year annual savings for the
period 2013-2015 is more than 1.19 million megawatt hours (“MWh”) greater than the combined
2010-2012 levels. 8 As compared to 2010-2012, this Plan includes a budget increase of
approximately $498 million in order to increase savings and reach the Commonwealth’s energy
efficiency goals. Electric budgets in 2013 include an $8.7 million decrease compared to 2012.
These changes are expected to lead to an additional $2.74 billion in projected benefits in 20132015 as compared to 2010-2012.
For gas Program Administrators, the proposed three-year annual savings for the period
2013-2015 is almost 22 million therms greater than the combined 2010-2012 levels. The 2013
planned savings relates closely to 2012 MTM savings levels to account for the setting of
challenging but achievable goals. As compared to 2010-2012, this Plan will include a budget
increase of nearly $231 million in order to increase savings and reach the Commonwealth’s
energy efficiency goals. Gas budgets in 2013 include a $36.8 million increase over 2012. These
changes equal an additional $388 million in projected benefits in 2013-2015 as compared to
2010-2012.
The total projected additional benefits in this 2013-2015 Plan are over $3.1 billion
greater than the benefits in 2010-2012. The Program Administrators sought to set goals that seek
all available cost-effective energy efficiency. Therefore, the goals are aggressive and
challenging, but also sustainable and cognizant of bill impacts, all in accordance with the
Council’s priorities.
7.
Innovation and Best Practices
In 2013-2015, the Program Administrators are committed to seeking even greater levels
of innovation, and new mechanisms with which to serve customers and promote deeper energy
efficiency savings. The Program Administrators seek to implement best practices at all times,
7
Pilot programs will retain individual budget line item status and specific names throughout the 2013-2015
Plan.
8
The figures in this section are based upon statewide “rolled-up” Program Administrator proposals for 20132015, as set forth in the Excel spreadsheets included with this Plan. 2010-2012 levels are equal to 2010
Energy Efficiency Annual Report values, 2011 Energy Efficiency Annual Report Values, and 2012 MidTerm Modification values.
18
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 24 of 274
and the list of awards noted in Section I.C above is testament to their success. The Program
Administrators strongly support continuing education programs for their staff, and members of
the Massachusetts Program Administrator team are frequent speakers at national and regional
energy efficiency events. The PAs will continue active participation in the Massachusetts
Technical Assessment Committee (“MTAC”), which is a forum created, organized, and
implemented by the Program Administrators in order to systematically and, at a statewide level,
review and discuss new technologies and innovations in the field of energy efficiency.
Technologies and innovations that pass MTAC screening are eligible for implementation on a
common basis throughout the Commonwealth. As described in more detail in Section III.F.4
below, the MTAC is an outstanding example of the approaches employed by the Program
Administrators to foster innovation, embrace new technologies and provide consistency in
program offerings across Program Administrators and service areas. The PAs coordinate to
ensure that any innovative strategies spearheaded by one PA are shared with others, including
the level of success of such ventures. The PAs also learn from various assessments, including
the Point 380 study, and will take into account the information gleaned from participants at the
Appreciative Inquiry held in May 2012, and any reports, consolidated comments and ideas
generated at the Appreciative Inquiry Summit. Other customer feedback, including daily
interactions with customers and public comments at Council meetings, contractor best practices
meetings facilitated by the PAs, feedback at training sessions, and other direct customer
feedback are all taken into account by the PAs when reviewing innovating strategies and
determining best practices. The Program Administrators will continue to collaboratively look for
innovative ways to secure all available cost-effective energy efficiency in a manner that is
sustainable and takes bill impacts into account.
To achieve the GCA’s mandate for a sustained and integrated statewide energy efficiency
effort, the Program Administrators will continue to engage in the unprecedented levels of
integration, coordination and cooperation that have been the hallmark of the initial three-year
plan, including working together on all levels of programming, implementation, and regulation.
The Program Administrators currently work together in formal groups, in regularly scheduled
and recurring meetings, and through ad hoc discussions. Examples of PA groups organized to
plan together and share experiences and ideas include: the Residential Management Committee,
the C&I Management Committee, the Evaluation Management Committee, Low-Income Best
Practices (convened by LEAN about ten years ago in order to coordinate practices across all PAs
and agencies, as well as to review new measures and innovations), and the Statewide Marketing
Committee, all of which meet regularly with representatives from all PAs, in person, and for
extended time periods, and cover all elements of planning, implementation, and evaluation,
including discussions related to best practices for reaching goals. In order to support innovation
and new technologies, the PAs all participate in the MTAC where they determine best practices
with respect to new technologies collaboratively. The PAs also participate in various topical
groups related to different programs, initiatives, and technologies.
The PAs also prepare materials for Council meetings jointly, including programming and
implementation presentations, data dashboards, and quarterly reports. Many regulatory
requirements are also met by the Program Administrators, who coordinate regulatory filings
including, without limitation, three-year plan filings and related draft submissions, annual
reports, mid-term modifications, comments and presentations related to investigations by the
19
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 25 of 274
Department, and RCS compliance filings. Efforts such as energy efficiency bill impact model
creation, preparation and quality control of PA-specific and statewide “rolled-up” D.P.U. 08-50
tables, and formation of the EM&V plan have been accomplished through a group effort of the
Program Administrators. A common statewide website (MassSave.com) devoted to energy
efficiency, coordinated training sessions, marketing materials, and presentations to interested
stakeholders, and special events, including the Appreciative Inquiry Summit, are other examples
of work that has been accomplished through coordination across all Program Administrators,
with many people working together to share ideas, develop best practices, coordinate messaging,
and accomplish common goals. The Program Administrators meet in-person monthly, and
participate in frequent discussions and subject matter group meetings. The PAs provide
appropriate flexibility for individual PAs to try a unique initiative, with the understanding that
any results are shared and that successful initiatives and strategies can be adopted by other PAs.
The Program Administrators discuss all aspects of the three-year plan and energy
efficiency programming on frequent topical group calls, as well as on one-to-one calls and
emails, in which each PA regularly reaches out to others to share and analyze planning and
implementation successes and challenges, and benefit from shared knowledge and PA expertise.
8.
Reducing Administrative Burdens/Streamlining Processes
Council meetings have been an important tool in planning for and implementing the
initial three-year plan. As the second Three-Year Plan begins, the Program Administrators will
have (1) three years of GCA-related energy efficiency experience with more mature programs,
which will inform future efforts to achieve energy efficiency cost effectively; (2) a better
understanding of the concerns and interests of the Councilors and an effective means of
continuing dialogue with them (through Council resolutions and other Council documents,
Council Executive Committee meetings and individual communications as well as Consultant
communications); (3) an established means of reporting data to the Council (through monthly,
quarterly and annual reports). Given the success and experience with this construct, the Program
Administrators will seek ways to streamline processes in 2013-2015, including ways to spend
more time with customers seeking savings. The PAs appreciate and recognize the work and time
invested by Councilors in preparing for Council meetings to ensure the mandates of the GCA are
being achieved. The Program Administrators devote time and attention to being as well prepared
as possible for each meeting, and respond to Councilors’ concerns during and after Council
meetings. The Program Administrators continue to support the role of the Council established in
the Green Communities Act and recognize that their energy efficiency programs have benefitted
from the many excellent suggestions of Councilors. The PAs will seek Councilor input on ways
to streamline processes and reduce meetings, while maintaining transparency and providing the
optimal amount of information to the Councilors. The Program Administrators are seeking to
leverage collective experience, identify possible efficiencies and optimize all stakeholders’ time
given the experience gained through the initial three-year plan. The Program Administrators
believe that the ongoing proceedings in the Department’s investigation in D.P.U. 11-120 will
also serve as a useful forum for exploring improved efficiencies.
20
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 26 of 274
9.
Incorporating RCS in Three-Year Plan
In accordance with Section 32 of An Act Relative to Competitively Priced Electricity in
the Commonwealth, Chapter 209 of the Acts of 2012 (“Energy Act of 2012”), the Program
Administrators included their proposed operating budgets for the Residential Conservation
Services (“RCS”) program in the Plan to meet the requirements of subsection (b) of Section 7 of
chapter 465 of the Acts of 1980. The RCS budgets have been combined with the Home Energy
Services core initiative in the Whole House program. Further, the PAs propose that the
Department allow recovery of RCS funds through each PA’s respective energy efficiency
surcharge, in accordance with the Energy Act of 2012. The gas Program Administrators will not
only incorporate RCS into the energy efficiency surcharge but will also change their tariffs to
cancel the separate gas RCS surcharge. Additionally, the Program Administrators propose that
this Three-Year Plan shall be the Coalition Action Plan for 2013-2015, as described in 225
C.M.R. 4.00 et seq.
10.
Engaging Third Party Stakeholders
The breadth of stakeholders with whom the PAs interact on a regular basis spans the entire
supply chain, including manufacturers, equipment distributors, contractors and service providers,
trade associations, policy makers, community advocates, civic leaders, and customers. Each of
these groups, individually and collectively, has an interest in, and is affected by, the energy
efficiency plans designed and implemented by the PAs. The legislature recognized this when it
created the Council, the formal entity responsible for stakeholder input.
The PAs recognize that other informal interactions also can benefit program development and
delivery, and have therefore established several venues to foster this interaction, including:
1. Annual Open House meetings for trade allies/vendors during which PAs present
program changes and updates from the prior year, and trade allies have an opportunity to
network with each other and PA staff and ask questions regarding the programs.
2. The Unsolicited Proposal Process by which vendors and trade allies wishing to do work
for the statewide committees/PAs can submit a formal proposal to the C&IMC.
3. Informal PA Speakers’ Bureau for Trade Association and Related Meetings in
which PAs respond to invitations from Industry and Trade Associations seeking
knowledgeable speakers to explain how programs work and provide case study examples
pertinent to their industry. Examples have included the Massachusetts Restaurant
Association and the Mass Lodging Association. Such meetings give attendees the chance
to ask questions of PAs, learn about industry-specific best practices, and establish contact
for future projects.
4. MTAC Committee which discusses and screens prospective new C&I technologies. This
committee was established in an effort to systematize the review of new energy efficient
technology proposals. Having a protocol and set process has not only streamlined the
workload of reviewing such proposals, but has also resulted in much greater flow of new
efficiency measures into the market.
21
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 27 of 274
5. Ad hoc discussions with Individual PAs in which stakeholder groups routinely contact
C&IMC members and other PAs, engaging them in one-off conversations regarding
program logistics and possible improvements and opportunities for collaboration.
6. Provision of Collateral Materials for Customer Events where individual PAs routinely
offer stakeholders significant volumes of program collateral for distribution at local
community and trade association meetings.
7. Customer Feedback from which the PAs benefit from long term, close relationships
with their customers, allowing for continual feedback and refinement. This is one of the
most vital areas of benefit to the programs and process.
During the preparing of this Plan, at least one C&I stakeholder group has requested the
additional option of meeting with the C&IMC directly, outside the channels listed above, to
provide input to the Plan. The C&IMC recognizes stakeholders such as this would like a more
formalized process for engaging with the PAs, however, the PAs feel strongly that the C&IMC is
not the appropriate venue. Instead, the C&IMC will take the lead to review best current
structures as previously described, as well as best practices in other states, with the intent of
creating a common process and guidelines to ensure consistent and effective responses from the
PAs as a collective. The details of this concept will be developed during Q4 2012 with expected
implementation in Q1 2013.
11.
Updates Since July 2, 2012 and September 19, 2012 Draft Plans
Following the submission of the July 2, 2012 and September 19, 2012 drafts of this Plan,
the Program Administrators have made significant updates based on stakeholder input and
additional PA review culminating in the Term Sheets. Each PA has reviewed its budget and
savings goals, and has increased savings over the three years of the Plan. For electric PAs,
budgets have reduced by approximately $118 million based upon the increased savings goals and
decreased costs proposed in this Plan when compared on a proportionate basis with the July 2,
2012 draft. This demonstrates the PAs’ careful consideration of, and responsiveness to, the
Council’s resolution of July 23, 2012 and continuing discussions with DOER, the Attorney
General, the Council’s consultants and other stakeholders. While working to increase savings,
the PAs have continued to be mindful of commensurate budget increases and bill impacts and
note the budgets, and savings interlink with performance incentives. The PAs have retained their
commitment to going deeper, and to providing comprehensive energy efficiency services. In
their efforts to go deeper, the PAs have sought to utilize segmentation in order to address the
unique needs of specific customer types, including those within the healthcare and property
management industries, as well as municipalities. In addition, the PAs have also emphasized gas
and electric integration, which provides a seamless experience for customers and an environment
promoting deeper energy efficiency measures.
Within the residential and low-income sectors, the PAs have focused on hard-to-reach
and hard-to-serve markets, particularly in developing the Efficient Neighborhoods+ initiative.
PAs have also been investigating tenant/landlord split incentives barriers, and assessing preweatherization incentives, as informed by 2012 evaluation findings. Other areas of recent focus
include assessing packaging incentives into the Home Energy Services core initiative,
22
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 28 of 274
developing an integrated HVAC / Heating equipment early retirement incentive by Q2 2013, and
providing enhanced incentives for Top Ten appliances. The PAs have also been updating efforts
for condominiums, including expanded availability of the HEAT loan.
In the C&I sector, PAs have been developing segmentation efforts, as described above,
and preparing targeted outreach to assist municipalities, including promoting Green
Communities. Working with DEP, the PAs are emphasizing their commitment to build on
success and implement more energy efficiency at the 120 municipal/district wastewater
treatment plants and 250 municipal/district drinking water treatment plants in the
Commonwealth.
See Section I.G.5 below for a matrix of actions taken in response to the Council’s
resolution of July 23, 2012, which demonstrates the PAs’ diligence in considering Council
recommendations.
F.
Overview of the Key Aspects of the Plan
1.
Savings and Core Benefits
The Program Administrators are proposing to obtain all available cost-effective energy
efficiency through an aggressive and sustainable level of savings for their energy efficiency
activities. The PAs’ savings goals are consistent with the Department’s orders and the Council’s
priorities, both of which emphasize setting challenging goals that take into account bill impacts
and sustainability of efforts over an extended period, and the Term Sheets. Based upon the
statewide targets representing the aggregation of each Program Administrator’s proposals for
2013-2015 (set forth in the tables provided with this Plan), the 2013-2015 Plan calls for electric
savings on an overall statewide basis of 3,705,368 annual MWh over the three-year period and
40,271,670 lifetime MWh savings. This Plan also calls for gas savings on an overall statewide
basis of 72,011,183 annual therms over the three-year period and 938,314,079 lifetime therm
savings. As a direct result of these savings, GHG emissions will be reduced by approximately
25,602,440 short tons over the life of those savings. This achievement, over the three years of
the plan, is comparable to the environmental benefits achieved of taking approximately 403,407
cars off the road or eliminating the output of a 470 MW power plant for one year.
Please see the following tables for a graphical comparison of annual savings from 2010
through 2015.
23
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 29 of 274
Total Electric Annual Savings
Annual MWh Savings
1,400,000
1,200,000
1,000,000
800,000
600,000
400,000
200,000
2010
(Actual)
2011
(Actual)
Residential
2012
(MTM)
Low-Income
2013
2014
2015
2014
2015
C&I
Total Gas Annual Savings
Annual Therm Savings
30,000,000
25,000,000
20,000,000
15,000,000
10,000,000
5,000,000
2010
(Actual)
2011
(Actual)
Residential
2012
(MTM)
2013
Low-Income
C&I
Please see the following tables for a graphical comparison of lifetime savings from 2010
through 2015.
24
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 30 of 274
Lifetime MWh
Total Electric Lifetime Savings
16,000,000
14,000,000
12,000,000
10,000,000
8,000,000
6,000,000
4,000,000
2,000,000
2010
(Actual)
2011
(Actual)
2012
(MTM)
Residential
Low-Income
2013
2014
2015
2014
2015
C&I
Total Gas Lifetime Savings
350,000,000
Lifetime Therms
300,000,000
250,000,000
200,000,000
150,000,000
100,000,000
50,000,000
2010
(Actual)
2011
(Actual)
Residential
2012
(MTM)
Low-Income
2013
C&I
The Program Administrators developed these goals based on their review of the
Council’s priorities, including sustainability, cost drivers and bill impacts, as well as the
mandates of the Green Communities Act, and in their discussions culminating in the Term
Sheets. Following the adoption of the “Sense of the Council,” prepared by the Council on June
12, 2012 and the Department’s resolution of July 23, 2012, as well as in response to additional
stakeholder comments and continued discussions, the PAs re-assessed their savings goals and the
manner in which they were determined, and established the figures set forth herein. In
formulating these goals, the PAs reviewed the types of projects, customers already served, those
markets that have potential to be served as informed by the PAs’ market assessment, historical
performance (taking into account any outliers), EM&V results, preliminary results, and bill
impacts. These savings goals are designed to achieve all available cost-effective energy
efficiency with due consideration of bill impacts. As set forth in Appendix D, based upon the
PAs’ research to date, the level of savings set forth herein exceeds the saving goals of any other
25
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 31 of 274
state on a proportionate basis. Section III.D of this Plan and Appendix C provide more detail on
savings and benefits of the Plan, including cost-drivers and unique drivers of savings goals in
specific territories.
2.
Program Budgets
The Program Administrators’ proposed energy efficiency budgets for the period 20132015 are provided in this Plan at the program level, and reflect the cost of achieving all available
cost-effective energy efficiency and the aggressive stretch savings goals detailed above. These
budgets allow for continued progress on identified Council priorities, all while remaining
mindful of bill impacts (highlighted in Section III.E of the Plan). 9 The proposed budgets reflect
economies realized through prior efforts in 2010-2012. As graphically illustrated below, based
upon “rolled-up” Program Administrator proposals for 2013-2015, the Plan calls for cumulative
electric expenditures on an overall statewide basis of $1,495,698,331 over the three-year period,
and cumulative gas expenditures on an overall statewide basis of $523,085,799 over the threeyear period. The overall statewide electric and gas budgets proposed in this Plan are below the
levels specified in the Term Sheets. While the planned expenditures on energy efficiency under
the Plan are significant, the net present economic value of the benefits to be achieved under the
Plan greatly outweighs expected costs. The magnitude of these expected benefits, with a
statewide electric and gas value of $8,921,966,158, demonstrates the exceptional value of the
increased energy efficiency expenditures called for in the Plan. Please see the graphical
comparison of the 2010-2015 budgets and benefits below.
9
The PAs have included $500,000 of funding for a statewide database in each annual budget for the next
three years. For additional details, see Section III.N.
26
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 32 of 274
Total Electric PA Budgets
$600,000,000
$500,000,000
$400,000,000
$300,000,000
$200,000,000
$100,000,000
$2010
Residential
2011
2012
Low-Income
2013
C&I
2014
2015
Actual
Total Gas PA Budgets
$200,000,000
$150,000,000
$100,000,000
$50,000,000
$0
2010
(Actual)
Residential
2011
(Actual)
2012
(MTM)
Low-Income
27
2013
C&I
2014
Actual
2015
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 33 of 274
$3,000
$0.22
$2,500
$0.21
$2,000
$0.20
$1,500
$0.19
$1,000
$0.18
$500
$0.17
$0
$0.16
2010
2011
2012
(Actual) (Actual) (MTM)
Residential
2013
Low-Income
2014
C&I
2015
Cost per $ of Lifetime Benefits
Benefits (In Millions of $)
Total Electric Benefits
Cost per Benefit
$500
$0.45
$0.40
$0.35
$0.30
$0.25
$0.20
$0.15
$0.10
$0.05
$-
$400
$300
$200
$100
$2010
2011
2012
(Actual) ( Actual) (MTM)
Residential
2013
Low-Income
2014
C&I
2015
Cost per $ of Lifetime Benefits
Benefits (In Millions of $)
Total Gas Benefits
Cost per Benefit
The Program Administrators determined the costs and benefits of the energy efficiency
plan for 2013-2015 following an extensive review of Plan objectives, cost drivers, as well as
savings goals and the cost to achieve savings (including deeper savings), the costs of new and
innovative strategies, methods of cost reduction and cost efficiency, historical data, and the
discussions culminating in the Term Sheets. Proposed budgets also take into account new
initiatives and other efforts that have been included in the Plan in response to stakeholder input
and reflect over $69.2 million in statewide EM&V expenditures as called for in the Term Sheets.
Section III.D of this Plan and Appendix C provide more detail on budgets and benefits of
the Plan, including cost drivers.
28
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 34 of 274
3.
Cost Effectiveness
Consistent with the statutory mandate that the Plans “provide for the acquisition of all
available energy efficiency and demand reduction resources that are cost-effective or less
expensive than supply” (G.L. c. 25, § 21(b)(1)), the Program Administrators have conducted
cost-effectiveness screening associated with the energy efficiency programs and services they
plan to administer in 2013-2015 using the Total Resource Cost (“TRC”) test, consistent with
Department’s directive in Energy Efficiency Guidelines, D.P.U. 08-50-A at 14 (2009) and as
reaffirmed by the Department. Electric Order at 48; Gas Order at 47.
In addition to individual, PA-specific cost-effectiveness screening, the Program
Administrators have undertaken a statewide-level screening of the cost-effectiveness of the
implementation of the 2013-2015 Plan using the Department’s TRC test at the sector level. The
results of this testing indicate that, at a statewide level, the proposed Plan is projected to be costeffective.
The PAs note that the Department is considering changes to the avoided costs that have
been used in the current analysis of cost-effectiveness. If the Department directs the PAs to
make changes to these avoided costs, then proposed efforts may need to be re-evaluated for costeffectiveness.
Section III.A.3 of this Plan provides more detail on cost-effectiveness for 2013-2015.
4.
Progress Toward Green Communities Act Requirements and Goals
The PAs are committed to meeting in the 2013-2015 Plan all of the requirements and
achieving the goals set forth in the Green Communities Act, including the attainment of all
available cost-effective energy efficiency, and the mandate that electric and natural gas resource
needs shall first be met through all available energy efficiency and demand reduction resources
that are cost effective or less expensive than supply. G.L. c. 25, В§ 21(b)(1). In determining the
level of savings to achieve in order to satisfy these mandates and to provide the optimal value for
their customers and the Commonwealth, the Program Administrators took into account the
considerations set out in Department Orders (including the need to consider bill impacts), various
assessments and other evaluation studies. As noted in Section III.B.1.h below, the PAs also
reassessed all savings goals originally filed on April 30, 2012, consistent with the Council’s
request at its June 12, 2012 meeting. The PAs again assessed savings following the Council’s
July 23, 2012 resolution and after the September 19, 2012 draft submission, and have increased
savings goals even further, to levels above those set forth in the Term Sheets, and that are
unmatched for any comprehensive, integrated, statewide effort anywhere in the United States. In
this Plan, the PAs also discuss certain key factors, challenges and market barriers that have
factored into their assessment of the achievable level of energy efficiency set forth in the Plan.
The PAs also seek to meet requirements and goals related to coordination and integration of
efforts, low-income funding, minimizing administrative costs, competitive procurement
processes, and demand response.
29
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 35 of 274
In order to achieve the nation-leading savings targets proposed in this Plan, in light of
more rigorous codes and standards and EM&V results, the PAs are proposing to deliver more
products and services to customers over the next three years.
5.
Programs
The Plan sets forth general program descriptions as well as detailed strategies for
coordinated program implementation in the residential, low-income, and C&I sectors. The
program descriptions represent the results of collaboration and cooperation among the Program
Administrators, Council members, Consultants, and other interested parties. The program
designs reflect comprehensive proven strategies that provide for: (1) greater consistency in
offerings throughout the Commonwealth; (2) an enhanced customer experience, including
seamless delivery strategies that integrate gas and electric efforts; (3) an expanded, diverse, and
well-trained workforce; and (4) the delivery of new state-of-the-art technologies and services. In
addition, the PAs have incorporated numerous new and innovative strategies into planned efforts
in response to stakeholder input, including input following the submission of draft versions of
this Plan.
Section III.F of this Plan provides more detail on statewide electric and gas programs for
2013-2015.
6.
Evaluation, Monitoring and Verification
The proposed EM&V framework in this 2013-2015 Plan is designed to build on the
extensive EM&V achievements accomplished in 2010-2012, and reflects both the core principles
of the Council Resolution on Evaluation, Measurement, and Verification approved on
September 8, 2009 (“EM&V Resolution”) and key lessons learned over the last three years. For
the 2013-2015 Plan, the Program Administrators, after discussion with the Council’s
independent expert EM&V consultant, are proposing several enhancements to the current
EM&V framework, including the reduction of research areas from six to three and the
continuation of the Evaluation Management Committee (“EMC”) that was created in 2012.
These enhancements are intended to improve the EM&V framework based upon actual
experience in order to make evaluation efforts more streamlined and transparent, with the goal of
improving the precision and usefulness of the studies. The EMC provides a forum for statewide
evaluation issues, and provides guidance, planning and direction to each of the evaluation
research areas. As tellingly demonstrated during the EM&V webinar of June 25, 2012, the
EM&V framework and EMC are high functioning and marked by excellence and commitment to
nation-leading EM&V practices that ensure confidence in energy efficiency efforts. The threeyear combined gas and electric EM&V budget is nearly $70 million, in accordance with the
Term Sheets.
Section III.I of this Plan provides more detail on the enhancements to the current
evaluation framework that are being proposed.
7.
Cost Recovery and Performance Incentives
30
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 36 of 274
Cost recovery, including the recovery of lost base revenues (“LBR”) for those PAs
without a Department-approved revenue decoupling mechanism, as well as the ability to recover
performance incentives 10, are critical elements of the Plan. The Plan sets forth proposals on cost
recovery that seek to utilize existing recovery mechanisms that have worked over time and that
are well understood by most customers. 11 The Plan seeks to ensure that, prior to the collection of
funds from customers, the Program Administrators have fully accessed other potential available
sources of funding, such as funds available from the Regional Greenhouse Gas Initiative
(“RGGI”), the Forward Capacity Market (“FCM”) (which are available to electric PAs), and
other sources as available.
The Plan allows the Program Administrators the opportunity to recover their costs and be
made economically whole for aggressively pursuing sales-reducing energy efficiency efforts, as
well as to earn a modest return associated with these efforts based upon their actual performance
compared to approved goals. In this regard, patterned on the approach reviewed and approved
by the Department in the Orders for the 2010-2012 Plan, with adjustments consistent with the
Term Sheets, the Program Administrators have set savings targets that provide for an incentive
pool of $80.0 million for electric PAs, and $16.0 million for gas PAs, for a total three-year
electric and gas incentive pool of $96.0 million statewide. The Program Administrators will
substantially maintain the performance incentive models applicable to their initial three-year
plans as a basis for the 2013-2015 performance incentive model and allocations, with a limited
number of performance metrics and related lower allocation value. The model maintains the
Savings Mechanism, the Value Mechanism, and Performance Metrics with uniform payout rates
for all electric PAs (excluding Cape Light Compact), and for all gas PAs, in the Savings and
Value Mechanisms, all consistent with the Term Sheets. Overall, the performance incentive
mechanism currently in place has functioned well and has been retained for 2013-2015.
Sections III.K and III.L of this Plan provide more detail on performance incentives and
cost recovery.
8.
Mid-Term Modifications
In D.P.U. 08-50-A and the D.P.U. 08-50-B Guidelines, the Department directed the
Program Administrators to seek Department approval for certain specified Mid-Term
Modifications, including adding or terminating a program, and changes in a program budget,
savings goals, or performance incentives of greater than 20 percent. D.P.U. 08-50-A at 64;
D.P.U. 08-50-B Guidelines at В§ 3.8.2.
Subsequent to D.P.U. 08-50-A and B, the Department provided further guidance
regarding the need for Department approval of proposed mid-term program modifications.
Specifically, in Cape Light Compact, D.P.U. 10-106 (2011), the Department clarified that
10
11
As a public entity and municipal aggregator, the Cape Light Compact does not participate in performance
incentives.
The PAs will seek approval to recover Plan related costs from the Department of Public Utilities as a part
of Plan approval. Specific cost-recovery details will be the subject of separate proceedings. The
requirements for those cost-recovery proceedings may be affected by Department decisions anticipated in
DPU 11-120.
31
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 37 of 274
Program Administrators are required to seek Department approval only for a program budget
modification that is 20 percent greater than the program’s three-year budget. Subject to the
outcome in D.P.U. 11-120, Phase II, the Program Administrators propose to apply the
D.P.U. 08-50-B Guidelines, as clarified by the Department in D.P.U. 10-106, supra, to program
modifications that lead to savings adjustments during the three years of the Plan. This will allow
Program Administrators continued flexibility to make adjustments to programs that are necessary
to promote innovation and efficiency without unduly burdening the administrative process for
the Department as well as the PAs and other stakeholders.
As discussed in Sections II.G and III.O, the Department issued an order on May 25, 2012,
opening an investigation into the mid-term modifications process in order to potentially simplify
the process based upon lessons learned over the last three years. The Department called for
comments on or before July 12, 2012, on its straw proposal streamlining the MTM process; The
Department subsequently issued on September 21, 2012 updated revised Energy Efficiency
Guidelines which are currently the subject of ongoing comment and review. The results of this
ongoing process may result in Program Administrators adjusting their approach to mid-term
modifications for 2013-2015. The Program Administrators appreciate the Department’s
development of a straw proposal and the Revised Guidelines and its concerns discussed in the
accompanying order, as well as the Department’s efforts for the technical conferences convened
and facilitated by the Department on June 19, 2012 and August 16, 2012.
Section III.M of this Plan provides more detail on the mid-term modifications process
currently anticipated for 2013-2015.
9.
Economic Development and Job Growth
An important element of the Plan is the economic impact of energy efficiency on the
Commonwealth and its citizens, including job creation and retention stemming from energy
efficiency programs. One way that energy efficiency affects consumers and businesses is by
reducing energy costs, thereby allowing the money saved to be spent elsewhere, thus stimulating
the economy. Additionally, energy efficiency programs create a wide variety of jobs, many of
them tied to local communities. According to the 2012 Massachusetts Clean Energy Industry
Report, energy efficiency has been adding jobs to the Commonwealth at a 10% growth rate since
2011. To quantify the job creation impacts of its energy efficiency programs, the Program
Administrators engaged the New England Clean Energy Foundation (“NECEF”) to update
NECEF’s analysis of workforce requirements and impacts associated with Program
Administrator energy efficiency programs. The resulting report entitled “An Estimate of Direct
Full-Time Equivalent (FTE) Employment in 2011 Supported by Mass Save Energy Efficiency
Programs” is included at Appendix P, Study 16.
The Program Administrators are committed to job training for emerging clean energy
industries, as well as sustainable funding of energy efficiency programs in order to maintain a
consistent workforce.
Section III.A.5.b of this Plan provides preliminary results of NECEF’s research.
10.
Conclusion
32
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 38 of 274
The Plan represents the ongoing results of an unprecedented collaboration among all the
Program Administrators in Massachusetts, both gas and electric, as well as diverse interested
parties, and fully complies with the bold initiatives required under the Green Communities Act.
The Program Administrators thank the Council, DOER, the Attorney General, the Council’s
consultants, and other stakeholders for participating in the Plan development process and for all
their efforts, analysis, and suggestions to date. The Program Administrators look forward to
working cooperatively with the Council and other interested parties in reviewing this Plan and
ensuring that Massachusetts customers are provided with programs that are marked by
excellence and innovation, and that produce economic and environmental benefits throughout the
Commonwealth.
G.
Council Priorities, Sense of the Council, Council Action Plans and Individual
Councilor Comments
For ease of reference, the PAs provide the following charts detailing various activities
and outcomes that were identified as Council priorities along with the location in this document
where the Program Administrators discuss strategies to focus explicitly on these activities and
outcomes.
1.
Council Priorities
In its February 14, 2012 Resolution Concerning Its Priorities for 2012, the Council
articulated its priorities for program planning, analysis, implementation, and evaluation. The
PAs are committed to these priorities, including building on the initial plan, achieving all
available cost-effective energy efficiency, maximizing net economic benefits through a sustained
and integrated statewide energy efficiency effort, setting aggressive, achievable goals, while
staying focused on bill impacts, cost efficiency and integrated program delivery. The PAs are
also committed to seeking outside financing and funding and addressing any barriers to energy
efficiency, where possible.
33
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 39 of 274
Council Priority
PA Summary Discussion
(Details in Section III)
Support the achievement of the savings
goals set in the 2010-2012 program plans
and the maximization of benefits.
Set Aggressive and Achievable Targets for
2013-2015 plans.
Continue to Improve the Cost Efficiency of
Program Delivery
Provide Support on Key Program
Development and Implementation Needs
12
Intense in-the-field efforts are ongoing, as documented in periodic reports to the
Council.
For details, see Section II.C.
Most aggressive savings goals for any integrated electric and gas effort ever
undertaken in the United States. Goal of $8.79 billion in benefits is aggressive and
layered on top of historic goals and achievements in the 2010-2012 period. Goals
reflect experience-based knowledge from the initial Three-Year Plan, as well as
available market intelligence. Goals have increased since July 2 draft Plan and are
consistent with the Term Sheets..
For details, see Sections I.B, I.D, I.F.1, III.A, III.B, III.D, III.E
The Program Administrators meet regularly in the Residential Management
Committee, the C&I Management Committee, the Evaluation Management
Committee and the Low-Income Best Practices Group to review and share best
practices, go to market strategies, 12 and discuss MTAC findings about new
technologies in order to enhance cost-effectiveness. The evaluation effort which
includes joint procurement practices demonstrates where efficiencies can be gained.
Also, upstream initiatives are a good example of efforts to enhance costeffectiveness. In addition, planning and reporting requirements are shared by the
Program Administrators, who coordinate filings and presentations to the
Department and Council, thus avoiding some duplication of costs and resources.
For details, see Sections I.B., I.F.4, III.A, III.B, and III.D
The sections cited below describe integration successes and plans. Bold new
initiatives targeting economically challenged neighborhoods, municipalities, health
“Go to market” strategies include the tactics employed by a PA to bring program services to a customer that frames the opportunities in a way that will
resonate with the customer and that helps the PA to leverage both its internal and external resources.
34
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 40 of 274
Council Priority
PA Summary Discussion
(Details in Section III)
care sector and public education. Broadly supported pre-weatherization approach
is underway and will guide final 2013-2015 approach. Tenant-landlord barriers
and hard-to-reach customers are also being targeted in community engagement
strategies described in Section II.H.2. In addition, the PAs meet consistently with
the Council, its Consultants, and efficiency experts to focus on continuous
improvement of energy efficiency efforts.
For details, see Sections III.F, III.G and III.H.
Define and Encourage Better Data Analytics The PAs are currently reporting statewide data in a consistent and timely manner.
An enormous amount of data is being successfully and consistently provided in a
and Access
public and transparent manner by the PAs, including DOER’s PARIS database,
which requires substantial PA time and resources to populate. The PAs have been
working collaboratively and proactively with DOER for over eight months to
discuss the purpose, challenges and strategies for developing a new, enhanced
database that would provide value both to the PAs and to the Commonwealth
generally. The PAs remain committed to working with DOER and other
stakeholders to develop a database solution that is efficient, reliable, and useful.
The PAs have identified core issues, concerns and questions and suggested next
steps that they believe should be addressed before a potentially costly, new
database development initiative is launched. The PAs remain committed to
determining if there is a workable database solution that will provide cost-effective
benefits to both the PAs and the Commonwealth in general. The PAs have
included budget resources for possible new database initiatives in this Plan.
Additionally, the PAs have developed and are providing new statewide data
analysis tables with this Plan, which provide key statewide and PA-specific data in
a user friendly format.
Identify Best Practices
For details, see Section III.N. See also Appendix L.
Intense commitment to sharing of ideas and to cooperation, professional
development and participation in seminars/industry groups/continuing education
35
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 41 of 274
Council Priority
PA Summary Discussion
(Details in Section III)
and innovation, such as the creation of the MTAC, are all hallmarks of the PAs’
commitment to drive and embrace best practices. Hosting of Appreciative Inquiry
Summit and Energy Expos to drive best thinking and cross pollination of ideas even when critical of aspects of PA efforts. Active and coordinated engagement in
regulatory proceedings, such as D.P.U. 11-120, which are probing best practices in
multiple areas, from planning to logistics, such as MTMs. Ongoing work of
Residential Management Committee and C&I Management Committee, Evaluation
Management Committee, and Low Income Best Practices Working Group. PAs are
fully and intensely engaged in diverse public processes seeking out best energy
efficiency practices.
For details, see Sections I.E, III.A.4, III.F, III.G., III.H., III.I, III.J, III.N
2.
Sense of the Council Regarding the Three-Year Plans (2013-2015)
In its June 12, 2012 Summary of EEAC Discussion – Sense of the Council Regarding the Three-Year Plans (2013-2015), the
Council discussed its expectations on what the PAs should include and specifically address in the July 2, 2012 draft Gas and Electric
Energy Efficiency Plan. The PAs addressed these expectations in the July 2, 2012 draft Plan, including reassessment of savings goals,
costs and cost drivers, innovation in pursuing aggressive and sustainable savings goals and best practices, and have continued to
review these areas of interest and update the Plan accordingly for this September draft of the Plan. The PAs are also including action
plan summaries for the Council’s convenience in Section I.G.3 below
Sense of the Council
Reassessment of Savings Goals
Reassessment of Savings Goals—where
appropriate, considering all-cost-effective
mandate, the Council’s priorities, including
sustainability, cost drivers and bill impacts,
determine whether the PAs can increase
savings goals for both gas and electric program
PA Summary Discussion
The PAs have adjusted proposed savings goals to take into account comments
received from the Council, Council consultants, and other stakeholders. Findings
from recently completed evaluation studies and other market intelligence has also
been factored into proposed savings goals. National Grid, NSTAR, and Western
Massachusetts Electric Company (“WMECO”) have increased electric savings
goals over the nation-leading 2.5 percent level. On the gas side, notwithstanding
serious challenges from EM&V results, Berkshire, Columbia Gas, New England
36
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 42 of 274
Sense of the Council
portfolios, supported with scenario analysis
where helpful. This should include a detailed
explanation as to how the ultimate
determination was made.
Costs and Cost Drivers
Include the complete analysis, methodologies
used, assumptions, background, data sources,
market uncertainties, etc. used to analyze the
cost drivers and build the budgets. Connect the
cost drivers to initiatives contained within the
programs and indicate their effect—both
positive and negative. Factor past actual costs
into estimates for the 2013-2015 gas and
electric plans.
Innovation
Innovation in pursuing aggressive and
sustainable savings goals—provide specific
and detailed information as to how Point 380,
the January 10, 2012 Public Comments, the
Appreciative Inquiry and the Synapse
economic study were reviewed and used to
inform, enhance and deliver the gas and
electric plans.
PA Summary Discussion
Gas, and Unitil have all increased savings goals above April 30th levels. Where
PAs did not increase goals, such action was taken only after review of EM&V
results and/or unique service area challenges. Following the July 23, 2012 Council
resolution, all PAs have further increased savings. Savings goals are set at levels
for all PAs that are consistent with the Term Sheets and are appropriate for 20132015.
For details, see Section III.B.1.h.
The PAs have carefully examined cost drivers, including sector cost trends, the
impact of CHP in 2011 and 2010, C&I cost drivers, upcoming changes in federal
codes and standards and resulting changes to program impacts, residential sector
cost and increasing reliance on savings to be obtained in that sector in the next
three-year plan, production and savings, and gas costs and evaluation impacts.
Detailed discussion is provided in this Plan. As a key milestone, the PAs made
presentations on these issues to the Council in July and September 2012. Overall
gas and electric 2013-2015 budgets are below overall levels in Term Sheets.
For a detailed discussion, including multiple tables, see Section III.D.
New initiatives targeting economically challenged neighborhoods, the healthcare
sector, municipalities and public education have been directly informed by January
10, 2012 public comments, Appreciative Inquiry and Council comments. The
Point 380 Study has informed the market segments that should be targeted in this
Plan and continues to be used as a tool to inform “go to market” strategies. The
Synapse study confirmed the PAs’ expectations with respect to the economy for
2013 -2015, and provided customer interviews reviewed by the C&I Management
Committee to help develop enhanced integration strategies for 2013-2015. Synapse
did not project a major economic boom or major recession in 2013 -2015, and PA
goals similarly are not predicated on extreme economic swings as compared with
current conditions.
For additional, more detailed discussion, see Sections I.E, III.A.4, III.B, III.F,
III.G, III.H., III.I, III.J
37
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 43 of 274
Sense of the Council
PA Summary Discussion
Action Plans
For each sector and key related programs or
initiatives (i.e., those that have a major impact
on savings/benefits or that are associated with
a major driver of costs), provide an action plan
with defined goals, deliverables, timelines and
methods of evaluation (working within the
EM&V framework).
Best Practices
For each sector and related programs, explain
how best practices were reviewed and modeled
across PAs, and then used to develop and
implement best practices across all PAs’ gas
and electric plans.
The PAs strongly emphasize that this Plan is an integrated document with multiple
parts interrelating. In order to fully appreciate and understand the PAs’ approach to
addressing key sectors, the provisions of the entire Plan need to be considered. In
particular, the most detailed descriptions of program plans and action strategies,
including key goals and dates, are within the program descriptions or other
applicable sections within this Plan.
For additional, more detailed discussion, see Sections I.G.3, III.F, III.G., III.H, III.I.
The sharing of best practices is an activity that occurs consistently within the C&I
Management Committee, Residential Management Committee, Low Income Best
Practices Working Group, and the Evaluation Management Committee. The
sharing of these best practices results in dynamic program efforts that evolve over
time. The program designs in each sector are the cumulative result of distilling best
practices in the field and from the industry. These designs were developed through
the C&I Management Committee, Residential Management Committee, and Low
Income Best Practices Working Group and were developed only after sharing early
drafts with the Council’s Consultants and considering the Consultants’ comments.
Early draft designs were also shared with individual Councilors in order to allow
them to weigh in with suggestions and recommended best practices. The PAs also
developed checklists of all Councilor comments on the April 30 short form draft
plan as well as a report on suggestions coming out of the Appreciative Inquiry
Summit in order to help systematically review recommended best practices. The
PAs have proactively and aggressively sought out the best thinking on energy
efficiency, both critical and supportive, to better inform this Plan – no other state
has embraced the open Appreciative Inquiry Summit process with respect to energy
efficiency, nor the level of PA cooperation and collaboration.
For additional and more detailed discussion, see Sections I.E, III.A.4, III.F, III.G.,
III.H., III.I, III.J, and III.N.
38
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 44 of 274
3.
Action Plans for the Three-Year Plans
On June 18, 2012, the Council voting members circulated an Action Plans document for the next three year plan. The Council
explained that it is an extension of the Sense of the Council prepared on June 12, 2012, and represents the specific requests of voting
Council members. The Council further explained that it does not supersede the Council priorities, but requests more planning on the
most significant programmatic and market sector issues to the voting Council.
In the following stand-alone section, the PAs provide Action Plans with respect to each of the 12 topics requested by the
Council. The PAs strongly emphasize that this Plan is an integrated document with multiple parts interrelating. In order to fully
appreciate and understand the PAs’ approach to addressing each of these 12 items highlighted by the Council, the provisions of the
entire Plan need to be considered. In particular, the most detailed descriptions of program plans and action strategies are within the
program descriptions or other applicable sections within this Plan. The PAs recognize, however, that having a separate section
highlighting action items and key milestones is useful and directly responsive to Council requests. Accordingly, the PAs have
summarized their action plans with respect to the 12 items noted by the Council below.
Council Request
1. Enhanced fuel integration
through program delivery in
the C&I sector
PA Action Plan
The PAs have made significant progress integrating electric and gas
service delivery in the C&I sector. There has been significant
progress in providing customers with a uniform message about
energy efficiency. Examples of current efforts that have contributed
to integration include but are not limited to cross training for PAs
and vendors, consistent requirements and post inspection verification
for contracted vendors, continued support of the MTAC process, and
the combined screening tool. Additional efforts focused on fuel
integration will continue in 2013.
1.
For 2013, additional gas measures will be evaluated for
inclusion in the C&I Direct Install initiative.
2.
Although PAs encourage comprehensive Technical
Assistance (“TA”) studies, these efforts are supported and
therefore directed by both the PA and the customer. To
encourage customers to consider comprehensive gas and
39
Applicable EM&V Studies
Large C&I - Process
Evaluation of the Large
Commercial and Industrial
Energy Efficiency Programs
included in the 2011 Annual
Report.
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 45 of 274
Council Request
PA Action Plan
Applicable EM&V Studies
electric opportunities, the PAs will require the consideration
of combined gas and electric opportunities in order to be
eligible for TA funds.
2. Community mobilization
models
3.
In those service areas which have separate gas and electric
PAs, opportunities may exist for more formal strategies
including cross-sales support and combined MOUs. NSTAR
and National Grid will develop and test these concepts in the
cities of Boston and Worcester. Although initial efforts are
with two large PAs, lessons learned and best practices will be
shared with the other PAs. Results reviewed at the end of 2nd
quarter of 2013 and best practices expanded to all
PAs/communities.
4.
The PAs will also provide continued formal statewide gas
and electric integration training to staff with the purpose of:
(1) Increasing networking among the PAs so the electric and
gas PAs can meet with their counterparts increasing the
ability to share knowledge; (2) Training electric staff on how
they may identify gas measures and training gas staff on how
they may identify electric measures (and potential leads) for
the partner PA when at customer site visits; (3) Developing a
closer partnership between the Cool Smart/GasNetworks’
rebate initiatives; and (4) Development of an Integrated Gas
& Electric Working Group.
For details, see Sections I.E.4, III.F.3, and III.F.6.d.
Community-based pilots developed during the last three-year plan
provided valuable lessons and were instrumental in identifying
outreach challenges and barriers to participation that exist in certain
communities. Over the course of the next three years, the PAs plan
to continue working closely with community organizations and
advocates to enhance the engagement process as a means to increase
40
Community-Based
Partnerships 2011 Evaluation
Final Report included in the
2011 Annual Report.
A study to review the
Northampton and Pittsfield
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 46 of 274
Council Request
PA Action Plan
program participation levels.
While the PAs acknowledge there are varying scopes for
community-based engagement efforts, there is also
acknowledgement that having an established framework to serve as
a common delivery model across PAs may be beneficial for
achieving and measuring success. The PAs also recognize the
frame work needs to be flexible enough to adjust for size and scope,
yet common core elements will be designed to yield measurable
energy savings and benefits to the community participants.
Examples of core components include, but are not limited to:
creating a formalized application process, establishing engagement
specific saving goals and reporting process, and developing a
performance-based incentive mechanism.
Applicable EM&V Studies
commercial outreach efforts is
planned for 2012.
Projected Milestones:
•
PAs will develop a statewide framework which incorporates
an application process, establishing a community specific
saving goals and reporting process, and developing a
performance-based incentive mechanism by the end of Q3
2013.
Each PA will work with their internal staff, implementation vendors,
and community organizations (where applicable) to introduce and
incorporate the formalized process to planned engagement activities
by Q4 2013.
3. Hard to reach and lower
income strategies, including
For details, see Sections III.H.2. See also the details and dates with
respect to the new Efficient Neighborhoods+ initiative in Section
III.F.6.b.i.
Building on the successful community engagement efforts and lowincome programs, the PAs plan to develop a new initiative called
41
Potential study to review the
2013 enhanced strategies to
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 47 of 274
Council Request
understanding and addressing
the 61-120% of state median
income customer segment
PA Action Plan
Applicable EM&V Studies
Efficient Neighborhoods+. This initiative will target lower to
increase penetration into hard
moderate-income consumers in designated communities and
to reach markets to be
neighborhoods. As an extension of the Home Energy Services
launched in late 2013.
(“HES”) core initiative, Efficient Neighborhoods+ is intended to
provide significant energy saving benefits to customers who live in
neighborhoods with older housing stock and are often financially
constrained from making energy efficiency investments. In addition
to the benefits provided by the HES core initiative, Efficient
Neighborhoods+ will include an enhanced incentive structure
designed to make energy efficient improvements more affordable for
consumers living in these sometimes harder to reach neighborhoods.
Projected Milestones:
1. PAs intend to define target neighborhoods and finalize
initiative design (including incentive structure) by the end of
Q1 2013.
2. PAs plan to test this initiative in May-August, 2013. This
timeline will serve the secondary goal of maintaining a
steady work flow for IICs and HPCs.
3. Monthly reporting of the uptake will be submitted by the lead
vendors to the PAs.
4. PAs will assess results and report to Council in Q1 2014.
PAs plan to include LEAN in the initiative design and
implementation phases to ensure a fully integrated cross-sector
approach.
4. Enhancements to the
multi-family program,
including integration of
For details, see Section III.F.6.b.i. See also III.H.2.
The PAs will continue integration efforts in multi-family facilities to Potential study to review the
provide consistent messaging and seamless delivery to customers initiative to streamline
within this unique sector. The PAs have developed effective delivery of packaged,
42
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 48 of 274
Council Request
commercial and residential
services that result in
increased penetration with
renters
PA Action Plan
strategies and made great strides toward integration of program
delivery services during the 2010-2012 three-year plan. For
example, the PAs discovered that condominium owners within this
initiative view themselves and act similar to the single family
homeowner. In an effort to meet the condo customers’ expectations,
the PAs expanded the HEAT Loan eligibility and allowed for single
unit assessments where warranted. In 2013, all PAs plan to offer a
coordinated facility assessment, regardless of meter type, and a
packaged offer to a facility, based on the positive experiences seen
by some PAs that previously implemented this approach. To further
increase penetration with renters, PAs will enhance efforts to target
landlords, property management firms, building management,
building operator trade associations, and design professionals. See
Section III.H. PAs will also consider stakeholder comments and
ideas generated at the Appreciative Inquiry Summit in May 2012.
Milestones
•
PAs will develop a statewide template which incorporates
measures and incentives into a packaged portfolio for
presentation to the facility owner by the end of Q2 2013.
•
Each PA will work with their internal staff, implementation
vendors, the Multi-Family Market Integrator and PA data
support teams to implement a seamless process by Q4 2013
•
PAs plan to engage multi-family stakeholders in a focus
group setting to assess the effectiveness of new
enhancements and future program planning by Q1 2014.
Dates of implementing marketing tactics will be dependent
on PA goal attainment.
For details, see Sections III.F.6.a, III.H.2
43
Applicable EM&V Studies
comprehensive energy
efficiency services to the
multi-family sector to be
launched in late 2013.
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 49 of 274
Council Request
PA Action Plan
5. Implementation of preweatherization measures in
residential services as
determined through the value
to greater savings
As discussed previously at Council meetings, the PAs offered
limited time incentives from May to July 2012 for combustion safety
repairs, knob and tube wiring inspections, or repair of improper
dryer venting. Up to $1,000 has been included for knob and tube
upgrades and remediation of moisture in the HEAT Loan.
Applicable EM&V Studies
Ongoing study to review the
2012 pre-weatherization
barrier initiative expected to
be completed shortly.
In Q3 2012, the evaluation contractor is expected to provide
preliminary results, and full results are expected in Q4 2012.
Evaluation results will inform initiative design in Q1 2013 with
expected implementation at the end of Q2 2013.
6. A consistent and more
comprehensive approach with
municipalities
7. Targeted strategies for the
midsized commercial market
(greater than 300 kW, not
account managed)
For details, see Section III.F.6.a.
The PAs recognize that municipal customers have unique barriers
and challenges to adopting energy efficiency. Effective in 2013 the
PAs will consider broader adoption of a dedicated turn-key track
within the C&I Retrofit Program to assist in overcoming these
barriers and providing closer alignment with the Green Communities
division of the Office of Energy and Environmental Affairs.
National Grid and NSTAR will implement a dedicated key track for
municipal customer within the C&I Retrofit program in 2012 and
will share experiences with other PAs. This new approach is a core
benefit of this Plan. Review by all PAs of this new approach being
implemented by NSTAR and National Grid will occur in the second
quarter of 2013.
For details, see Sections III.F.6.b.i., III.F.6.d, and III.H.
National Grid historically served these customers as managed
accounts with implementation support through contracted program
expediter (“PEX”) vendors. In 2012, NSTAR created a tiered sales
force whereby all accounts above 300 kW are now assigned and
managed. NSTAR also adopted the National Grid model with a
44
None currently planned; a
customized approach could be
developed based upon future
plans.
Large C&I - Process
Evaluation of the Large
Commercial and Industrial
Energy Efficiency Programs
included in the 2011 Annual
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 50 of 274
Council Request
PA Action Plan
Applicable EM&V Studies
stable of contracted PEX vendors. By 2013, WMECo will also
follow this model. Effectiveness will be shared and reviewed within
C&IMC.
Report. 2012 Massachusetts
Umbrella Marketing
Evaluation Report included in
the 2011 Annual Report.
For details, see Section III.F.6.d.
8. Targeted strategies for
commercial real estate,
including resources for
building performance
management tools, as well as
potential behavior programs
and increased penetration
with lessees
A study to assess mid-sized
C&I customer needs is
planned for 2012.
A study to assess mid-sized
C&I customer needs is
planned for 2012.
These three efforts are being targeted comprehensively through an
MOU strategy. In order to achieve persistence, multi-year corporate
engagement is critical. The barriers here include lease structures,
owner/management structures and buy-hold versus flip business
models. NSTAR and National Grid have been working with several A study to develop customer
large commercial property owners/operators and are currently testing profiles for C&I customers is
some concepts to begin addressing these barriers. By second quarter planned for 2012.
of 2013, progress will be reviewed and actions adjusted in response
to lessons learned.
In parallel, the PAs are also progressing on the Office of the Future
effort. This is focused on the technical opportunities for deeper
savings along with the associated cost challenges. National
collaboration has provided several initial technical projects focused
on system integration techniques to provide deeper savings.
Although cost effective, these projects were several orders of
magnitude more costly than traditional approaches. Opportunities to
fine tune the balance between budgets and savings exist. NSTAR
and National Grid are in talks with several commercial property
owners to implement up to 12 projects which will guide efforts
forward. An external project manager and consultant team has been
retained. With buy-in from property owners, implementation will be
targeted for 2013 and results available for review in 2014.
45
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 51 of 274
Council Request
PA Action Plan
9. Targeted strategies for
healthcare that meet the needs
of both large academic
medical centers as well as
smaller healthcare facilities
For details, see Section III.F.6.d.
The PAs commit to a continued focus on this customer sector.
MOUs are already in place with several health care sector customers
leading to significant savings in this important sector. The PAs
continue to work closely with customers in this sector to refine
energy efficiency services in a meaningful way. These efforts will
continue in this and other sectors in 2013 – 2015.
Applicable EM&V Studies
A study to assess mid-sized
customer needs is planned for
2012.
MTAC has also begun work with the Fraunhofer Center for
Sustainable Energy Systems CSE, located in Cambridge,
Massachusetts. Fraunhofer CSE, part of the international Fraunhofer
applied research organization, specifically focuses on building
energy technologies. Along with supporting MTAC’s overall
proactive charter, they will be supporting the effort of identifying
and addressing opportunities for equipment specific to the healthcare
industry. Key milestone: initial findings are expected to be reviewed
in 1st quarter of 2013 and will guide the direction of the effort going
forward.
10. Enablement for statewide
data management and
statewide data reporting in a
consistent and timely manner
For details, see Sections I.E.2, III.F.1, III.F.6.d, and III.H.1.
As discussed in more detail in the Council Priorities above, the PAs
are currently reporting statewide data in a consistent and timely
manner on a monthly, quarterly and annual basis. There is an
enormous amount of data that is being successfully and consistently
provided in a public and transparent manner by the Massachusetts
PAs, including DOER’s PARIS database, which the PAs have
populated throughout the Plan term. The PAs remain committed to
developing database solutions that will provide cost-effective
benefits to both the PAs and the Commonwealth in general. Key
milestone: PAs participate in database webinar hosted by DOER,
which is to be scheduled by DOER.
46
None currently planned; a
customized approach could be
developed based upon future
plans.
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 52 of 274
Council Request
11. Roadmap to
organizational structure and
staffing resources, including
systems for best practices
review, customer experience
and satisfaction in each sector
PA Action Plan
For details, see Section III.N. See also Appendix L.
Organizational structures adopted by individual PAs have evolved
over time to address evolving organizational objectives and costefficiencies in operations. As concretely demonstrated by the
budgets provided in this Plan, each PA is committed to maintaining
sufficient staffing levels, supplemented where necessary and
appropriate with external vendors, to continue to deliver successful
energy efficiency services to all customers. Each PA is acutely
focused on identifying and implementing strategies and tactics that
lead to an enhanced customer experience and high levels of
customer satisfaction. In addition, each PA is committed to
providing staff with ongoing education and training in support of
keeping efforts successful. Each PA also has a dedicated senior
expert who sits as a Council member and who stands ready to meet
with and talk to other Councilors.
The PAs also anticipate continuing to leverage resources by sharing
common resources. Examples of where this has been successful
include but are not limited to the technical review of potential new
technologies through the MTAC, sharing evaluation resources, joint
program design efforts, joint marketing efforts, having one or two
PAs staff meetings and reporting back to the group. The PAs
commit to continue to leverage resources between each organization
as a way to manage costs and overall efficiency.
Customer experience and satisfaction are also objectively reviewed
and measured through the comprehensive EM&V framework
adopted in Massachusetts and proposed for continuation in 20132015. Approximately three and a half percent of the overall budgets
for the PAs’ energy efficiency efforts are dedicated to EM&V work.
For details, see Sections I.E, III.A.4, III.B.4, III.B.5, III.F, III.G,
47
Applicable EM&V Studies
Large C&I - Process
Evaluation of the Large
Commercial and Industrial
Energy Efficiency Programs
included in the 2011 Annual
Report.
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 53 of 274
Council Request
12. Increased statewide
marketing and statewide
consistency in branding and
messaging efforts including
the use of the Mass SaveВ®
mark to reinforce seamless
program offerings across the
state
PA Action Plan
III.H., III.I, III.J, and III.N.
Support of the Mass Save mark and statewide brand is an important
priority. The PAs commit to statewide marketing efforts that
include the prominent integration and placement of the Mass Save
mark as the statewide brand. PAs will include the Mass Save mark
on statewide program, outreach and marketing materials and will
include a link to the Mass Save website on the portion of their PA
websites that is focused on energy efficiency services in
Massachusetts, except where expressly limited by internal corporate
website policies. PAs, in collaboration with DOER and the EEAC,
will conduct an evaluation of the effectiveness of all joint statewide
branding efforts to ensure that such brands support clear and
recognizable messages that help promote program awareness. Such
an evaluation will be completed by the end of 2013 and submitted to
the EEAC.
The key themes for the Statewide Marketing efforts for the 20132015 planning cycle are as follows:
•
Statewide Marketing’s role is to define who and what Mass
SaveВ® is and what it means to the customer
•
Statewide Marketing will take a strategic approach to
message and graphically tie in the PA Brand Logos with the
Mass Save mark to create a strong association and clarity of
message
•
Statewide Marketing will utilize the segmentation work
identified by the RMC and C&IMC so we can better and
more consistently target customers from a program and
statewide awareness level.
A request for proposal (“RFP”) was issued in July 2012 for a new
48
Applicable EM&V Studies
Phase II (2012): Umbrella
Marketing included in the
2011 Annual Report.
A follow up study which will
include post-campaign
analysis is planned for 2012.
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 54 of 274
Council Request
PA Action Plan
advertising agency to create and execute communications for the
Statewide Marketing Working Group. The PAs continue to review
the proposals and make a decision on a new agency after candidate
interviews in Q4 2012. The PAs will implement an agency review
process semi-annually to keep themselves and the agency on track
with a formal review mid-2014 prior to considering a contract
renewal for the final year. As part of that RFP process, the winning
agency will provide the PAs with recommendations and suggestions
for a 2013 communications plan, which can be leveraged and built
upon for development of the PAs’ 2013 campaign to be in market
Q1 2013. The 2013 plan will address the following:
•
PAs’ communications strategy by sector will be more diverse
and targeted and yield an improvement in awareness.
•
A need for increased spending has been identified so that the
PAs can adequately cover at least nine months versus six
months of activity in the market to support specific program
efforts. This will also be accomplished by a selective and
targeted use of the appropriate channels and media weights.
•
Mass Save Style Guidelines will be re-evaluated by the PAs
with the agency to determine their effectiveness and usability
and will be re-issued following this refinement within the
first half of 2013.
•
The 2014 and 2015 campaigns will be in market within the
first quarter of each year to complement the marketing
activities of the individual program communications.
From a market research perspective, the PAs will work with the
EM&V team to conduct a pre/post campaign study. Through the
PAs’ ad agency, the PAs will implement copy testing. The pre-test
will commence in Q1 2013 prior to the campaign being in market
49
Applicable EM&V Studies
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 55 of 274
Council Request
PA Action Plan
and will be conducted by sector and will be compared to the same
time in the prior year. The post test will commence immediately
following the conclusion of the campaign in Q4 2013. The copy test
will be conducted prior to creative execution in Q1 2013 so that the
PAs can be sure they have the right communication in the market in
that it is meaningful to the target and the channels the PAs elect to
use are appropriate. MassSave.com will be evaluated for content,
usability and improvements and a team established to maintain its
integrity.
As mentioned above, MassSave.com will be evaluated within Q1
2013 with a re-launch in Q2 2013. Subsequent reviews and
evaluations will take place quarterly to maintain its integrity and
technical prowess. The PAs will continue to feature all the PAs’
brands in conjunction with use of the Mass Save service mark per
the findings from the Umbrella Studies, which is also consistent with
the PAs’ goal to convey who and what Mass Save is.
Campaign tracking was introduced as a new process in 2012 and
will continue for each campaign. This activity will be set up at the
beginning of each campaign prior to launch and reviewed monthly
and then at the conclusion of each campaign year. The tracking
results will be utilized to plan going forward into the next year.
Tracking will include the number of customers visiting
MassSave.com, what they review and how much time they spend.
Surveys among visitors will be conducted on a half-year basis for
further learning.
For details, see Sections III.F.2 and III.H.
50
Applicable EM&V Studies
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 56 of 274
4.
Individual Councilor Comments Draft Plans
Under the process developed by the PAs and the Council, and in compliance with the
GCA, the PAs submitted their short form draft of the Plan on April 30, 2012, an expanded, full
draft on July 2, 2012, and an additional draft on September 19, 2012. Following those
submissions, the PAs solicited and received feedback from individual Councilors both in writing
and in individual meetings. The PAs collated and categorized the written comments from
Councilors on the April 30 draft, as reflected in the chart attached as Appendix E, and considered
both written and oral comments from Councilors in building the July 2 and September 19 drafts
of the Plan. The PAs appreciate the time and effort that the Councilors’ have devoted to
providing comments on the draft Plans. The PAs have endeavored to address these comments
wherever possible (see tables above which capture many of these comments), but given their
sheer number, complexity and interconnectedness with other issues, the PAs do not provide
specific references in the Plan to each and every comment. There are some instances in which
the PAs have not addressed comments directly because the PAs respectfully disagree with such
comments after consideration, or believe that such comments are too detailed for a strategic
program plan over three years. Accordingly, the PAs look forward to continuing discussions on
these issues with Councilors.
5.
Council Resolution of July 23, 2012
In its July 23, 2012 Resolution Concerning Its Priorities for 2012, the Council provided
many positive comments on the PAs’ July 2, 2012 draft plan. The Council also provided
comments and suggestions for enhancements as required by the GCA on the PAs’ draft plan.
The Council commended the PAs on the success achieved during 2010-2012, including the PA
role in Massachusetts’ number one ranking for energy efficiency by the American Council for an
Energy-Efficient Economy (“ACEEE”). The Council recognized that the PAs are going where
no energy efficiency providers have gone before with PA collaboration that is unparalleled. The
Council applauded the cooperation among PAs, the Council, its consultants and stakeholders.
The Council found that the PAs’ Plan “is well-written, responsive to input of the EEAC and its
consultants, reflective of stakeholder feedback, and worthy of Massachusetts’ nation-leading
status.” The Council provided comments and suggestions on ten topics following the July 2,
2012 draft of the Plan. The PAs are committed to working to address the Council’s comments
where possible and as discussed below and throughout this Plan. As demonstrated by the
increased savings and decreased costs in this version of the Plan, the PAs have worked diligently
to be responsive to the comments of the Council.
51
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 57 of 274
Council Resolution
Energy Savings Goals
The Council believes that
1. PA-proposed goals in the July Plan are low.
2. Benefit cost ratios of 3.19 for the electric
programs suggest the PAs can pursue additional
energy savings.
3. PA programs and goals must be aligned with
the Clean Energy and Climate Plan (CECP).
4. PA goals should be increased to be consistent
with the trajectories in the CECP “in pursuit of
all available cost-effective energy efficiency
pursuant to the GCA.”
5. PA goals need to increase “without increasing
costs to utility customers.”
6. Gas PAs should “increase the number of
training opportunities with their vendors, as
well as colleges and technical schools to expand
the technical capacity in thermal applications
and enable greater achievement of savings.”
PA Summary Discussion
1. After careful analysis of cost drivers, PA variances, potential
savings, performance incentives, and customer bill impacts, and
after productive discussions with the Consultants and other
stakeholders, the PAs are proposing higher goals than in the July
Plan, which they believe can be achieved in a cost-effective and
sustained manner. To the PAs’ knowledge, these are the highest
savings targets ever proposed for an integrated statewide effort.
These savings are at or above the levels supported in the Term
Sheets. For additional discussion, see Sections I.B, I.D, I.F.1, III.A,
III.B, III.D, and III.E.
2. The PAs continue to seek all cost effective energy efficiency as
mandated by the GCA and are committed to achieving deeper
savings, which in some instances can correlate with lower BCRs.
But several factors affect the TRC test and BCRs do not necessarily
always correlate with deep savings. The PAs continue to seek robust
BCRs in order to keep programs cost effective through normal
programmatic transitions. In response to BCR questions, the PAs
have developed and provided a detailed new table providing core
initiative level BCR analysis at both the statewide and PA-specific
level. The table indicates increasing convergence among PAs on
BCRs, especially at the portfolio level. For additional discussion,
see supplemental statewide summary tables provided with this Plan;
see Sections III.D.1 and III.D.4.
3. Proposed savings targets are projected to attain environmental
benefits that are aligned with the CECP. For additional discussion,
see Section III.P.
4. Proposed savings targets are on a favorable trajectory to support
CECP objectives. Most tellingly, the savings goals provided in
today’s filing include the incrementally higher savings trajectories
for each of 2013, 2014, and 2015, which is an important priority of
52
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 58 of 274
Council Resolution
PA Summary Discussion
Councilors. In addition, the PAs had productive discussions with the
Consultants, DEP and DOER on this issue. PA goals are set
consistent with the GCA’s mandate to pursue all available costeffective energy efficiency and Department precedent. The
Commonwealth’s climate plan is distinct from the GCA and does
not impose a statutory or regulatory mandate on PAs or other
industries. The PAs are committed to achieving GHG reductions in
a manner consistent with the CECP goals, but must do so within the
confines of the regulatory requirements of the GCA and the
Department. In support of both the mandate of all cost-effective
energy efficiency provided for in the GCA and the greenhouse gas
reduction goals established by the GWSA, the PAs will utilize full
and diligent effort to meet their established savings goals as set forth
in this term sheet and participate in developing strategies to assist
the Commonwealth of Massachusetts in meeting its CECP goals.
For additional discussion, see Section III.P.
5. Since the July and September draft Plans, each PA has been focused
on increasing savings targets and reducing costs. This has been an
iterative process informed by Council comments, discussions with
EEAC consultant team, and feedback from other stakeholders. All
PAs are increasing savings goals from July Plan, diligently
following up on the Council’s request. Each PA is identifying
budgets needed to achieve higher savings targets while being
mindful of EEAC concerns on costs. The PAs emphasize that
savings, costs and performance incentives are interlinked. This Plan
sets forth savings, costs, and incentive levels that flow from, and are
consistent with, the Term Sheets. For additional discussion, see
Sections I.B, I.D, I.F.1, III.A, III.B, III.D, and III.E.
Benefits
The July Plan estimates $8 billion in total benefits from
This Plan estimates $8.92 billion in total benefits for 2013-2105. For
additional discussion, see Sections I.F.1 and III.A.
53
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 59 of 274
Council Resolution
the 2013-2015 electric and gas energy efficiency
programs. This level of total benefits is impressive and
demonstrates the significant value of cost-effective
energy efficiency for consumers, businesses, and the
Commonwealth.
Deeper Savings
PAs should have continued focus on deeper savings
strategies, which should lead to greater savings for
more customers, in all sectors, throughout the decade.
The plan should highlight the deeper savings strategies
proposed for all customer segments. PAs are
encouraged to implement deeper savings strategies in
communities and neighborhoods, including the harderto-reach/harder-to-serve customers, and carry deeper
savings strategies through to the commercial and
industrial sector, including well-designed MOU
practices with a specific focus on small and medium
business customers, including commercial real estate,
municipal and healthcare facilities.
Program Costs
Costs to achieve the goals are expected to be reduced,
taking into account the cost ranges identified by the
EEAC consultants. PAs should provide different
PA Summary Discussion
The PAs’ strategies in all sectors focus on serving more customers and
increasing comprehensiveness. The PAs are focused on streamlining the
participation experience in all sectors and making efforts more customerfocused (i.e., addressing unique needs by segments of customer base).
For residential and low-income customers, the PAs have strong
commitments to investigate tenant/landlord split incentives barriers; assess
packaging incentives in HES; target 60% - 80% of average median income
through Efficient Neighborhood+ initiative (in development); assess current
pre-weatherization incentives informed by 2012 evaluation findings; focus
on early retirement of boilers in HES; develop an integrated HVAC/Heating
equipment early retirement incentive by Q2 2013; and provide enhanced
incentives for Top Ten appliances. In the low-income sector, PAs will
continue funding comprehensive whole-house solutions. For multi-family,
PAs will look to expand the availability of the HEAT Loan to condominium
owners and coordinate between Residential and C&I teams to increase
comprehensiveness in multi-family facilities. The PAS hired a vendor to
identify efficiency opportunities in the healthcare industry with a specific
focus on large medical equipment. The PAs continue to support energy
efficiency efforts with municipalities, Green Communities, wastewater and
water treatment plants and in the property management/real estate sector.
For additional discussion, see Sections III.F, III.G and III.H.
PAs have been engaged in extensive cost and cost driver analysis and
modeling culminating in the budgets set forth in the Terms Sheets and this
Plan. Since the July and September Plans, there have been intensive efforts
by and productive and frequent meetings/calls with the PAs/Consultant on
54
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 60 of 274
Council Resolution
PA Summary Discussion
scenarios to show what would be needed in terms of
program budgets to get to the level of savings goals
presented by the Council Consultants. These scenarios
should answer the following questions: What
additional actions must the PAs perform, and what
would be the necessary budget levels? What would be
the benefit-cost ratios of these scenarios?
cost drivers. The key drivers in discussion are: EM&V results, new
developments (including upstream lighting, upstream HVAC, behavioral
programs, CFLs vs. LEDs, addition of RCS to energy efficiency plan),
Codes & Standards, CHP levels, measure mix, and EM&V costs. This
process has allowed a good faith understanding of costs drivers, with goal of
achieving consensus on costs. The PAs have reduced electric costs as
compared to the July draft. PAs not proposing to achieve statewide targets
due to unique service area characteristics have provided information and
scenario analyses on the cost to achieve targets in the appendices. The gap
between savings targets and the PAs’ proposed savings level has been
materially reduced. Efforts to achieve these reduced differences have been
the core focus of much PA effort. For additional discussion, see Sections
III.D and IV, Apps. G and H.
On August 16, 2012, the Department announced at a meeting of the Bill
Impacts Working Group that it intends to return to the use of traditional bill
impacts. Based on a historical review and reexamination of the goal of bill
impact models, the Department proposed to use traditional bill impacts in
2013-2015. Comments were filed with the Department by September 14,
2012, and the Department issued updated directives on October 19, 2012.
For additional discussion, see Section III.E.
The PAs recognize the development of common definitions as a core
priority and have been diligently working toward common definitions. The
RMC and the C&IMC each met with the tables group in order to agree on
common participant definitions for 2013-2015. The definitions resulting
from these discussions are included in this Plan. See Section III.D.3 and
Section IV, Appendix M.
Bill Impacts
PAs, the DPU, and the EEAC and its consultants will
continue to work together to provide a bill impact
model that accurately captures overall impacts for
customers in a transparent, consistent and
comprehensive manner.
Participation
PAs will work on properly and precisely defining
program participants, which will facilitate a more
realistic estimation of market penetration, avoid double
counting of customers, and better facilitate the bill
impact analysis. To aid in transparency of programs,
PAs will distinguish customers from products by sector
to better demonstrate program penetration and
customer benefits, including for heating oil and
delivered fuel customers served through the electric
programs. PAs will share the participant data with the
55
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 61 of 274
Council Resolution
Council and interested stakeholders in a transparent and
timely manner.
Statewide Database
Voting Councilors are encouraged by the potential of
enhanced transparency to programs and more timely
access to program data. We look forward to continue
to investigate, establish, and implement systems in
collaboration with the PAs and Council Consultants
that work to meet these objectives.
Statewide Marketing
Brand recognition and awareness is a critical element to
the engagement of program participants and increasing
participation in programs. The Plan should have more
detail on the statewide branding efforts for 2013-2015,
including the efforts to emphasize and increase
awareness of the Mass Save brand, implement
community engagement initiatives and associated
budget, and heighten awareness of the energy
efficiency programs throughout the Commonwealth
and all the customer sectors.
Inconsistencies and Variations Across the PAs
There are significant variations and inconsistencies in
benefit/cost ratios, savings and savings targets, costs,
and cost per unit savings across the PAs. The PAs need
to provide justification for or resolve these variations in
detail.
PA Summary Discussion
The Program Administrators will continue to collaborate with the Council to
explore and develop options that are timely, appropriate and efficient for all
users. For additional discussion, see Section III.N.
The PAs are continuing a strong marketing campaign. The PAs look
forward to continuing productive conversations with DOER on statewide
marketing issues. The PAs have issued an RFP for advertising services and
will be interviewing finalists at the end of October. The vendor selected for
this RFP will help inform statewide marketing efforts for 2013-2105. In
addition, the PAs incorporate into this Plan results of and lessons learned
from the Umbrella Marketing Study. The PAs will also implement the
marketing provisions of the Term Sheets. For additional discussion, see
Sections III.F.2 and III.H.
At the September 11, 2012 EEAC meeting the PAs put forth a detailed
presentation on the drivers of appropriate cost variations among PAs as a
follow up to the Council’s request. As noted in that presentation, which was
supported by extensive statewide data, some variations in savings goals and
cost to achieve are appropriate due to unique characteristics in service
territories. Both the EEAC and the Department have supported variances
for the current Plan. Each PA has unique expertise and knowledge
regarding their individual customer needs. Prior to 2012, and to a degree
for 2012, multiple different assumptions/EM&V results were used and
approved for each PA. The key developing trend for 2013-2015 is fewer
variances. Cost to achieve and costs and savings estimates are converging
56
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 62 of 274
Council Resolution
PA Performance Incentives
Performance incentives are an integral part of the
planning process and program implementation. The
Council will review the overall framework of the
current performance incentive model, with the PAs and
Council consultants, to optimize and calibrate the
current structure including metrics. The Council will
review the performance incentive model, including the
75% threshold and the incentive cap, and work with the
PA and EEAC consultants to potentially modify
specific details of the overall performance incentive
model.
PA Summary Discussion
due to intense efforts of the C&IMC, RMC, LI Best Practices, and common
assumptions working group to develop common program designs, common
definition of participants, the TRM, and the statewide EM&V framework.
PAs with robust C&I customer bases have deeper savings opportunities to
mine and those savings can be achieved less expensively than low-income
or residential savings. Savings variations are at an appropriate level, and
budgets for each PA are reasonable, for 2013-2015, as determined in the
Term Sheets. For additional discussion, see Section III.D.
Performance incentives are closely tied to savings goals. The current
structure was carefully negotiated and reviewed by the DPU. The Term
Sheets propose some adjustments, and lower the incentive pool from the
levels in the July and September drafts. Thresholds for 2015 are increased
to 80%. Performance metrics will be developed consistent with the Term
Sheets and submitted in a supplemental filing. For additional discussion,
see Sections III.K.
57
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 63 of 274
II.
PROCEDURAL BACKGROUND
A.
The Green Communities Act
The Green Communities Act was signed into law on July 2, 2008. The legislation
promotes enhanced energy efficiency throughout the Commonwealth and requires the Program
Administrators to develop energy efficiency plans that will “provide for the acquisition of all
available energy efficiency and demand reduction resources that are cost effective or less
expensive than supply.” G.L. c. 25, § 21(b)(1). Electric and gas Program Administrators,
respectively, are required to submit a statewide electric efficiency investment plan and a
statewide natural gas efficiency investment plan on or before April 30, 2012 to the Council.13
The contents of those plans, which are specified in the statute, are to be prepared by the Program
Administrators in coordination with the Council. Id., at В§ 21(b)(1)-(2). In meeting that statutory
deadline, the Massachusetts gas and electric Program Administrators worked collaboratively to
prepare a Plan that represents the collective efforts and objectives of the Program Administrators,
and is intended to meet statutory requirements. In accordance with the schedule and processes
developed with the Council for the 2013-2015 Plan, on April 30, 2012, the electric and gas
Program Administrators submitted their short form initial draft 2013-2015 three-year energy
efficiency plan for the Council’s comment and approval.
Since their initial, short-form submittal, the Program Administrators have remained
engaged in a collaborative process with the Council and its Consultants, as well as other
interested stakeholders, to further develop and refine the statewide Plan. These discussions have
been successful, as reflected in the Term Sheets. This Plan marks the fourth iteration of the
2013-2015 Plan and, in accordance with the processes and schedule developed for the 2013-2015
Plan, contains full detail on program designs, budgets and savings goals. In accordance with the
GCA, the Program Administrators are required to file their respective PA-specific three-year
plans, “together with the Council’s approval or comments and a statement of any unresolved
issues, to the Department . . . on or before October 31.” G.L. c. 25, § 21(d). Given customer
service requirements and priorities resulting from Hurricane Sandy, this Plan is being filed on
November 2, 2012, as such date has been reviewed with the Department, DOER, and the
Attorney General.
Although this Plan meets statutory objectives for three-year plans, the Program
Administrators are also cognizant of the role that the statewide electric and gas efficiency
13
The Energy Efficiency Advisory Council is an advisory body consisting of eleven voting members of
diverse backgrounds and expertise, a non-voting member from the heating oil industry, a non-voting
member from the energy efficiency business, and a non-voting member from each Program Administrator.
G.L. c. 25, В§ 22. The PAs have been active and engaged participants in the Council process, participating
in at least 56 full Council meetings and 11 Council executive committee meetings since 2009. Sections 8
and 9 of An Act Relative to Competitively Priced Electricity in the Commonwealth, St. 2012, c. 209,
approved August 3, 2012, increase the voting members of the Council to 15 by adding the following
entities: the Massachusetts Non-Profit Network, a yet to be designated municipality, The Massachusetts
Association of Realtors and an energy efficiency service business having 10 or fewer employees (which
business is to be elected by a majority of the businesses performing energy efficiency services in the Mass
Save program). Additionally, Section 10 of that statute adds ISO New England to the non-voting members
of the Council.
58
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 64 of 274
investment plans occupy in the Commonwealth’s broader policy objectives. With a series of
additional legislative enactments in 2008, the Commonwealth has signaled its commitment to
ensuring that the Commonwealth is a worldwide leader in developing the green economy
through the Global Warming Solutions Act, St. 2008, c. 298 (“GWSA”), and the Green Jobs Act,
St. 2008, c. 307. The GWSA mandates the gradual reduction of greenhouse gas emissions
(“GHG”) in the Commonwealth, thus spurring innovation and promoting research and
development in the area of clean energy. Enacted concurrently, the Green Jobs Act provides a
robust funding source for the green technology industry, facilitating economic development and
job growth in the clean energy sector. Taken together, these legislative enactments reflect the
Commonwealth’s commitment to climate protection and its leadership in promoting clean and
renewable energy. The Program Administrators welcome the opportunity provided by this new
three-year Plan to further design and implement innovative energy efficiency programs that not
only advance the objectives of the Green Communities Act, but also promote the parallel goals
of decreasing GHGs and promoting job creation in the clean energy sector.
B.
D.P.U. 08-50-A
After the passage of the Green Communities Act, and in conjunction with the Program
Administrators’ well-established energy efficiency programs, the Department opened an
investigation to update the Department’s energy efficiency guidelines, as previously established
in Investigation to Establish Methods and Procedures to Evaluate and Approve Energy
Efficiency Programs, D.T.E. 98-100 (2000) (“D.T.E. 98-100 Guidelines”), to ensure that they
were consistent with the Green Communities Act. In that proceeding, Energy Efficiency
Guidelines, D.P.U. 08-50 (2008) (“D.P.U. 08-50”), the Department issued revised energy
efficiency guidelines, to address issues such as: (1) funding sources; (2) budgets; (3) costeffectiveness test; (4) evaluation plans; (5) performance incentives; (6) review of three-year
plans; and (7) mid-term modifications (“MTM”).
During the Department’s proceedings in D.P.U. 08-50, it solicited comments from the
Program Administrators, governmental bodies, and other interested stakeholders. The resulting
first Order, D.P.U. 08-50-A (March 16, 2009), provided a clarification of the criteria to be
applied in demonstrating cost-effectiveness and the process by which three-year energy
efficiency plans should be prepared and reviewed. In D.P.U. 08-50-A, the Department mandated
that the Program Administrators seek Department approval for certain specified mid-term
modifications. As a result, the PAs have filed mid-term modifications for 2011 and 2012 in
accordance with D.P.U. 08-50-A and D.P.U. 08-50-B, discussed below.
The Program Administrators have participated with the Department, DOER, and other
interested stakeholders in various D.P.U. 08-50 Working Group sessions convened and
moderated by the Department. The format of today’s filing, including the organization of the
Plan, statistical tables, and the bill impact review model, reflect the collaborative process that
occurred in the context of the D.P.U. 08-50 Working Groups.
C.
D.P.U. 08-50-B
The Department supplemented its 08-50-A Order with the issuance of D.P.U. 08-50-B
(October 26, 2009), which includes further directives clarifying how the Program Administrators
59
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 65 of 274
are to conduct and present their bill impact analysis and evaluation, monitoring and verification
processes, and established the energy efficiency guidelines which the PAs now rely upon for
such matters as annual report filings and mid-term modification filings or notifications (the
“D.P.U. 08-50-B Guidelines”). Through Orders D.P.U. 08-50-A and D.P.U. 08-50-B, the
Department established standards that sought to balance the need for Program Administrators to
make improvements to energy efficiency programs during the course of a three-year plan, with
the need for adequate regulatory review and stakeholder input of significant changes to the
Program Administrators’ planning assumptions and parameters.
D.
D.P.U. 08-50-C
Following its Order in D.P.U. 08-50-B, the Department established a working group to
review existing practices and develop an annual report template for review and comment,
resulting in an Order in D.P.U. 08-50-C (2011), which established a template for Energy
Efficiency Annual Reports.
The Department noted that the purpose of the Annual Report template is: (1) to clearly
identify the information that a Program Administrator is required to provide to fully review the
PA’s energy efficiency program performance for a particular year; and (2) to specify the format
for providing the required information. D.P.U. 08-50-C at 13-14. The PAs have used the
Annual Report template, in preparing their respective annual reports filed with the Department
each year on or about August 1st, and in compliance with G.L. c. 25, В§ 21(b)(3).
E.
Initial Three-Year Plans - D.P.U. 09-116 to D.P.U. 09-128
On October 31, 2009, the Program Administrators filed their respective PA-specific
three-year plans, together with the Council’s Resolution of October 27, 2009 (which Resolution
constituted the Council’s approval, comments and statement of any unresolved issues) with the
Department pursuant to G.L. c. 25, В§ 21(d). The plans sought to capture all available costeffective energy efficiency for the three-year period beginning January 1, 2010, with the
consideration of factors and concerns noted at the Council, including, but not limited to, bill
impacts, environmental benefits, and the need for a reasonable ramp-up schedule.
On January 28, 2010, the Department issued Orders on the initial three-year plans in
dockets D.P.U. 09-116 through D.P.U. 09-120 (“Electric Order”) and D.P.U. 09-121 through
D.P.U. 09-128 (“Gas Order”) (together, the “Orders”), approving the Plans subject to limited
specified exceptions and directives. The Program Administrators have provided quarterly
reports to the Council, and the Council in turn has provided an annual report to the Department.
G.L. c. 25, В§ 22(d). The Department is required to determine the cost-effectiveness of each
Program Administrator’s plan on an annual basis. Id., § 21(d)(2).
In addition to quarterly reports to the Council, the PAs voluntarily provide monthly data
dashboards to enhance transparency on implementation efforts under the initial three-year term.
These reports are provided in a timely fashion, in formats that were developed collaboratively by
the Program Administrators and the Council’s Consultants. The Program Administrators also
filed detailed annual reports in August of 2011 for program year 2010 and in August 2012 for the
program year 2011. In preparing these reports (monthly, quarterly and annual), the Program
60
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 66 of 274
Administrators collaborate, share assumptions, best practices and ideas; and, provide informal
review and quality control functions for each other.
As approved by the Department and as implemented by the PAs, these three-year plans
have supported the development of an enhanced energy services delivery infrastructure in
Massachusetts, promoted job creation throughout the Commonwealth in the energy efficiency
services sector, and enhanced program designs in order to provide a more seamless experience
for customers seeking energy efficiency services from both gas and electric Program
Administrators. Further, these joint efforts of the PAs, the Council, state regulators, and other
interested stakeholders, have taken Massachusetts to the forefront of energy efficiency efforts in
the nation, leading the ACEEE to name Massachusetts “the number one state in Energy
Efficiency” in both 2011 and 2012. Similar coordination by the Program Administrators and the
Council through this next three-year plan should allow for the continued aggressive pursuit of all
available cost-effective energy efficiency in a sustainable manner to achieve deeper and broader
levels of savings at customer homes and facilities. In turn, increased savings over time will
continue to provide economic and environmental benefits to all customers.
F.
D.P.U. 10-106
While В§ 3.8.2 of the D.P.U. 08-50-B Guidelines describes the conditions that require a
filing of a mid-term modification, that section did not state whether the 20 percent thresholds
should be applied on a three-year or an annual basis. On August 13, 2010, Cape Light Compact
(the “Compact”) filed a request with the Department for a mid-year modification of its 20102012 Three-Year Plan, consisting of an adjustment of its 2010 program budgets. The Compact
sought Department approval for a program budget change that was 20 percent greater than the
program’s annual budget. On January 10, 2011, the Department issued an Order in Cape Light
Compact, D.P.U. 10-106 stating that the three-year plan review process should move away from
routine mid-term modifications, and clarifying that D.P.U. 08-50-B “Guidelines § 3.8.2 should
be interpreted such that Department approval is required for a program budget change that is
20 percent greater than the program’s three-year budget.” D.P.U. 10-106, at 7-8. Additionally,
the Department noted that the D.P.U. 08-50-B Guidelines are not fixed and are intended to be
updated over time. Id. at 8-9.
G.
D.P.U. 11-120
On November 29, 2011, the Department opened an investigation to examine issues
associated with the Program Administrators’ three-year energy efficiency plans. Energy
Efficiency Guidelines, D.P.U. 11-120, Vote and Order Opening Investigation (2011). In the first
phase of the investigation, the Department announced that it will examine the following issues
associated with energy efficiency program benefits that are included in the cost-effectiveness
determination: (1) the method used to calculate program net savings; and (2) the method used to
calculate reasonably anticipated environmental compliance costs, in particular those associated
with the emission of carbon dioxide (“CO2”). Id. at 3. The Department stated that its
investigation did not mean that a change to the long-standing treatment of these benefits is either
necessary or appropriate at this time. Id. Instead, the Department solicited comments in order to
determine whether such changes are necessary and, if so, when and how such changes should be
incorporated into the measure of cost-effectiveness. Id. at 3-4.
61
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 67 of 274
Interested parties filed initial comments on these two issues by January 31, 2012. Reply
comments on CO2 compliance costs were filed by February 27, 2012. The Department held a
technical session on March 28, 2012, to discuss: (1) the extent to which the existing approaches
used to estimate net savings produce accurate and reliable results; and (2) alternate ways to
determine net savings estimates that may improve upon the existing approaches. Interested
parties filed reply comments on these savings issues by May 7, 2012.
In an example of the collaborative spirit and search for best practices brought to bear by
the Program Administrators and other stakeholders such as the DOER, Department of
Environmental Protection (“DEP”) and Environment Northeast (“ENE”), on May 7, 2012, the
Program Administrators joined a diverse group of stakeholders in a set of common comments
with respect to the issue of calculating net savings. The ability to file comments with such a
diverse group of stakeholders underscores the commitment to sharing ideas and best practices of
the multiple parties interested in energy efficiency in Massachusetts.
The Program
Administrators were proud to take a leadership role in the development, drafting and submission
of these joint comments.
On May 25, 2012, the Department opened a second phase of this investigation to examine
issues associated with the Program Administrators’ three-year energy efficiency plans.
D.P.U. 11-120, Phase II, Order on Investigation--Phase II (2012). In the second phase of this
proceeding, the Department expanded the scope of its investigation to include recurring filings
that the Department has reviewed during the term of the first three-year plans, including:
(1) mid-term modifications (“MTMs”); (2) the performance reports submitted by each Program
Administrator annually, which include the calculation of a performance incentive payment; and
(3) the calculation and reconciliation of each Program Administrator’s energy efficiency
surcharges (“EESs”). The Department held a technical session on June 19, 2012, to discuss these
three issues. Initial comments were filed on July 12, 2012, and a second technical session was
held on August 16, 2012. At the Department’s request, on September 14, 2012, the PAs filed
comments on two raised by the Department at the second technical session.
On August 10, 2012, the Department issued D.P.U. 11-120-A Order, addressing two
issues related to program net savings: (1) alternate methods to determine program net savings;
and (2) the prospective or retrospective application of evaluation study results. D.P.U. 11-120A, Order on Program Net Savings and Environmental Compliance Costs, at 12 (2012). In
addition, the Department declined to adopt an interim proxy value for carbon dioxide to be used
in the cost-effectiveness determination of energy efficiency programs. Id. at 18.
With respect to net savings, the Department indicated support for alternative approaches
to determining net savings that look at effects that occur over multi-year periods and across
programs, which is consistent with the approach recommended in the joint comments of the
Program Administrators, DOER, DEP, ENE and NEEP. The Department announced that it
would convene a working group to explore if and how an alternate (i.e., market-focused)
approach to determine program net savings could be developed and implemented. Id. at 13. The
Department scheduled a net savings technical session for September 7, 2012, which was
postponed to a future time at the request of the PAs and DOER. The Program Administrators
expect to continue efforts in future working groups on net savings organized by the Department,
after the filing of this Plan, and envision adopting any new approaches on a prospective basis.
62
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 68 of 274
With respect to EM&V results, the Department found that is appropriate for Program
Administrators, when calculating post-implementation program savings (gross and net), to use:
(1) the most recently updated gross savings impact factors; and (2) the net savings impact factors
that were used when the programs were designed and developed. Id. at 13-16. The Program
Administrators will apply this measurement approach for post-implementation savings
calculations resulting from this Plan.
On September 21, 2012, the Department invited all interested persons to file comments
on its proposed revisions to the energy efficiency guidelines (“Revised Guidelines”), which the
Department explained are based on the discussions at the technical sessions and in the initial
comments. Interested parties filed initial comments on the Revised Guidelines on October 15,
2012. The Program Administrators filed joint comments generally in support of the Revised
Guidelines.
As this proceeding continues, the Program Administrators will remain engaged. They
discuss the possible future implications of this investigation in Section III.O.
H.
2010 Annual Reports, D.P.U. 11-63 through D.P.U. 11-73, D.P.U. 11-126
On August 15, 2011, the PAs each filed for Department approval a 2010 Energy
Efficiency Annual Report. Consistent with D.P.U. 08-50-C, each Annual Report summarizes the
activities related to the delivery of each PA’s energy efficiency programs from January 1, 2010
to December 31, 2010 (“2010 Annual Report”), the first year of each PA’s initial Three-Year
Energy Efficiency Plan. On March 23, 2012, the Attorney General and the DOER filed
comments in the 2010 Annual Report proceedings, making a number of recommendations to be
applied in the future, but neither opposed approval of the 2010 Annual Reports by the
Department. On April 6, 2012, the PAs filed reply comments.
Pursuant to the Annual Report Template in D.P.U. 08-50-C, each 2010 Annual Report
submitted to the Department: (1) provides a comparison of its planned, preliminary year-end,
and evaluated (where applicable) expenses, savings, and benefits at the portfolio, sector, and
program levels for the program year; 14 (2) identifies significant variances between its planned
and evaluated costs, savings, and benefits for the program year, and discusses reasons for such
variances; (3) discusses how program performance during the program year informs the Program
Administrator’s consideration of modifications to program implementation during upcoming
years; (4) describes the evaluation, monitoring, and verification activities (“EM&V”) undertaken
by the Program Administrator (both individually and jointly with other Program Administrators)
14
Before a program year, each Program Administrator projects its planned values for expenses, savings, and
benefits based on anticipated performance during the year. At the end of the program year, each Program
Administrator estimates its preliminary year-end values based on actual performance during the year.
Finally, evaluated values revise the preliminary year-end values to take into account the evaluation studies
in which a Program Administrator participated during a program year. See Energy Efficiency Guidelines,
D.P.U. 08-50-C at 17 n.10 (2011).
63
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 69 of 274
and explains how the results of the activities influence program cost-effectiveness; and
(5) describes the performance incentive that the Program Administrator seeks to collect. 15
Discovery in this proceeding has been issued by the Department, the Attorney General
and the DOER and the PAs have responded to these statewide and individual information
requests. Finally, the PAs, the Attorney General and DOER have filed initial and reply
comments.
I.
2011 Annual Reports, D.P.U. 12-51 through D.P.U. 12-61
On August 1, 2012, the PAs each filed for Department approval a 2011 Energy
Efficiency Annual Report. Consistent with D.P.U. 08-50-C, each Annual Report summarizes the
activities related to the delivery of each PA’s energy efficiency programs from January 1, 2011
to December 31, 2012 (“2011 Annual Report”), the second year of each PA’s initial Three-Year
Energy Efficiency Plan.
Pursuant to the Annual Report Template in D.P.U. 08-50-C, each 2010 Annual Report
submitted to the Department: (1) provides a comparison of its planned, preliminary year-end,
and evaluated (where applicable) expenses, savings, and benefits at the portfolio, sector, and
program levels for the program year; (2) identifies significant variances between its planned and
evaluated costs, savings, and benefits for the program year, and discusses reasons for such
variances; (3) discusses how program performance during the program year informs the Program
Administrator’s consideration of modifications to program implementation during upcoming
years; (4) describes the evaluation, monitoring, and verification activities (“EM&V”) undertaken
by the Program Administrator (both individually and jointly with other Program Administrators)
and explains how the results of the activities influence program cost-effectiveness; and
(5) describes the performance incentive that the Program Administrator seeks to collect.
The filing of very detailed 2011 annual reports, using a common template, represents a
milestone achievement by all PAs, as such reports contain a wealth of new EM&V data and
demonstrate historically high 2011 savings levels, based on objective evidence.
J.
2011 Energy Efficiency Mid-Term Modifications, D.P.U. 10-140 through 10-150
Each Program Administrator individually filed MTMs to its initial three-year energy
efficiency plan for effect in calendar year 2011 (“2011 MTMs”) on or about October 29, 2010,
pursuant to § 3.8 of the Department’s D.P.U. 08-50-B Guidelines and the Department’s Gas
Order and Electric Order. The PAs developed their 2011 MTMs based on a set of four
“operating assumptions” which were based on their interpretation of the Guidelines as set out in
D.P.U. 08-50-B, particularly Guideline В§3.8.2 which relates to the timing and substantive
requirements for MTMs.
15
In D.P.U. 08-50-C, the Department adopted a template, developed by a Department-convened working
group, to be used by the Program Administrators in preparing their performance reports. D.P.U. 08-50-C at
3-4.
64
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 70 of 274
The 2011 MTMs submitted to the Department included: (1) a Petition; (2) an Executive
Summary; (3) Savings, Budget, and Performance Incentive Modifications pursuant to В§ 3.8 of
the Guidelines; (4) the 2011 EM&V Plan; (5) a 2011 Performance Incentives Proposal; (6)
Pilots; (7) a Cost-Effectiveness Analysis; (8) Updated 08-50 Tables; (9) the Technical Reference
Manual- 2011 Plan Version; and (10) Appendices. In addition, the PAs responded to numerous
statewide and individual information responses from the Department and intervenors. Finally
and significantly, on December 14, 2010, the Council adopted a resolution in support of the 2011
MTMs.
On April 15, 2011, following comprehensive negotiations, the PAs, DOER, the LowIncome Weatherization and Fuel Assistance Network, Massachusetts Energy Directors
Association, the Low-Income Energy Affordability Network and Environment Northeast jointly
filed for approval with the Department a Memorandum of Agreement (“MOA”) intended to
resolve all issues related to the respective requests for the 2011 MTMs. The MOA resolves
eleven docketed matters of first impression and has the support of a broad array of stakeholders,
including the approval of the Council. On July 1, 2011, the Attorney General filed comments in
the 2011 MTM proceedings, making a number of recommendations but not opposing approval of
the MOA by the Department.
K.
2012 Energy Efficiency Mid-Term Modifications, D.P.U. 11-106 through D.P.U. 11116
Each Program Administrator individually filed MTMs to its Three-Year Energy
Efficiency Plan (“Plan”) for effect in calendar year 2012 (“2012 MTMs”) on October 31, 2011,
also pursuant to § 3.8 of the Department’s D.P.U. 08-50-B Guidelines and the Department’s Gas
Order and Electric Order.
Like the 2011 MTMs, the 2012 MTMs submitted to the Department included: (1) a
Petition; (2) an Executive Summary; (3) Savings, Budget, and Performance Incentive
Modifications pursuant to В§ 3.8 of the Guidelines; (4) the 2011 EM&V Plan; (5) a 2011
Performance Incentives Proposal; (6) Pilots; (7) a Cost-Effectiveness Analysis; (8) Updated 0850 Tables; (9) the Technical Reference Manual- 2012 Plan Version; and (10) Appendices. In
addition, the PAs have responded to numerous statewide and individual information requests
from the Department and other intervenors. Finally and significantly, on December 12, 2011,
DOER filed with the Department the Council’s resolution in support of the 2012 MTMS, which
was adopted on November 8, 2011.
On May 2, 2012, the Department approved a Partial Settlement on Scope of the
Proceedings, submitted jointly by the PAs and the Attorney General , DOER, and the LowIncome Weatherization and Fuel Assistance Program Network, the Massachusetts Energy
Directors Association, the Low-Income Energy Affordability Network (collectively, “Network”),
and Environment Northeast. Accordingly, any issue with respect to the use of estimated avoided
costs based on the 2011 Avoided Energy Supply Costs in New England: 2011 Report (July 21,
2011, amended August 11, 2011) (“2011 AESC Study”) and estimated non-energy benefits (also
known as non-energy impacts) based on the Massachusetts Special and Cross-Sector Studies
Area, Residential and Low-Income Non-Energy Impacts (“NEI”) Evaluation (August 15, 2011)
(the “NEI Evaluation”) would not be addressed in the 2012 MTM proceedings.
65
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 71 of 274
L.
D.P.U. 08-50-D
On October 19, 2012, the Department issued an order on bill impacts, explaining that the
pace at which the Program Administrators acquire all available cost-effective energy efficiency
resources “is moderated in part by the requirement that the Department consider the effect of any
rate increases on residential and commercial customers bills before the approval of ratepayer
funding for energy efficiency programs.” Energy Efficiency Guidelines, D.P.U. 08-50-D, Order
on Bill Impacts at 9 (2012). 16
The Department acknowledged the efforts of the D.P.U. 08-50 Bill Impact Working
Group, a large group of stakeholders who developed various bill impact models consistent with
Department directives in D.P.U. 08-50. Id. at 10. The Department, however, declined to adopt
the bill impact models under discussion. Id.
The Department concluded “that the model suffers from at least two deficiencies that
preclude [the Department] from using it in analyzing energy efficiency bill impacts.” Id. The
Department explained that “the electric efficiency model requires the Program Administrators to
make assumptions . . . [that] significantly compromise the reliability and accuracy of the model’s
results.” Id. at 10-11. The Department determined that, “notwithstanding the great effort
devoted to this task, stakeholders were unable to devise a way to meaningfully analyze bill
impacts for program participants using this model.” Id. at 11.
Second, and more importantly, the Department recognized that, “because of its long-term
focus, the D.P.U. 08-50 bill impact model is not an appropriate means to satisfy [the
Department’s] statutory mandate to consider the effect of any rate increases on residential and
commercial customers. Id. Instead, the Department determined that “this mandate is best
satisfied through a traditional bill impact analysis which, with its short-term perspective that
isolates the effect of a proposed change in the EES, will provide an accurate and understandable
assessment of the increase that will actually appear on customers’ bills.” Id. The Department
agreed “with the stakeholders who argue that, when considering the reasonableness of a shortterm bill impact from energy efficiency activities, it is important to look at it the long-term
benefits that energy efficiency will achieve.” The Department stated that the “long-term benefits
of energy efficiency are fully documented by the Program Administrators and reviewed by the
Department and stakeholders in the context of evaluating program cost-effectiveness” and that
the Department will consider bill impacts through “the lens of the long-term benefits that energy
efficiency can achieve.” Id. at 11-12 (citations omitted).
16
“Determining a reasonable pace for a sustained acquisition requires the Program Administrators and the
[Energy Efficiency Advisory] Council (in developing the three-year plans) and the Department (in
reviewing the three-year plans) to strike an appropriate balance between several factors, including:
(1) identifying the potential level of cost-effective resources currently available; (2) exploring ways in
which this level can be increased; (3) assessing the capability of the energy efficiency vendor and
contractor industry to support increased program activity; and (4) assessing the capacity of the Program
Administrators to administer increases in program activity efficiently and effectively. The Department
must take into consideration an additional factor: the rate and bill impacts that result from increased
program activity.” Id. at n.11 (citations omitted)
66
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 72 of 274
The Department directed the PAs to conduct bill impact analyses going forward for energy
efficiency participants as well as non-participants. This methodology is discussed in more detail
in Section III.E.
67
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 73 of 274
III.
THE THREE-YEAR PLAN
A.
Core Benefits and Cost-Effectiveness
1.
Energy and Demand Savings
The savings goals and program budgets set forth in the body of this Plan are presented on
an aggregate, statewide basis by program. In the D.P.U. 08-50 table format, each Program
Administrator has set forth its own recommended savings and budget levels for the three-year
period commencing January 1, 2013, consistent with the overall goals and budgets developed in
the statewide Plan review process, which are included as supplemental enclosures with this Plan.
The statewide Plan review process is a phased process that first requires the filing of a joint
statewide plan by all Program Administrators in April, followed in October by individual PAspecific plans, after the conclusion of the review process of the statewide plans at the Council.
G.L. c. 25, §§ 21(b)-21(d). 17
In developing the proposed statewide goals and budgets in this Plan, the Program
Administrators first submitted goals and budgets on April 30, 2012 and revised, updated goals
and budgets on July 2, 2012 and September 19, 2012. The Program Administrators discussed
these goals and budgets among themselves and with the Council and the Council’s Consultants
and have considered feedback on the April 30th, July 2nd, and September 19th versions, as well as
important new EM&V results and information described further below. For the September draft,
each Program Administrator was tasked with submitting to the full group of Program
Administrators its own PA-specific proposed savings goals and budgets for the three-year period.
These proposals were subject to an internal review and discussion process, as described in
Section III.D.2 that allowed for adjustments to be made by all Program Administrators based not
only on peer review, but also upon the presentations made at the Council meetings by the
Consultants and based on discussions with stakeholders, including DOER. Subsequent to the
September draft, and in advance of the filing of this Plan, the Program Administrators performed
the same proposal and review process. Further, the PAs engaged in intensive discussions
regarding savings goals, budgets, benefits, and incentives with DOER, the Attorney General, and
the Consultants, culminating in the Term Sheets. The savings goals and budgets presented on a
statewide basis by the Program Administrators in this Plan represent the results of that
collaborative process. As noted in the Term Sheets, “[s]avings goals are set on the path to satisfy
the Green Communities Act (“GCA”) mandate to capture all available cost-effective energy
efficiency, with consideration of sustainability and bill impacts, while supporting the
achievement of the emissions reductions called for in the Clean Energy and Climate Plan
(“CECP”). NU and National Grid have shown leadership by proposing savings goals that exceed
the statewide total savings targets of 2.50% in 2013, 2.55% in 2014, and 2.60% in 2015, and all
Program Administrators (“PAs”) have contributed to committing to unprecedented statewide
savings goals.”
While each Program Administrator is increasing its aggregate three-year saving goals and
budgets relative to historic aggregate three-year levels, the levels of these increases will not be
17
This Plan is being filed on November 2 due to recovery efforts in the aftermath of Hurricane Sandy. The
Department, DOER, and the Attorney General have reviewed this two day delay.
68
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 74 of 274
directly proportionate across all Program Administrators. The increases that are set forth in each
Program Administrator’s PA-specific filing reflect the unique characteristics of each Program
Administrator’s service area and the specific needs of its customers and are appropriate for 20132015. The Program Administrators’ have aggregated savings goals and budgets presented
individually by the Program Administrators in their PA-specific filings that are consistent with,
and flow out of, the overall goals developed in the statewide Plan review process. 18 Please see
Section III.D for the annual savings goals proposed by the Program Administrators in this Plan,
on a per sector basis, by year and in total. Please also see Appendix C for statewide D.P.U. 0850 tables for budgets, savings, benefits, and cost-effectiveness.
2.
Environmental Benefits
In addition to economic benefits, energy efficiency resources bring significant
environmental benefits including reduced air pollution and improved air quality in Massachusetts
and in the region from the reduction in the amount of electricity and natural gas required to run
the Commonwealth’s economy, as well as other resource benefits such as oil savings and water
savings. The more efficient homes, businesses and schools are the less energy and other
resources they are likely to consume. Decreasing energy consumption results in less demand for
energy from fossil fuel power plants and natural gas pipelines. By reducing plant operation time,
emissions of air pollutants and greenhouse gases can be reduced. In addition, Massachusetts can
become a more cost-efficient place in which to live and work.
Generating electricity from non-renewable fossil fuels (e.g., coal, oil or natural gas)
produces nitrogen and sulfur oxides - two of the six “criteria pollutants” defined by the Clean Air
Act and identified as air quality indicators by the U.S. Environmental Protection Agency.
Nitrogen oxides are precursors to ozone, a primary component of summer smog. In addition,
nitrogen and sulfur oxides in particulate form reduce visibility and are associated with public
health problems such as asthma; both air pollutants are linked to acid rain. Reducing the amount
of fossil fuel needed to run power plants through the adoption of energy efficiency reduces the
amount of nitrogen and sulfur oxide pollution emitted into the atmosphere. In addition to
providing cleaner air and water for Massachusetts, the Plan’s programs will provide climate
benefits in the form of reduced greenhouse gas (“GHG”) emissions.
Collectively, the programs contained in this Plan are expected to provide three-year
electric annual savings of 3,705,368 MWh and electric lifetime savings of 40,271,670 MWh, and
three-year gas annual savings of 72,011,183 therms and gas lifetime savings of
938,314,079 therms. Based on the region’s average power plant emissions rate, these lifetime
savings are the equivalent to reductions in air emissions of 25,602,440 short tons of GHG,
18
Program Administrators are not required to make all changes or revisions recommended by the Council in
filing their PA-specific plans. G.L. c. 25, В§ 21(c)-(d)(1). It is the plan and goal, however, of each Program
Administrator to be able to support in full the statewide Plan that ultimately results from the Council review
process. The Program Administrators seek full PA consensus on the statewide Plan, as well as unanimous
Council approval. Each Program Administrator must necessarily reserve its statutory rights in the event of
unexpected developments in the Council review process that it does not believe are consistent with the best
interests of its customers, but it is the goal of Program Administrators that their PA-specific filings be built
upon and consistent with the statewide Plan.
69
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 75 of 274
29,446 short tons of SO2, and 10,393 short tons of NOx. In addition, these programs will
provide non-electric and non-gas benefits such as reductions in fuel oil and water use.
Under climate cap and trade programs such as RGGI and any potential federal program,
and the Commonwealth’s climate change initiatives under the GWSA, investment in energy
efficiency is recognized as the most effective cost-containment and climate protection tool of the
Commonwealth. Indeed, the Program Administrators expect that some portion of the three-year
Plan’s funding will come from the proceeds of the sale of RGGI allowances. Investing cap and
trade proceeds in energy efficiency lowers energy consumption, which reduces GHGs and the
demand for allowances. The result is a lower price for carbon allowances and lower overall cost
of the cap and trade program.
3.
Net Benefits and Cost-Effectiveness
The Program Administrators have projected the expected benefits and costs associated
with this statewide Plan consistent with the requirements of D.P.U. 08-50-A, in which the
Department reaffirmed that “the Total Resource Cost test is the appropriate test for evaluation of
the cost-effectiveness of ratepayer-funded energy efficiency programs.” D.P.U. 08-50-A at 14.
To conduct the TRC test, Program Administrators routinely update their benefit/cost screening
models to reflect new assumptions relating to program costs and benefits, the discount rate, the
general rate of inflation, and avoided costs. In general, the benefit categories in the TRC test
include the value of energy savings, gas and electric system benefits, and other measurable
benefits (for example, participant resource benefits, participant non-resource benefits and
benefits due to measurable market effects).
Costs included in the TRC test include all Program Administrator costs and program
participant costs. Program Administrator costs include program implementation expenses,
evaluation costs, proposed performance incentives, and the tax liability for performance
incentives. Program-participant costs include initial costs incurred by the customers as a result
of their participation in the program.
The benefit/cost screening model uses all of this data to calculate the present value of the
program benefits and costs, and then calculates ratios of these values to produce benefit/cost
ratios (“BCRs”) for the TRC test. The present value of costs and benefits is calculated over the
expected duration of the useful life of the measures installed in the program.
The tables below summarize the expected benefits, costs, and BCRs at the sector level for
the portfolio of programs the Program Administrators propose to implement over the three-year
period. For more detailed information on savings, budgets, and benefits, please see tables in
Section III.D below and Appendix C.
70
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 76 of 274
Electric Program Administrators
BENEFIT-COST RATIOS
Sector
Residential
Low-Income
C&I
TOTAL
2013
2014
3.12
2.08
3.88
3.50
2015
3.21
2.16
4.27
3.77
2013-2015
3.27
2.16
4.27
3.79
3.20
2.13
4.14
3.69
Gas Program Administrators
BENEFIT-COST RATIOS
Sector
Residential
Low-Income
C&I
TOTAL
2013
2014
1.53
1.65
2.24
1.77
2015
1.55
1.66
2.28
1.80
2013-2015
1.57
1.66
2.42
1.86
1.55
1.66
2.31
1.81
The Program Administrators note that for cost-effectiveness screening purposes they are
utilizing the 2011 Avoided Energy Supply Cost Study (“AESC Study”) and current Non-Energy
Impact (“NEI”) study. 19 Certain NEIs have undergone a collaborative process of review by the
Program Administrators, the Council’s Consultants and the LEAN. The cost-effectiveness
screening utilized in this filing reflects the most current NEI information resulting from this
collaborative process and is supported by LEAN, the Council’s EM&V consultant and the
Program Administrators. The Program Administrators also note that, in agreement with LEAN,
the PAs plan to study low-income health benefits in 2013-2015. With respect to carbon
compliance cost items, the current AESC Study is being utilized, without any additional carbon
compliance proxy value as directed by the Department in its Order on Program Net Savings and
Environmental Compliance Costs in docket D.P.U. 11-120-A. Also, the Program Administrators
will continue to review possible approaches to coordinate updates or new avoided cost studies in
an optimal manner. One idea under consideration is examining the possibility of keeping
avoided cost values in place for a full three years that is synchronized with the three years of the
applicable plan, as opposed to having mid-term updates for avoided cost values. Given the
regional nature of avoided cost study work, the consideration of such an approach is necessarily
complex and multifaceted.
The PAs are committed to perform a follow-up study on the level and accuracy of
Demand Reduction Induced Price Effects (“DRIPE”) as set forth in the 2011 Avoided Energy
Supply Cost Study, and as utilized as an economic benefit in the TRC test. This study will help
19
Because the AESC Study’s Energy DRIPE estimates extend only through 2013, the Program
Administrators extrapolated 2014 and 2015 Energy DRIPE consistent with the methodologies and
assumptions of the AESC Study.
71
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 77 of 274
inform and optimize the accuracy of DRIPE in future
avoided cost studies, which is a continued and important
priority for the Attorney General, DOER and the PAs,
as is the accuracy of all components of the TRC test.
The DRIPE study will not affect the performance
incentive pool set forth herein. This DRIPE study is
expressly called for in the Term Sheets.
4.
Gas and Electric Program Integration and
Coordination
a. Focus on Seamless Delivery
The PAs remain committed to a continuous
focus on improving the customer’s participation
experience. Over the next three years, the Program
Administrators will continue to work collaboratively to
increase the seamless delivery of gas and electric energy
efficiency programs. The electric and gas PAs are
working together to implement processes and
procedures that will lead to increased coordination when
providing electric and gas energy efficiency services to
customers. Participation in management committee
meetings by each Program Administrator allows for
regular communication and real time refinement of
programs and the streamlining of work with regard to
conducting such refinements. In addition, the Program
Administrators continue to improve the working group
structures dedicated to each program delivery area in an
effort to share best practices and to discuss the relative
merits of alternative “go-to-market” strategies (i.e., the
mechanism by which the Program Administrators
propose to deliver energy efficiency to customers) and
program needs.
Most recently, the Program
Administrators have introduced a combined gas and
electric working group for the C&I sector to handle and
improve upon any program discrepancies or
communication issues between gas and electric program
delivery.
The Program Administrators will also focus on
enhanced integration of gas and electric measures on
program applications. In addition, the PAs will provide
continued formal statewide gas and electric integration
training to staff with the purpose of: (1) increasing
networking among the PAs so the electric and gas PAs
can meet with their counterparts, increasing the ability
72
Interplex
Metal Logic:
Comprehensive Gas
and Electric Project
Interplex Metal Logic in Attleboro, MA
partnered with National Grid to perform
energy efficient equipment upgrades to
help reduce energy costs at the facility.
A combination of high efficient lighting,
a variable displacement air compressor,
variable frequency drive motors, an
energy management system and an
efficient HVAC were installed resulting
in gas and electric savings, a reduced
impact on the environment and
improved efficiency of their facility.
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 78 of 274
to share knowledge; (2) training electric staff on how they may identify gas measures and
training gas staff on how they may identify electric measures (and potential leads) for the partner
PA when on customer site visits; (3) developing a closer partnership between the Cool
Smart/GasNetworks’ rebate initiatives; and (4) development of an Integrated Gas & Electric
Working Group.
An additional key element of greater gas and electric integration will be expanding the
network of capable trade allies through more active vendor training and outreach. The program
descriptions set forth in Section III.F illustrate many of the ways in which the Program
Administrators have implemented a coordinated gas and electric delivery system. The PAs will
continue to work toward a seamless integrated delivery process throughout the next three-year
plan.
b. Ongoing Work of Management Committees
The Program Administrators have developed a management committee structure to
facilitate the process of enhanced integration and coordination between gas and electric
programs. These efforts are focused on sharing best practices, identifying and sharing innovative
strategies that drive success in program deployment efforts, identifying and securing costefficiencies where joint efforts may result in reduced costs compared to independent efforts, and
jointly addressing other key issues. Through development of the Residential Management
Committee (“RMC”) structure and C&I Management Committee (“C&IMC”) structure, the
Program Administrators are effectively able to work toward implementation of seamless
program designs and delivery strategies to achieve savings goals. In addition, the Evaluation
Management Committee (“EMC”) provides a forum for EM&V discussions and decision
making, and the Low-Income Best Practices Committee, instituted originally by LEAN,
continues to offer opportunities for various stakeholders to discuss program implementation, new
measures and other matters related to the PAs’ low-income programs.
The RMC and C&IMC each meet bi-weekly (or as needed). From these meetings, the
Program Administrators are able to: (a) stay up to date on the key energy efficiency activities of
other Program Administrators; (b) integrate and coordinate energy efficiency implementation
activities and efforts by all Program Administrators; (c) develop statewide marketing and media
campaigns with easy-to-understand communications for all customers; and (d) review and
discuss best practices and integration/coordination efforts in other jurisdictions to maximize
collaboration efforts and build on the experiences in other regions. The agenda for management
committee meetings may be set based on any of the following:
•
•
•
•
•
•
Special attendees
Pertinent issues that arise
Requests of committee members
Council reporting/presentations that need to be developed
Unsolicited proposals that are submitted for review
Updates that are required from specific statewide working groups, evaluation, or
marketing teams
73
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 79 of 274
The EMC serves as a steering committee for statewide evaluation issues, providing
guidance and direction to each of the evaluation research areas. The EMC will also help plan,
prioritize and delineate the research studies to be undertaken over the three-year plan period.
First organized in spring 2012, the EMC has already held seven meetings and successfully
developed a mechanism to track the progress of evaluation studies and a straw proposal of best
practices in research area management, to build on lessons learned during the first three-year
plan. The Program Administrators believe that the EMC will be an effective tool in 2013-2015
to facilitate evaluation efforts, enhance communication and improve EM&V efforts for the
benefit of customers.
The statewide management committees established by the Program Administrators over
the past three years play an integral part in the continued improvement and offering of gas and
electric program integration and coordination. These management structure and decision making
processes will allow the Program Administrators to focus efforts more proactively over the
course of the next three-year plan, specifically with regard to exploration of new program
delivery models and expanded service offerings for customers. The invention, organization and
ongoing successful work of these committees across multiple sectors is a uniquely
Massachusetts-based success story and demonstrates the Program Administrators’ conviction
and commitment to not only adopting and sharing best practices, but to driving new program
enhancements and new best practices.
5.
Additional Benefits
a. Reduction in Peak Load
Energy efficiency efforts often provide capacity savings in addition to energy savings.
These capacity savings and benefits are reflected under the cost-effectiveness screening efforts
described in Section III.A.3 above.
b. Economic Development and Job Growth/Retention
i. New England Clean Energy Foundation Study
The Program Administrators have engaged the New England Clean Energy Foundation
(“NECEF”) to estimate the number of full-time equivalent workers (“FTE”) directly involved in
selected activities related to the implementation of the approved programs for residential, low
income and C&I energy efficiency during calendar year 2011. To assure that the NECEF study
team could make accurate estimates, the PAs provided significant data on residential and C&I
participation and expenditures.
The NECEF study, “An Estimate of Direct Full-Time Equivalent (FTE) Employment in
2011 Supported by Mass Save Energy Efficiency Programs”, estimates that a minimum of 2,300
FTE workers were directly involved in the selected energy efficiency implementation activities
in Massachusetts in 2011.
The study report details the breakdown of these FTEs among residential, low-income
and C&I programs. The study also outlines the study methodology in detail and provides related
74
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 80 of 274
information on the structure of the PA energy efficiency programs, including appendices, noting
the names of many of the contractors involved.
Because the NECEF study is narrowly focused on direct FTEs in selected categories in a
specific calendar year, it does not capture all direct jobs in energy efficiency, and it does not
seek to estimate indirect jobs, and “induced” employment. The targeted focus of the study,
however, has produced information that will be especially helpful to the Commonwealth’s
workforce development community in their efforts to understand the number and type of direct
FTEs working to implement PA energy efficiency initiatives in the Commonwealth.
Draft findings were reviewed by expert evaluators and by professional members of
appropriate committees involved in implementing residential and C&I programs, and the NECEF
study team responded to these comments and queries as they completed the final report.
The final report is included at Appendix P, Study 16.
ii. Contribution to Clean Energy Economy
The Massachusetts Clean Energy Industry Report 2012 (“Report”) published by the
Massachusetts Clean Energy Center has identified energy efficiency as responsible for 9.9
percent of the growth in the Clean Energy job sector of the Massachusetts economy between
2011 and 2012. See Report at p. 8-9. During the 2013-2015 Plan, energy efficiency vendors and
contractors funded in part by incentives under the Plan will continue to make a comparable if not
greater contribution to the clean energy economy and jobs in the Commonwealth.
B.
Progress towards Green Communities Act Requirements and Goals
1.
Acquisition and Assessment of All Available Cost-Effective Energy Efficiency
and Demand Reduction Resources
This Plan seeks to capture all available cost-effective energy efficiency for the three-year
period beginning January 1, 2013 pursuant to G.L c. 25, В§ 21 (b)(1), with the consideration of
factors and concerns noted at the Council and in Department Orders, including, but not limited
to, bill impacts, environmental benefits, and the need for sustainability. The GCA does not
define “all available” cost effective energy efficiency, and thus developing related values
requires a reasonable level of judgment. There is no single study or planning tool that can
reliably set forth such a value. Rather, a multifaceted approach is necessarily employed and
multiple reference points are considered. In determining the level of savings to achieve in order
to satisfy this mandate, the Program Administrators considered and weighed multiple factors,
including: (1) the plain language of the GCA; (2) the directives of the Council, including the
Council’s Priorities of February 14, 2012, the Sense of the Council of June 12, 2012, the Action
Plans of June 18, 2012, and the Council Resolution of July 23, 2012; (3) the Department’s
Orders approving the Program Administrators 2010-2012 plans and the assessment contained
therein, (4) the Department’s Order in D.P.U. 08-50-A (including bill impact considerations);
(5) the Department’s Order in D.P.U. 08-50-B; (6) assessments of all available cost effective
energy efficiency noted below; (7) multiple studies and reports; and (8) the PAs’ experience in
implementing nationally-recognized energy efficiency programs for over two decades. The
75
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 81 of 274
Program Administrators met collaboratively on a frequent basis to determine the appropriate
savings goals and budgets to propose in this Plan. The Program Administrators also engaged in
numerous discussions with the Councilors and Consultants, culminating in the Term Sheets,
which have all helped establish statewide savings targets, performance incentives, and projected
program costs.
a. Experience in Field
First and foremost, the Plan has been designed based on the in-depth experience of the
Program Administrators in designing and implementing energy efficiency programs over more
than 20 years, and, more specifically, in the course of implementing the first three-year plans for
the period 2010-2012. This experience includes (1) understanding of the customers’
circumstances and the cost of implementing aggressive programs over a sustained period and (2)
knowledge that the PAs can very successfully deliver impressive savings levels in the field. This
experience also informs the PAs that as energy efficiency efforts yielding high savings become
more difficult to identify and achieve and as market penetration increases, there will be
challenges in achieving additional savings. Importantly, the Program Administrators are
factoring in upward pressures on the cost to achieve energy efficiency savings in 2013-2015,
especially as the result of EM&V results, the level of CHP projects currently foreseen, and
increased efficiency codes and standards that make the achievement of incremental efficiencies
through PA-sponsored programs more difficult. (Also, please refer to Section III.D.1 below for
more detailed discussion of cost drivers that have been identified by the Program
Administrators.) In short, the PAs’ experience in the field provides valuable lessons that inform
this planning process in a uniquely important way.
b. Point 380 Market Characterization
NSTAR and National Grid have led an effort to characterize the market for energy
efficiency during the term of the 2013-2015 Plan through a study performed by the consulting
firm Point 380. WMECO has similarly engaged Point 380. The Point 380 study results have
been, and will continue to be, used to inform the PAs “go-to-market” strategies by identifying
the industries, building types and end uses representing greater efficiency opportunities and thus
warranting relatively greater attention. The results also greatly support sales force planning and
resource allocation while enabling more relevant and effective value propositions to better meet
specific customers’ needs.
The Point 380 materials were shared with all Program
Administrators, who have each benefitted from this effort. NSTAR and National Grid made a
joint presentation to the Council summarizing the Point 380 study, which is available at
http://www.ma-eeac.org.
c. Synapse Assessment
The Plan has also been informed by a study performed for the Council by Synapse
Energy Economics of C&I customer perspectives on energy efficiency opportunities in
Massachusetts. The primary purposes of the study were to help the Council in understanding the
economic environment likely in New England over 2013-2015 and to assess the extent to which
C&I customers are likely to participate in Massachusetts energy efficiency programs over the
next few years. The Synapse study for the Council informed Program Administrators’ Plans in
76
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 82 of 274
that it forecasted an improving economy but not at dramatic levels; Synapse also forecasted that
economic recession conditions would not return. In developing the 2013-2015 Plan, this
information was a useful calibration point for the PAs with respect to their own views of current
and future economic conditions. In addition, the Synapse study provided qualitative information
that the PAs have used in program design to help foster more seamless delivery for gas and
electric customers. The study indicated that the payback period is the main criteria for
evaluating energy efficiency investments and often must be two years or less. In addition, it
found that a better understanding of customer participation types would provide the PAs with
useful information about where the untapped efficiency opportunities lie and how to pursue
them. The study also provided that encouraging customers to adopt a deeper level of efficiency
measures will require increased engagement from the PAs’ staff.
d. Review of EM&V Results
Working together and with the Council, the Program Administrators have undertaken
extensive EM&V efforts designed to ensure accuracy and accountability in program planning
and implementation and to guide the PAs as they focus on improving energy efficiency program
efforts. Section III.I of the Plan includes information regarding the comprehensive EM&V
efforts that have been undertaken to date, which has informed the Program Administrators’
program designs and savings goals for 2013-2015. EM&V efforts will continue throughout the
term of the Plan. As discussed below, EM&V results have been used by the Program
Administrators to more accurately forecast the actual savings resulting from their energy
efficiency activities, in particular, net savings resulting from these activities. EM&V results
indicate that strong savings are occurring as a result of the Program Administrators’ efforts, but
that savings, in particular for several gas programs, are not as high as originally forecasted. This
is an important factor in looking to establish goals for 2013 -2015.
e. Appreciative Inquiry Summit
The Plan takes into account the results of the Appreciative Inquiry Summit hosted by the
Program Administrators in May 2012. This PA-hosted summit, independent from the efforts of
the Council, provided a venue for a diverse array of nearly 300 key stakeholders, including
customers, civic leaders, contractors, key trade allies, energy efficiency experts, and others to
provide the PAs with insights to guide efforts designed to continue to create a culture of
sustainability in the Commonwealth.
The event provided an opportunity for customers and other stakeholders to contribute
their expertise, their opinions, and their experiences to help the PAs better understand their needs
and interests. Additionally, the attendees were offered an opportunity to better understand the
full breadth of activities being undertaken and planned by the PAs and to contribute to making
this Plan and its implementation more responsive and effective to make homes, businesses, and
organizations more energy efficient.
Participants articulated their needs and wishes with respect to energy efficiency and
developed specific recommendations for the future. The needs and wishes in those statements
have been considered and addressed in this Plan. Dominant themes emerging from participants
include: the need for more education and training of students and practicing energy efficiency
77
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 83 of 274
professionals to build a broader base of educated and capable consumers and providers; the need
to develop more targeted and customer-centric offerings and initiatives to specific subsets of
customers; and simplifying and improving the customer experience.
The PAs have developed a detailed report on the Appreciative Inquiry Summit that is
now posted on the Mass Save website for easy access to all participants.
f. Council Meetings
The Program Administrators have also considered presentations made and materials
presented at Council meetings both by the Councilors, their Consultants, industry stakeholders
and the general public. The level of interest and commitment evidenced by these presentations
confirms that opportunities for savings remain in Massachusetts because its citizens embrace a
culture of energy efficiency and sustainability. At a more specific level, these comments have
suggested, among other things, program design enhancements that the Program Administrators
believe will help them target and achieve new savings in 2013-2015. For example, public
comments have helped shape the Program Administrators’ new initiative targeting economically
challenged areas and their new approaches to targeting the healthcare sector and municipalities.
Comments from the DEP have been particularly helpful in identifying opportunities in the
wastewater facility sector.
g. Consultant Assessment
The Program Administrators have reviewed the energy efficiency potential assessment
developed and prepared by the Council’s Consultants and presented at the March 13, 2012
Council meeting. After a careful review of this assessment, the PAs note that differences are
driven by the following core issues:
•
The assessment was conducted before the most recent set of EM&V results were
available. Therefore, the Consultants were not able to take into account evolving
baselines or evaluation findings when completing their review of available secondary
data. In the Program Administrators’ view, this understandable impediment has resulted
in an overstatement of available cost-effective opportunities, especially in the gas sector.
•
The Program Administrators project that the cost of savings to achieve the stretch goals
in this Plan are higher than proposed by the Consultants in their assessment. The
Program Administrators have carefully reviewed proposed cost drivers and have
summarized those drivers in section III.D.1 below. The Program Administrators have
shared their analysis with the Consultants and anticipate continuing to work together.
•
The PAs believe that they will be able to have more effective and informed discussions
with the consulting team on their initial assessment given the existence of new EM&V
results and the extensive planning efforts reflected in this Plan.
Based on the PAs’ review of the Consultants’ assessment, the PAs have determined that the
assessment relies heavily on assumptions that have serious technical issues. The key analyses
utilized by the Consultants and the areas of concern that were identified are as follows:
78
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 84 of 274
•
The Marketing Opportunity Analysis (Point 380 Study) results are misapplied. This
analysis was framed to inform go-to-market strategies and not as a technical potential
study.
•
Based on conversations with customers, savings associated with an early retirement
opportunity have been overstated in the Consultants’ assessment.
•
The PAs have limited confidence in the applicability of the out-of-state potential studies
referenced in the assessment in view of the mature efficiency market in Massachusetts.
In addition, some of the referenced studies are dated and, as a result, do not take into
account changes in baseline energy use assumptions that are reflected in the Program
Administrator’s proposed savings goals.
These three technical concerns are discussed below.
•
Marketing Opportunity Analysis (Point 380 Study)
The objective of the analysis was to deliver relative market opportunity findings and was
neither designed nor executed in an appropriate fashion to meet needs of a potential study. The
study confirms that there are large opportunities in key segments and those opportunities are
being leveraged to inform PA go-to-market strategies. Although the study presented achievable
market opportunity in year one, this was necessary in order to demonstrate the relative
importance of sectors and measures only. The achievable market opportunity values presented
are not proportional to total achievable market opportunity and are intended only to forecast the
market opportunity for a given set of measures implemented in the near term.
The study was informed by PA-specific considerations such as past performance, budgets
and operating characteristics. Neither the speed of ramp-up nor slope of s-curve was defined.
Even minor discount rate changes could significantly impact aggregate potential estimates.
Furthermore, the study relies heavily on secondary data (note: primary data collection would
have been emphasized had total achievable potential been a key objective).
•
Early Retirement Opportunity Assessment
It is critical to understand that customers do not make the decision to replace functioning
equipment based on efficiency alone. Customers need to “assume” that the equipment could
breakdown anyway in the near future. Barriers to early retirement include:
o Replacement cost is very high compared to savings and maintenance and repair
costs which are relatively modest in many cases
o Best case scenarios have paybacks of 10-20 years
o There is no “burning platform” for customers when equipment is still functioning
o Furnaces & boilers are not 1-1 replacements, with larger scope, cost and risk
o Code compliance issues
•
Additional Referenced Studies
79
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 85 of 274
Massachusetts - The GDS study was completed in 2009 and thus did not account for
significantly lower gas avoided costs, which are used to determine cost-effectiveness. In
addition, this study did not take into account changes in baseline energy use or evaluation study
results that are now reflected in proposed efforts.
Vermont - While the study was conducted for a state in the same region, the demographics and
firmographics of Vermont differ significantly from Massachusetts, which limits the applicability
of that study’s findings in Massachusetts.
Rhode Island - A significant portion of projected achievable savings were from:
•
Behavioral programs not yet launched in Rhode Island where evaluated results could not
be used to inform performance as is the case in Massachusetts.
•
Price response programs included in the assessment that are not designed and, in
addition, may not be compatible with energy efficiency.
•
New/emerging technologies that were identified as measures that had technical potential,
but were not yet economical.
Furthermore, no modeling was used to demonstrate how specific items that are not
currently economically justified would become economical. Cost modeling of future
technologies was not informed by research and likely underestimates the actual costs needed to
realize the “achievable” potential. The report indicates that it is based on conservative
assumptions, but that assertion is supported with only logical arguments as opposed to empirical
evidence/facts.
As noted above, now that EM&V results are in and cost drivers are better understood, the
Program Administrators are engaging in more refined, informed, and effective discussion with
the consulting team about its assessment. The Program Administrators remain open-minded to
suggestions that will increase opportunities to deliver available cost-effective energy efficiency
savings.
h. Re-Assessment of Savings Goals following June, July, August, and September
Council Meetings
At its June 12, 2012 meeting, the Council requested that the PAs reassess the savings
goals in their April 30, 2012 short form submission. The Council stated:
Reassessment of Savings Goals—where appropriate, considering all-costeffective mandate, the Council’s priorities, including sustainability, cost drivers
and bill impacts, determine whether the PAs can increase savings goals for both
gas and electric program portfolios, supported with scenario analysis where
helpful.
At its July 23, 2012 Council meeting, and then at its September 27, 2012 meeting
reviewing the September 19, 2012 draft Plan, the Council, while noting much positive progress,
80
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 86 of 274
requested that the PAs continue to assess savings goals and increase them even further. Each of
the PAs has reassessed savings goals consistent with these requests, after expressly considering
the factors enumerated by the Council. In this Plan, the Program Administrators provide detailed
discussion of their review of the all cost-effective energy efficiency mandate (Sections I.F.3,
III.A.3, III.B.1, and III.D), the Council priorities (Section I.G), sustainability (Sections I.G, III.B,
and III.D), cost drivers (Section III.D.1), and bill impacts (Section III.E). In addition, each PA
internally conducted multiple scenario analyses examining measure mixes, different costs, and
different savings levels. The PAs engaged in extensive collaborative discussion with each other,
considering multiple data points, including the Council’s Consultants’ recommended savings
levels, planning assumptions, and sharing of best practices. As indicated in Section III.D.3 and
Appendix H, a number of PAs with unique service area challenges expressly reviewed
scenarios showing potential bill impact effects associated with materially higher savings levels
and have presented the results of such analyses in summary format. 20
Another essential factor that was considered by the PAs after the submission of the April
30, 2012 short form submission was the application of new EM&V results. As effectively
presented during the June 25, 2012 EM&V webinar, new study results that became available
after the April 30, 2012 short form submission for both electric PAs (in particular with respect to
the Home Energy Services initiative) and for gas PAs (in particular with respect to large C&I
projects and weatherization projects, as well as with respect to certain equipment rebates) have
materially reduced savings estimates for a number of important initiatives offered by the
Program Administrators. As described in the cost drivers section in Section III.D.1 above, the
effect of these results is to make it more challenging and more costly to achieve the savings
levels presented in the April 30, 2012 short form submission. In short, maintaining the savings
goals presented in the April 30, 2012 short form submission became much more challenging.
Following the Council’s September 27, 2012 meeting, the PAs continued to engage in
rigorous discussions with the DOER, as chair of the Council, the Attorney General and the
Council’s consultants. As a result of these discussions, these parties were able to reduce, and
then eliminate, the gaps in their differences with respect to savings, benefits, budgets and
incentives for 2013-2015 in the context of an overall, negotiated resolution, with “puts and
takes” by all parties. The agreements in principle reached with respect to these core elements of
the Plan are set forth in the Term Sheets, which are scheduled to be presented to the full Council
for a supportive resolution on Monday, November 5, 2012. This Plan is designed to be
consistent with each of the elements of the Term Sheets, and to reflect the culmination of
ongoing Council discussion and review that began even in advance of the original April 30, 2012
short form Plan.
The PAs have proposed the most aggressive set of integrated electric and gas savings
goals in the nation, reflecting the PAs’ deep commitment to fulfilling the mandates of the GCA,
and their reasoned confidence in their excellence in in-the-field implementation. See Appendix
D. Notably, for electric PAs, the Commonwealth’s two largest electric companies, National Grid
and NSTAR, as well as WMECO, are each proposing escalating savings levels of 2.5 percent,
20
As indicated at the June 12, 2012 Council meeting, there are multiple different methods of scenario
planning that are possible.
81
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 87 of 274
2.55 percent, and 2.6 percent of retail sales, which are more challenging goals than have been
historically set. Both Cape Light Compact and Unitil are proposing very aggressive savings
goals that reflect the unique challenges of their service areas, as have been recognized previously
by the Council. Electric PAs have increased savings goals (and decreased costs) in response to
comments and suggestions on the July 2, 2012 and September 19 draft Plans. For gas PAs,
based on Council and DOER requests for increased savings targets from the levels proposed on
July 2, 2012 and September 19, 2012, the Program Administrators have proposed escalating
statewide savings goals of 1.07 percent, 1.13 percent, and 1.14 percent of retail load, which goals
are supported by the Term Sheets. These targets are supported by the Council’s Consultants.
Each of NSTAR and National Grid is proposing savings levels in excess of these challenging
benchmarks. Moreover, Columbia Gas of Massachusetts, The Berkshire Gas Company, New
England Gas Company, and Unitil, have each increased overall savings goals as compared to the
levels proposed in the July 2, 2012 submission based upon the Council’s and DOER’s requests to
reassess savings goals and each Company’s continuous self-assessment.
In sum, each of the PAs has carefully considered and reassessed its savings goals in light
of the Council’s request and in light of the factors enumerated by the Council, as well as multiple
other factors described in this Plan. The PAs emphasize that this Plan is an integrated whole and
each of the multiple elements set forth in the Plan relate to a certain degree with the goal setting
process. The process is iterative, data-reliant, integrated, and involves a level of judgment after
consideration of multiple data points. The PAs have aggressively looked to see how they can
increase savings goals while also remaining cognizant of the additional priorities and emphases
enumerated by the Council. The nation-leading and aggressive savings goals set forth in this
Plan reflect those intense efforts, and the PAs’ reasoned confidence, as a statewide team, in their
abilities to deliver benefits on an integrated basis to customers at levels that lead the country.
Importantly, the goals demonstrate the PAs’ careful consideration of the Council’s requests on
July 23, 2012 and September 27, 2012 and their responsiveness to these requests. In short, the
Program Administrators are proposing integrated savings goals that have never been matched for
any similar sustained effort—they are helping Massachusetts to lead the nation in energy
efficiency.
2.
Key Factors, Challenges and Market Barriers
While seeking all available energy efficiency and demand reduction resources that are
cost-effective or less expensive than supply, the PAs considered certain key factors, challenges
and market barriers in their assessment of the achievable level of energy efficiency set forth in
the Plan. These factors were included in the assessment of all available cost effective energy
efficiency in the 2010-2012 three year plan supported by the Council and approved in the Orders.
Accordingly, they have been considered by the Program Administrators in developing the
proposals set forth in this Plan.
a. Market Barriers
This Plan, which strives to obtain all available cost-effective energy efficiency, is
grounded in an understanding that market barriers exist and deliberately strives to address
significant market barriers and policy concerns.
82
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 88 of 274
To be successful in energy efficiency, the programs must bridge the five major market
barriers of awareness, availability, accessibility, affordability, and aversion to risk. These
barriers affect customers’ adoption of energy efficiency measures and the ability of Program
Administrators to achieve and obtain savings. This Plan outlines many initiatives that Program
Administrators feel are critical in bridging these five major market barriers.
•
Awareness is a barrier that historically was not confronted on a large scale, given capped
budgets, marketing, and outreach. This Plan recognizes that continued strong public
education, marketing, and outreach, including community-based efforts, will be needed to
achieve deeper and broader penetration. Deeper penetration refers to the promotion of
additional cost-effective technologies and strategies to capture comprehensive, wholebuilding savings among the traditional base of expected program participants. This
deeper penetration requires raising participants’ awareness and understanding of the
value of investing in additional measures that create increased savings per participant. In
addition to expanding marketing and incentive promotion strategies, this Plan
incorporates other strategies to overcome awareness barriers, with the goal of sustaining
and increasing the level of participation among eligible customers, i.e., making
participation broader. Broader penetration can include outreach to traditionally hard-toreach customer groups, including economically marginalized communities and groups
where English is not the first language.
•
Availability is a barrier when manufacturers either do not produce or do not effectively
market sufficient quantities of energy efficient products and services. Availability may
also be constrained by limited workforce or delivery mechanisms. The challenge for
manufacturers in the energy efficiency sector is to respond not only to the
Commonwealth’s demand for more efficient products, but also to demands for such
products nationally or even globally. This challenge is compounded by the economic
pressures which reduce manufacturers’ willingness to make additional investments.
From a workforce perspective, Program Administrators recognize that continued
workforce training and deployment is required to effectively deliver the programs. This
is not an insignificant barrier.
•
Accessibility is another market barrier which refers to the customers’ access to the
product. To mitigate this barrier, Program Administrators must continue to connect with
mid-stream market actors, such as distributors, to help ensure that products are displayed
and stocked in sufficient quantity. The program descriptions set forth in this Plan provide
for continued work with key market actors, and include campaigns for training and
marketing, as well as proposed community mobilization outreach strategies.
•
Affordability is a market barrier resulting from the initial cost of energy efficiency
solutions. Program Administrators are concerned that affordability remains a major
barrier and one that is more difficult to predict as customer buying patterns have changed
dramatically with the advent of more limited credit. The Plan attempts to mitigate this
barrier through the use of incentives, new delivery models for economically challenged
neighborhoods, as well as through the use of broadly accessible financing In some
cases, particularly with respect to gas energy efficiency efforts, the PAs are proposing to
83
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 89 of 274
increase incentives for measures so that the low commodity cost of natural gas does not
impede investments in cost-effective gas energy efficiency measures and services.
•
Aversion to Risk is a market barrier that describes customers who are unwilling to take a
chance on technologies that they perceive to be unproven. In order to address this
barrier, the Program Administrators seek to provide detailed, clear information to
customers about the direct benefits of energy efficiency measures. In some cases, this
information will be provided to customers in the form of a case study that highlights the
performance of proposed measures, helping to reduce the perceived risk associated with
energy efficient measures and practices.
b. Policy Issues
In addition to market barriers, it is important to also understand the policy issues that
need to be addressed to secure all available energy efficiency. These include economic,
sustainability, and regulatory issues.
•
Economic obstacles continue to be relevant in today’s environment. The Program
Administrators recognize the Plan’s tremendous value, but also understand that it is
important to consider the short-term rate impacts of the ramp-up of these programs.
Given the sensitivity to the cost of the programs, this Plan discusses the associated
preliminary expected bill impacts of program implementation. Traditional incremental
bill impact analyses, as well as participant analyses are provided for each Program
Administrator in the PA-specific filings. Detailed bill impact analyses for each Program
Administrator using traditional bill impact models are provided with each PA’s Plan and
will also contain the information required by the Department’s orders in D.P.U. 08-50-D.
•
Sustainability of the programs is an important consideration for the Plan and an
expressly repeated priority of the Council. Many advocates, including the Program
Administrators and the Attorney General, stress that in achieving all available energy
efficiency, the annual efforts must also strive to be sustainable for the long term. This
sustainability is vital to support the health of the economy, and the growth of the
workforce and infrastructure needed to ensure the long-term benefits of these efforts.
•
Regulatory Guidance includes the support of strong regulatory frameworks that
complement the Program Administrators’ ramp-up of programs. These frameworks
create a healthy regulatory infrastructure by which Program Administrators can
confidently advance programs knowing that there is clarity in the regulatory rules and
process and the opportunity to align shareholder objectives with public policy objectives.
The Department’s investigation in D.P.U. 11-120 is an ongoing example of the strong
commitment to regulatory guidance in Massachusetts, and the Program Administrators
will incorporate any outcomes from this proceeding into their plans as soon as practicable
after an Order is issued. The Program Administrators appreciate ongoing efforts of the
Department and other stakeholders to streamline regulatory processes associated with
energy efficiency, as evidenced in the D.P.U. 11-120 Phase II proposal.
c. Assessing Technical Potential
84
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 90 of 274
As noted above, the Program Administrators used multiple resources to build a robust
understanding of the potential for all available cost-effective energy efficiency and demandreduction resources. These efforts all are grounded in the definition of “Technical Potential” as
the complete penetration of all measures analyzed in applications where they are deemed
technically feasible from an engineering perspective. Technical Potential does not necessarily
take into account cost-effectiveness, budget constraints, or whether homeowners or businesses
are willing to undertake energy saving actions or investments
Economically Achievable Energy Efficiency Potential (“EAEEP”) is defined as that
portion of the technical potential that is cost-effective (either from a customer, societal, or total
resources perspective). As was endorsed in the 2010-2012 Plan as approved in the Orders, this
2013-2015 Plan aggressively targets all available cost-effective energy-efficiency resources, but
the Plan also takes in account program implementation constraints such as market and policy
barriers. Such barriers led to this Plan’s focus on obtaining all available cost-effective energy
efficiency in a manner that allows for a sustained effort and that does not create unacceptable bill
impacts, consistent with the Council’s Priorities, the Sense of the Council document of June 12,
2012, Department precedent and the PAs’ public service obligation to their customers.
Assessing potential takes into account impediments to program implementation,
including financial, political, and regulatory barriers that are likely to limit the amount of savings
that might be achieved through energy efficiency and demand response programs. It, therefore,
recognizes both the market and policy barriers. After more than two decades of successfully
implementing energy efficiency programs, the Program Administrators have an in-depth
understanding of these barriers and were able to integrate their knowledge of both market and
policy concerns to inform this Plan. The program incentive design, delivery models, and support
infrastructure developed by the Program Administrators and discussed throughout this Plan are
informed by a careful review of different types of potential.
3.
Allocation of Funds for Low-Income Programs and Education
Energy efficiency funds shall be allocated to customer classes in proportion to their
contributions to those funds, and, “at least 10 percent of the amount expended for electric energy
efficiency programs and at least 20 percent of the amount expended for gas energy efficiency
programs shall be spent on comprehensive low-income residential demand side management and
education programs.” G.L. c. 25, § 19(c). Based on the budget figures set forth in this Plan, for
electric Program Administrators, 11 percent of the total budget will be allocated to the electric
low-income residential sector for 2013-2015. Based on the budget figures set forth in this Plan,
for gas Program Administrators, approximately 21 percent of the total budget will be allocated to
the gas low-income residential sector for 2013-2015.
4.
Minimizing Administrative Cost
General Laws c. 25, В§ 19(a) requires the Department, when authorizing energy efficiency
programs, to ensure that such programs minimize administrative costs to the fullest extent
practicable. Administrative costs, also commonly referred to as Program Planning &
Administration (“PP&A”) costs, have traditionally been defined as all in-house and outsourced
costs associated with planning activities and program administration. These include costs
85
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 91 of 274
associated with developing program plans, and day-to-day program administration, including
labor, overhead costs, and any regulatory costs associated with energy efficiency activities.
As has been their historical practice, each of the Program Administrators is fully
committed to pursuing both internal and external opportunities to streamline the administration
of their energy efficiency programs and thus their associated administrative costs. To that end,
and within the context of the D.P.U. 08-50 Working Group, the Program Administrators initiated
discussions in 2010 to review the definition of administrative costs and the classification of the
costs in this category to ensure that all Program Administrators report such costs consistently.
The result of this effort is that, with one limited exception of the categorization of employee
salaries and related expenses, 21 consistent statewide cost categories are in place across all
Program Administrators. This allows all interested stakeholders to review administrative costs in
an objective manner.
The most significant factor in the PA approach to minimizing administrative costs is the
statewide collaborative process, which is used by the Program Administrators to coordinate
planning, the adoption of consistent programs and processes, program design, EM&V studies,
statewide marketing, regulatory proceedings, and the development and sharing of all best
practices. Sharing of these costs, which would otherwise be borne by each Program
Administrator individually, results in economies of scale that reduce the cost for each Program
Administrator. For example, joint releases of Requests for Proposals (“RFPs) lead to
minimization of administrative costs in that the cost for preparation and release of the RFP are
shared by the PAs. The Program Administrators also minimize administrative costs by
coordinating energy efficiency program delivery, where appropriate, with other customer service
activities such as customer acquisition, key account management and trade ally relationships.
Notwithstanding any appropriate coordination with other customer service departments, it
is necessary and appropriate for all Program Administrators to maintain a skilled and dedicated
administrative staff in order to ensure successful delivery of programs, compliance with the
GCA, timely responses to the directives of the Council, Department, and DOER; and
documentation and achievement of substantial savings. The Program Administrators seek to
balance the need to minimize administrative costs to the extent prudent with the need to
maximize program quality and oversight. Councilors have emphasized the need to devote
sufficient administrative resources to successfully implement the aggressive programs called for
in this Plan.
While the economies of scale and other steps taken by the PAs to minimize costs are
effective, and administrative costs incurred by the PAs are transparent and are presented in each
Program Administrator’s D.P.U. 08-50 tables, exact quantification of the minimization of
administrative costs is not possible in a meaningful way. This is because the continuous scaling
up and evolution of the Plans make it impossible to establish a solid baseline for a comparison.
21
For certain PAs, employee labor and related expenses are included in the PP&A, Marketing-Advertising,
Sales, Technical Assistance & Training, and Evaluation & Market Research categories, depending on the
employee’s responsibility; for other PAs, all employee labor costs and related expenses are included in the
PP&A category. This one limited difference is due to different historical practices and differing staff sizes
and staff assignments, as well as internal tracking mechanisms.
86
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 92 of 274
When the variables are constantly (and necessarily) shifting, there is no opportunity to make a
meaningful quantitative comparison or to estimate a counterfactual. Further, a direct quantitative
comparison would not be useful because it would only provide a comparison of two points in
time; the mandate of the GCA, however, is to seek administrative efficiencies, which is a
continuous process that evolves along with energy efficiency planning and programming,
whereas costs and administrative efficiency opportunities are always changing. The Program
Administrators seek to minimize costs at all available opportunities, and not just from one point
in time to another.
The PAs note, however, that they carefully track administrative costs and, as indicated in
the statewide summary tables provided with this Plan (and as highlighted in the PAs’ September
11, 2012 presentation to the Council), administrative costs as a proportion of overall PAspending is projected to decrease in 2013-2015, with increases in proportionate spending on
customer incentives and technical assistance. Please see the tables below for a graphical view of
costs.
Cost of Lifetime Savings (MWh) by Category
$140
$120
$100
$80
$60
$40
$20
$-
Program
Planning and
Administratio
n
Marketing and
Advertising
Participant
Incentive
Sales,
Technical
Assistance &
Training
Evaluation
and Market
Research
Res 2011 Report
$3
$4
$42
$11
$2
$62
LI 2011 Report
$7
$1
$82
$23
$3
$117
Total
C&I 2011 Report
$2
$0
$12
$2
$1
$16
Statewide 2010 Report
$3
$1
$23
$4
$1
$32
Statewide 2011 Report
$2
$1
$18
$4
$1
$26
Statewide 13-15 Plan
$2
$1
$27
$5
$1
$37
87
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 93 of 274
Cost of Lifetime Savings (therms) by Category
$0.80
$0.70
$0.60
$0.50
$0.40
$0.30
$0.20
$0.10
$Program
Marketing and
Planning and
Advertising
Administration
Participant
Incentive
Sales,
Technical
Assistance &
Training
Evaluation and
Market
Research
Total
Res 2011 Report
$0.05
$0.02
$0.43
$0.08
$0.02
$0.59
LI 2011 Report
$0.07
$0.01
$0.54
$0.13
$0.02
$0.76
C&I 2011 Report
$0.04
$0.01
$0.18
$0.02
$0.01
$0.26
Statewide 2011 Report
$0.05
$0.01
$0.33
$0.06
$0.01
$0.47
Statewide 13-15 Plan
$0.03
$0.03
$0.39
$0.09
$0.02
$0.56
5.
Competitive Procurement Process
The Program Administrators utilize competitive procurement processes to engage and
retain contractors and vendors to perform activities including, but not limited to: audit delivery;
quality control; monitoring and evaluation; marketing; and website design. The Program
Administrators are committed to continuing to utilize competitive procurement practices to the
fullest extent practicable throughout the implementation of the 2013-2015 Plan. Therefore,
consistent with past practice, the Program Administrators anticipate that they will issue RFPs to
engage appropriate third party vendors to provide energy efficiency services, consider the input
of the Council with respect to the retention of necessary consultants, and, where necessary, work
collaboratively to ensure that energy efficiency services have been procured in a manner that
minimizes cost to the ratepayers, while maximizing the associated benefits of that investment. In
order to build upon the progress made in the 2010-2012 Plan, the Program Administrators will
continue to work to expand the pool of qualified program vendors, promote the entry of new
market actors into contractor and subcontractor roles, and ensure the transparency of the
contractor bidding process and selection criteria used to evaluate proposals.
6.
Demand Response
Demand Response is not a key focus in the proposed Plan because such efforts are
difficult to cost-justify using the current Total Resource Cost test. Demand savings, however,
are a key benefit of proposed efforts. In addition, demand response “enabled” measures and
88
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 94 of 274
systems, including those that have the potential to be dispatched or controlled in conjunction
with Smart Grid systems, are featured in proposed efforts. Further, where applicable, the PAs
will facilitate engagement with demand response providers in the open marketplace. Examples
of potential measures and systems contemplated include but are not limited to “Smart” devices,
energy management system sequence of operations, dimmable lighting systems and controls, as
well as demand response enabled technologies.
C.
Funding Sources & Financing Initiatives
The Program Administrators seek to leverage available funding sources and financing
initiatives in order to increase the benefits of the Plan and minimize customer rate impacts. The
following funding sources and financing initiatives are currently available to the Program
Administrators.
1.
System Benefit Charge (electric only)
The System Benefit Charge (“SBC”) is calculated consistent with G.L. c. 25, § 19(a)
which states: “The [D]epartment shall require a mandatory charge of 2.5 mills per kilowatt-hour
for all consumers, except those served by a municipal lighting plant, to fund energy efficiency
programs including, but not limited to, demand side management programs.”
2.
Forward Capacity Market (“FCM”) Proceeds (electric only)
Pursuant to G.L. c. 25, § 19(a), electric Program Administrators’ energy efficiency plans
shall be funded in part by “amounts generated by the distribution companies and municipal
aggregators under the Forward Capacity Market program administered by ISO-NE, as defined in
section 1 of chapter 164.”
The Program Administrators allocate FCM funds across customer sectors according to
each sector’s percentage of contribution to SBC funds. Each Program Administrator’s projection
of individual FCM revenues is based on its respective FCM bidding.
Bid levels are based on projected and historic achieved annual peak period MW
reductions from a PA’s energy efficiency programs, as well as ongoing studies and evaluations
that may affect savings. Bids into the FCM must be submitted three years in advance.
Therefore, the PAs develop bids based on estimates using the best information available at the
time. The PAs also must balance the goal of maximizing FCM revenue with the financial risk to
program funding if projected peak savings are not achieved.
As noted above, a portion of the funding for energy efficiency efforts including customer
incentives is derived through participation in the FCM. Although limited, there are some unique
opportunities to further benefit customers and increase savings, as well as the region’s capacity
requirements. The PAs will provide FCM-supported energy efficiency services to electric
customers who are not currently eligible for services due to other factors. For these customers,
incentives would be limited to the value of the lifetime revenue stream associated with the
demand savings from the project less any administrative expenses that are associated with the
project.
89
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 95 of 274
3.
Regional Greenhouse Gas Initiative Proceeds (electric only)
The electric Program Administrators have estimated the proceeds they expect to receive
from Massachusetts’ participation in the RGGI based on the following assumptions.
Projections take into account anticipated lags between when RGGI auctions occur and
when DOER is able to transfer funds to each electric PA. In 2013, the electric Program
Administrators will be allocated revenues from a part of 2012 and part of 2013 RGGI auctions.
In 2014, the electric Program Administrators will be allocated revenues from a portion of 2013
and a portion of 2014 RGGI auctions. Similarly, in 2015, the electric Program Administrators
will be allocated revenue from a portion of 2014 and a portion of 2015 RGGI auctions. The
Program Administrators are working with DOER to develop a forecast that more accurately
projects receipt of funds from DOER.
Eighty percent of the Massachusetts proceeds from RGGI auctions will be allocated to
energy efficiency Program Administrators, consistent with the Green Communities Act’s
directives that cap-and-trade pollution control programs including, but not limited to, not less
than 80 percent of amounts generated by the carbon dioxide allowance trading mechanism
established under the RGGI Memorandum of Understanding and the NOx Allowance Trading
Program, will be made available for energy efficiency program expenditures. G.L. c. 25, В§ 19(a).
Electric Program Administrators will receive RGGI proceeds in proportion to the amount
of funding required to fund their energy efficiency programs above the SBC and FCM.
The electric PAs expect that DOER will continue to pay the electric Program
Administrators’ portion of the costs of the Council’s Consultants retained pursuant to G.L. c. 25,
В§22(c) out of the 80 percent of RGGI auction proceeds that are allocated to the PAs. This
assumption is reflected in anticipated RGGI proceeds amounts, which take into account the
reduction of proceeds receivable by the PAs by the amount payable to the Consultants. Because
the Consultant fees will be paid by DOER directly out of the RGGI proceeds, the electric PAs’
proposed budgets do not include separate expense amounts for Council Consultant costs.
Additional assumptions used by the Program Administrators with regard to the number of
Massachusetts allowances sold in each year and the clearing price of future auctions are provided
in the table below.
Forecast: RGGI Allowance Sales & MA EE Funding
Allowance Price ($/Ton)
Total RGGI Proceeds ($M)
2013
1.97
232
2014
2.01
236
2015
2.05
231
MA RGGI Proceeds ($M)
MA EE RGGI Funds ($M)1
38
30
39
31
37
29
(1) 80% of MA RGGI proceeds dedicated to energy efficiency
90
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 96 of 274
The Program Administrators have been monitoring the 2012 RGGI program review. The
projected allowance, allowance price and revenue forecast included in this Plan assumes no
changes to the current operating structure. The PAs will continue to monitor RGGI market
conditions.
4.
Energy Efficiency Reconciliation Factor (“EERF”) (electric only)
In the event that program costs exceed other available revenue sources, a fully
reconciling funding mechanism, the EERF, ensures that the costs for all available cost-effective
energy efficiency measures will be funded. The EERF recovers and reconciles energy efficiency
costs for a particular program year with the revenue an electric PA receives through: (1) the
SBC; (2) participation in the FCM; (3) proceeds from participation in cap-and-trade programs
such as RGGI; (4) LBR, for electric PAs without a Department-approved decoupling
mechanism; and (5) proceeds available from other private or public funds that may be available
for energy efficiency or demand resources. G.L. c. 25, В§ 21.
5.
Carryover Information
In determining its Energy Efficiency Surcharge, a Program Administrator takes into
account funds carried over from the previous year’s program, whether positive or negative.
These “fund balances” are used to adjust projected funding levels in the Plan. 22
6.
Outside Funding Levels
The 2013-2015 Plan does not contain outside funding assumptions given the absence of
material viable funding sources. The Program Administrators, as well as Councilors and
government agencies, all actively continue to seek new sources of outside funding. The Program
Administrators’ approach in this regard reflects lessons learned over the course of the 2010-2012
plan, in particular the low likelihood that a major new federal “cap and trade” program will be
implemented in the foreseeable future as had been anticipated when the 2010-2012 Plans were
initially developed and approved by the Council.
7.
Financing Initiatives
During the course of the last two years, the Program Administrators developed, deployed
an offered customers several financial products in conjunction with the Massachusetts Bankers
Association and Credit Unions - with roughly fifty financial institutions participating in this
initiative. The new Mass SaveВ® financing initiative is offered through multiple financial
institutions. The Program Administrators expect to have enough capital infusion from the
diverse Massachusetts lending community to meet customer demand for financing in the next
three years. The Program Administrators’ collaboratively-developed financing initiatives reflect
both the strong coordination among the PAs, as well as the Program Administrators’
responsiveness to comments and suggestions from Councilors. Program implementers in other
22
The Cape Light Compact has identified the need to update its 2012 historical budget. While the total is
correct, there is a difference of about 2% of the total budget from the actual allocation to the sectors. This
update has no affect on the 2013-2015 plan numbers and bill impacts.
91
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 97 of 274
states have frequently contacted the Program Administrators to learn from the Massachusetts
experience in development of a state-of-the-art lending initiative that leverages the experience of
local banks.
The HEAT Loan initiative also remains available, which provides qualified customers
with zero percent interest loans up to $25,000 with terms up to seven years and can be applied
towards certain specified energy efficiency upgrades. With the express support of DOER and
the Council, a portion of the HEAT Loan may be used to finance the mitigation of barriers
preventing the installation of energy efficient measures (i.e., pre-weatherization measures).
From 2010 to 2012 (to date), HEAT Loan funds totaling approximately $70,106,000 were
approved for customers to make energy efficiency improvements. For 2013-2015, certain gas
PAs are proposing additional budgetary dollars in the Residential Home Energy Services
initiative to make the HEAT Loan available in support of gas energy efficiency efforts in service
territories where electricity is supplied by a municipal light plant. All customers of electric PAs
will receive the HEAT Loan applications. Gas PAs that have municipal electric companies
within their territories will offer the HEAT Loan to those natural gas/municipal electric
customers. Hence, all customers that pay into the SBC funds will be able to access the HEAT
Loan. The gas PAs that have no line-item budget for the HEAT Loan have no municipal electric
customers within their respective territories.
Financing allows customers, who may not be able to raise enough capital to pay for their
customer contribution, to borrow funds in order to invest in energy efficiency. Customer
financing does not reduce the amount of money necessary to be collected from ratepayers
because it does not reduce the Program Administrators’ energy efficiency budgets. To the extent
that access to low-cost capital is a barrier for certain customers, financing can alleviate that and
encourage energy efficiency investments.
The Program Administrators are continuing their efforts to understand the nature of
barriers, for different customer segments, which may be related to accessing capital, and to
explore financing products/solutions to address them, particularly for C&I customers who have
not taken advantage of the financing mechanism described above in great numbers as has been
the case for residential customers. In addition, some of the Program Administrators are
proposing to provide customers with the ability to repay their share of program costs with zero
percent interest over a two year period.
D.
Summary of Budgets, Savings, and Benefits
For the 2013-2015 Plan, the Program Administrators have sought to balance savings and
budgets; therefore, savings goals are aggressive in order to acquire all available cost-effective
energy efficiency, but sustainable so that these aggressive goals can be maintained throughout
the entire three-year period and planned with consideration of bill impacts. The Program
Administrators have integrated planning and implementation in order to achieve sustainable
savings. Based on prior experience, in this Plan, the Program Administrators have taken note of
EM&V factors and trends when planning savings goals. The process for developing goals is
discussed further in Section III.D.2, below. In order to present reliable data, the Program
Administrators have focused on program-driven savings, which are the savings achieved through
the efforts of the PAs. The PAs intend to participate in the working group which will be
92
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 98 of 274
convened to explore if and how a market-based approach could be developed and implemented
per D.P.U. 11-120-A, as discussed in Section III.O below.
Budgets in this Plan take into account statutory low-income expenditure requirements,
and reflect economies realized through prior efforts. In 2013-2015, the PAs are placing an
increased focus on benefits. In determining target benefits, the PAs have sought to accommodate
the effect of changed avoided costs.
The budgets, savings, and benefits tables in this Plan are preliminary, and will necessary
evolve based on (1) any (currently unexpected) changes in regulatory policy, such as cost
recovery and incentive plans; (2) planning refinements; and (3) program level data.
1.
Cost Drivers
Introduction
The Program Administrators’ statewide energy efficiency programs have evolved
significantly since the development of the first three-year plan in 2009. As a result of their
success, the Program Administrators are currently facing a new series of challenges – changes in
projected program costs and the hurdles associated with achieving historically high savings
levels on a sustained basis after having already had notable success in penetrating markets. To
address these challenges and deliver the most cost-effective energy efficiency programs to their
Massachusetts gas and electric customers, the Program Administrators seek to develop a
thorough understanding of current and future cost drivers and savings levels for their proposed
energy efficiency programs. The Council has identified cost drivers as a core priority and has
asked that the Program Administrators continue to discuss such cost drivers in the Plan. The
Program Administrators address this priority below.
Since the July 2 and September 19 submissions of the Plan, the PAs have continued to
work with the Consultants to identify the largest, most material cost drivers and to understand the
impacts to the PAs budgets, savings goals and bill impacts. This work has entailed an intensive,
good faith effort, with multiple conference calls and exchanges of data, utilizing data from
National Grid and NSTAR given their indicative role as the PAs with the largest customer bases
in the Commonwealth. While multiple inputs and assumptions at the detailed measure level, and
at the macro statewide level all drive costs, based on the work of the PAs and the consultants to
date, the four main drivers that affect the PA cost of savings are Evaluation, Measurement and
Verification results, new codes and standards that increase baselines and decrease potential
savings, new measures and approaches that were not implemented in 2011, and the effect of
varying measure mixes in each PA’s projections.
The PAs and Council Consultants primarily used 2011 evaluated results as a baseline for
costs to achieve, as it represents the most recent and best available information. It is important to
note however that 2010 information (which had higher costs than 2011, e.g., $0.032 per lifetime
kWh as opposed to $0.026 in 2011) and 2012 MTM data (again with higher costs at $0.041 per
kWh than 2011) are also important data points and factor into any overall discussion of cost
drivers From there, the cost drivers team looked at the four drivers listed above in an attempt to
quantify the effect on costs going forward and to narrow the previously existing gaps in the
93
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 99 of 274
consultants and the PAs views on costs to achieve in 2013-2015. The cost drivers can have both
negative and positive impacts on the cost of savings, but overall the PAs experienced a net
increase in costs to achieve its savings targets in 2013-2015 relative to 2011. Some key
takeaways:
•
Adopting EISA standards for lighting measures and shifting the measure mix
more towards LEDs instead of CFLs will increase the cost per kWh.
•
Furnace standards increased from 78% to 90% AFUE and boiler standards
increased from 80% to 82% AFUE. Increased standards raise the baseline for
energy efficient equipment, decreasing the incremental savings that PAs can
claim. PAs had to change its measure mix to offer equipment above the new
standards. These changes increased the cost per therm.
•
New approaches, such as Efficient Neighborhoods+, paying for the costs of preweatherization, and serving multi-family master-metered gas customers, will
increase the cost per unit of savings.
•
2011 CHP savings levels are not replicable in the 2013-2015 Plan. This large,
low-cost measure decreased the 2011 cost per kWh as compared to what is
reasonably projected going forward.
•
EM&V results for the Home Energy Services core initiative increased the cost to
achieve for the electric initiative and decreased the cost to achieve for the gas
initiative.
•
PAs have significantly reduced savings claimed for thermostats in gas residential
programs and spray valves in gas C&I programs. This decrease to savings
increases the cost per therm.
The PAs have engaged in numerous discussions with the Council’s Consultants on cost
drivers, and the costs set forth herein reflect these discussions and collaborative efforts.
Appropriate Variances among the Program Administrators
Each Program Administrator is affected differently by each cost driver. Despite
statewide offerings and increased application of common assumptions, some variations in
savings goals and cost to achieve these goals are appropriate due to unique characteristics in
service territories and PA knowledge and historical experience with its customer base. Building
demographics, income types, fuel type and population density vary widely across each PA’s
service territory and will influence how each PA plans to achieve its goals.
The graph below shows the balance of electric savings by PA and between sectors. The
graph shows that the balance of savings between residential, low-income and C&I sectors varies
both among the PAs and across years. For example, 97% of Unitil’s 2011 savings were achieved
in the C&I sector due to a large CHP project. This achievement is not indicative of Unitil’s
2013-2015 Plan, and underlies the importance of taking a multi-year look at costs and savings.
94
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 100 of 274
Distribution of Lifetime Savings (MWh)
Res
LI
C&I
100%
90%
80%
51%
70%
60%
78%
79%
71%
85%
82%
84%
16%
14%
97%
50%
40%
30%
44%
20%
10%
18%
19%
24%
12%
2%
0%
WMECO
Statewide National Grid NSTAR 2011
2010 Report 2011 Report
Report
2011 Report
CLC 2011
Report
Unitil 2011 Statewide Statewide 13Report
2011 Report
15 Plan
The balance of gas savings between residential, low-income and C&I sectors varies less
than electric, as shown in the graph below. However, in the 2013-2015 Plan, more savings are
attributable to the C&I sector than what the PAs have experienced in the past.
95
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 101 of 274
Distribution of Lifetime Savings (therms)
Res
LI
C&I
100%
90%
80%
30%
31%
42%
44%
44%
44%
50%
70%
12%
60%
50%
12%
14%
8%
8%
49%
12%
9%
40%
30%
20%
53%
56%
45%
42%
42%
48%
44%
38%
21%
10%
0%
National Grid NSTAR 2011 Columbia
NEG 2011
Berkshire Unitil 2011 Statewide
Statewide
2011 Report
Report
2011 Report
Report
2011 Report
Report
2011 Report 13-15 Plan
The distribution of savings among sectors is important to understand because each sector
has a very different cost to achieve, with C&I historically being the least expensive sector and
low-income being the most expensive sector. The graphs below show the cost of lifetime
savings by sector and by PA for 2010, 2011 and 2013-2015.
96
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 102 of 274
Cost of Lifetime Savings (MWh)
$250
$213
$200
$150
$100
$84
$50
$37
$25
$0
Res
LI
C&I
Total
Statewide 2010 Report
$62
$109
$22
$32
National Grid 2011 Report
$64
$125
$18
$29
NSTAR 2011 Report
$60
$101
$14
$22
WMECO 2011 Report
$52
$102
$26
$36
CLC 2011 Report
$86
$221
$33
$64
$117
$189
$6
$9
Statewide 2011 Report
$63
$117
$16
$26
Statewide 13-15 Plan
$84
$213
$25
$37
Unitil 2011 Report
Cost of Lifetime Savings (therms)
$1.40
$1.27
$1.20
$1.00
$0.80
$0.74
$0.56
$0.60
$0.31
$0.40
$0.20
$-
Res
LI
C&I
Total
National Grid 2011 Report
$0.62
$0.76
$0.30
$0.50
NSTAR 2011 Report
$0.61
$0.86
$0.17
$0.45
Columbia 2011 Report
$0.46
$0.69
$0.22
$0.36
NEG 2011 Report
$0.50
$0.82
$0.33
$0.48
Berkshire 2011 Report
$0.61
$0.70
$0.18
$0.43
Unitil 2011 Report
$0.75
$0.44
$0.58
$0.55
Statewide 2011 Report
$0.59
$0.76
$0.26
$0.47
Statewide 13-15 Plan
$0.74
$1.27
$0.31
$0.56
The important cost drivers implications from these data are that customer and measure
mixes are important elements in driving costs (and savings opportunities), and that it is expected
97
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 103 of 274
and appropriate that there will be some variations in costs (and savings) among PAs based upon
their unique mixes and customers and measures within their service areas.
Conclusion
As always, the Program Administrators will strive to keep costs down, but the PAs do not
control the eroding savings from increases in federal standards and any downward free-rider
results from evaluations. There is potential, however, for new opportunities, which the Program
Administrators will continue to explore through best practices and market assessments. As
standards rise, incremental cost will decline, and this could allow for new technologies and
measures that were previously too cost-prohibitive to be included in the PAs’ already robust
portfolio of programs.
Additionally, the PAs will continue to strive to reduce variations in costs to achieve to the
extent practicable through the use of common assumptions. The PAs emphasize, however, that
some variations are acceptable and appropriate due to different service territories and varying
planned measure mixes, as indicated in the data presented above and in the appendices to this
Plan.
2.
Process to Determine Goals
The PAs engage in a collaborative and iterative planning process for setting savings goals
and budgets. The planning process for savings varies for each program and initiative, but certain
common assumptions are used across programs and initiatives. An example of a specific
planning process includes budgeting for core initiatives within the Residential Products Program,
which is very measure-specific and driven by the number of rebates. Other initiatives take a
whole house approach and plan by audits, homes, or customer sites. Regardless of the type of
program, the PAs typically begin the planning process by looking at historical data from the most
recent few years and examine some key metrics that provide insight into participation trends
(i.e., how many boilers were rebated or number of weatherization jobs completed), savings
achieved, and costs to achieve these savings. The PAs collaboratively discuss changes that need
to be made to each program based on both the historical data as well as forward-looking
information. Using this information, the PAs may decide, for example, to discontinue measures
that have become standard efficiency, or to test new measures for cost-effectiveness and add
them to the appropriate program. These types of overarching decisions are done at the statewide
level at the respective management committees, ensuring input from all stakeholders and
continuous sharing of best practices and facilitating consistency of offerings among the Program
Administrators.
Each PA uses this information to develop a forecast that is sustainable for the planning
period. To help verify these forecasts, PAs may consult their lead vendors to assist with realistic
projections based on field experience in the program or what is in the vendor’s queue.
The latest savings impacts are applied to the forecast savings, and the annual and lifetime
savings are summed up at the program, sector and portfolio level. The process must be fluid and
flexible, because information is received at various times during the planning process that is
critical to include, such as evaluation impact results. Changes dictated by evaluation impact
98
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 104 of 274
results are what make the planning process so iterative. If an evaluation impact result lowers
savings for a specific program, the PAs need to adjust the implementation strategies to ensure
that the overall goal at the portfolio is still achievable, while minimizing the impact to the
budget. As an example, the 2010 High Efficiency Heating Equipment gas evaluation impacted
the PAs so significantly that they would have had to spend three times the program’s original
budget to achieve the original savings estimates. Instead, PAs reallocated part of this budget to
other programs that yielded a lower, more realistic cost per savings.
In addition to forecasting savings goals, PAs must also develop budgets for marketing
expenses, internal payroll, evaluation, administrative expenses and vendor-related fees. These
budgets are program-specific and are often driven by how aggressive the goals are (a large rampup in savings goals typically needs more marketing dollars), when the program was last
evaluated, and how many full-time employees are dedicated to each program. These budgets can
vary significantly by PA, and typically make up a quarter to a third of each program’s budget,
with the largest portion of the budget typically dedicated to customer incentives.
3.
Common Assumptions
The Program Administrators recognized that they historically have used different
assumptions in energy efficiency planning and reporting. As part of the process of integration,
the PAs have emphasized the need for common assumptions and have jointly revised the
assumptions used in order to meet this goal. The Program Administrators have common
program designs, and continuously work together to develop assumptions and to apply those
assumptions in the RMC, C&IMC, low-income best practices, EMC, common assumptions
working group, and other PA working groups and discussions.
Despite common program designs, the PAs identified and set forth to eliminate
discrepancies with some key planning assumptions such as the definition of a participant,
application of evaluation results, budgets, and avoided costs.
The Program Administrators have developed a set of definition guidelines that guide each
PA’s participant calculation in order to be able to review participants in a consistent manner.
Such definitions were designed to most accurately reflect a unique participant in each program,
while keeping in mind the differences in PA tracking. In certain instances, particularly for C&I
programs, the PAs seek to reach a conceptual definition, such as location, but may reach it
through different fields that are available in their tracking system, such as a representative
account number or representative meter at specific location. The definitions that the PAs have
used for participants in this Plan are set forth in Appendix M. Using these common definitions,
the PAs have worked together to determine how best to apply them to estimate the number of
participants for this Plan in a consistent manner.
PAs have also confirmed common approaches to various cost and savings data. The
manner of application of evaluation results, including non-energy impacts, has also been
determined collectively. Specific program assumptions have been accounted for uniformly, and
algorithms will be applied in the same manner across PAs, with such assumptions set forth in the
TRM. The PAs also collectively agreed to use the avoided costs from the 2011 AESC study for
all three years within the Plan, inflated to 2013 dollars. Transmission and distribution costs have
99
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 105 of 274
been updated and inflated consistently. PAs have made changes to energy DRIPE that will
slightly increase DRIPE values in 2014 and 2015 consistently across PAs. Additionally, PA cost
categories are now consistent, with one limited exception of the categorization of employee
salaries and related expenses. 23
The PAs have reviewed all assumptions included in the development of this Plan in order
to harmonize them to the greatest extent practicable. This has reduced variances between PAs
and allows the PAs to provide the best available data in the most consistent manner.
4.
Unique Service Areas - Drivers of Appropriate Savings Variations among PAs
As the Program Administrators’
statewide energy efficiency programs have
successfully evolved to sustain acquisition
of all cost-effective energy efficiency, they
currently face new challenges in terms of
increasing savings targets beyond the
already historic levels in place. The PAs
are going where no other utilities in this
nation have ventured in terms of an
integrated statewide, sustained energy
efficiency effort.
The Council has
identified PA variances on savings levels as
a core priority and has asked that the
Program Administrators discuss what
actions and budget levels would be necessary to achieve the level of savings goals presented by
the Council Consultants. To understand current and future drivers of savings levels for PAs’
proposed energy efficiency programs requires an understanding of cost drivers and how savings,
costs and performance incentives are interlinked, which are discussed throughout this Plan. But
it also requires an understanding of the unique characteristics and service territories of each
Program Administrator.
Some variations among PAs in savings goals and costs to achieve, as discussed in
Section III.D.1, are appropriate due to unique characteristics in each PA’s service territory, and
should continue to be supported by both the EEAC and the Department consistent with sound
regulatory policy and the GCA. The Commonwealth of Massachusetts is a composite of
different communities and regions. While it is necessary to address energy efficiency plans,
programs and objectives on a statewide basis, the detailed factors that influence costs, savings
potential, and the cost to achieve savings are different in each PA’s service territory. In general,
as noted in section III.D.1, and as presented to the Council on September 11, 2012, the data show
23
For certain PAs, employee labor and related expenses are included in the PP&A, Marketing-Advertising,
Sales, Technical Assistance & Training, and Evaluation & Market Research categories, depending on the
employee’s responsibility; for other PAs, all employee labor costs and related expenses are included in the
PP&A category. This one limited difference is due to different historical practices and differing staff sizes
and staff assignments, as well as internal tracking mechanisms.
100
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 106 of 274
that service areas with a more robust C&I customer base have more opportunities for savings at
lower costs than PAs without this customer mix.
Each PA has a distinct mix of customers and sectors, which affects energy efficiency
programs in different ways. For some PAs, the variety of communities in which they serve
results in costs, savings and costs to achieve that closely resemble the statewide average.
However, for other PAs, the unique or more limited geographical regions they serve can result in
a mix of specific characteristics that are significantly different from statewide averages. These
specific factors have a direct impact on the costs, savings and cost to achieve that these PAs need
to reflect in their individual PA energy efficiency plans.
Each PA has unique demographics, with different mixes of building types, income types,
fuel types and population density. For example, the geographical area served by one PA may
have a disproportionately smaller percentage of commercial customers in its territory as
compared with the statewide averages. Similarly, a PA may have a disproportionately lowerincome population than the statewide averages, or serve a region that is economically
disadvantaged as compared with the Commonwealth as a whole.
At a more granular level, the mix of energy efficiency measures deployed by one PA may
also vary considerably from statewide averages based on factors such as the age of the housing
stock, the percentage of homes with electric heat, or the concentration of certain industries and
business in the service area. While PAs with lower diversity in key customer segments can be
susceptible to larger uncertainties in program performance, they may also be able to tailor go-tomarket strategies and outreach approaches more specifically to their customers in ways that
positively impact planning assumptions. All of these factors can result in variances in a
particular PA’s costs, savings and cost to achieve relative to statewide averages.
In addition, each PA has unique customer demand and customers who have competing
priorities. Each PA also has a unique saturation level, with histories of successes. Moreover,
each PA has unique expertise and knowledge regarding its individual customer needs, and has
taken this into account in setting its savings goals. Despite these many variations, all PAs are
increasing their savings goals from the July 2 draft Plan.
As recognized explicitly in the Gas Order and the Electric Order and in the Council’s
resolutions with respect to the 2010-2012 gas and electric plans, these differences in service
areas can justify variations from statewide targets in savings goals and related matters. See, e.g.,
Gas Order at 28; Council Resolution of October 27, 2009. Specific factors that the Department
considered in endorsing the Council’s approach included “economic conditions and median
income.” Gas Order at 28.
In this Plan, The Berkshire Gas Company, New England Gas Company, Unitil and Cape
Light Compact are proposing aggressive savings goals that are tailored to the conditions within
and characteristics of their service areas and to ensure compliance with the GCA’s mandate to
acquire all available cost-effective energy efficiency in a sustainable manner. Each of these PAs
has also increased its savings goals as compared with the aggressive goals set forth in the July 2
and September 19 drafts of the Plan in response to the Council’s comments and outreach efforts
101
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 107 of 274
by DOER. Presentations related to their specific service territories can be found in Appendix H,
with the presentations referring to/summarizing scenario analyses consistent with the Council’s
requests. 24 Maps showing the PA service territories in the Commonwealth are included in
Appendix G. While these PAs expect that BCRs would decrease somewhat as increased savings
opportunities are pursued, their core concerns with adopting the Consultants’ proposed savings
targets are not BCRs, but rather are costs, achievability based upon the characteristics of their
customer base and bill impacts.
The presentations in Appendix H outline unique challenges in each PA’s respective
service area that justify variations from statewide targets and these PAs have welcomed
Councilors to visit their service areas: unique communities in which they are all proud to serve.
The largest of these PAs, Cape Light Compact, has also made supplemental filings discussing its
unique service territory in connection with both the July 2 draft Plan and the September Plan. As
part of these filings, the Compact provides a report from an independent expert consulting firm,
Synapse Energy Economics, Inc. The report examines the key drivers behind higher costs per
lifetime MWh savings for the Compact as compared to other PAs. Both the Council and the
Department supported variations from state targets for each of these Program Administrators
with respect to the 2010-2012 Plan, and the sound reasoning applied in that decision-making
process continues to apply for the 2013-2015 Plan.
In the Term Sheets, the need for flexibility for PAs with unique service areas is expressly
supported, as is the PAs’ approach to utilizing an integrated, statewide approach to achieving
savings. The savings goals proposed for Cape Light Compact, The Berkshire Gas Company,
New England Gas Company, and Unitil are found appropriate for the 2013-2015 Plan, and each
of the utility PAs noted will be required to document the penetration of program offerings and
remaining cost-effective potential for energy efficiency in that PA’s service territory through a
study (joint or by PA, and with input and review by the Council’s Consultant) that would be
prepared and finalized during 2014, in time for the planning stages of the 2016-2018 Plan.
All Program Administrators are supportive of these specific requests and note the
valuable contributions to the overarching statewide effort set forth in this Plan that are provided
by each of these Program Administrators and their personnel. Each Program Administrator,
regardless of size, contributes uniquely and materially to the overall statewide effort and
commitment that is the hallmark of energy efficiency implementation in Massachusetts. By way
of example, the chair of the statewide and essential RMC has been a representative of the
comparatively very small Berkshire Gas and the RMC has achieved notable success with his
leadership. The Massachusetts PAs have developed a team, with each PA assisting the others on
energy efficiency efforts based on its strengths and challenges. Reasonable variances in savings
goals that reflect these unique strengths and challenges among service areas are entirely
appropriate.
24
Columbia Gas of Massachusetts has set incremental goals that place it on track to achieve the current
statewide savings target of 1.1% of retail sales. Because CMA’s goals are only slightly below current
savings targets, this variance did not merit separate discussion in this section. By committing to achieve
savings targets of 1.02, 1.05 and 1.075 over the next three years, CMA has sought to set goals that are
incremental, achievable and sustainable and that will allow for success year to year.
102
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 108 of 274
5.
Electric Statewide Budget, Annual Savings, Lifetime Savings, and Benefits
BUDGET ($)
Sector
Residential
Low-Income
C&I
TOTAL
$
$
$
$
2013
153,238,206
54,136,213
273,941,506
481,315,926
$
$
$
$
2014
162,494,057
54,923,052
278,240,071
495,657,181
2015
170,956,663
56,912,443
290,856,118
518,725,224
$
$
$
$
$
$
$
$
2013-2015
486,688,926
165,971,708
843,037,696
1,495,698,331
ANNUAL SAVINGS (MWh)
Sector
Residential
Low-Income
C&I
TOTAL
2013
329,216
28,782
836,559
1,194,556
2014
364,244
27,756
844,268
1,236,268
2015
380,343
26,795
867,405
1,274,544
2013-2015
1,073,804
83,332
2,548,232
3,705,368
2015
1,984,491
254,194
11,623,911
13,862,596
2013-2015
5,823,526
778,773
33,669,371
40,271,670
2015
712,396,495
123,284,674
1,832,252,644
2,667,933,813
2013-2015
2,029,235,918
365,150,220
5,243,659,235
7,638,045,373
LIFETIME SAVINGS (MWh)
Sector
Residential
Low-Income
C&I
TOTAL
2013
1,890,890
264,621
10,989,232
13,144,743
2014
1,948,146
259,958
11,056,228
13,264,331
BENEFITS ($)
Sector
Residential
Low-Income
C&I
TOTAL
$
$
$
$
2013
630,276,894
119,649,869
1,609,497,918
2,359,424,681
$
$
$
$
2014
686,562,530
122,215,676
1,801,908,673
2,610,686,879
$
$
$
$
$
$
$
$
* All of these tables reflect statewide “rolled-up” proposals of the individual Program
Administrators for 2013-2015.
103
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 109 of 274
6.
Gas Statewide Budget, Annual Savings, Lifetime Savings, and Benefits
BUDGET ($)
Sector
Residential
Low-Income
C&I
TOTAL
$
$
$
$
2013
84,772,958
34,409,368
49,247,475
168,429,800
$
$
$
$
2014
86,874,337
35,928,797
51,760,258
174,563,392
$
$
$
$
2015
88,758,509
37,844,460
53,489,638
180,092,607
$
$
$
$
2013-2015
260,405,804
108,182,625
154,497,371
523,085,799
ANNUAL SAVINGS (Therms)
Sector
Residential
Low-Income
C&I
TOTAL
2013
10,291,144
1,397,743
10,972,151
22,661,039
2014
11,608,186
1,438,993
11,353,951
24,401,130
2015
11,605,934
1,486,017
11,857,063
24,949,014
2013-2015
33,505,264
4,322,753
34,183,165
72,011,183
LIFETIME SAVINGS (Therms)
Sector
Residential
Low-Income
C&I
TOTAL
2013
117,101,911
27,514,929
159,357,540
303,974,380
2014
119,419,923
28,353,158
165,248,442
313,021,522
2015
116,138,323
29,325,641
175,854,213
321,318,178
2013-2015
352,660,157
85,193,728
500,460,194
938,314,079
2015
191,047,468
60,783,199
187,120,420
438,951,088
2013-2015
575,977,393
178,073,424
529,869,969
1,283,920,785
BENEFITS ($)
Sector
Residential
Low-Income
C&I
TOTAL
$
$
$
$
2013
190,646,393
58,078,882
167,676,684
416,401,958
$
$
$
$
2014
194,283,532
59,211,343
175,072,864
428,567,739
$
$
$
$
$
$
$
$
* All of these tables reflect statewide “rolled-up” proposals of the individual Program
Administrators for 2013-2015.
104
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 110 of 274
E.
Bill Impacts
Consistent with the goal of the three-year Plan to provide for the acquisition of all
available energy efficiency and demand reduction resources that are cost effective or less
expensive than supply, the Program Administrators sought to develop a statewide Plan that
provides for this acquisition with the lowest reasonable customer contribution. G.L. c. 25,
§ 21(b). Additionally, consistent with the requirements of the GCA and of the Department’s
Order in D.P.U. 08-50-A, the Program Administrators worked diligently and collaboratively to
review and analyze the rate and bill impacts associated with the implementation of the Plan in
order to ensure that such impacts are equitable. The PAs have sought to balance the value of the
long-term benefits expected from proposed energy efficiency efforts with short-term customer
bill impacts. Proposed budgets reflect these considerations along with a focus on the equitable
distribution of costs and benefits for customers.
Through the D.P.U. 08-50 Bill Impact Working Group, the Program Administrators, the
Department, and interested stakeholders, including DOER and the Attorney General, prepared
and reviewed common analytic models for billing analysis, and reviewed the output and utility of
such detailed models. The collaborative work on bill impacts is an example of the Program
Administrators’ commitment to developing and sharing best practices, not only among
themselves, but also with interested stakeholders (including learning from such stakeholders).
The Department convened a technical session on August 16, 2012, at which the
Department reviewed the history of bill impacts and D.P.U. 08-50, GCA requirements, the
Department’s goals with respect to rate continuity, and different aspects of the traditional bill
impact models and the D.P.U. 08-50 bill impact models. Ultimately, the Department explained
that the short-term information provided in traditional bill impact models satisfies the GCA
requirement that the Department consider the effect of any rate increases on residential and
commercial customer bills before approving ratepayer funding of energy efficiency programs.
See G.L. c. 25, В§ 19(a).
On October 19, 2012, the Department issued an order acknowledging the efforts of the
Bill Impact Working Group, but declining to adopt the bill impact models under discussion.
D.P.U. 08-50-D; see also Section II.L, supra. Instead, the Department directed the PAs to submit
traditional bill impacts for nonparticipants under the following scenarios:
1. the current (e.g., 2012) EES to the proposed EES for the first year of the three-year
plan (e.g., 2013);
2. the EES from the first year of the three-year plan (e.g., 2013) to the proposed EES for
the second year of the three-year plan (e.g., 2014);
3. the EES from the second year of the three-year plan (e.g., 2014) to the proposed EES
for the third year of the three-year plan (e.g., 2015);
4. the current EES (e.g., 2012) to the proposed EES for the third year of the three-year
plan (e.g., 2015).
105
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 111 of 274
D.P.U. 08-50-D at 12. The Department also directed the PAs to submit bill impacts for
participants, “where consumption is reduced for three levels of savings -- low, medium, and high
-- and [to] provide a description of how these savings levels were determined.” Id. The
Department later clarified the bill impact requirements for non-participants by providing a
spreadsheet to the PAs directing them to use average monthly usage levels under the first and
fourth scenarios listed above.
Accordingly, to calculate bill impacts for participants, the PAs will populate the
Department’s spreadsheet (with peak and off-peak rates on separate sheets), using the average
monthly average kWh and/or therm usage for nonparticipants for each rate class, and the
percentages set forth in the table below. To best approximate, consistent with the Department’s
directive in D.P.U. 08-50-D, low, medium and high annual savings, the PAs collaborated on
appropriate assumptions for residential, low-income and C&I programs to develop statewide
percentages that best approximate savings for those types of participants. The PAs determined
that the percentages in the table below will provide directional information on the bill impacts a
residential, low-income or C&I participant may experience.
The PAs determined that there is no low, medium and high savings scenario for lowincome participants. These participants typically receive a comprehensive “whole house” energy
efficiency approach, meaning potential measures are installed in most cases (the work that can be
done is done). Similarly, the PAs determined that there is no low, medium and high savings
scenario for residential and low-income gas non-heating participants and street lighting.
Accordingly, the PAs determined that the percentages in the table below best approximate
savings for those types of participants.
Residential- Electric:
Residential- Gas:
Residential Gas Non-Heating:
Low-Income Gas Non-Heating:
Low-Income:
Street Lighting:
C&I- Electric:
C&I- Gas:
Low
2%
2%
1%
1%
Medium
10%
15%
2%
2%
25%
10%
10%
10%
High
30%
30%
20%
20%
Each PA will provide these bill impacts for all rate classes in its individual filing to be
made at the Department on the same date as this Plan.
The Program Administrators emphasize that the actual rate and bill impact that will be
realized by a customer will depend on several variables, including the cost of service in a
particular Program Administrator’s service territory, the customer’s actual individual usage, the
level and quality of measure installation, and the availability of public or private funds other than
those collected through the SBC for application towards energy efficiency expenditures, such as
proceeds realized from the FCM or from cap-and-trade programs (e.g., the RGGI).
106
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 112 of 274
F.
Statewide Programs
1.
Strategic Overview of Residential, Low-Income, and C&I Programs and Program
Consolidation
Throughout this 2013-2015 Plan, the Program Administrators intend to expand upon
strategies to promote greater energy savings and peak demand reductions by building on existing
programs and services. The PAs intend to continuously improve the methods by which
programs are delivered by focusing on developing the suite of measures and practices in order to
remain relevant over time. The Program Administrators will pursue new technologies and
incentive structures to encourage expanded and more comprehensive program participation.
Consistent with Council priorities, the depth of existing programs will also continue to expand
over the next three years as new initiatives are introduced to increase participation and savings.
Programs that address potential energy and demand savings in both existing buildings and new
construction, which have a history of producing significant savings, will be ramped up and new
initiatives will be developed and introduced.
In the 2013-2015 Plan, the PAs are providing consolidated programs, with several core
initiatives available under each program. This consolidation will allow for increased flexibility
to address market conditions and maximize savings, reduced customer confusion, and potentially
reduce the need for mid-term modifications.
2.
Consistent Messaging
A critical component of integration and seamless delivery is consistent messaging. The
Program Administrators continue to improve and expand the statewide website (marketing
portal) and marketing approach to increase customer awareness of program offerings and the
Mass SaveВ® mark as a representation of the consistency across all Program Administrators.25
Continued use of the Mass Save mark as the umbrella under which the PAs’ energy efficiency
programs operate will reinforce that the Program Administrator offerings across the state are
seamless and consistent. Per with evaluation findings, the PAs will continue their practice of cobranding by using the Mass Save mark concurrently with the Program Administrators’ brands,
which represent highly recognizable local entities that are trusted by customers. The Program
Administrators will continue their practice of communicating to customers that Mass Save is
brought to them through the local utility or municipal aggregator. Individual Program
Administrators will continue to implement their own complementary marketing initiatives to
reinforce and support the overall statewide marketing strategy, as well as to address unique needs
or local conditions and/or sub-markets in their service areas. These individual activities will be
undertaken in consultation with all other Program Administrators in order to avoid inadvertent
inconsistent messaging. 26 As stated in the Term Sheets, support of the Mass Save mark and
statewide brand is an important priority. The PAs commit to statewide marketing efforts that
include the prominent integration and placement of the Mass Save mark as the statewide brand.
25
Mass Save is a registered trademark of the Program Administrators and all rights thereto are reserved.
26
Program Administrators have used the ENERGY STARВ®, GasNetworks, and COOL SMART brands on
a consistent basis for applicable equipment initiatives in order to help drive participation.
107
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 113 of 274
PAs will include the Mass Save mark on statewide program, outreach and marketing materials
and will include a link to the Mass Save website on the portion of their PA websites that is
focused on energy efficiency services in Massachusetts, except where expressly limited by
internal corporate website policies. PAs, in collaboration with DOER and the Council, will
conduct an evaluation of the effectiveness of all joint statewide branding efforts to ensure that
such brands support clear and recognizable messages that help promote program awareness.
Such an evaluation will be completed by the end of 2013 and submitted to the Council.
3.
Same Delivery Mechanism for Gas and Electric
The Program Administrators will continue to utilize consistent delivery mechanisms for
gas and electric programs. While delivery will remain seamless across the state, the Program
Administrators plan to continue to examine additional ways to reach new gas and electric
customers. New delivery mechanisms for gas and electric will be explored from a statewide
prospective (e.g., with C&I customers, the feasibility of introducing a self service portal for
smaller customers, personal conduits via web-based chat or telephone assistance, and provision
of fee-based on-site assessments for C&I customers). In addition, the Program Administrators
plan to expand upon current delivery mechanisms which have proven successful including
expanding upstream offerings to include other gas and electric equipment within the replacement
on failure market. Coordination and consistency among and between electric and gas PAs will
continue to be a point of emphasis, including in the process of interacting with customers.
4.
Review of New Technologies
There is a steady flow of new technologies being developed and offered to increase the
efficiency of energy use for residential and C&I customers. Before incorporating new or
unfamiliar technologies in their program offerings, the Program Administrators are responsible
for performing a thorough review to ensure that such products or devices will provide costeffective energy savings for their customers. To address the need for these reviews, the Program
Administrators have established the Massachusetts Technical Assessment Committee
(“MTAC”).
The MTAC consists of key technical staff from each Program Administrator as well as a
representative of the advisor hired by the PAs to act as a facilitator for this committee. The
MTAC reviews technical and incentive issues of statewide interest and is coordinated by a
project manager designated by the Program Administrators represented in the committee.
MTAC provides documented technical interpretations and technology assessments to the
program implementers and is the authority for consistent program interpretation of technical
matters for all of the participating Program Administrators. The MTAC has developed a set of
protocols for the content of their review and procedures for documenting and disseminating their
conclusions and technical interpretations. The MTAC meets as needed to address specific issues
and during the annual Program review and planning periods.
Requests for program consideration of a new or unfamiliar technology that come from a
vendor or customer are forwarded to the MTAC by the receiving Program Administrator or
through the Mass Save website. This group can undertake or direct such tasks as:
108
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 114 of 274
•
Research and analysis of specific measures that are candidates for inclusion in the
programs.
•
Determination whether a specific new technology should be approved as a) a prescriptive
measure eligible for all appropriate PA programs or b) a measure whose eligibility is
limited to custom projects where savings and cost effectiveness are to be determined on a
site-specific basis.
•
When appropriate and agreed to by the respective Program Administrators, development
of common program implementation materials or procedures including: technical
specifications, technical study/commissioning protocols, equipment baseline reference
sheets, inspection forms, and other technical and administrative support materials, for use
by the respective Program Administrators’ staff and contractors.
•
Development and maintenance of statewide uniform “custom express” software
applications which provide an expedited approach to calculating savings and incentives
for certain custom technology projects.
•
Recommendation of new items or changes to existing items on prescriptive offering lists,
adjustments to savings estimations, and additions or modifications to the list of
acceptable measures on an annual basis, or on a cycle and through a procedure to be
determined.
•
As-needed assignments to collect data and/or to produce recommendations which would
allow the Program Administrators to address unanticipated program implementation
issues.
5.
Long-term Goals
The Plan’s long-term goal is to provide a consistent set of statewide programs and
strategies that can be delivered to customers in a seamless fashion, regardless of whether the
customer is served by a combined gas/electric Program Administrator, by different gas and
electric Program Administrators, or has facilities or projects in multiple Program Administrator
service areas. Program Administrators will continue to explore ways to achieve this goal.
In line with increasing savings goals, the Program Administrators are looking to garner
participation throughout market sectors that have had historically low participation rates in
Massachusetts programs, while identifying ways to provide customers who are more active in
Mass Save programs packaging of services to encourage the pursuit of more comprehensive
projects.
Over this Three-Year Plan, the Program Administrators are committed to a continued focus
on deeper savings, exploring ways to effectively encourage customers and trade allies to focus
on more long-term, comprehensive and advanced energy efficiency solutions. The PAs also
recognize that reducing or eliminating barriers to customer and vendor participation is an
important driver of successful program operations, and the PAs will work to implement findings
from process evaluations to streamline and improve programs. In addition, the Program
Administrators will continue to improve delivery mechanisms to encourage statewide
participation in energy efficiency programs by all customer segments.
109
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 115 of 274
6.
Program Descriptions
a. Residential Program & Core
Initiative Descriptions
Over the course of the next three years the PAs
plan to build on the many successes that occurred in
the electric and gas residential and low-income sectors
during the initial three-year plan. As noted in the
following program descriptions, there are many new
program enhancements planned for 2013-2015. These
enhancements are designed to take residential and lowincome programs to the next level in terms of strategic
program delivery and maximizing energy savings
opportunities for our consumers.
While there are many new components within
these descriptions, there are also fundamental program
elements that will continue to serve as the core
infrastructure for future innovation. The best example
of this is the Home Energy Services initiative that
provides the gateway for residential consumer
participation and exposure to the broad array of
complementary program initiatives that drive broader
and deeper savings. The PAs plan to enhance and
refine this recently redesigned initiative (strongly
supported by the Council) through greater initiative
integration and inclusion of innovative strategies
designed to minimize participation barriers.
As noted throughout this Plan, the PAs are
committed to building upon the other successful
electric and gas residential and low-income programs
through greater integration, introduction and
acceleration of new technologies such as LED lighting,
strategic focus on multi-family and performance-based
community engagement initiatives, combined with an
overall goal of delivering robust, cost-effective
programs.
110
Mass Saver Combo
Events Tour Malls
and Outlets Across
the State
Cape Light Compact booth, shown
here at the Cape Cod Mall,
distributed 2,500 packages of the
most cost effective energy efficient
lighting products to customers
between March & April, 2012.
Statewide, all PAs distributed over
21,000 packages through similar
mall events during 2011.
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 116 of 274
RESIDENTIAL WHOLE HOUSE PROGRAM
Description:
This program focuses on comprehensive gas and electric energy efficiency opportunities
associated with mechanical, electrical and thermal systems in existing residential single homes
and multi-family facilities. It offers energy assessments and provides technical assistance and
incentives in a variety of core initiatives to encourage whole house or whole building upgrades
of measures and equipment with a higher efficiency product. The program also includes new
construction opportunities in conjunction with retrofit efforts for residential customers in the
Commonwealth.
Program services include technical assistance (to identify and quantify opportunities),
and financial incentives, typically based on a percentage of project costs (both material and
labor) that make upgrades attractive to building owners, home owners, tenants and new
construction builders. The Program Administrators also partner with advocates, building
scientists, and regulators to ensure that the best practices in building design and equipment
specifications introduced and propagated by the program are ultimately built into the evolution
of better building requirements.
For the 2013-2015 Plan, the Program Administrators are proposing to include all whole
house core initiatives (i.e., HES, Multi-Family Retrofit, and Residential New Construction)
within the overall Residential Whole House Program. As the name implies, this program targets
residential single family homes and residential multi-family dwellings by addressing the entire
home or facility with energy efficiency opportunities. The core initiatives offer incentives, for
recommended retrofit measures including lighting, refrigeration, insulation and air sealing, and
coordinates with the Residential Products Program to incorporate technologies such as heating
and cooling equipment, controls, and programmable thermostats. In addition to the financial
incentives, the HES and Multi-Family Retrofit core initiatives allow participants to qualify for
interest-free loans for the customer portion of project costs.
Behavioral-based Initiatives
Program Administrators understand that identifying the motivational factors that cause
residential customers to actively employ personal energy saving actions and/or participate in
energy efficiency programs is integral to meeting the PAs’ long and short term goals. Over the
course of the last three-year plan, several PAs have introduced various behavior–based initiatives
within their respective territories. These initiatives all varied in size and scope and included
different implementation mechanisms along with a mix of vendors. They also included various
delivery methodologies such as opt in/opt out, rewards based, energy reports, meter data
feedback, and in some cases a combination thereof.
For the 2013-2015 Three-Year Plan, there is a consensus among the PAs to research offering a
behavioral-based initiative. However, an evaluation study of the existing behavior-based
initiatives has been conducted concurrently with these draft filings to-date. Thus, the pending
results are expected to influence the specific path and direction of PA initiatives. For PAs
111
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 117 of 274
participating in a behavioral-based initiative, separate budget line items appear in the D.P.U. 0850 tables.
Codes and Standards
The PAs plan to pursue a codes and standards initiative in the Residential Whole House
program. Activities under this initiative will be tracked by the PAs so there is better
understanding of budgets for future funding cycles.
The theory behind a codes and standards effort is that the PAs can provide support to
improve compliance with building energy codes and appliance standards. As codes become
increasingly stringent, the residential building community (owners, developers, contractors) is
struggling to interpret requirements and to comply with building codes. The recently completed
Massachusetts code compliance study highlighted that many energy code requirements in new
construction homes were not fully compliant with the energy code. The Residential Whole
House program has a successful history of promoting, educating, and delivering energy efficient
measures and products in the past. For these reasons, the PAs are in an advantageous position to
support code compliance and code enhancement through energy codes training and education as
they work closely with policy makers and trade allies. The PAs’ efforts could supplement the
efforts of code enforcement officials who may be challenged to fully enforce the energy use
provisions, where their focus is more on health and safety related aspects of the code. Existing
infrastructure could also be leveraged to provide the research and advocacy required to promote
increased codes and standards. The PAs plan to act as a conduit to influence and recommend
increases and improvements to new stretch codes and appliance standards. Through their
relationship with contractors and builders, the PAs will be able to support the implementation of
those improvements going forward. This should result in the realization of the energy savings
that are lost when newly constructed homes are not 100 percent compliant with the locally
applicable building code. The PAs could expand upon existing incentive-based new construction
program outreach efforts to target various stakeholders.
The Program Administrators plan to introduce efforts to assist in encouraging the
adoption of and compliance with more stringent building energy codes and appliance efficiency
standards during the 2013-2015 program cycle. The intent is to claim the additional savings
generated through the unique efforts attributable to PA actions. The potential paths to achieving
savings through codes and standards efforts by the PAs include:
1. Compliance Support for Base and Stretch Code: The PAs would work with local
builders, contractors and building enforcement officials to increase the number of homes
complying with the locally applicable energy code, generally either the IRC
(International Residential Code) version adopted statewide, or the Stretch Code.
Activities may include targeted trainings, outreach and technical support in the form of
code ambassadors and circuit riders, compliance documentation tool development, and
review support. Looking ahead, additional infrastructure needs to be developed to
support the next iteration of requirements for residential new construction. For example,
the IECC 2012 building code requires blower door testing for all residential buildings.
Starting in 2013, the PAs plan to begin the strategic identification of jurisdictions that
would benefit from code compliance support.
112
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 118 of 274
2. Stretch Code Development Support: The PAs will support the DOER’s development of a
stretch code that exceeds statewide minimum requirements and is adopted by local
governments. A coordinated approach by the PAs will provide technical support for the
DOER’s development of the next round of stretch code (potentially 2015 version) to
avoid duplicate efforts and costs.
3. Appliance Standards Advocacy: The objective here would be to accelerate the
development and adoption of targeted new residential appliance standards as the selected
appliances and their advanced levels of efficiency start to become established as current
good practice in the marketplace. PAs would provide support, which may include the
technical resources necessary for assessment of potential appliance standards and
advocacy either at the state or regional/federal level. Market and technical potential
studies (in coordination with Northeast Energy Efficiency Partnerships (“NEEP”) and
Appliance Standards Awareness Project (“ASAP”)) for a handful of residential
appliances will begin in 2013 and may include game consoles, set-top boxes, outdoor
lighting and televisions.
Evaluation, Savings, Attribution: The PAs will collaborate with the stakeholders on development
of an evaluation plan that will enable the measurement and attribution of savings from these
efforts to the PAs for the 2013-2015 program cycle. A detailed evaluation plan, along with an
appropriate attribution methodology, will be developed in 2013. Qualitative as well as
quantitative research would be planned for in 2013 and 2014 to evaluate ongoing initiative
efforts and will be used for savings projections that can potentially be claimed within this three
year cycle and future cycles.
113
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 119 of 274
SECTOR
PROGRAM
CORE INITIATIVE
WHOLE HOUSE
RESIDENTIAL NEW
CONSTRUCTION
ADMINISTERED BY
в—Џ
RESIDENTIAL
Core Initiative
Overview
ELECTRIC &
GAS PAs
JOINT
PA SPECIFIC
Key Objectives:
The Massachusetts Residential New Construction (“RNC”) Core Initiative strives to increase the
construction of energy efficient market rate homes that exceed the state’s energy code. To address the
challenges of rising energy codes and a downturn in the housing market, the Program Administrators will
look to incorporate the lessons learned from the past three years and the associated initiative pilots
(lighting design and multi-family new construction) to increase participation and energy savings.
The PAs will continue working with the Home Energy Rating System (“HERS”) infrastructure and
provide ongoing training to the construction industry. The initiative is a proud participant of the national
ENERGY STARВ® Homes Program and benefits from the regional, as well as national, advertising efforts
that ENERGY STARВ® Homes implements.
New Enhancements
• The PAs plan to incorporate the multi-family new construction pilots mentioned above by Q1
2013.
• The initiative will transition to add prescriptive offerings for homes exceeding the Massachusetts
User Defined Reference Home (“UDRH”) by Q1 2013.
• As a means to maintain high performance builders and attract new builder participation:
o
PAs to work with Evaluation to explore an alternative method to calculate savings for the
114
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 120 of 274
o
Performance Path
Streamline and simplify builder participation path through prescriptive package offerings
These additional initiative enhancements, will build on the current initiative structure to help broaden
participation and overall market penetration and gain additional energy savings. The prescriptive offerings
are detailed in the “Core Initiative Design” section below.
Core Initiative Design
The PAs continue their strong commitment to a whole-house approach for the residential new construction
market. The initiative is committed to achieving both a broader market penetration of energy-efficient
homes as well as moving builders toward deeper energy savings where possible. The PAs will strive to
both retain existing participating builders and recruit additional homebuilders and contractors. The PAs
will train builders on the Environmental Protection Agency’s (“EPA”) ENERGY STAR® Homes Program
in support of the 2012 Massachusetts Stretch Energy Code.
The initiative will provide incentives for projects exceeding the UDRH:
• Prescriptive Option 1 – a bundle of prescriptive measures that address heating, cooling, and hot
water equipment, lighting, water use reduction, efficient appliances, and enhanced envelope air
tightness and duct tightness.
• Prescriptive Option 2 - a bundle of prescriptive measures that include all Option 1 measures as
well as enhanced envelope thermal performance
• Performance Tier 1 - 15% improvement or better over the UDRH and compliance with sections 3
and 5 of the ENERGY STAR Thermal Enclosure System Rater Checklist
• Performance Tier 2 - 30% improvement or better over the UDRH and compliance with sections 3
and 5 of the ENERGY STAR Thermal Enclosure System Rater Checklist
• Performance Tier 3 - 45% improvement or better over the UDRH and compliance with sections 3
and 5 of the ENERGY STAR Thermal Enclosure System Rater Checklist
All percentages may vary due to UDRH changes.
Builders are encouraged to improve a building’s energy usage through enhanced envelope measures,
energy efficient space and water heating, appropriately sized cooling equipment, programmable
115
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 121 of 274
thermostats, ENERGY STARВ® qualified appliances, Water Sense plumbing fixtures, efficient lighting and
controls, and proper mechanical ventilation. Builders are also encouraged to properly orient homes to take
advantage of passive heating and cooling.
All homes participating in the initiative are required to install efficient lighting products in appropriate
hard wired sockets and pass a final verification inspection. As energy codes become more stringent, the
PAs will continue to encourage proper lighting design and the installation of new, cutting edge, lighting
products and controls. A single family home is defined as a single family detached house, while a multifamily home is defined as two or more attached units. All residential new construction projects in the
Commonwealth are encouraged to participate in the initiative. Mixed-use and large buildings are
addressed on a custom basis in cooperation with the commercial initiatives.
The Multi-Family New Construction (“MFNC”) core initiative offers incentives to eligible 4+ story multifamily facilities that are located in participating PA territories. The goal of the MFNC core initiative is to
provide a seamless transition from the current multi-family pilot to a fully integrated initiative. This
initiative will take the lessons learned from the three year pilot and continue to provide a single point-ofcontact for the participants and service for all fuel sources and meter configurations. A suite of offerings
will include a comprehensive list of measures, such as wall insulation, heating systems, instant savings
domestic hot water measures, appliances, lighting, and controls, to maximize energy savings above
Massachusetts energy code.
Marketing Overview
Target Market:
Homebuilders/Developers
Contractors
Architects/Designers
Trade allies
HERS raters
Homebuyers
Realtors
Code Officials
Appraisers/Mortgage bankers
116
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 122 of 274
Strategy:
The initiative will use a combination of the following to reach the target markets:
Trade shows, builder training (on-site and lecture), lumber yard outreach, strategic partnerships such as
Home Builders Associations (“HBA”), geo-specific targeting based on construction activity.
Technologies/Incentives The following is a list of packages, recommended technologies, and incentives offered:
Package
Requirements
Incentive
Performance
Single
Multi Family
Path
Family
100-199
2-99 units
units
Tier 1
15% improvement or
better over the UDRH
and compliance with
sections 3 and 5 of the
$750
$650
$500
ENERGY STAR
Thermal Enclosure
System Rater Checklist
Tier 2
30% improvement or
better over the UDRH
and compliance with
sections 3 and 5 of the
$1,250
$1,150
$850
ENERGY STAR
Thermal Enclosure
System Rater Checklist
Tier 3
45% improvement or
better over the UDRH
and compliance with
sections 3 and 5 of the
$7,000
$4,000
$3,000
ENERGY STAR
Thermal Enclosure
System Rater Checklist
117
200+ units
$350
$550
$2,000
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 123 of 274
Prescriptive
Path
Prescriptive
Option 1
Prescriptive
Option 2
heating, cooling, and
hot water equipment,
lighting, water use
reduction, efficient
appliances, and
enhanced envelope air
tightness and duct
tightness
a bundle of prescriptive
measures that include
all Option 1 measures as
well as enhanced
envelope thermal
performance
$1,250
$1,150
$850
$550
$7,000
$4,000
$3,000
$2,000
Single Family is defined as a detached unit. Two or more attached units are classified as Multi-family. A
Multi-family project must be no more than three stories and residentially permitted to qualify.
Multi-family Buildings with Four or More Stories
Package
Prescriptive In-unit
Requirements
Efficient heating, cooling,
and ventilation
equipment, efficient hot
water equipment, lighting
power reduction, water use
reduction, and efficient
118
Incentives
Up to $250 per unit
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 124 of 274
Whole building &
prescriptive in-unit
Whole Building Custom
appliances
Same as in unit
Prescriptive whole building
prescriptive incentive.
incentives to be determined
Whole building measures
include enhanced
envelope, efficient central
heating, cooling, and
ventilation
equipment, efficient central
laundry equipment, and
efficient lighting and
controls in common areas
Commercially metered
projects are eligible for the
same instant savings
measures and will be
referred to the vendor to
evaluate applicable custom
improvements.
Custom incentives
The PAs will work with the MTAC to include new measures or technologies as appropriate.
Delivery Mechanism
The initiative is administered statewide by the PAs. Through a competitive bid process, the PAs chose a
statewide implementation vendor to oversee the daily operations. The vendor is responsible for tracking
and reporting program activity to each PA. Throughout the planned timeframe, the PAs will continue to
work with the market-based network of trained contractors who offer energy efficiency and rating services
to homebuilders.
The PAs will deliver in-depth trainings to the target market in the fundamentals of building science,
energy codes, and the latest emerging technologies to promote the initiative, as well as support workforce
development efforts through the Green Jobs Act.
119
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 125 of 274
Three-Year
Deployment
Strategy/Roadmap
For residential new construction, the efforts to achieve both deeper savings and gain broader market
penetration will continue through multiple channels of participation, one of which continues to push
homes closer to net zero energy. The initiative is dedicated to promoting energy efficient new construction
by supporting the target market.
For the three-year deployment, the PAs will focus on the following efforts:
•
Support target market in achieving deeper levels of energy savings with relevant trainings
•
Expansion of the base of participating builders/homeowners
•
Continued coordination with existing and new market allies
•
Continue to promote consumer awareness through statewide marketing
Special Notes
120
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 126 of 274
SECTOR
PROGRAM
CORE INITIATIVE
WHOLE HOUSE
HOME ENERGY
SERVICES
ADMINISTERED BY
в—Џ
RESIDENTIAL
Core Initiative
Overview
ELECTRIC &
GAS PAs
JOINT
PA SPECIFIC
Key Objectives:
To offer single family (1-4 units) residential customers energy efficiency recommendations and incentives
that enable those customers to identify and implement cost-effective energy efficiency improvements. The
Home Energy Services (“HES”) Core Initiative utilizes outreach mechanisms, cross-marketing, incentives,
and financing to make it easy, clear, and compelling for customers to participate in all residential energy
efficiency programs. The program exemplifies a program-as-a-system approach where all components
work together to support the success of achieving deeper energy savings per customer.
New Enhancements:
The PAs are considering various initiatives for implementation over the next three years. However, as the
redesigned market model continues into the next three year plan, it is our recommendation that new
initiatives are phased in throughout the three-year plan. As Independent Installation Contractors and Home
Performance Contractors are still familiarizing themselves with the new program model, we believe it is
best to allow adequate time for the contractors to become proficient.
Also, to ensure proper roll out, the PAs recommend allowing for adequate planning of timelines for various
initiatives to include a test period and review prior to launch. The PAs are fully committed to the
enhancements listed below and will make every attempt to roll out, where feasible, any new enhancements,
prior to the noted timelines
The PAs are also making strides towards deeper savings. Some examples include the PAs’ exploration of:
Targeted customer segmentation outreach (best opportunities to fit the customer’s needs)
121
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 127 of 274
Packaging of measures
Whole house incentives (for multi-unit, single-family homes)
Targeted hard-to-reach (such as Efficient Neighborhoods+)
Pre-weatherization incentives
Inclusion of renovation and deeper savings measures incentives
Early retirement incentives for heating and cooling equipment
Targeting of higher tiered appliances for incentive offerings
Potential for engagement with the Massachusetts Clean Energy Center, if applicable
•
PAs plan to investigate the opportunity to incorporate cost-effective new technologies and measures
(e.g. advanced insulation including spray foam insulation). PAs plan to work with the evaluation
team to review measures by Q2 2013.
•
PAs intend to explore offering recognition events to encourage contractors to maintain high quality
work, highlight best practices and recognize various program partners for excelling in their
profession. PAs plan to work with Contractor Best Practices Group on ways to highlight quality
installers and installations.
•
PAs plan to explore enhanced customer follow-up strategies to encourage increased major measure
implementation. Strategies may include targeted emails and mailings. This is an ongoing effort.
•
PAs intend to investigate online options for customer sign-up/tracking by enhancing web/mobile
friendly applications for ease of customer use. For example, PAs would like to explore capturing
customer interest in receiving a Home Energy Assessment through the online portal. The HES Core
Initiative plan to work with other initiatives to coordinate implementation with the statewide
marketing group.
•
PAs intend to define the hard to reach/hard to serve market and explore solutions. PAs plan to
investigate options to overcome tenant-landlord barriers to program participation, focusing on clear
program outreach to maximize savings and benefits from this hard to reach/ hard to serve market.
PAs plan to build on lessons learned from past experience. Please refer the Efficient
Neighborhoods+.
•
PAs plan to review evaluation results from the 2012 Pre-weatherization barrier initiative, which
offered incentives to evaluate conditions and remediate health and safety barriers such as knob and
122
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 128 of 274
tube wiring, dryer vents, and combustion safety. Based on the analysis, PAs intend to design a
standard pre-weatherization barrier offer and may review incentives for other barriers. Please refer
to the Action Plan section on Pre-weatherization.
•
PAs intend to continue supporting the development of highly qualified Home Performance
Contractors (“HPCs”) and Independent Insulation Contractors (“IICs”) by offering various training
subsidies for workforce development needs such as technical skills, business skills, and sales
trainings. This is an ongoing effort.
•
PAs intend to explore a shared incentive approach in multi-unit (2-4 unit) buildings to maximize the
incentive among all units in the building to achieve deeper energy savings. This approach will
address a whole-building approach as opposed to a unit-focused approach. The PAs plan to identify
a program model by Q3 2013 with implementation by Q2 2014.
•
PAs plan to continue engagement with community groups and initiatives to market HES. Refer to
the Elements of a Community Model section submitted as part of Metric #2 of the “2011
Community Outreach Report”, as well as the Community Engagement description in Section III.H.2
of this Plan. This is an ongoing effort.
•
PAs intend to test the efficacy of enhanced incentives to increase penetration into hard to reach
markets, such as 2-4 unit dwellings and economically challenged neighborhoods in 2013. PAs will
seek to incorporate lessons learned from a similar program offered in the early 2000s. PAs intend to
use lessons learned from the 2013 trial offer to implement a broad offering in 2014 and beyond.
•
PAs plan to review the HPC evaluation results to identify any variations in customer experience and
implementation rates to develop strategies for continued improvements. Recommendations may be
implemented among Lead Vendor Energy Specialists and Home Performance Contractors. This is
an ongoing effort.
•
PAs anticipate offering deeper energy savings based upon lessons learned from the major
renovations, including additions and deep energy retrofit pilots. Significant research is necessary to
develop the trainings needed to build the contractor infrastructure to implement this initiative
successfully. Currently, efforts are underway to create a manual for deep energy retrofit
components, but key trainings will be needed to ensure a quality end-product. The PAs plan to
offer new approaches to these efforts with key trade allies by Q1 2014. PAs intend to explore
possible partnerships and incentive offerings with trade allies such as fuel dealers, general
123
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 129 of 274
contractors, roofers, and siding contractors to increase customer participation by promoting the HES
initiative. Based on evaluations, these efforts may take some continued efforts. The PAs plan to
continue offer information to interested contractors and plan to work with other initiatives to offer
materials by Q2 2013. PAs plan to review the results of the 2011 “Packaged Measures Pilot” for
lessons learned to develop a cost-effective package or bundle of incentives for customers to
implement multiple deeper energy savings measures. Based on evaluations, these efforts may take
some continued efforts. The PAs plan to offer information to interested contractors and work with
other initiatives to offer a new packaged measure for a limited time promotional timeframe by Q32013.
Core Initiative Design
The HES core initiative is committed to a comprehensive whole-house approach and seeks to maximize
energy savings. The initiative directs customers using natural gas for space heating to their gas provider
and customers using electric, oil or propane for space heating to their electric provider. It is also
recognized that exceptions to this guideline may occur (e.g., specialized high bill complaints, community
outreach programs, etc.). In these cases, and unless there are prior mutual agreements between the gas and
electric PAs, the PAs will seek to negotiate in good faith to achieve a resolution that serves the common
interests of both PAs, the interests of the consumer, and maximizes savings opportunities on a fuel-neutral
basis. The initiative is committed to achieving maximum program success and deeper energy savings. The
program aims to make distinctions indiscernible to consumers.
The service is intended to be customizable, providing personalized information and incentives to a broad
group of customers. Customers are guided to the appropriate program services, including targeted energy
efficiency information, advanced diagnostics, and efficiency rebates and incentives. Low-income customers
are referred to appropriate low-income programs.
The PAs currently offer one single comprehensive assessment, called the Home Energy Assessment.
This assessment is an in-home visit designed to provide general information and education about energy
efficiency and identify opportunities and challenges for energy saving installations. With the customer’s
permission, Compact Fluorescent Lights (“CFLs”) are installed for no cost in all appropriate locations, as
are low-flow shower heads, faucet aerators and programmable thermostats (as needed and qualified). The
instant energy savings realized during the Home Energy Assessment are intended, on average, to exceed
124
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 130 of 274
the expected average cost to deliver this visit. Additionally, during this visit, customers’ specific needs will
be evaluated, and opportunities for subsequent direct installation measures may be identified. Customers
will be directed to other energy-efficiency resources as appropriate.
The Home Energy Assessment also includes a variety of diagnostic techniques such as infrared scanning
(temperature permitting). Wherever feasible, full installation of targeted cost-effective air sealing is
provided at no cost to the customer. In all cases where the customer elects the fully subsidized air sealing
offer, or installation of insulation, a blower door test and combustion safety test will be performed pre and
post installation to maximize air leakage reduction and maintain combustion safety standards. If specific
energy-efficient improvements require professional contractors, or a customer contribution, the Energy
Specialist explains the contractor services required to install recommended measures, as well as all
available energy efficiency financial incentives.
Another visit, the Special Home Visit, may be scheduled for those customers interested in measure
screening such as a refrigerator screening or in “no heat” emergency situations where a pre-screening for an
applicable incentive is required. An Energy Specialist will perform a quick assessment of the home for
energy efficiency opportunities, install instant savings measures (where appropriate), and screen the
refrigerator or heating system for upgrade eligibility. A customer may be scheduled for a Special Home
Visit as determined during the initial intake process.
To ensure all work is completed to the PAs’ standards, the Quality Assurance Visit allows all work to be
inspected. This may be done through a combination of methods, including a phone survey, postcard, e-mail
or actual site visit by the lead vendor and/or a third-party PA-approved vendor. Quality inspections are
performed to ensure that contractor-installed measures are accurate, professional, and safely installed based
on initiative standards, as well as to ensure savings.
The PAs strive to maximize energy savings by promoting and supporting contractor training and education
in an effort to establish a broader workforce knowledgeable of proper installation techniques. The goal is
to have a sustainable and experienced workforce focused on achieving maximum energy savings and ready
and able to meet customer demand.
Marketing Overview
Target Market:
125
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 131 of 274
The HES initiative target market is all non-low-income residential customers living in single family houses
or one- to four-unit buildings that are not part of a larger site where an association exists (such as a condo
association with multiple 4-unit buildings). The initiative aims to reach the aforementioned customers who
are interested in making their homes more energy efficient. HES is a fuel-blind initiative.
Strategy:
Outreach and marketing efforts will be expanded and PAs plan to explore building relationships with
realtors, home improvement contractors, architects and others involved in renovations of one-to-four family
homes. Marketing efforts will be designed to meet the objectives of reaching more customers (going
broader into the customer base) and maximizing energy savings opportunities (going deeper into each
home to find ways to save energy). The PAs will also continue market segmentation work to strategically
target customers with the most opportunity as to increase the rate of audits that result in energy efficiency
measure recommendations.
The PAs plan to work closely with Independent Installation Contractors and Home Performance
Contractors as a means to increase participation and consumer savings. Further, the PAs plan to continue
to seek new ways to identify, educate and reach landlords and other hard to reach/ hard to serve customers
to increase participation. Efforts may include targeted marketing based on identified key demographics to
better reach the 2-4 unit property sector.
The initiative’s multi-media outreach campaign will focus on partnerships with local media outlets or
affiliates, radio, print advertising, web-based marketing through various social media sites, and through
part of the consolidated website, www.masssave.com, which integrates all of the Massachusetts energy
efficiency programs and incentives into a single source web-based outlet.
Current forms of multi-media outreach include:
•
•
•
•
•
Mass SaveВ® website (enhanced via the Statewide Integrated Energy Efficiency Website)
Bill inserts
Highly visible billboards
Radio, print and visual media advertising
Registry of Motor Vehicle advertising
126
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 132 of 274
•
•
•
Cinema advertising
New media advertising (advanced online options)
Targeted outreach through Community-based Outreach Initiatives (“CBOs”). These initiatives
utilize community outreach for promoting this program and the array of incentives available.
Individual Program Administrators may conduct additional marketing, such as behavior feedback
mechanisms, if applicable and may ramp their marketing up or down as needed to meet participation and
budget goals.
Technologies/Incentives The following is a list of targeted end uses, recommended technologies, and incentives offered:
Targeted End Use
Technology
Incentive
In Unit Lighting
In Unit Lighting
Compact Fluorescent Light Bulbs
LED technology
Water Conservation
Heating and Cooling
Appliances
Faucet Aerators and Showerheads
Programmable Thermostats – electric
heat
Smart Strips (where applicable)
Targeted cost effective air sealing
Attic Insulation
Wall Insulation
Basement/Crawl Space Insulation
Rim Joist Insulation
DHW insulation
Pipe Insulation
ENERGY STARВ® Rated Refrigerator
No Cost to Customer
limited (subject to planning
and budget impact)
No Cost to Customer
No Cost to Customer
Heating
Water Heating
Heating System
Water Heating
Electricity Conservation
Heating and Cooling
Weatherization
127
No Cost to Customer
No Cost to Customer
75% Incentive up to $2,000
$150 For Qualified
Replacements
Varies by type
Varies by type
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 133 of 274
Additionally:
•
•
•
•
•
Delivery Mechanism
0% financing HEAT Loan offers $500-$25,000 with terms from 2 - 7 years for qualified customers
Alternative insulation types, if cost effective, (e.g., spray foam, rock wool) will be incorporated into
the program offers
Pre-weatherization offers
Early heating system and heat pump water heater replacement rebates
The PAs will work with the MTAC to include new measures or technologies as appropriate.
The program is delivered by lead vendors selected through a competitive bidding process. Lead vendors are
responsible for managing and training market based participants such as participating IICs and HPCs.
Additional lead vendor responsibilities include:
•
•
•
•
•
•
•
•
Consistent statewide training
Data reporting
Achieving aggressive savings
Customer satisfaction
Quality control standards
Scheduling requirements
Technical Assistance
Maintain and report health and safety information
Two groups of participating contractors, Home Performance Contractors (“HPCs”), and Independent
Installation Contractors (“IICs”) provide services in addition to those services offered by the lead vendor.
All participating contractors must meet program eligibility and requirements. HPCs independently recruit
customers, provide Home Energy Assessments, and implement weatherization measures. IICs provide
installation of weatherization measures for those customers who received a Home Energy Assessment from
the lead vendor. IICs also have the opportunity to independently recruit customers and refer them to the
lead vendor for the Home Energy Assessment.
In order to receive incentives or program rebates, customers are required to have a Home Energy
Assessment through either the PAs lead vendor or via a participating Home Performance Contractor to
128
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 134 of 274
identify and prioritize all cost-effective energy efficiency upgrades. Insulation work, whether performed by
a Home Performance Contractor or Independent Installation Contractor, will have a quality control
inspection performed by the PA-vendor, or third party vendor when the work is complete. This will ensure
that high quality is maintained, and installations meet BPI standards or similar standards set by the PAs.
After a competitive bidding process, the PAs contracted with a third-party Quality Control (“QC”) vendor
to perform QC inspections of program implementation vendors, and participating contractors. The QC
vendor will provide valuable information and feedback to the HES members on successes and identify
areas of possible improvement.
The HES members are working together toward a “best practices” approach to provide a more coordinated
statewide training to reinforce quality installation techniques in HES. It is expected that training
requirements will increase over time in order for contractors to retain their status as a HES participating
contractor. Additionally, contractors must maintain a high level of customer satisfaction to continue
participating in the initiative.
Three-Year
Deployment
Strategy/Roadmap
With the numerous enhancements that have been identified for this initiative, HES will continue to
prioritize the enhancements that will lead to the most benefits for the largest number of customers. PAs
intend to better capture and utilize property data for the purpose of identifying properties with potential
installation opportunities to implement targeting marketing efforts. PAs will continue to explore new
technologies in conjunction with significantly increasing the implementation of known cost effective
measures. PAs intend to continue to develop the proficiency of participating contractors through
establishing qualification/training guidelines using the BPI or its equivalent as a benchmark. Please see
Core Initiative Overview section for near term and longer term enhancements that will be explored in this
three-year plan.
Special Notes
HES underwent significant changes in 2011, and numerous enhancements are proposed to continually
address customer needs. The priorities have been made to address the most customers with the biggest
savings impacts. The PAs will continue to refine the priorities as evaluations are completed. The key to
proposed efforts will be to research, train, and test theories before full-blown implementation to ensure that
the PAs are addressing opportunities with the best information available. One key effort, Efficient
Neighborhoods+, will address hard to reach/hard to serve customers in economically challenged
neighborhoods. For further detail, please refer to section III.F.6.b.i.
129
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 135 of 274
SECTOR
PROGRAM
CORE INITIATIVE
WHOLE HOUSE
MULTI-FAMILY
RETROFIT
ADMINISTERED BY
в—Џ
RESIDENTIAL
Core Initiative
Overview
ELECTRIC &
GAS PAs
JOINT
PA –
SPECIFIC
Key Objectives:
The Multi-Family Retrofit core initiative offers energy assessments to eligible multi-family facilities,
containing five or more dwelling units that are located in participating PA service territories. Incentives
are offered for eligible cost-effective improvements that increase gas and electric efficiency (including, but
not limited to lighting, hot water measures, shell improvements, heating, cooling and water heating
equipment and controls). They are supplemented by additional incentives and services from the applicable
C&I initiatives.
New Enhancements:
Strategies under consideration to achieve deeper savings include (please refer to the Multi-Family Action
Plan):
•
Differentiated services for condominiums - The PAs discovered that condominium owners within
this initiative view themselves and act similar to the single family homeowner. In an effort to meet
the condo customers’ expectations, the PAs are expanding the HEAT Loan eligibility and allowing
for single unit assessments where warranted by Q1 2013.
•
Incorporate additional emerging technologies. Ongoing throughout program years 2013-2015.
•
Modify weatherization incentives to master-metered gas heated sites for greater consistency across
the entire multi-family sector. The PAs plan to coordinate with C&I team and have incentives in
place in Q2 2013.
•
Consider expanding offerings to certain multi-family market segments to allow customers to
130
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 136 of 274
receive incentives for deliverable fuel efficiency improvements from their electric PA. Effort will
be prioritized during program year 2013.
Core Initiative Design
•
Target landlord, building management, building operator trade associations, and design
professionals, including the expansion of successful case studies. Ongoing throughout program
years 2013-2015.
•
Renew focus on coordinating the multi-family and commercial initiatives to streamline delivery of
packaged, comprehensive energy efficiency services to the multi-family sector. The PAs will
coordinate with C&I team and work to identify potential approaches by Q2 2013.
•
Develop opportunities for lead generation through other PA programs. Ongoing throughout
program years 2013-2015.
The initiative design is based upon the following guiding principles:
•
Participants will initiate a request for all services offered by the initiative through one party,
without the need to directly contact multiple program administrators or multiple parties within the
same program administrator. Throughout the project life cycle, the participant will have access to
a single point-of contact that will facilitate all programmatic communication and coordination.
•
Eligibility for initiative measures and services will be based on cost-effectiveness and will not be
restricted by the rate class associated with the meter(s) for the facility.
•
The initiative is structured to ensure that participants are provided with an integrated “whole
facility” assessment that would provide the customer with documented opportunities for
improvement regardless of fuel type.
•
For condominium owners who wish to receive a single assessment rather than involve the
condominium association, the initiative is structured so a request for facility management contact
information is made. The design and goal is to pursue engagement of the entire facility to receive
services, thus having the ability to obtain deeper savings for the facility.
The PAs strive to deliver a fully integrated offering to a participant, regardless of fuel type, service
territory or rate class, in a manner that will result in a seamless customer experience, thus mitigating the
potential for customer confusion and lost opportunities. An integral part of the initiative’s design involves
the services of a Multi-Family Market Integrator (“MMI”) who provides a single point-of-contact at intake
131
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 137 of 274
to help ensure the seamless delivery of the initiative’s phases described below.
Participant Screening:
Delivering energy efficiency services to the multi-family market is challenging because of the many
variations in size and construction, as well as ownership and decision making structures that exist. The
Program Administrators will ensure that the services offered by the Multi-Family Retrofit Core Initiative
are easily scalable to accommodate simple projects to highly complex projects. In addition, there will be a
screening process to identify where along this continuum a project lies. The screening information will be
obtained when the potential participant is contacted upon enrollment. It is during the initial discussion
with the potential participant, that the MMI will gain a better understanding of the end uses available for
treatment and the motivations that drove the potential participant to solicit energy efficiency services.
Armed with this information, the MMI will explain that, in addition to the measures initially requested, a
more complete assessment may be performed to identify other energy savings opportunities. By
motivating the participant to accept the whole facility assessment, the project could ultimately result in
deeper savings than otherwise would have been realized.
Enrollment:
Because of the diversity within the multi-family sector and the various market actors that may be involved
in lead generation, the Initiative allows for multiple points of entry that will all ultimately provide
participants with comprehensive offerings and a seamless experience. Participants may enroll via
telephone or their request for services may be initiated by other market actors, such as a PA’s Account
Executive, referral from another PA initiative, a contractor, a consultant or engineer. Each participant will
need to contact only one party to avail themselves of comprehensive services. Once the MMI is made
aware of a project (either via telephone or lead from another market actor), he or she reviews the
information provided then makes the initial contact with the customer and collects further information, as
needed, to complete the enrollment.
Whole Facility Assessment
Based on the outcome of the screening/enrollment process, the appropriate technical resources will be
assigned to conduct a whole facility, fuel-blind assessment. The MMI will attempt, through the screening
process, to identify all resources required for the assessment; however, there may be instances where
additional expertise is required and further site visits may be necessary. Technical assessments,
benchmarking, and engineering studies may be conducted on a custom basis.
132
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 138 of 274
Proposal for Energy Efficiency Services
Using the findings from the site specific assessment, the appropriate parties will draft a project proposal
including measures, other available services and incentives. Once the comprehensive offer receives PA
approval, it will be presented to the participant by the parties required to help the customer fully
understand the offering.
Delivery of Measures and Services
The implementation vendor(s) will coordinate the delivery of the measures and services opted by the
customer. To the extent possible, all dwelling unit measures will be installed in a single visit to minimize
disruption for the tenants; however, multiple visits may be required for the installation of common area
measures. The multi-family core initiative will continue to integrate with the commercial initiatives for
applicable measures and services for seamless delivery to the customer.
Quality Assurance
Quality assurance will be performed in support of this initiative. After a competitive bidding process, the
PAs contracted with a third-party Quality Assurance/Quality Control (“QA/QC”) vendor to perform
inspections on a select percentage of projects. The QA/QC vendor will provide valuable information and
feedback on successes and identify areas of possible improvement. These inspections will be in addition to
the final inspections already performed by the implementation vendors of their subcontractors.
Additional Core Initiative Design Elements
A link to the current EPA Benchmarking tool (Portfolio Manager), or other comparable tool, is included
on the website page(s) associated with the Multi-Family Retrofit Core Initiative. This will allow building
owners/managers to assess the energy efficiency of their buildings against comparable facilities.
The PAs recognize that proper training for building operator and maintenance staff is a key factor in
ensuring that expected savings are realized initially and persist over time. PAs plan to fund training events
and opportunities as appropriate.
Marketing Overview
Target Market:
Residential multi-family facilities with five or more dwelling units. The initiative will address unique
circumstances associated with mixed use buildings.
133
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 139 of 274
Strategy:
•
Strategies for marketing to target market and industry actors should focus on, but not be limited to:
lower energy and maintenance costs, more durable and comfortable building, enhanced property
value, generous financial incentives, tenant retention, and environmental benefits for your
community.
•
Continue to develop and promote case studies for print and online media to help educate and
market to facility owners.
•
Develop additional marketing strategies to capture and use data on participant in other initiatives to
help achieve deeper market penetration.
•
Target landlord, building management, building operator trade associations, and design
professionals, including the expansion of successful case studies.
•
PAs will investigate ways to enhance the online user experience.
•
Continue to build on the MMI relationship with larger property manager to enroll complete
portfolios of eligible sites.
•
Explore opportunities in industry newsletters to educate market actors such as engineers, realtors,
architects and/or property manager.
•
Participate, as appropriate, in trade ally shows, such as realtor conferences, multi-family property
manager conferences, for example: the Rental Housing Association Conference and Expo.
Technologies/Incentives The following is a list of targeted end uses, recommended technologies, and incentives offered for
qualified replacements with dollars caps (as applicable):
Targeted End Use
Technology
Incentive
In Unit Lighting
In Unit Lighting
Compact Fluorescent Light Bulbs
ENERGY STARВ® Rated Light Fixtures
(in unit)
LED technology
No Cost to Customer
No Cost to Customer
In Unit Lighting
134
Copayment varies, based on
cost-effectiveness screening
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 140 of 274
Water Conservation
Heating and Cooling
Weatherization
DHW Insulation
Electricity Conservation
In Unit Lighting
Insulation
Insulation
Insulation
Insulation
Common Space Lighting
Common Space Lighting
Common Space Lighting
Common Space Lighting
Common Space Lighting
Common Space Lighting
Common Space Lighting
Safety and Lighting
Common Space Lighting
Faucet Aerators and Showerheads
Programmable Thermostats
Air Sealing
Pipe Insulation
Smart Strips
Night Lights
Attic Insulation
Wall Insulation
Basement/ Crawl Space Insulation
Rim Joist Insulation
ENERGY STARВ® Light Fixtures for
Common Areas
Metal Halide Pulse Start Lighting
Daylight Dimming
Occupancy Sensors: Remote Mount
Occupancy Sensors: Wall Mount
HIF and HID: Wall Mount
HIF and HID: Ceiling Mount
Exit Signs
LED technology
Appliances
ENERGY STARВ® Rated Refrigerator
Domestic Hot Water
Future Technologies under consideration:
Demand Control Circulators
No Cost to Customer
No Cost to Customer
No Cost to Customer
No Cost to Customer
No Cost to Customer
No Cost to Customer
75% Incentive
75% Incentive
75% Incentive
75% Incentive
$10 Co-Payment per fixture
$10 Co-Payment per fixture
$10 Co-Payment per fixture
$10 Co-Payment per fixture
$10 Co-Payment per fixture
$10 Co-Payment per fixture
$10 Co-Payment per fixture
$10 Co-Payment per fixture
Copayment varies, based on
cost-effectiveness screening
$150 For Qualified
Replacements
Copayment determined on a
custom basis after costeffectiveness screening
Controls
WiFi Thermostats
$100
Indoor Air Quality
Improved ventilation systems
Custom incentive, based on
cost-effectiveness
Additionally, the PAs will work with the MTAC to include new measures or technologies as appropriate.
Commercially metered projects are eligible for the same instant savings measures and will be referred to
135
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 141 of 274
the C&I program measures list for any applicable custom improvements.
The multi-family core initiative will extend the residential 0% HEAT Loan to residentially metered
condominium owners residing in facilities with five or more dwelling units in the association.
Delivery Mechanism
The initiative will be administered cooperatively by the gas and electric Program Administrators. Each
PA is represented in the Multi-Family Working Group which will continue to be responsible for oversight
of the initiative and promoting continuous improvement/best practices with regard to the multi-family
market.
The MMI role will be a key to the delivery of this fully integrated statewide Multi-Family Retrofit Core
Initiative. The MMI creates a seamless customer experience for participants regardless of the fuels, rates
and service territories involved in a project. The MMI will be responsible for facilitating the delivery of
the initiative’s services as well as acting as the conduit through which participant questions and concerns
are directed to ensure that participants are not required to directly contact multiple parties during the
project lifecycle.
Provisions will be made within the delivery process to allow for participants to use their own staff or
contractors to install the measures, provided that they have PA approval which will involve providing
documentation of their qualifications prior to the installation.
Three-Year
Deployment
Strategy/Roadmap
The PAs will continue to coordinate efforts through the MMI and other PA initiatives to ensure consistent
implementation across the Commonwealth for the next three years. The PAs will accomplish training by
working with industry stakeholders, implementation vendors and the MMI. The Multi-Family Working
Group will continually review and evaluate new, applicable measures and technologies. Through
marketing efforts the PAs plan to broaden participation and incorporate deeper savings opportunities using
a comprehensive, whole facility approach.
The Multi-Family Working Group will continue to coordinate with the Residential and C&I Management
Committees and the Low Income Best Practices group to ensure consistency and support for an integrated
initiative.
Special Notes
136
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 142 of 274
RESIDENTIAL PRODUCTS
Description:
The Residential Products Program is designed to optimize the efficiency of lighting,
heating and cooling equipment used by residential customers served by the Program
Administrators. In the 2013-15 Plan, the Program Administrators are proposing to include all the
product-focused core initiatives (i.e., Residential Heating, Water Heating, Cooling, and
ENERGY STARВ® Lighting and Consumer Products) within the broader Residential Products
Program. In this Program, the Program Administrators partner with retailers, manufacturers,
distributors, and trade allies to ensure the highest quality, energy efficient products are
introduced and promoted to the residential consumer market. The core initiatives offer
incentives, for a variety of cost-effective, ENERGY STARВ® qualified lighting products,
ENERGY STARВ® qualified appliances, high efficiency heating and water heating equipment,
programmable thermostats and controls, all within the Residential Products Core Initiatives.
As a form of best practices, the Residential Products Program Core Initiatives will
leverage a single circuit rider for gas and electric products to coordinate with participating
retailers and distributors. This allows the PAs to consolidate efforts within the retail space as
well as offer a “one-stop-shopping” experience to retail partners that may participate in multiple
initiatives.
137
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 143 of 274
SECTOR
PROGRAM
CORE INITIATIVE
ADMINISTERED BY
в—Џ
RESIDENTIAL
Core Initiative
Overview
PRODUCTS
RESIDENTIAL LIGHTING
ELECTRIC
PAs
JOINT
PA –
SPECIFIC
Key Objectives:
To increase consumer awareness of the importance and benefits of purchasing ENERGY STARВ® qualified
lighting products and expand the availability, consumer acceptance, and use of high-quality energyefficient lighting technologies and controls. The initiative utilizes upstream incentives and an online
catalog channel, which dramatically increased sales and lowered costs of product for the customer.
Additionally, lighting technology has extended past basic compact fluorescent spirals to more specialty
products and light emitting diodes (“LEDs”). Expansion of customer education to promote understanding
of the impacts of the Energy Independence and Security Act (“EISA”) on product selection and the rapidly
expanding market for LED products.
New Enhancements:
Further expansion and focus on introducing LED bulbs and fixtures into the marketplace.
Core Initiative Design
•
The PAs will continue to explore ways to mitigate declining savings issues, such as new EISA
standards, including market lift and other strategies. This is an ongoing effort, but PAs plan to
work with the EMC to review measures in Q1 2014.
•
The PAs will also explore lighting controls as a possible measure for initiative expansion. The
PAs will work with other research and development efforts to coordinate.
The ongoing collection of data on overall market conditions, product availability, market share, and
pricing keeps PAs up-to-date on changes in the residential lighting market. That awareness, in turn,
enables PAs to adapt initiative offerings as needed to maintain momentum in increasing the market share
138
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 144 of 274
of energy-efficient lighting products.
The Residential Lighting Core Initiative includes several components designed to educate consumers
about the benefits of ENERGY STARВ® qualified lighting products and to make these products more
affordable:
Marketing Overview
•
The internet/mail-order sales channel offers education, rebates, and introductions to new products
that may not be available at most retailers, and access to a variety of hard-to-find replacement bulbs.
Internet sales account for a high percentage of this component’s sales. Recognizing the importance
of Internet sales, the PAs are working to improve the internet/mail-order website as an educational
tool for consumers.
•
Upstream incentives/negotiated promotions provide instant price relief to the consumer for qualified
products. By leveraging prices at that level, it has a magnifying effect to the consumer, as well as
assurance that the product will be available at a wider variety of retail outlets.
•
“Pop-up” retail allows the PAs to offer efficient lighting products to consumers in temporary retail
locations, such as mall kiosks, corporate and public events, basically bringing both the technology
and education about it to the consumer.
•
School fundraising offers the opportunity for the PAs to educate students on the benefits of energy
efficiency, while allowing the schools to raise funds through the sale of lighting products.
Target Market:
All residential electric customers.
Strategy:
The focus for Residential Lighting initiative over the next three years will be to strategically leverage the
market impact of the Energy and Security Act of 2007 to drive increased participation.
Two key, strategic approaches will be employed, including:
1. Maintain and build market share for bare spiral and specialty ENERGY STARВ® qualified CFLs, and
139
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 145 of 274
2. Building demand and purchase of select ENERGY STARВ® LED replacement bulbs.
To continue promotion of CFLs, several tactics will be utilized, including retail promotions, community
outreach, and consumer education, all designed to protect and build market share from the introduction of
EISA compliant incandescent and halogen products.
As LED replacement bulbs and fixtures are increasingly introduced into the market, marketing initiatives
will be geared towards encouraging consumer trial of these new technologies with the use of discounted
products and special manufacturer/retailer promotions. Key to growing market share for LEDs will be to
shift consumer perception of lighting from a commodity product to a more considered purchase and
educating customers about the product's benefits, which will be accomplished through educational
advertising, in-store displays, social media outreach, and other point-of-sale communications.
In addition, consumers will be educated on the benefits of lighting controls through in-store displays,
community outreach, and retail point-of-purchase materials to highlight the ease of use and their energy
savings potential. A key consideration for this overarching lighting strategy is a classic Consumer
Packaged Good (“CPG”) “Good, Better, Best” strategy, which can help to unite these diverse product
offerings as a robust, energy-efficient lighting portfolio.
Technologies/Incentives The following is a list of targeted end uses, recommended technologies, and incentives offered:
Targeted End Use
Technology
Incentive
Residential lighting
Residential lighting
Residential lighting
Residential lighting
Residential lighting
Delivery Mechanism
Standard spiral Compact Fluorescent
Bulbs (CFL)
“Specialty” CFL
Compact Fluorescent Fixtures
Light Emitting Diode Bulbs (LED)
LED Fixtures
Maximum $1.40
Maximum $6.00
Maximum $15.00
Maximum $20.00
Maximum $15.00
A manufacturer/retailer outreach contractor will recruit and train retailers, including discount retail outlets,
to participate in the program; place point-of-purchase materials in participating retail stores; oversee the
Negotiated Cooperative Promotions (“NCP”) process; and act as a liaison for PAs, manufacturers, and
retailers.
140
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 146 of 274
A rebate fulfillment contractor will collect data and payment requests from manufacturers, retailers, and
consumers; process reimbursement requests from NCP partners and provide documentation to the Program
Administrators for program tracking and evaluation purposes.
An internet/mail-order sales channel contractor will purchase and stock products offered through the
catalog and the Mass Save website; staff a toll-free line for customers; and process catalog and website
purchases.
PAs may employ temporary retail kiosks at key events and locations.
Three-Year
Deployment
Strategy/Roadmap
The Residential Lighting Core Initiative faces some challenges in the upcoming three-year period. The
per-unit annual savings for CFLs and LEDs will decline over the three years to account for the anticipated
multi-year phase out of incandescent bulbs due to EISA standards. In addition, the per-unit lifetime
savings have been reduced in this Plan to account for the post 2020 EISA savings for both CFLs and
LEDs. At this time, it is unclear how industry will respond to this federal mandate. The standard may
accelerate the adoption of CFLs for many applications, or industry may promote a less efficient
technology such as infrared halogen. Finally, the proposed lighting program also assumes uncertainty
with regards to savings from LEDs based on estimates of future product availability and price. However,
this technology is evolving very rapidly and cost competitive screw-in replacement lamps may become
readily available within the three-year implementation timeframe.
For the three-year deployment, the PAs will focus on:
•
Expansion of the mix of products available in retail
•
Increased focus on specialty products to reach “deeper” savings for each customer with more
options for each socket
•
Expansion of retailers and other channels for the sale and distribution of efficient lighting, such as
online retailers
•
Continuous offerings over longer horizon periods at retail to assure year-round product availability
to consumers
•
Innovative approaches to community and corporate events (including hard-to-reach communities)
141
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 147 of 274
•
Phasing in of qualified products for new technologies that require new entrants and implementation
strategies.
Special Notes
142
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 148 of 274
SECTOR
PROGRAM
CORE INITIATIVE
ADMINISTERED BY
в—Џ
RESIDENTIAL
Core Initiative
Overview
PRODUCTS
CONSUMER PRODUCTS
ELECTRIC
PAs
JOINT
PA –
SPECIFIC
Key Objectives:
To increase consumer awareness of the importance and benefits of purchasing or recycling ENERGY
STARВ® qualified appliances and electronic products and expand the availability, consumer acceptance,
and use of high-quality energy-efficient technologies. The initiative utilizes upstream incentives and mailin rebates, which dramatically increases sales and lowers the costs of product for the customer.
New Enhancements:
Core Initiative Design
•
The PAs are exploring various methods to streamline incentive delivery methods to the consumer
(e.g., midstream/upstream) and to address the rapidly changing electronics marketplace. This is an
ongoing effort, but PAs plan to review delivery methods by Q1 2014.
•
The PAs also plan to work with retailers to explore the potential for streamlining the rebate process
via online purchases. PAs plan to conduct a review of online rebate application offered by current
rebate processing vendor and on-line applications offered by other PAs from across the country by
Q4 2013. If deemed practical from a cost and implementation perspective PAs would plan an
expected roll-out by Q3 2014.
The Consumer Products Core Initiative educates consumers about the benefits of ENERGY STARВ®
qualified products to increase consumer acceptance of products and to encourage them to look for and
purchase ENERGY STARВ® qualified models when they shop.
The initiative promotes select ENERGY STARВ® qualified consumer products at the point-of-sale by
143
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 149 of 274
providing promotional literature and displays to retailers, working with sales staffs to ensure they
understand and can accurately market the benefits of these products, and providing labels to identify
models that meet ENERGY STARВ® standards. As ENERGY STARВ® qualified products achieve a high
share of market sales, the PAs and other interested parties are in a good position to advocate for higher
minimum federal and ENERGY STARВ® standards.
The initiative actively participates in national ENERGY STARВ® awareness campaigns and in efforts to
keep ENERGY STARВ® specifications up to date and relevant. Similarly, the PAs will also work with the
Consortium for Energy Efficiency (“CEE”) to develop efficiency tiers above ENERGY STAR® for many
products.
Marketing Overview
Target Market:
All residential electric customers
Strategy:
In the appliance and electronics category, marketing initiatives will be designed to leverage new product
specifications being rolled out in several product categories, the emergence of high efficiency initiatives.
Key marketing strategies will aim to build awareness of and demand for new, high efficiency products,
and consumer education to help customers take advantage of these new technologies.
Consumer education tactics will continue to employ retail point-of-purchase materials and sales
promotions, consumer engagement events, social media, email, and other best practice marketing tactics to
drive sales of qualified energy-efficient appliances and electronics.
Efforts will also continue in monitoring smart metering and the market for energy-efficient "smart"
technologies in appliances and consumer electronics to inform future program planning and marketing
opportunities. Go-to-market strategies will be explored to introduce new "connected" smart appliances
and plug load controlling electronics into the marketplace.
Tactics to support these efforts will include consumer education via social media channels, consumer
events, and retail promotions and point-of-sale materials to educate and motivate consumers to use these
144
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 150 of 274
new technologies. It is the PAs intention to be prepared for these technologies, as they become more
prevalent toward the third year of this plan.
Technologies/Incentives The following is a list of current targeted end uses, recommended technologies, and incentives offered:
Targeted End Use
Technology
Incentive
Consumer products
Consumer products
Consumer products
Consumer products
Consumer products
Consumer products
Consumer products
Consumer products
Consumer products
Delivery Mechanism
Room Air Cleaners
Advanced Power Strips
Televisions
Desktop Computers
Computer Monitors
Pool pumps
Refrigerator/Freezer Recycling
Refrigerators/Freezers
Room Air Conditioners
$20.00
$10.00
$20.00
$10.00
$20.00
$250.00
$50.00
up to $75
$25.00
A manufacturer/retailer outreach contractor will recruit and train retailers to participate in the program;
place point-of-purchase materials and rebate applications in participating retail stores; oversee the NCP
process; and act as a liaison for PAs, manufacturers, and retailers.
A rebate fulfillment contractor will collect data and payment requests from manufacturers, retailers, and
consumers; process rebate applications and NCPs; and provide documentation to the PAs for program
tracking and evaluation purposes.
Three-Year
Deployment
Strategy/Roadmap
For consumer products, efforts to broaden categories as well as allow consumers the opportunity to
increase the savings in their homes with new technologies provide unique challenges for the PAs. For
2013-2015 planning, increasing standards and market saturation will continue to decrease kWh savings for
some energy efficient products, forcing the PAs to adapt and explore avenues of program deployment that
are new and possibly untested.
The PAs began to expand their upstream efforts in 2010 from just advanced power strips to ENERGY
STARВ® TVs and Room Air Conditioners, in efforts to maximize the effect of lower incentive dollars, with
145
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 151 of 274
some success. Over the next three years, the PAs will continue to explore expanding the products included
in upstream efforts, in an attempt to duplicate the successes with lighting.
As standards become more stringent, the PAs will look into promoting more efficient products to
consumers, using such categories as the higher CEE Tiers, and the newer higher tier of ENERGY STARВ®
“Most Efficient” and “Top Ten” categories.
The PAs will also explore tactics to support deeper savings through education, promotion, and possibly
higher incentive offerings, if appropriate.
The PAs would like to explore the Lighting “Market Lift” model for use with products that have similar
acceptance histories to CFLs, such as clothes washers.
Special Notes
146
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 152 of 274
SECTOR
PROGRAM
CORE INITIATIVE
RESIDENTIAL
RESIDENTIAL
PRODUCTS
RESIDENTIAL HEATING
AND COOLING - HVAC
ADMINISTERED BY
в—Џ
Core Initiative
Overview
ELECTRIC
PAs
JOINT
PA SPECIFIC
Key Objectives:
The Residential Heating and Cooling core initiative (“CoolSmart”) is designed to increase consumer
awareness, sales, and market share of ENERGY STARВ® qualified central air conditioning units, air
source heat pumps, and electronically commutated motor (“ECM”) furnace fan systems by offering
customer rebates and contractor incentives. The initiative also promotes best installation practices and
quality installations, as promulgated by the Air Conditioning Contractors of America (“ACCA”) and the
Environmental Protection Agency’s ENERGY STAR® Quality Installation (“QIV”) Program.
New Enhancements:
The PAs will explore the following proposed enhancements:
•
An early replacement package offer, which provides ECM Furnace with Central Air Conditioning.
The PAs plan to work with evaluation team to develop the offer for measure implementation by Q2
2013.
•
Partnering with HPWH leasing companies to increase participation and savings. The PAs plan to
research existing water heating leasing infrastructure and determine leasing offer potential by Q3
2013.
•
An HPWH early retirement program component; coordinate with the PAs whole home initiatives.
PAs plan to use lessons learned from the 2012 gas heating early retirement offer to implement a
similar offer by Q2 2013.
•
Emerging technologies such as residential climate controls, geothermal heat pumps and drain water
147
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 153 of 274
heat recovery systems will be reviewed and considered for implementation. Ongoing effort but
PAs plan to work with the evaluation team to review all potential measures for consideration by Q1
2014.
•
Continue to investigate opportunities for resistance heat to cold climate heat pump conversions.
PAs plan to work with the evaluation team to review conversion potential measures by Q2 2014.
•
An upstream program model to increase overall participation levels. The PAs plan to coordinate
with C&I team and work with manufacturers and distributors to identify potential approaches by
Q2 2013.
•
Modify existing equipment rebates subject to review of market conditions, equipment qualifying
for the new ENERGY STARВ® Most Efficient or Top Ten rating, combined with incremental costs
of high efficiency equipment. Ongoing review throughout program years 2013-2015.
•
Review and adjust contractor incentives with emphasis on achieving program savings from
improved equipment specification and installation. Ongoing review throughout program years
2013-2015.
•
Expanded training programs to greatly increase contractor capabilities related to HVAC system
efficiencies and quality installation practices. Ongoing throughout program years 2013-2015.
•
Work with Residential Heating and Water Heating Core Initiative to further coordinate
implementation, marketing and training activities and to develop and implement joint program
offerings whenever feasible and cost-effective. Efforts will be prioritized during program year
2013 but ongoing throughout three-year period.
•
Simplify customer and contractor transactions, such as online rebate fulfillment. PAs plan to
conduct a review of an online rebate application offered by current rebate processing vendor, as
well as online applications offered by other PAs from across the country (e.g., PG&E) by Q4 2013.
If deemed practical, PAs plan an expected roll-out by Q3 2014.
•
Continue focus on curriculum of contractor training and look for opportunities for vocational
school teacher training. Contractor training is planned as an ongoing effort throughout 2013-2015
but PAs plan to evaluate the potential of trainings for vocational schoolteachers by Q1 2013.
148
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 154 of 274
Core Initiative Design
This initiative provides customer rebates for the installation of ENERGY STARВ® qualified HVAC
equipment, as well as a “voluntary” QIV incentive for those customers who work with a residential
heating and cooling trained contractor to install and properly test their rebate eligible equipment. Cool
Smart trained contractors also earn an incentive for doing the proper testing to check and adjust system air
flow and refrigerant charge using third-party verification. Other incentivized measures include duct testing
and sealing, and downsizing of replacement equipment.
PAs use a third-party verification process for its quality installation verification offerings for all residential
HVAC installations and tune-ups, including existing systems, retrofit and new installations.
The Residential Heating and Cooling core initiative will continue to work with the Residential Heating and
Water Heating core initiative (“GasNetworks®”) on joint offerings; marketing, contractor training and
trade ally outreach, including circuit rider, and strive toward creating a seamless integration of the gas and
electric energy efficiency programs. The PAs will continue their work with HVAC distributors, and where
possible, develop upstream opportunities.
In addition, the PAs will continue to work with the following industry partners to promote best installation
practices, awareness, education, and training for HVAC contractors:
ENERGY STARВ® HVAC Quality Installation Program (EPA)
Consortium for Energy Efficiency (CEE)
Air Conditioning Contractors of America (ACCA)
Northeast Energy Efficiency Partnerships (NEEP)
The Residential Heating and Cooling core initiative will also continue to promote the North American
Technician Excellence (“NATE”) in HVAC contractor and customer educational materials. This strategy is
designed to promote the value of NATE certification in the HVAC community and support best installation
practices, education, and training for HVAC technicians and contractors
Marketing Overview
Target Market:
The Residential Heating and Cooling core initiative provides an opportunity for HVAC professionals to
achieve a measure of success that might not otherwise be available to them. Effectively marketing the
149
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 155 of 274
advantages of this initiative will help enable the PAs to achieve their energy saving goals. Consumers will
benefit from having lower energy costs than they would otherwise have, during the cooling and heating
seasons.
Marketing activities will continue to align the elements of this initiative with that of the EPA’s ENERGY
STARВ® QI standard, and will emphasize outreach to HVAC professionals (contractors and distributors,
including gas contractors). The PAs will work in collaboration to build an integrated marketing and
branding approach incorporating key elements such as contractor and distributor outreach and training, the
CoolSmart portion of the Mass Save website, collateral updates, e-mail blasts, bill inserts, as well as other
activities. In 2013-2015 the marketing strategy will utilize effective contractor and customer education
messaging to meet the initiative goals and provide essential opportunities for HVAC professionals in
coordination with all Residential Whole House Core Initiatives. The marketing activities described above
aim to reach several target markets:
•
•
•
New systems in existing and new homes (new systems)
Replacement systems in existing homes (new equipment/old systems), including the early
retirement of existing equipment.
Improvements in operational systems in existing homes (new equipment/old systems)
The Residential Heating and Cooling core initiative targets the following market actors:
•
•
•
•
•
Residential customers in the market to purchase HVAC equipment
HVAC contractors and technicians
Manufacturers, distributors, and suppliers of HVAC equipment
New-home builders and remodeling contractors
Big-box stores
Strategy:
The Residential Heating and Cooling core initiative is designed to promote the purchase and proper
installation of ENERGY STARВ® residential central air conditioning and air source heat pump systems at
multiple levels. In addition, it will increasingly emphasize the importance of proper installation and sizing
practices as well as the promotion of duct sealing and enhanced air distribution system efficiency. The
150
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 156 of 274
Residential Heating and Cooling core initiative will collaborate with the Residential Heating and Hot
Water core initiative to develop and implement joint marketing activities whenever feasible. The planned
marketing effort include:
•
A joint circuit rider provides outreach services, education, and support in the field through visits
and calls to HVAC distributors, supply houses, and contractors. The circuit rider also participates
in training, trade shows and related industry events.
•
Development of cooperative (“upstream”) promotions with the HVAC industry, in coordination
with C&I where feasible.
•
Sponsorship of contractor competitions and awards programs for rebates and QIV services, and an
annual recognition celebration for contractors in a venue that helps recruit more contractors
•
Periodic COOL Talk meetings with QIV-listed HVAC contractors and distributors
•
Targeted outreach to large HVAC contractors previously inactive in the program.
•
Development of consumer testimonials affirming the benefits of program measures.
•
Customer certificates when a quality installation is performed
•
Print and media advertising targeting consumers, contractors, and distributors (including bill
inserts, information on the website, participation at trades shows, articles in trade publications,
mailings to distributors, contractor, and non participants). These will be in conjunction with the
Residential Heating and Hot Water core initiative, where possible.
•
Promote program education and awareness utilizing manufacturer/distributor level marketing and
training infrastructure as a platform to educate contractors and wholesalers at a regional level.
These will be in conjunction with the Residential Heating and Hot Water core initiative, where
possible.
•
PAs will market and leverage all available federal tax credits where applicable as well as all
supplemental consumer incentives (e.g., equipment manufacturers) as a means to increase
consumer adoption of purchases of high efficiency central air conditioning and heat pump systems.
•
PAs will work with the ENERGY STARВ® HVAC Quality Installation Program team, the CEE
HVAC Committee, and other industry partners to promote best installation practices, awareness,
151
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 157 of 274
education, and training for HVAC contractors.
Technologies/Incentives The following is a list of targeted end uses, recommended technologies, and incentives offered:
Targeted End Use
Technology
Incentive
Incentives for Equipment
Cooling
Central Air Conditioning SEER>14.5
EER>12
$150
Heating and Cooling
Air Source Heat Pump SEER>14.5
EER>12 HSPF > 8.2
$150
Cooling
Central Air Conditioning SEER>15
EER>12.5
$300
Heating and Cooling
Air Source Heat Pump SEER>15
EER>12.5
$300
HSPF > 8.5
Cooling
Central Air Conditioning SEER>16
EER>13
$500
Heating and Cooling
Ductless Minisplit Heat Pump: SEER
>14.5 EER >12 HSPF> 8.2
$150
Heating and Cooling
Ductless Minisplit Heat Pump: SEER >19 $300
EER >12.8 HSPF> 10
Heating and Cooling
Ductless Minisplit Heat Pump: SEER >23 $500
EER >13 HSPF> 10.6
Cooling
Ductless Mini Split Cool only:
SEER>14.5 EER >12
Incentives for Services
152
Up to $100
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 158 of 274
Cooling
Quality Installation Verification (QIV) CAC
$175
Heating
Quality Installation Verification (QIV) –
Heat Pump
$175
Heating and Cooling
ENERGY STARВ® Quality Installation
Program (“QIV”).
$125 ($75 airflow testing +
$50 CO Monitor installed)
Promotes best installation practices, as
promulgated by the Air Conditioning
Contractors of America (“ACCA”) and
the Environmental Protection Agency
Heating and Cooling
ENERGY STARВ® Quality Installation
Program (“QIV”) with duct
modifications.
$525 ($75 airflow testing +
$50 CO monitor installed +
duct sealing repairs)
Promotes best installation practices, as
promulgated by the Air Conditioning
Contractors of America (“ACCA”) and
the Environmental Protection Agency.
Heating and Cooling
Customer incentive for QIV
$150
Heating and Cooling
Duct Sealing in spaces outside the
building envelope that have air
conditioning and heat in connected
ductwork.
$2.00 per cfm reduction up
to $600 maximum.
Cooling
Down Sizing per ВЅ ton reduction
$ 250.00 per ВЅ ton
Heating and Cooling
Early Replacement of central AC
equipment
$850
Heating
ECM Furnace – 95% and 97%
$100
Heating and Cooling
Brushless Fan Motor
$150 placeholder – pending
153
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 159 of 274
evaluation
Water Heating
Heat Pump Water Heater – 50 gallon;
must replace existing electric storage tank
water heater
$750
Water Heating
Heat Pump Water Heater – 80 gallon;
must replace existing electric storage tank
water heater - *subject to change in 2015
$750*
Water Heating
Heat Pump Water Heater – Lease HPWH
through a nationally recognized leasing
company
Incentive to be determined.
Heating and Cooling
Air Source Heat Pump SEER>16
EER>13 HSPF > 8.5
$500 (proposed)
Additionally, customers may now utilize the 0% HEAT loan to finance eligible HVAC equipment
purchases.
Delivery Mechanism
The Residential Heating and Cooling core initiative will be administered by the PAs in each service
territory. Delivery is through a common vendor selected through a common RFP. Whenever possible,
there is coordination with the Residential Heating and Hot Water core initiative. These initiatives will
continue to use a single, joint circuit rider in the field. The Residential Heating and Cooling initiative
leverages the Residential New Construction, HES, and Multi-Family Retrofit Core Initiatives:
• Participating residential new construction builders and their HVAC contractors are referred to the
Residential Heating and Cooling for training and QIV. Whenever appropriate, these training will
be provided jointly with the Residential Heating and Hot Water core initiative.
• HES and qualifying Multi-Family Retrofit participants are referred to residential heating and
cooling for HVAC measures using residential heating and cooling literature, which is part of the
standard HES information package.
Quality control/follow-up inspections are performed by independent inspectors on up to 10 percent of
154
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 160 of 274
installations to verify equipment installation and performance.
The initiative continues to use equipment distributors to sell high-efficiency equipment and QIV-related
technology, and to provide indoor training labs for HVAC contractors.
Three-Year
Deployment
Strategy/Roadmap
The PAs believe that an adjustment in equipment incentive levels may be required to address market
barriers and achieve higher levels of participation and savings goals during 2013-2015. Rebate levels
approaching full system incremental cost may be required to address two fundamental market barriers in
the state.
• In Massachusetts, a low dollar savings compared to incremental costs associated with high
efficiency air conditioning investments represents a significant program barrier to increasing
the market share of high SEER/EER equipment.
• In Massachusetts, another barrier to improved efficiency is the common practice in which
HVAC contractors install “efficient” outdoor condensing equipment but fail to replace the
existing indoor equipment with a high efficiency indoor evaporator coil. Additionally, other
cases involve use of non matched non-AHRI rated indoor coils, which do not reach the
ENERGY STARВ® standards. At each stage, customers are not well informed of the
consequences and also do not benefit directly from the demand savings that are important to the
program and the region.
The PAs plan to:
• Host strategic discussions to promote the expanded HVAC program which may include a
significant number of new and emerging technologies and quality installation practices.
• Strive to identify and support gas and electric integration opportunities where appropriate as a
means to increase consumer participation, gain economies of scale, create consumer-focused
transparency across programs, and achieve broader and deeper energy savings.
• Increase the focus of the program towards marketing and targeting opportunities for early
retirement of existing equipment.
• Strive to develop a more detailed way to track and differentiate early retirement systems from
155
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 161 of 274
replacement of units at the end of their useful life.
Special Notes
The PAs note that there is a discount to the Non-Resource Benefits in the D.P.U. 08-50 tables. While the
PAs continue to explore the correct factors for the NEIs, the PAs have conservatively lowered the overall
benefits to account for the potential impact of replacement on failure based upon implementation
experience. In this plan, the PAs plan to target early retirement of heating and cooling systems and
explore better ways to track replacement on failure versus early retirement.
156
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 162 of 274
SECTOR
PROGRAM
CORE INITIATIVE
ADMINISTERED BY
в—Џ
RESIDENTIAL
Core Initiative
Overview
RESIDENTIAL
PRODUCTS
RESIDENTIAL HEATING
& HOT WATER
JOINT
GAS PAs
PA SPECIFIC
Key Objectives:
The primary objective of the Residential Heating and Water Heating core initiative is to increase market
awareness and penetration of high efficiency gas heating (forced hot water boilers, electrically efficient gas
warm air furnaces) water heating equipment and associated controls. The initiative provides ongoing
support to enhance and maintain Program Administrators’ strategic partnerships with equipment
manufacturers and distributors who assist in conducting aggressive outreach, education and training of our
trade allies and contractors on the latest technologies, high efficiency equipment and installation techniques.
New Enhancements:
The PAs anticipate the following initiative enhancements for the three year planning period of 2013-2015:
• Expand trade ally awareness and strengthening existing partnerships by implementing seasonal or
year-round contractor incentive promotions and new technology training initiatives. While these
efforts will likely be ongoing throughout the Three-year plan, the PAs plan to develop an initial
incentive promotion by Q2 2013.
• PAs will closely monitor the results the 2012 seasonal initiative - Early Boiler Replacement - and
implement successes based on evaluated results. Gas PAs will consider expanding early
replacement promotion to furnaces, in conjunction with the Residential Cooling Core Initiative. The
gas and electric PAs plan to work jointly with the evaluation team to propose an integrated HVAC /
Heating equipment early retirement incentive by Q2 2013.
157
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 163 of 274
• Enhance integration efforts with Residential Heating and Cooling Heating, Ventilation and Air
Conditioning (“HVAC”) training. This will allow the ability to develop “packaged” incentive
offerings to drive consumer participation, allow for deeper energy savings and the adoption of new
high efficiency technologies. Ongoing throughout program years 2013-2015.
• Implement cross promotions with HES core initiative (e.g., messaging on rebate checks). The PAs
plan to research messaging/insert potential with vendor and if feasible roll-out by Q2 2013.
Core Initiative Design
•
Explore the feasibility of targeted upstream promotions on new heating, hot water or controls
equipment. Ongoing effort throughout program years 2013-2015 to explore new technologies in
collaboration with evaluation team. Regarding the feasibility of an upstream heating promotion, the
PAs plan to coordinate with electric HVAC and C&I teams to identify potential approaches by Q2
2013.
•
Provide further opportunities on joint-trainings for trade allies on gas and electric HVAC and high
efficiency equipment, including brushless fan retrofits. Ongoing review throughout program years
2013-2015.
•
Simplify customer and contractor transactions, such as online rebate fulfillment. PAs plan to
conduct a review of an online rebate application offered by current rebate processing vendor, as well
as online applications offered by other PAs from across the country (e.g., PG&E) by Q4 2013. If
deemed practical, PAs plan an expected roll-out by Q3 2014.
Description:
The GasNetworksВ® high efficiency heating and water heating core initiative is designed to offer customer
rebates to offset the higher cost of purchasing qualifying gas heating, hot water equipment and controls in
the new construction and replacement market. In collaboration with the CoolSmart electric efficiency core
initiative, GasNetworks also offers a dual electric/natural gas rebate incentive for high-efficiency furnaces
equipped with Electronically Commutated Motor (“ECM”) or equivalent advanced furnace fan systems. The
high efficiency water heating core initiative offers customer incentives for energy efficient indirect, ondemand, and stand-alone water heating equipment
In addition to heating and water heating equipment, customer incentives are also offered for select heating s
158
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 164 of 274
controls, such as programmable thermostats, boiler reset controls and heat recovery ventilator units.
In 2012, the initiative introduced an early replacement boiler promotion, integrated with the HES core
initiative providing an incentive to replace old, inefficient, but still operating, heating equipment with new
high efficiency equipment.
Gas PAs consistently monitor this initiative and evaluate free-ridership in order to drive customers to go
deeper and achieve the highest level of efficiency available.
Marketing Overview
Target Market:
Residential Target Market includes all 1-4 family residential non-low income and residentially metered
condominiums
• New construction
• Existing homes
Residential Market Actors include :
•
•
•
•
•
•
•
•
•
•
•
Plumbing and HVAC contractors and technicians
Suppliers of high efficiency heating and water heating equipment and related parts/accessories
Manufacturers and distributors of high efficiency heating and water heating equipment
New home builders and remodeling contractors
Residential home owners with natural gas heating and water heating equipment
Multi-Family property owners (residentially metered)
Home designers and architects
Massachusetts Building Inspectors, i.e., Southeastern Massachusetts Building Officials Association
(“SEMBOA”)
Plumbing, Heating and Cooling Contractors of MA (“PHCC of MA”)
International Association of Plumbing and Mechanical Officials (“IAPMO”)
Engineers
159
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 165 of 274
Strategy:
The initiative will be promoted through a variety of marketing and educational campaigns including, but not
limited to: upstream outreach, direct mail, bill inserts, sponsorships and trade ally circuit-rider visits and
other training events. The initiative has been particularly successful utilizing a direct vendor outreach
marketing approach to gas equipment suppliers and installation contractors and the PAs will continue to
implement this approach in 2013-2015. The PAs will continue to enhance their outreach to customers in
collaboration with the other PA working groups. PAs will also enhance awareness through successful
targeted techniques involving website and email. For example, PAs have approximately fifteen hundred
trade allies and recipients signed up to receive the GasNetworks e-newsletter on a quarterly basis since its
launch in 2007.
In addition to direct rebate offers to customers, PAs will evaluate and offer strategic seasonal or year-round
incentives to contractors to further encourage the installation of high efficiency heating equipment.
PAs will also market and leverage all available federal tax credits where applicable and other consumer
incentives as a means to increase consumer adoption of high efficiency heating and water heating
equipment.
Technologies/
Incentives
The following is a detailed list of targeted end uses, recommended technologies, and incentives offered
within the Residential Heating and Water Heating core initiative:
Targeted End Use
Heating
Technology
Heating
>= 95% Furnace w/Electronically
Commutated Motor (ECM) or equivalent
>= 97% Furnace w/ECM or equivalent
Heating
Heating
Heating
Heating/Water Heating
Water Heating
>= 90% Forced Hot Water Boiler
>= 96% Forced Hot Water Boiler
Heat Recovery Ventilator
Integrated water heater/condensing boiler
Indirect Water Heater
160
Incentive
$200 (+$100
Electric)
$350 (+$100
Electric)
$1000
$1500
$500
$1200
$400
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 166 of 274
Water Heating
Water Heating
Water Heating
Water Heating
Controls
Controls
Controls
Condensing Gas Water Heater (T.E*. 95)
On-demand Water Heaters (.94)
On-demand Water Heaters (.82)
Stand Alone Storage Water Heaters (.67)**
After Market Boiler Reset Controls
Programmable Thermostats
Smart Thermostats
$500
$800
$500
$100
$225
$25
$100
*Thermal Efficiency
** 2013 and 2014 only
Additionally, PAs will continue to explore cost-effective offerings, such as seasonal incentives to
contractors or special promotion resources to trade allies and other market actors that assist with the
stocking, sales and installation of high efficiency heating and water heating equipment.
In addition to the incentives listed above, gas customers who have participated in the HES core initiative
and purchase and install select high efficiency heating equipment may be eligible for 0% financing through
participating lenders.
Delivery Mechanism
The initiative is administered by each gas PA and strategically coordinated regionally through the
GasNetworks collaborative. The PAs utilize three vendors secured through a competitive bid process to
assist in implementation to its customers:
•
Administrative – Integrated with Residential Heating & Cooling Equipment, Residential Lighting
and Consumer Products core initiatives, this vendor is secured to review, process, and deliver valid
rebate claims to customers. This vendor is also responsible for tracking and reporting program
activity to gas and electric PAs as well as providing verification of a percentage of installed qualified
equipment across PAs.
•
Outreach – Integrated with Residential Lighting and Consumer Products core initiatives, this vendor
is secured to provide field visits and sales training through the distribution of point-of-purchase
rebate materials to big box stores and other applicable retail outlets.
•
Outreach/Training – Integrated in part with Residential Heating & Cooling Equipment core
161
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 167 of 274
initiative, this third-party vendor is responsible for direct communication and education of all key
trade allies, in particular manufacturers, distributors, supply houses, heating and water heating
contractors and vocational school faculty members.
In 2012, the PAs collaborated with the HES core initiative to deliver a seasonal Early Boiler Replacement
(enhanced) rebate initiative to qualifying participants in order to encourage the proactive replacement of
aging and inefficient steam and forced hot water boilers. This “whole house” approach will allow for
“packaged” incentive opportunities for qualifying participants and allow for broader and deeper energy
savings.
Three-Year
Deployment
Strategy/Roadmap
The PAs will review the results from the Early Boiler Replacement rebate offer for inclusion into the 20132015 Plan. The PAs will work to enhance integration and cross-promotion efforts with the Residential
Heating & Cooling Equipment and the HES Core Initiatives. In addition, PAs will review emerging
technologies for cost-effectiveness and will continue to explore an upstream program model.
The PAs plan to:
• Increase the focus of the program towards marketing and targeting opportunities for early retirement
•
Special Notes
of existing equipment.
Strive to develop a more detailed way to track and differentiate early retirement systems from
replacement of units at the end of their useful life.
The PAs note that there is a discount to the Non-Resource Benefits in the D.P.U. 08-50 tables. While the
PAs continue to explore the correct factors for the NEIs, the PAs have conservatively lowered the overall
benefits to account for the potential impact of replacement on failure based upon implementation
experience. In this plan, the PAs plan to target early retirement of heating and cooling systems and explore
better ways to track replacement on failure versus early retirement.
162
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 168 of 274
SECTOR
STATEWIDE MARKETING
ALL
SUMMARY OVERVIEW
Key Objectives
ADMINISTERED BY
ELECTRIC & GAS PAs
The overarching goal of Statewide Marketing is educating customers about the PA-sponsored programs
available under the umbrella of the Mass Save mark. Please also see Section III.H.1 for additional
information regarding PA marketing activities.
The PAs’ priority is creating powerful, engaging, and motivating strategies that will increase
Massachusetts’ consumer and business awareness of the benefits of energy efficiency and will also increase
their subsequent actions to reduce usage, primarily through the PAs available energy efficiency programs.
These efforts will build on the awareness of the energy efficiency programs that are offered to
Massachusetts customers by the PAs under the Mass SaveВ® umbrella and establish the PAs as the
recognized, reliable sources for all things about energy efficiency in the Commonwealth.
Strategies
The strategies will take into account the unique motivational differences between residential and the various
subsets of non-residential customers. While these actions may include commonly recognized multi-channel
campaigns for residential customers, it is expected that the campaign strategy will identify the most
effective touch points for residential and non-residential customer targets, sectors and motivations in order
to move consumers from awareness to action. In addition, the different tactics used for these sectors will be
measurable so that feedback will inform changes to deployment of the marketing and communication
campaigns.
The core goals of any campaign put forth by the PAs will attempt to: reach the maximum level of
residential and business customers possible; provide messages that are not overly technical and that clearly
describe the benefits of energy efficiency; utilize diverse media (e.g., internet, bill inserts, television, radio,
billboards, public transit) to disseminate consistent and clear messages; ensure that the various strategies
work together to ultimately achieve deeper and broader savings.
In order to realize their public education, community outreach, and marketing potential, the PAs have
163
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 169 of 274
identified the following goals to guide strategy and campaign planning:
•
Prioritize public education.
•
Broaden awareness of available resources and actions to all potential audiences, including
residential and business customers.
•
Identify and understanding the barriers to action, and developing potential motivators to bridge the
gap between awareness and action.
•
Communicate with the general public and with targeted audiences in the most effective ways
possible to reach those audiences.
•
Provide an good mechanism for customers to respond to marketing and outreach strategies (e.g.,
website)
•
Maximize the number of individuals, organizations, and businesses that take action to reduce their
energy consumption.
•
Encourage behavioral change to conserve energy, save money, and reduce greenhouse gas
emissions.
In creating energy efficiency messages, both high level and targeted, the ultimate goal is to have customers
understand the many benefits of energy efficiency and then take action. Further, to engage customers who
have already implemented energy efficiency measures, the message will include and highlight the
additional benefits and importance of going “deeper” by implementing additional energy efficiency
measures, such as case studies. In addition to the overall message, the PAs will also develop messaging at
the program level in order to engage varied customers and other important market actors (contractors,
equipment suppliers, opinion leaders) with differing motivations. The strategies and messages developed
for statewide energy efficiency education, outreach and marketing will augment the efforts thus far across
the Commonwealth and will attempt complement and leverage program-specific marketing and individual
PA efforts wherever possible.
Further, the PAs will apply evaluation results and findings from the Statewide EM&V framework to better
understand the unique drivers, demographics, economic parameters, and behavioral differences among
residential customers and among various key subsectors of non-residential customers, then design and
164
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 170 of 274
deliver messaging accordingly.
The ultimate goal of these educational, outreach, and marketing efforts is to develop a broad system of
communication with Massachusetts citizens and businesses and deliver comprehensive energy efficiency
programs. Through an array of effective messages and valuable information resources, the PAs will engage
with a large portion of the population to assist in delivering value to residential and business customers and
achieving the aggressive energy efficiency goals set forth in this Plan.
Special Notes
Please also see Section III.H.1 for additional information regarding PA marketing activities.
165
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 171 of 274
b. Residential General Initiatives
i. Efficient Neighborhoods+
Overview
Building on the successful Community Engagement efforts and Low-Income programs,
the Efficient Neighborhoods+ initiative will target lower to moderate-income energy consumers
in designated communities and neighborhoods. As an extension of the Mass SaveВ® HES
initiative, this initiative is intended to provide significant energy saving benefits to customers
who live in urban neighborhoods with older housing stock and are often financially constrained
from making energy efficiency investments. In addition to the benefits provided by the HES
initiative, Efficient Neighborhoods+ will include an enhanced incentive structure designed to
make energy efficient improvements more affordable for consumers living in these sometimes
harder to reach neighborhoods. It is also expected that these targeted neighborhoods will include
low-income qualified/eligible consumers thus the Program Administrators plan to work with
LEAN on the initiative design and implementation phases to ensure a fully integrated crosssector approach. Further, given the predisposition of pre-weatherization barriers in this housing
stock, it is important to consider introducing limited pre-weatherization incentive offers into the
overall initiative design.
Key Strategies
1. Eligibility
While the specifics of eligibility have yet to be determined, the premise is to target
neighborhood/community “areas” that meet certain demographic criteria versus individual
consumers, thus these areas would be designated as “Target Communities”. The following is the
minimum guidelines proposed for eligibility:
•
All customers in the target areas will be offered the incentives thus eliminating the
arduous individual income verification screening process. However, similar to current
HES protocols, customers will be educated on Low-Income eligibility requirements and
will be referred to appropriate Low-Income Agency to receive eligible energy efficiency
services. It is also expected that these targeted neighborhoods will include low-income
qualified/eligible consumers. Thus the Program Administrators plan to include LEAN in
the initiative design and implementation phases, as well as reporting and assessment to
ensure a fully integrated cross-sector approach. Further, the Program Administrators will
consider LEAN’s Network infrastructure as a delivery mechanism for implementation
services.
•
Only 1– 4 unit existing buildings are eligible for the enhanced incentives.
•
5 + units will be referred to the Mass Save Multi-Family Retrofit core initiative, and lowincome-eligible multi-family building owners will be referred to the Low-Income MultiFamily Retrofit initiative or to the appropriate low-income agency to receive
comprehensive eligible energy efficiency services without co-payment, where applicable.
166
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 172 of 274
2.
Target Areas
Determining specific target areas based on pre-determined demographic and housing stock
criteria is a key component as well as a key challenge of this effort. Prospective areas of focus
may include but are not limited to Green Communities that have also been designated as
Gateway Communities or Environmental Justice communities with a focus on best addressing
low- to moderate- income consumers. Although the best methodology for employing eligibility
identification has yet to be determined, one potential for consideration is using the 2010 census
to identify those census tracts that met the following criteria:
1. Lower to moderate income customers based on the state’s median income
2. Greater than 70% penetration of 1-4 unit existing buildings (those eligible for HES)
3. Target census tracts may then be �fitted’ to Zip+4 groups based on some or all of the
Zip +4 being in the tract. The Zip+4 residences might then, subject to personal data
privacy protection laws, be able to link to PA customer data to develop lists of
eligible customers
4. These customers/addresses may then be fed into mapping software to generate a map
of the target neighborhoods.
Only people in the designated areas will be eligible for the Efficient Neighborhoods+ initiative.
3. Marketing-Outreach Strategies
As previously mentioned, the overall goal of this effort is to identify and target selective
neighborhood areas where consumers meet a certain demographic criteria. Once the areas have
been identified, the PAs will deploy a variety of marketing outreach efforts that includes using
traditional marketing methods and market segmentation activities in combination with
coordinated outreach activities. Examples of this include:
•
Community Engagement (refer to Section III.H.2) – this marketing outreach initiative
provides a great opportunity to engage local community leaders as well as communitybased advocate organizations committed to aiding in the delivery of energy efficiency
services. As such, Efficient Neighborhoods+ serves to be a logical extension of our
future Community Engagement plan where a “pay for performance” approach for local
organizations is expected to deliver results.
•
Low-Income - Coordination with the low-income programs and the community agencies
that deliver them is another key component. It is very important that we maximize
opportunities for weatherization and energy efficiency upgrades for existing low-income
customers as well as those who may be low-income but have not been identified as such
and are not receiving services under existing low-income utility rates or public programs.
Procedures for handling low-income customers will be coordinated with the Community
Action Program (“CAP”) agencies. Low-income discount rate customers will be
screened out of initial targeted efforts, such as direct mail, to avoid large numbers of
customers being directed to an initiative that may not be the optimum vehicle for meeting
167
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 173 of 274
their needs. A joint strategy will be developed with local agencies to insure that
customers get the appropriate level of service.
•
Cross-Promotion Outreach - As a direct sub-component of the HES core initiative, the
PAs plan to utilize existing marketing tools and opportunities to create awareness and
educate consumers about this initiative. However, due to the community-based nature of
this initiative, it also affords the PAs the opportunity to cross promote electric and gas
initiatives as a means to drive deeper savings and participation diversity.
Projected Milestones
1. PAs intend to define target neighborhoods and finalize initiative design (including
incentive structure) by the end of Q1 2013.
2. PAs plan to test this initiative in May-August, 2013. This timeline will serve the
secondary goal of maintaining a steady work flow for IICs and HPCs.
3. Monthly reporting of the uptake will be submitted by the Lead Vendors to the PAs.
4. PAs will assess results and report to EEAC in Q1 2014.
c. Low-Income Program Descriptions
Overview
During 2013-2015, the Program Administrators look forward to expanding upon the
success of their historic partnership with LEAN, whose pioneering efforts in providing energy
efficiency services to the low-income sector have positively influenced both best practices and
program development across sectors and have served as a national model among low-income
professionals.
168
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 174 of 274
SECTOR
PROGRAM
CORE INITIATIVE
WHOLE HOUSE
LOW-INCOME NEW
CONSTRUCTION
ADMINISTERED BY
в—Џ
LOW-INCOME
Core Initiative
Overview
ELECTRIC
PAs
JOINT
PA SPECIFIC
Key Objectives:
The Low-Income New Construction (“LINC”) Core Initiative strives to increase the efficiency of lowincome homes at the time of construction. To address the challenges of rising energy codes and more
competition for funding for low-income housing, the Program Administrators will look to incorporate the
lessons learned from the past three years to increase participation and energy savings.
The PAs will continue working with HERS infrastructure and provide ongoing training to the construction
industry. The initiative is a proud participant of the national ENERGY STARВ® Homes Program and
benefits from the regional, as well as national, advertising efforts that ENERGY STARВ® Homes
implements. This also dovetails with many of the requirements of funding agencies and foundations that
also support low-income new construction.
New Enhancements:
•
The PAs plan to incorporate the multi-family new construction pilots mentioned above by Q1
2013.
•
The initiative will transition to add prescriptive offerings for homes exceeding the Massachusetts
User Defined Reference Home (“UDRH”) by Q1 2013.
•
As a means to maintain high performance builders and attract new builder participation:
o
PAs to work with Evaluation to explore an alternative method to calculate savings for the
Performance Path
o
Streamline and simplify builder participation path through prescriptive package offerings
169
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 175 of 274
These additional initiative enhancements, will build on the current initiative structure to help broaden
participation and overall market penetration and gain additional energy savings. The prescriptive offerings
are detailed in the “Core Initiative Design” section below.
Core Initiative Design
The PAs continue their strong commitment to a whole-house approach for low-income new construction.
The initiative is committed to achieving both a broader market penetration of energy-efficient homes as
well as moving builders toward deeper energy savings where possible. The PAs will strive to both retain
existing participating builders and recruit additional homebuilders and contractors. The PAs will train
builders on EPA ENERGY STARВ® Version 3 in support of the 2012 Massachusetts Stretch Energy Code.
The initiative will provide incentives for projects exceeding the UDRH:
•
Prescriptive Option 1 – a bundle of prescriptive measures that address heating, cooling, and hot
water equipment, lighting, water use reduction, efficient appliances, and enhanced envelope air
tightness and duct tightness.
•
Prescriptive Option 2 - a bundle of prescriptive measures that include all Option 1 measures as
well as enhanced envelope thermal performance
•
Performance Tier 1 - 15% improvement or better over the UDRH and compliance with sections 3
and 5 of the ENERGY STAR Thermal Enclosure System Rater Checklist
•
Performance Tier 2 - 30% improvement or better over the UDRH and compliance with sections 3
and 5 of the ENERGY STAR Thermal Enclosure System Rater Checklist
•
Performance Tier 3 - 45% improvement or better over the UDRH and compliance with sections 3
and 5 of the ENERGY STAR Thermal Enclosure System Rater Checklist
Builders are encouraged to improve a building’s energy usage through enhanced envelope measures,
energy efficient space and water heating, appropriately sized cooling equipment, programmable
thermostats, ENERGY STARВ® qualified appliances, Water SenseВ® plumbing fixtures, efficient lighting
and controls, and proper ventilation. Builders are also encouraged to properly orient homes to take
advantage of passive heating and cooling.
All homes participating in the initiative are required to install efficient lighting products in appropriate
170
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 176 of 274
hard wired sockets and pass a final verification inspection. As energy codes become more stringent, the
PAs will continue to encourage proper lighting design and the installation of new, cutting edge, lighting
products and controls. A single family home is defined as a single family detached house, while a multifamily home is defined as two or more attached units. All low-income new construction projects in the
Commonwealth are encouraged to participate in the initiative. Mixed-use and large buildings are
addressed on a custom basis in cooperation with the commercial initiatives.
The Multi-Family New Construction (“MFNC”) core initiative offers incentives to eligible 4+ story multifamily facilities that are located in participating PA territories. The goal of the MFNC core initiative is to
provide a seamless transition from the current multi-family pilot to a fully integrated initiative. This
initiative will take the lessons learned from the three year pilot and continue to provide a single point-ofcontact for the participants and service for all fuel sources and meter configurations. A suite of offerings
will include a comprehensive list of measures to maximize energy savings above Massachusetts energy
code.
Marketing Overview
Target Market:
Homebuilders/Developers
Contractors
Architects/Designers
Trade allies
HERS raters
Homebuyers
Realtors
Code Officials
Appraisers/Mortgage bankers
Strategy:
The initiative will use a combination of the following to reach the target markets:
Trade shows, builder training (on-site and lecture), lumber yard outreach, strategic partnerships such as
Home Builders Associations (“HBA”), geo-specific targeting based on construction activity.
171
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 177 of 274
Technologies/Incentive
s
The following is a list of packages, recommended technologies, and incentives offered:
Package
Performance
Path
Tier 1
Tier 2
Tier 3
Prescriptive
Path
Prescriptive
Option 1
Requirements
Incentive
Single
Family
15% improvement or better
over the UDRH and
compliance with sections 3
$750
and 5 of the ENERGY
STAR Thermal Enclosure
System Rater Checklist
30% improvement or better
over the UDRH and
compliance with sections 3
$1,250
and 5 of the ENERGY
STAR Thermal Enclosure
System Rater Checklist
45% improvement or better
over the UDRH and
compliance with sections 3
$7,000
and 5 of the ENERGY
STAR Thermal Enclosure
System Rater Checklist
heating, cooling, and hot
water equipment, lighting,
water use reduction,
efficient appliances, and
enhanced envelope air
172
$1,250
Multi
Family
2-99 units
100-199
units
200+ units
$650
$500
$350
$1,150
$850
$550
$4,000
$3,000
$2,000
$1,150
$850
$550
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 178 of 274
tightness and duct tightness
Prescriptive
Option 2
All Packages
a bundle of prescriptive
measures that include all
Option 1 measures as well
as enhanced envelope
thermal performance
ENERGY STARВ®
qualified refrigerator
$7,000
$4,000
$3,000
$2,000
$50.00
Single Family is defined as a detached unit. Two or more attached units are classified as Multi-family. A
Multi-family project must be three stories or below and residentially permitted to qualify.
Multi-family Buildings with Four or More Stories
Package
Requirements
Prescriptive In-unit Efficient heating, cooling, and ventilation
equipment, efficient hot water equipment, lighting
power reduction, water use reduction, and efficient
appliances
Whole building & Same as in unit prescriptive incentive. Whole
prescriptive in-unit building measures include enhanced envelope,
efficient central heating, cooling, and ventilation
equipment, efficient central laundry equipment, and
efficient lighting and controls in common areas
Incentives
Up to $250 per unit
Whole Building
Custom
Custom incentives
Commercially metered projects are eligible for the
same instant savings measures and will be referred to
the vendor to evaluate applicable custom
improvements.
173
Prescriptive whole
building incentives to be
determined
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 179 of 274
The PAs will work with the MTAC to include new measures or technologies as appropriate.
Delivery Mechanism
The initiative is administered statewide by the PAs (both gas and electric).Through a competitive bid
process, the PAs chose a statewide implementation vendor to oversee the day-to-day operations. The
vendor is responsible for tracking and reporting program activity to each PA. Throughout the planned
timeframe, the PAs will continue to work with the market-based network of trained raters who offer
energy-efficiency and rating services to homebuilders.
The PAs will deliver in-depth trainings to the target market in the fundamentals of building science,
energy codes, and the latest emerging technologies to promote the initiative, as well as support workforce
development efforts through the Green Jobs Act.
Three-Year
Deployment
Strategy/Roadmap
For low-income new construction, the efforts to achieve both deeper savings and gain broader market
penetration will continue through multiple channels of participation, each of which continues to push
homes closer to net zero energy. The initiative is dedicated to promoting energy efficient new construction
by supporting the target market.
For the three-year deployment, the PAs will focus on the following:
•
Streamline and simplify initiative offerings to reduce complexity and increase participation
•
Support target market in achieving deeper levels of energy savings with relevant trainings
•
Expansion of the base of participating low-income builders/homeowners
•
Continued coordination with existing and new market allies
•
Continue to promote consumer awareness through statewide marketing
Special Notes
174
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 180 of 274
SECTOR
PROGRAM
CORE INITIATIVE
WHOLE HOUSE
LOW-INCOME
SINGLE FAMILY
ADMINISTERED BY
в—Џ
LOW-INCOME
Core Initiative
Overview
ELECTRIC &
GAS PAs
JOINT
PA SPECIFIC
Key Objectives:
The Low-Income Single Family Core Initiative implements cost-effective, energy efficiency
products and services directly for residential customers living in 1 to 4 unit dwellings in which at
least 50 percent of the occupants are at or below 60 percent of the state median income level. The
initiative leverages all applicable revenue streams and piggybacks on the current Department of
Housing and Community Development (“DHCD”) Weatherization Assistance Program (“WAP”),
consistent with a comprehensive, whole house approach generally with no co-payment required
from participating customers.
New Enhancements:
•
The PAs will continue to work with the Best Practices Working Group to identify new costeffective energy efficiency services, measures and technologies that are appropriate to offer to
income-eligible customers. LED lighting is one of the primary new measures that has been and
will continue to be examined as the technology evolves and pricing declines. The Heat Pump
Water Heater (50 gallon and 80 gallon tank) is also a new measure for the initiative as it was
deemed cost-effective for use when replacing an electric water heater of equivalent size. While
this measure provides excellent savings potential, installations are required to meet manufacturer
recommended temperature and space specifications as well as condensation removal criteria.
Ongoing throughout program years 2013-2015.
•
PAs will work with the Low-Income Energy Affordability Network (“LEAN”), state
organizations such as the DHCD, lead vendor, and Community Action Program (“CAP”)
175
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 181 of 274
agencies to increase qualified contractor participation in the initiative through training and
workforce development. The PAs also plan to continue to support contractor and auditor training
as needed. Ongoing throughout program years 2013-2015.
•
Core Initiative Design
PAs will work with LEAN in the design of the Efficient Neighborhoods + initiative and its
implementation phases. It is expected that the targeted neighborhoods in this initiative will
include low-income qualified/eligible consumers; thus the Program Administrators plan to work
with LEAN to ensure a fully integrated cross-sector approach. Efforts will be prioritized during
program year 2013 but ongoing throughout 3-year filing.
The PAs will work in collaboration with the Best Practices Working Group, including LEAN, DHCD, lead
vendor (where applicable), and CAP agencies to coordinate statewide on all aspects of the Low-Income
Single Family Core Initiative, including but not limited to planning, delivery, implementation, education,
marketing, training, cost-effectiveness, evaluation, and quality assurance.
Once customers are deemed eligible, they will receive an in-home energy assessment from their local CAP
agency. The assessment evaluates the building shell, efficiency and appliance conditions (for electric PAs
only), as well as home health and safety. The CAP agency will then arrange for all applicable measures
and services to be installed by a qualified contractor. Savings will be deepened by installing additional
efficiency measures; to the extent the overall initiative remains cost-effective.
The initiative piggybacks on the current DHCD WAP. All applicable revenue streams available are
leveraged to enhance services consistent with a whole-house approach. PA funding will primarily be used
to address more items on the cost-effective priority list, including approved weatherization related repairs.
Federal money will primarily be used to address health and safety issues, as well as repairs, to allow for
cost-effective energy efficient measures to be installed.
As mandated by DHCD for all projects that receive Department of Energy (“DOE”) funding, the CAP
agencies perform 100 percent post-installation quality assurance inspection of projects to ensure that all
work is performed to the program guidelines. The CAP agencies also perform a minimum of 50 percent
in-process inspection of projects. Because the PA initiative piggybacks on the DHCD program, many jobs
are multi-funded therefore, quality control is completed for both DOE and PA funded projects at the same
time. DHCD performs another level of visual inspection for 20 percent of all DOE-funded projects.
176
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 182 of 274
During these inspections, DHCD reviews both DOE and PA funded work. Additionally, the PAs have an
independent third-party vendor perform quality assurance inspections for an additional level of quality
control. PAs require a specified percentage of all jobs exclusively funded by the PAs to be inspected.
Energy efficiency education and information is provided to all participating customers. The primary form
of energy education is verbal communication between the auditor and the client along with leave-behind
materials. The Low-Income Single Family Core Initiative plans to review the opportunity of developing
common education materials with the Best Practices Working Group.
Marketing Overview
Target Market:
Residential customers living in 1 to 4 unit dwellings who are at 60 percent of the state median income
level or who are qualified to receive fuel assistance and/or utility (or municipal aggregator) discount rates.
For 2 to 4 unit dwellings, 50 percent of the occupants must qualify as low-income in order to be served by
the Low-Income Single Family Core Initiative.
Any changes to eligibility criteria will be addressed collectively between the PAs, LEAN, DHCD, lead
vendor (where applicable) and CAP agencies.
Strategy:
Marketing outreach designed to reach more income-eligible customers and maximize energy savings
opportunities will continue to expand through the 2013 – 2015 Low-Income Single Family Core Initiative
(where applicable). PAs, in collaboration with lead vendor (where applicable) and CAP agencies, will
continue to engage in targeted, localized outreach efforts to notify customers of the availability and value
of energy efficiency services. Marketing consists of contacting qualified income-eligible customers
subscribing to the discount rate who have not received prior energy efficiency services. Telemarketing,
direct mail, bill inserts, and literature distributed through social services agencies, government offices, and
other networks are also used to market the initiative. In addition, PAs are participating in statewide
marketing efforts to encourage all customers to participate in energy efficiency initiatives. Those efforts
will assist in driving income-eligible customers to take advantage of not only energy efficiency programs
but also discount rates, fuel assistance and other social programs. Awareness of the initiative is also gained
through participation in local community events such as job fairs, senior centers, and employee
177
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 183 of 274
presentations, which may include case studies.
Outreach and marketing efforts as well as PA collaboration will be expanded as needed. Approaches may
include building relationships with unemployment centers, medical service providers, and other venues
that could reach potential income-eligible customers. PAs will continue to examine other potential service
providers and venues such as community-based outreach that could reach income-eligible customers.
Technologies/Incentives The following is a list of targeted end uses, recommended technologies, and incentives (not meant to
be limiting) offered where qualified:
Targeted End Use
Building Shell
Building Shell
Heating
Domestic Water Heating
Domestic Water Heating
Comprehensive, Whole
House Approach
Comprehensive, Whole
House Approach
Lighting and Appliances
Lighting and Appliances
Lighting and Appliances
Lighting and Appliances
Lighting and Appliances
Lighting and Appliances
Lighting and Appliances
Lighting and Appliances
HVAC/Mechanical Systems
Technology
Insulation (Attic, Wall, Pipe, & Duct)
Air Sealing / Duct Sealing
Heating System Repair & Replacement
DHW Measures (Low Flow Showerhead,
Faucet Aerator, & Pipe Wrap)
50 and 80 gallon Heat Pump Water
Heater (Electric)
Weatherization Repairs (electrical
repairs, roofs, etc.)
Health and Safety
LEDs
CFLs
Lighting Fixtures
Torchieres
Refrigerator Replacement
2nd Refrigerator Removal
Freezer Replacement
“Smart” power strips
Window Air Conditioner Replacement
178
Incentive
No cost to customer with
established caps (where
applicable)
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 184 of 274
In coordination with LEAN, the PAs will work with the MTAC to include new measures or technologies
as appropriate.
Delivery Mechanism
PAs, when appropriate, use a lead vendor to administer the initiative. The PAs work closely with their
lead vendor and/or respective CAP agencies on all aspects of the initiative design and implementation.
The lead vendor/CAP agencies are responsible for providing coordination of energy efficiency services to
the customer. The lead vendor/CAP agencies work with installation contractors to ensure that the proper
initiative guidelines are enforced. These agencies are also responsible for ensuring that the customer
meets the eligibility requirements for initiative participation and providing the lead vendor and/or PA with
the required documentation of all work performed. Quality assurance is completed by the CAP agencies,
DHCD, as well as by a PA funded independent third party vendor.
Three-Year
Deployment
Strategy/Roadmap
The PAs will coordinate efforts through the existing low-income weatherization and fuel assistance
program via LEAN to ensure consistent implementation throughout the state and retain the advantages of
the existing infrastructure of central coordination while avoiding the creation of a new or central entity.
Training and workforce development will be accomplished by the PAs working with LEAN, DHCD, lead
vendors and CAP agencies to increase the number of qualified contractors, energy auditors, and
administrative staff. The PAs in conjunction with LEAN, the lead vendors and the CAP agencies will
continually review and evaluate new measures and technologies. All applicable revenue streams available
will be leveraged to enhance services. Through marketing and outreach efforts, the PAs will attempt to
broaden initiative participation. PAs will attempt to deepen efficiency penetration consistent with a
comprehensive, whole house approach.
Special Notes
179
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 185 of 274
SECTOR
PROGRAM
CORE INITIATIVE
WHOLE HOUSE
LOW-INCOME
MULTI-FAMILY
ADMINISTERED BY
в—Џ
LOW-INCOME
Core Initiative
Overview
ELECTRIC &
GAS PAs
JOINT
PA SPECIFIC
Key Objectives:
The Low-Income Multi-Family Retrofit Core Initiative leverages all applicable revenue streams and
provides cost-effective, residential energy efficiency improvements that benefit income-eligible occupants
and owners of multi-family buildings. Energy efficiency products and services are implemented directly in
the dwellings of residential, income eligible customers living in multi-family facilities (with 5 or more
attached units), in which at least 50 percent of the occupants are at or below 60 percent of the state median
income level. The Program Administrators will provide up to 100 percent of the cost-effective project
with established caps based on projected savings.
New Enhancements:
•
In 2012, the funding of the Low-Income Multi-Family Core Initiative and Low-Income Single
Family Core Initiative was proposed to be combined. The PAs continue to combine funding for
the Low-Income Multi-Family and Single Family Core Initiatives in 2013-2015 to offer more
flexibility in servicing the greatest potential number of income-eligible customers if demand for
one initiative surpasses the other. Additionally, the PAs and LEAN will explore ways to address
the disproportionate electric and gas Multi-Family budgets. Ongoing throughout program years
2013-2015.
•
The PAs will continue to work with the Best Practices Working Group to identify new costeffective energy efficiency services, measures and technologies that are appropriate to offer to
income-eligible customers. Common area lighting controls provide an excellent opportunity to
reduce wasted lighting energy in common-area applications such as stairwells and hallways when
the area is unoccupied. All PAs will include best practices within the 2013-2015 Low-Income
180
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 186 of 274
Multi-Family Core Initiative. LED lighting is a new measure that has been and will continue to be
examined as the technology evolves and pricing declines. The Heat Pump Water Heater (50 gallon
and 80 gallon tank) is another new measure for the initiative as it was deemed cost-effective for use
when replacing an electric water heater of equivalent size. While this measure provides excellent
savings potential, installations are required to meet manufacturer recommended temperature and
space specifications as well as condensation removal criteria. Ongoing throughout the program
years 2013-2015.
•
As a new initiative in 2010, the Low-Income Multi-Family Core Initiative focused on multi-family
properties that were non-institutional dwellings owned or operated by non-profit entities or public
housing authorities. In 2012, based upon available funding, some PAs also served “for profit”
properties under the same guidelines in which at least 50 percent of the occupants were at or below
60 percent of the state median income level. With better data and more experience in this sector,
the Low-Income Multi-Family Core Initiative for 2013 – 2015 will broaden participation and plans
to serve “for profit” multi-family properties in addition to “non-profit” multi-family properties
based upon an individual PA’s budget constraints with prioritization for the “non-profit” properties
by Q1 2013.
•
PAs will work with the Low-Income Energy Affordability Network (“LEAN”), the Low-Income
Multi-Family Advisory Committee, state organizations such as the Department of Housing and
Community Development (“DHCD”), and Community Action Program (“CAP”) agencies to
increase qualified contractor participation in the initiative through training and workforce
development. The PAs also plan to continue to support contractor and auditor training as needed.
Ongoing throughout program years 2013-2015.
•
Currently, the Low-Income Multi-Family Core Initiative serves properties that are heated by gas
and electricity; however, facilities heated by deliverable fuels are excluded from participating in all
of the available energy efficiency measures that are offered within the initiative, specifically
weatherization improvements and heating system repairs and replacements. The 2013-2015 MultiFamily Core Initiative plans to explore the potential of offering all available measures and
incentives to any eligible multi-family facility regardless of fuel type. Efforts will be prioritized
during program year 2013.
181
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 187 of 274
Core Initiative Design
The Low-Income Multi-Family Core Initiative services properties that have five or more units in which at
least 50 percent of the occupants are at or below 60 percent of the state median income level. Eligibility
for the initiative measures and services will be based on the established cost-effectiveness test, which
includes agreed upon non-energy benefits, and will not be restricted, to the greatest extent possible, by rate
class associated with the meter(s) for the facility. Eligible projects involve efficiency upgrades for
buildings with currently high energy consumption and require that applicants participate in benchmarking
their building’s energy usage post-improvements. The Low-Income Multi-Family building inventory has
been an innovative component of this initiative to both help identify potential participants and help
determine usage patterns in this sector.
The PAs will work in collaboration with the Best Practices Working Group including LEAN, the MultiFamily Advisory Committee, DHCD, lead vendors, and CAP agencies to collaborate and coordinate
statewide on all aspects of the Low-Income Multi-Family Core Initiative, including but not limited to
planning, delivery, implementation, education, marketing, training, cost-effectiveness, evaluation, and
quality assurance. When topics to be discussed apply to both market-rate customers and low-income
customers, PAs will further coordinate between initiatives as needed.
The initiative will be structured to ensure that participants are provided with a “whole building”; fully
integrated offering that targets both gas and electric end users. Once a property is deemed eligible, it will
receive an energy assessment through a lead vendor or local CAP agency. The assessment evaluates the
building shell, efficiency and appliance conditions (for electric PAs only), as well as home health and
safety. The CAP agency will then arrange for all applicable measures and services to be installed by a
qualified contractor. Savings will be deepened by installing additional efficiency measures; to the extent
the overall project remains cost-effective.
The initiative piggybacks on the current DHCD low-income energy efficiency programs and all other
eligible funding sources (i.e., federal and state) to enhance services consistent with a whole-building
approach. PAs will use a lead vendor or local CAP agency to administer the initiative. Sub-contracting
will be appropriate to the complexity of the work required and will be based on a similar audit tool as in
the Multi-Family Retrofit Core Initiative. Low-income customer inquiries will be referred to the lead
vendor/CAP agency, the Multi-Family Advisory Committee, or PA by the Multi-Family Market Integrator
(“MMI”), as defined in the Multi-Family Retrofit Core Initiative. Low-income customers may also apply
directly to the initiative via their PA and/or local CAP agency. An essential element of this initiative is
182
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 188 of 274
that interested customers also have the option, at their discretion; of electing to participate in the MultiFamily Retrofit Core Initiative. This approach helps ensure that there are multiple paths to participation in
energy efficiency initiatives in this unique market sector that has also been served over many years by
skilled contractors and engineering firms. These firms will continue to be eligible to provide services in
this sector, both through the Multi-Family Retrofit Core Initiative (and its terms and conditions) and,
where qualified, as providers for the Low-Income Multi-Family Core Initiative under the terms and
conditions of this initiative.
Customer Education
Energy efficiency education and information are included in all PAs’ energy efficiency initiatives. The
primary forms of energy education are benchmarking building inventories and verbal communication
between the auditor and the participants. The Low-Income Multi-Family Core Initiative plans to
develop/improve education materials and material distribution which will include education for landlords,
property managers, building occupants, and property management personnel as well as development of
case studies.
Marketing Overview
Target Market:
Residential customers on the discount rate and/or customers living in multi-family facilities with five or
more dwelling units in which at least 50 percent of the occupants are at or below 60 percent of the state
median income level in addition to the landlords and property managers of these buildings.
Any changes to eligibility criteria will be addressed collectively between the PAs, LEAN, lead agencies
and CAP agencies.
Strategy:
Demand for the Low-Income Multi-Family Core Initiative will be managed jointly by the PAs and the
Multi-Family Advisory Committee.
The PAs will engage in outreach efforts to notify customers of the availability and value of energy
efficiency services to stimulate interest in the initiative and operate within budgets. Marketing will consist
of contacting landlords or property managers of income-eligible tenants. Direct mail, bill inserts, case
183
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 189 of 274
studies and literature distributed through social service agencies, housing funders, government offices,
community outreach, and other networks are also used to market the initiative. PAs will use their
relationship with PHAs, CDCs, community based outreach and other income-eligible property managers
to market the benefits of the initiative.
In addition, PAs are participating in statewide marketing efforts to encourage all customers to participate
in energy efficiency initiatives. Those efforts will assist in driving income-eligible customers to take
advantage of not only energy efficiency programs but also discount rates, fuel assistance, and other social
programs when appropriate.
Technologies/Incentives The following is a list of targeted end uses, recommended technologies, and incentives (not meant to
be limited) offered:
Targeted End Use
Building Shell
Building Shell
Heating
General Waste Heat
Domestic Water Heating
Domestic Water Heating
Domestic Water Heating
Lighting and Appliances
Lighting and Appliances
Lighting and Appliances
Lighting and Appliances
Lighting and Appliances
Lighting and Appliances
Lighting and Appliances
Lighting and Appliances
Technology
Incentive
Insulation (Attic, Wall, Pipe, & Duct)
Air Sealing
Heating System Repair & Replacement
Programmable Thermostat
DHW Measures (Low Flow Showerhead,
Faucet Aerator, Pipe Wrap, & Tank
Wrap)
Water Heating Equipment
Heat Pump Water Heater (Electric)
LEDs
CFLs
Lighting Fixtures
Common Area (Interior & Exterior)
Lighting Upgrades & Controls
Torchieres
Refrigerator Replacement
Freezer Replacement
ENERGY STARВ® Clothes Washer
PAs will pay up to 100
percent of the project cost
with established dollar caps
where applicable. Larger
capital investment projects
will be screened for costeffectiveness (with the
Multi-Family Advisory
Group.
184
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 190 of 274
Lighting and Appliances
HVAC/Mechanical Systems
HVAC/Mechanical Systems
HVAC/Mechanical Systems
HVAC/Mechanical Systems
HVAC/Mechanical Systems
HVAC/Mechanical Systems
HVAC/Mechanical Systems
HVAC/Mechanical Systems
HVAC/Mechanical Systems
Comprehensive, Whole
House Approach
Comprehensive, Whole
House Approach
Power Smart Strips
Window Air Conditioner Replacement
Energy Management System (EMS)
Motors and drives
Chillers
Air Compressors
Ventilation system repair, adjustment,
replacement
Heat Recovery Ventilation/Energy
Recovery Ventilation
Redistribution systems
Temperature Building Controls
Weatherization Repairs (electrical repairs,
roofs, etc.)
Health and Safety
The PAs will work with the MTAC to include new measures or technologies, as appropriate, and in
coordination with LEAN’s other efforts.
Delivery Mechanism
The initiative will be administered cooperatively by the gas and the electric PAs in conjunction with
interested stakeholders.
Enrollment
Participants for this initiative may enroll through a local CAP agency, statewide website, the multi-family
statewide toll free number, PA(s), the Low-Income Multi-Family website or other venue (use of the lowincome multi-family website is required in most cases).
Participant Screening
Currently, the Multi-Family Advisory Committee comprised of LEAN, Community Development
Corporations (“CDCs”), other non-profit owners of low-income non-institutional multi-family housing,
and Public Housing Authorities (“PHAs”) are tasked with prioritizing low-income multi-family projects
185
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 191 of 274
for each PA. The Advisory Committee integrates flexibility into their planning to handle unique needs of
PAs and their customers or potential participants. The Multi-Family Advisory Committee may include
representatives of other sectors.
Due to the nature of this market segment, most leads will be generated through the Multi-Family Advisory
Committee; however, leads coming in via other venues will be screened by the MMI and forwarded to the
Multi-Family Advisory Committee for eligibility confirmation.
Upon confirmation of a project, the lead vendor or CAP agency is responsible for coordinating the
appropriate parties to address the project needs based on protocols agreed to by the specific PA(s) and in
consultation with the specific PA(s) to move the project forward.
Whole Building Assessment
Based on the outcome of the screening process, the appropriate technical resources will be assigned to
conduct a whole building, (fuel blind) assessment. The lead vendor or local CAP agency will attempt,
through the screening process, to identify all resources required for the assessment; however, there may be
instances where additional expertise is required and therefore more than one site visit is necessary.
Technical assessments and engineering studies will be conducted as needed. At the time of the
assessment, education will be provided to participants and instant saving measures will be installed, as
appropriate and authorized by the customer.
Integrated Proposal for Energy Efficiency Services
Using the findings from the site-specific assessment, the appropriate parties will draft a project proposal
that will include gas and electric cost-effective measure opportunities and other available services where
applicable. Where appropriate, the project proposal will be forwarded to the appropriate PA(s) for
approval. Once the comprehensive offer has received PA approval (if necessary), it will be presented to
the participant by the parties required to help the customer fully understand the offering.
Delivery of Measures and Services
The lead vendor or CAP agency will coordinate the delivery of the measures and services. The
installation contractors will strive to have all dwelling unit measures installed in a single visit to minimize
disruption for the tenants; however, multiple visits may be required for the installation of common area
measures. All installations are coordinated with the owners, property managers and the tenants.
186
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 192 of 274
Quality Assurance/Quality Control
Quality assurance will be performed in support of this initiative. Quality assurance is completed by the
CAP agencies, as well as by a PA funded independent third party vendor.
The delivery mechanism serves to minimize lost opportunities and encourage deeper savings in the
following ways:
Three-Year
Deployment
Strategy/Roadmap
•
The increased incentive amounts may allow for achieving energy savings that would not be
possible if this population had to provide a significant co-payment.
•
Having the PHAs and CDCs and other owners of non-institutional low-income multi-family
housing involved in the process helps facilitate access to the tenant spaces, which has been
traditionally cited as a potential barrier in the multi-family market.
The PAs will coordinate efforts via LEAN to ensure consistent implementation throughout the state and
retain the advantages of the existing infrastructure of central coordination while avoiding the creation of a
new or central entity. Participants may inquire for enrollment through a CAP agency, statewide website,
low-income multi-family website, multi-family statewide toll free number, PAs or other venue. Many
leads will be generated through the Multi-Family Advisory Committee; however, leads coming in via
other venues will be screened by the MMI and/or the PAs and forwarded to the lead vendor/CAP agency
for eligibility confirmation. Once eligibility has been confirmed, the Multi-Family Advisory Committee
prioritizes the low-income multi-family projects for each PA. Training and workforce development will be
accomplished by the PAs working with LEAN, DHCD, and CAP agencies to increase the number of
qualified contractors, energy auditors, and administrative staff. The PAs in conjunction with LEAN and
the CAP agencies will continually review and evaluate new measures and technologies. All applicable
revenue streams available will be leveraged to enhance services. Through marketing and outreach efforts,
the PAs will attempt to broaden participation. PAs will attempt to deepen efficiency penetration consistent
with a comprehensive, whole building approach.
Special Notes
187
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 193 of 274
d. C&I Program Descriptions
Overview of C&I Efforts
Lessons Learned
Over the past three-year program delivery period , the Program Administrators achieved
success by both expanding and accelerating existing program “through put” , and by targeting
new initiatives and strategies to identifiable market pockets where a local market assessment or
the experiences of other programs indicated that unrealized efficiency potential could be
captured. The PAs actively sought out examples of program or initiative success from other
jurisdictions and incorporated promising models into local program design and delivery. For
example, the PAs moved some lighting incentives upstream to capture a demonstrable share of
the new construction/equipment replacement opportunities not being captured by the established
program.
The PAs were also quick to exploit new opportunities as they appeared, and pioneered
program delivery models that are now being emulated elsewhere. One example is in the
dynamic and rapidly-changing lighting market, where the PAs must balance marketplace
enthusiasm for LEDs with the need to ensure product reliability and appropriate incentives as a
percentage of product price. For example, the convergence of a reliable and appropriate product
and a suddenly very competitive market price allowed the PAs to rapidly deploy a targeted
initiative to a niche market - LED replacements into sockets in the hospitality industry.
In addition, the Massachusetts PAs pioneered some delivery concepts, such as creating
multi-year agreements with the largest customers, which are now being examined for application
in other parts of the country. At a higher level, the PA model for managing the multi-entity
delivery of a dual-fuel statewide program has drawn inquiries from other emerging statewide
efforts around the country.
ARRA funding created a time-specific stimulus and unique opportunities to forge
creative partnerships with municipalities and there are expected to be some continuing effects of
this program that can be applied to “second generation” partnership efforts. The collaborative
working relationship established with state and federal agencies (e.g., Mass Energy Leaders,
DOER, DCAM, DEP, Green Communities Division, EPA) during the ARRA stimulus period has
created lasting improvements in mission alignments and process efficiencies benefiting multiple
stakeholders. These efforts will continue to be enhanced and leveraged going forward.
Financing was also a focus of PA efforts over the past several years as lack of financing
was identified as a potential barrier to increased participation. As a result, a financing offering
was developed in collaboration with the Massachusetts Bankers Association (“MBA”). The
financing design was well-researched, drawing on the lessons learned from the myriad of
financing approaches put forth in Massachusetts and in other states over the last twenty years.
The Massachusetts offering provides a very streamlined process. Additional concepts of “off-
188
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 194 of 274
balance sheet” financing have been discussed; however, these concepts can prove challenging
under GAAP (Generally Accepted Accounting Principles). 27
Moving forward, the PAs will increase efforts to highlight the favorable investment
attributes of efficiency and promote the MBA offering, as well as Performance Contracting and
other financing vehicles, for the minority of customers for whom lack of capital is an obstacle to
engagement. In addition, the PAs will develop tools to provide customers with additional
financial perspectives to evaluate efficiency investments which can be used by account managers
as well as third parties.
One of the benefits of having multiple Program Administrators is the ability to test
different models and to share best practices. Two recent examples include NSTAR’s Municipal
Program to test a direct-install model tailored to the specific needs of municipal customers and
National Grid’s test of a comprehensiveness initiative that increases their multiple measure
bonus from 10% to 25% for a limited time during the summer of 2012 – this enhanced incentive
is intended to both to encourage greater comprehensiveness and to smooth out participation
during the year. Each company shares the progress of these efforts with the C&I Management
Committee, and will formally report results in the fourth quarter of 2012. Depending on the
success of this effort, the other PAs may adopt similar approaches in 2013.
The PAs have also largely succeeded in moving from separate, siloed electric and gas
delivery to an integrated gas/electric delivery model. Cross training has been conducted for both
internal and external personnel. Post audits have been conducted to confirm Direct Install
vendor compliance and customer satisfaction. Multiple-PA, multi-year duel fuel MOUs have
been signed, and a number of co-funded technical assistance (“TA”) studies and projects have
been implemented. As the effects of this integration become recognized, the marketplace has
responded – with vendors hiring new technical staff and partnering and merging in order to
acquire integrated delivery capabilities. The PAs continue to focus on expanding the pool of
technical assistance vendors and program expediters (“PEXs”) who have the ability to pursue
comprehensive electric and gas opportunities for the participating customer. Integration is an
ongoing and dynamic process, and the C&I Management Committee, as well as MTAC and the
various specialized working groups and subcommittees, all include representatives from both
electric and gas PAs and they all continue to focus on opportunities to further streamline efforts
for customers, enhance comprehensiveness, and to move forward with enhancements in the
integration effort.
Structural Changes
PAs will be consolidating the former freestanding Direct Install program as an initiative
under the Retrofit program. The purpose of this change is to provide improved clarity for
customers. Post-consolidation, non-residential customers will have two clear umbrella options to
participate: a Retrofit Program or a New Construction Program. This clarification also helps
stakeholders distinguish the different characteristics (e.g., incentive basis, decision makers,
27
National Grid and WMECO will continue to offer on-bill repayment to small businesses and other nonresidential electric customers as a tool for addressing this barrier to participation. A portion of National
Grid’s budget includes funding for this purpose.
189
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 195 of 274
barriers, market actors, and project timeframes) of these two large programs and direct go-tomarket strategies for each.
Moving Forward
In order to both sustain current program activity levels, and ramp up to new levels of
savings, the PAs will continue to expand current efforts while focusing on several new initiatives
that are described in detail below. The intent is not to add new “programs”, which best practice
research concludes only lends to customer confusion, but rather to increase customer
participation within the existing framework by identifying, understanding and developing
strategies to overcome barriers to participation. The PA strategy is to promote broader and
easier adoption of appropriate efficiency services and solutions, not specific programs.
190
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 196 of 274
SECTOR
PROGRAM
COMMERCIAL &
INDUSTRIAL
RETROFIT
Program Overview
ADMINISTERED BY
ELECTRIC & GAS
PAs
в—Џ
JOINT
PA - SPECIFIC
Key Objectives:
This program increasingly will focus on comprehensive gas and electric energy efficiency opportunities
associated with mechanical, electrical, and thermal systems in existing commercial, industrial,
governmental and institutional buildings. The Retrofit program provides technical assistance and
incentives to encourage the retrofitting of equipment that continues to function, but is outdated and
inefficient, and can be replaced with a premium efficient product. The program includes both prescriptive
and custom measures.
The program provides technical assistance (to identify and quantify opportunities) and financial incentives
based on a percentage of project costs (both material and labor) to make equipment removal and
replacement attractive to building and business owners in terms of conventional business payback
requirements. Given the current low cost of gas, this will likely require an increase in incentives currently
offered for gas energy efficiency measures.
The program can also help participants identify specific peak load management opportunities that enable
participants to maximize other time-based incentives – such as those available from the ISO – to manage
their electric and thermal loads, and assists occupants in improving their ongoing operation and
maintenance practices. While the primary focus of efforts is on energy savings opportunities, the PAs
recognize the value of creating demand savings that can be bid into the FCM, providing enhanced funding
for efforts.
New Enhancements:
Program Definition - Move the Small Business Retrofit Program (Direct Install (“DI”) into the overall
C&I Retrofit Program, as a sub-program/initiative targeted toward smaller C&I customers with combined
191
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 197 of 274
peak demand of 300 kW or less
Financing/Energy Efficiency Investment: Provide additional financial tools for use starting in Q1 2013
for improved customer evaluation of financial benefits and continually assess additional opportunities to
address competition for internal customer resources for energy efficiency investments in 2013 – 2015.
Municipalities: Review and adopt, as appropriate, a focused turn-key Municipal Track model in which
contracted vendors will be dedicated to serve Municipal customers.
Expanded Service Offerings: Improve customer experience and broadening service offerings by
exploring new streamlined and lower cost delivery pathways for both small and medium sized customers,
as well as for larger customers who choose a more limited engagement in energy efficiency. The new
delivery pathways may potentially include:
•
A web based portal to provide one-stop-shopping for customer efficiency opportunities;
•
Self-assessment through an internet portal that provides an interactive response to customer submitted
data;
•
Personal assistance via web-based (chat) or telephone support services that would screen potential
customers/facilities for services that best address their specific needs; and
•
Fee-Based on-site assessment to evaluate energy efficiency opportunities when savings potential
appears limited and/or customer commitment to implementation is uncertain.
Community Based Implementation Campaigns: Expand on pilot “Main Street” models to overcome
challenges to cost-effective service to some of the smallest customers by targeting geographical areas with
high densities of small customers for highly focused, time-limited delivery of program services in order to
achieve economies of scale in implementation cost.
LED Street Lighting: Continuation or launching of major retrofit initiatives for municipally-owned
streetlights by several PAs, and evaluation by others. New PA working group to focus on addressing and
overcoming the regulatory and technical issues surrounding the implementation of efficiency options for
utility-owned street lighting.
192
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 198 of 274
Market Segmentation: Continued analysis and adoption of industry-segmented marketing approaches,
delivery systems, value propositions and offerings to better meet the needs and interests of those segments.
Initial examples include Healthcare and Commercial Real Estate which have been described above.
Five Largest Gas and Electric Customers Accelerated Rebate Pilot: The PAs are committed to
implementing a voluntary accelerated rebate pilot program for their five largest gas and electric customers,
in accordance with Sections 5 and 54 of An Act Relative to Competitively Priced Electricity in the
Commonwealth, St. 2012, c.209, approved August 3, 2012.
Program Design
Key strategies of the Retrofit Program as planned for 2013-2015 include:
Technical Assistance Services:
Solid, professional, unbiased, and independent technical advisory services will continue to provide the
foundation for the achievement of deep and broad savings in existing buildings. The Technical Assistance
(“TA”) Services component of the program provides technical support matched to the specific needs and
capabilities of each commercial or industrial customer. Services include walk-through audits, detailed
energy-efficiency studies for buildings or building components, and specialized technical studies, such as
studies of industrial process improvements and compressed air projects.
Study proposals are typically assigned to and performed by TA consultants who have been selected as
preferred vendors through a competitive procurement process by the PAs. TA consultants will be assigned
based on an assessment of their expertise with the technology area under consideration. Customers can
also elect to use a TA provider of their own choosing as long as the co-funding PA approves the firm’s
qualifications and cost-estimate. Non-preferred vendors must comply with the same level of detail and
quality as preferred vendors.
In many instances, commercial and industrial customers may have both gas and electric equipment options
for a particular end-use. In order to (a) encourage more comprehensive, integrated, and balanced
consideration of all the energy efficiency options available, and (b) ensure that customers have open
choices, the gas and electric PAs delivering the statewide program will continue to provide coordinated
TA studies. In addition, starting in 2013, PAs will require the consideration of both gas and electric
193
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 199 of 274
opportunities in order for customers to be eligible for TA funds. In general, as previously, the study costs
will be shared between gas and electric PAs according to the proportionate share of the analysis and/or
opportunities found through the analysis. Study opportunities are likely to appear in larger complex
buildings and industrial facilities.
Municipalities: Municipalities often have unique barriers and the Program Administrators recognize an
integral role they can play to helping to overcome such barriers. These barriers can include capital and
staff limitations and procurement processes which were not designed to easily accommodate the vendordriven process of energy efficiency. Municipalities may lack the technical resources to become familiar
with complex energy efficiency options, and requirements for governing body approval of all capital
budget items can make it difficult for municipal officials to act on opportunities to reduce energy costs.
Also, many cities and towns have old public facilities with outdated systems. Local government structures
also delegate responsibility for energy upgrades to the individual department level, while payment of bills
often resides at a central finance office. Thus, there is little incentive for departments to upgrade the
energy efficiency of their buildings because the reward for reduced energy bills may simply be a reduced
operating budget in the subsequent year.
The cumulative consequence is that municipal customers often have very outdated and inefficient energy
systems. Because savings per building may be low and the transaction costs of public procurements are
high, energy service companies have little or no incentive to market to these customers.
The GCA provides a new streamlined contracting process that allows cities and towns to sole-source
efficiency projects to a PA, or the PA’s delivery contractors, if the total work is less than $100,000. By
providing upfront competitive bidding, enhanced financial incentives, and PA financing options, including
on-bill payment, some PAs have been able to provide a turnkey service with incentives structured to create
positive cash flow and to encourage comprehensive projects. This addresses many of the implementation
barriers cited above. The Program Administrators are committed to supporting the Green Communities
Initiative and assisting new communities in entering the process. We will continue to assist prospective
communities by offering a high level assessment of their apparent energy savings potential based upon a
walk through of their facilities. Support is also committed in providing data to the community’s hired
assessment vendor to support the municipalities more detailed audit.
The Program Administrators will continue their successful and highly productive working relationship
194
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 200 of 274
with the DOER Green Communities Division by sharing municipal efficiency data on a quarterly basis and
meeting with DOER staff to discuss municipal specific issues on an established quarterly meeting
schedule. In addition to working closely with the Green Communities Division, the PAs will expand their
direct, targeted outreach to municipalities to ensure that each city and town is aware of all energy services
and customized assistance available to them to facilitate and expedite their participation. The PAs are
committed to make every effort to simplify transaction and administrative burdens for this key customer
segment. To aid in this effort, the Program Administrators have agreed to a common direct install
municipal initiative starting in Q1 2013, which will identify both immediately actionable measures and
those requiring further study, as part of a uniform municipal statewide offering. 28 All PAs will offer
financing to municipalities. Utilities will advise and assist municipalities in working with Section 44 of
the GCA to navigate the exemption authority they have to expedite procurement of efficiency services.
The sections below on Wastewater and Water Treatment Segment and Street Lighting contain additional
information on these initiatives.
Wastewater and Water Treatment Segment: The PAs will build on the success of our on-going
partnership with the DEP to achieve implementation of additional efficiency measures among the 120
municipal / district wastewater treatment plants and 250 municipal / district drinking water treatment
plants. The PAs previously provided comprehensive energy assessments at many of these facilities in this
partnership under the Energy Action Program and the Energy Leaders Program. A major success of this
partnership included a PA efficiency study completed under the Energy Action Program being used as the
major documentation to leverage the award of a multi-million dollar ARRA grant resulting in the Pittsfield
waste water treatment plant now self-producing 80% of its annual electric energy. This was achieved
through the installation of aggressive efficiency upgrades to their aeration system, CHP utilizing waste
methane gas, and a large photovoltaic system, all of which were analyzed in the PA study.
The PAs and DEP have targeted efficiency opportunities in wastewater aeration and pumping, as well as,
drinking water pumping as area of enhanced focus efficiency. The PAs will work with DEP and DOER to
conduct equipment screening of facilities aeration and pumping system assets in order to identify potential
energy-saving opportunities in high electric use areas. Once screened, facilities with opportunities will
receive incentive offers under the current Mass Save Efficiency program. DEP very recently informed the
PAs that they were trying to develop a Sustainable Financial Assistance Model for this specific market
28
Cape Light Compact incentive levels will continue to differ.
195
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 201 of 274
segment that would include Mass Save efficiency incentives. The agreed upon timeline includes an
interagency/PA workgroup being held in the last quarter of 2012, and development of recommendations
by the second quarter of 2013. It is also recognized that early engagement of municipal/district key
decision makers is a key to achieving implementation and leveraging the existing permitting process to
include efficiency.
Multifamily Commercial: It is not uncommon for large multifamily properties to be classified as
commercial customers. Even if individual condo or apartment rental units have residential electric or gas
accounts, common areas, and in some cases, the entire building, may be on a commercial rate class even if
the individual units are residential in nature. To classify these mixed use sites as either Residential or
Commercial can lead to numerous lost opportunities and an under-served customer base. In order to
alleviate these concerns, the PAs created the Multifamily Working Group in 2010 (Note: See additional
description in the Residential Program section) and launched the concept of using a Multifamily Market
Integrator (“MMI”). The MMI is the vendor, selected through a competitive procurement process that
takes leads for multi-family sites and determines how to best serve the customer given the various program
options.
While this process has been working increasingly well since its launch in 2010, a recent evaluation
conducted by The Cadmus Group indicated that some commercial-type opportunities remained
unaddressed. In order to address this in the 2013-2015 Plan, the commercial program managers are
increasing their commitment to working jointly with residential program managers, and are increasing
their active representation on the Multi-Family Working Group. The Multi-Family Working Group is
redoubling its efforts to review protocols and procedures, particularly for lead processing, to ensure that
every cost-effective opportunity for energy savings is addressed. The C&I Management Committee places
a priority on continuing cross-sector efforts to ensure that this important customer sector is effectively
served.
Compressed Air: Significant energy savings can be achieved from optimizing compressed air systems in
industrial facilities (over 100 HP). The focus is on the efficiency of the compressor system elements and
recovery of waste heat generated by these systems.
Industrial: Small and large industrial customers will be targeted with a combined gas and electric delivery
model. Industrial energy savings opportunities will be viewed comprehensively and all the potential cost
196
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 202 of 274
and savings streams will be quantified. To support deeper savings with industrial processes, the PAs will
seek out specific TA vendors with expertise in certain target industrial processes and customer segments
commonly found within PA service territories. The approach will incorporate measures like heat recovery
and process improvements, as well as the DOE Steam Assessment and Savings program. Non-gas/electric
energy benefits or additional costs related to improvements will be quantified to the extent possible.
Examples of additional benefits will include but will not be limited to: raw material, scrap and increased
through-put. The PAs will target industrial opportunities aggressively and will endeavor to more routinely
quantify the non-energy benefits of efficiency measures and educate customers about them. This effort
will also take into account best practices experience from other PAs across the country.
Retro-Commissioning: Deferred maintenance, piecemeal upgrades, “sensor drift” and other factors affect,
and degrade, building operation over time. Retro-commissioning allows a thorough evaluation of all
building systems to ensure they are operating as designed. Remedial actions resulting from these studies
are usually low cost or no cost and have an immediate impact on the energy use and quality of the
building’s operation. Typically, these studies require a significant time investment by a higher level
engineer and are may not be not cost-effective. In order to look for ways to reduce such study costs, PAs
will examine best practice approaches of other utilities in the US and consider adoption of more costeffective approaches in Massachusetts in the first quarter of 2014.
Lighting Retrofit Redesign: Most spaces have lighting that was installed without benefit of a customized
lighting design matched to the work requirements in the space or with limited or no consideration for
comprehensive energy performance. By combining better fixtures, lamps and controls, and altering layout
where cost-effective, there is often significant opportunity for both greater energy savings and an
improved visual and working environment. Although lighting redesign provides a significant opportunity
for deeper savings in many facilities, the costs to achieve them are several orders of magnitude greater
than the standard equipment replacement retrofit alternative. The PAs will research and experiment with
new delivery models that match lighting design expertise with lighting retrofit opportunities in an attempt
to identify lower cost delivery models that would allow this opportunity to be scaled. This will be offered
on a limited basis to begin in Q4 2013, and projects will be evaluated through the custom path to
determine the potential for a broader customer application and cost effectiveness in 2014.
CHP: The Program Administrators have had substantial success with the Combined Heat and Power
(“CHP”) Program during implementation of the first Three-Year Plan making Massachusetts’ CHP
197
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 203 of 274
Program the most successful in the country to date. The PAs attribute that success to our screening process
that has allowed customers to make informed decisions regarding CHP and energy efficiency investments
and the CHP Guidebook that delineates the process for achieving a successful CHP project and qualifying
for an energy efficiency incentive.
Individual CHP projects can produce dramatic savings at a single site and have the potential to
significantly impact overall PA savings results with a low cost per kWh. As such, good CHP installations
are highly desired. At the same time, CHP systems typically have BCRs between 1.0 and 1.5, which
means that deliberate care needs to be taken in identifying appropriate opportunities and in proper
engineering of installations, which makes them hard to plan for with any accuracy. A number of key
lessons have emerged from the PAs’ experience to date to guide CHP program efforts during
implementation of this 2nd Three Year Plan. These include:
1. Focusing on CHP candidates that have a thermal load requirement that is year-round and in excess
of 5,000 hours per year is necessary to ensure cost-effective systems. Such candidates include
facilities with significant daily laundry requirements like hospitals, nursing homes and some hotels,
as well as others with thermal process requirements like food processors and other manufacturers.
2. Understanding that CHP projects require significant investment by the customer in time,
engineering planning, and capital costs, and as such, often require greater sustained customer
commitment and involvement than other EE projects and programs. PA account executives play a
key role in enabling CHP projects to be successful, with involvement through several stages of the
customer’s CHP process: a) in the initial identification of CHP opportunities; b) in the active
advocacy for appropriate CHP projects with the customer; and c) in the overall shepherding of
customers through the process to successful conclusion. 29 PA involvement has been designed to
assist the customer throughout the process (see below).
3. Proper sizing of CHP systems is essential to their being cost-effective, so that virtually all thermal
output is used by the facility. Key to correct sizing is making sure any significant opportunities to
reduce load through energy efficiency are pursued prior to final sizing of the CHP system.
Otherwise, the customer can be left with an oversized system producing excess heat, which will not
29
At least one PA provides account management staff with significant incentive to identify and complete CHP installations in their assigned territory.
198
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 204 of 274
be cost-effective. The PAs, therefore, will continue to educate customers that the first step to take
prior to conducting a CHP engineering study, is to implement electric and thermal energy
efficiency measures as their first priority. “Energy Efficiency First or Simultaneously” continues to
be our professional recommendation because efficiency is by far the more cost-effective savings
opportunity and has the potential to reduce the required size of the CHP system.
Based on this experience, the CHP Program process has evolved to ensure more successful identification
and completion of CHP installations. The PAs survey customers for CHP potential and offer significant
technical assistance where appropriate. This begins with an initial scoping assessment of electric and
thermal loads, and where this initial scoping indicates that a reasonable potential exists, an offer is made to
co-fund an in depth engineering analysis. PAs provide continuous active assistance with the objective of
providing customers an unbiased partner in evaluating their CHP potential. This includes clearly
communicating about CHP incentive eligibility requirements very early in the process, identifying
qualified consulting engineers for the customer to select for the analysis, reviewing the analysis for
accuracy, and providing a professional opinion of the feasibility of the CHP opportunity indicated by the
analysis.
In addition, in Q2 of 2013, the CHP Working Group will fully vet and refine the results of the KEMA
CHP Market Characterization study, which identified an initial list of potential CHP prospects. A small
number of customers were deemed to be appropriate leads and are being aggressively pursued. The PAs
have added to the list based on marketing the program to other potential CHP candidates.
Street Lighting: A key component of the PA role for street lighting is to provide stakeholders with
knowledge and guidance on the appropriate replacement of older street lighting technologies with more
efficient street lighting technology. The Program Administrators will continue to promote efficient street
lighting technologies to private and municipal entities. Program Administrators will expand and
accelerate the current collaboration with all stakeholders to address barriers, such as regulatory tariffs,
which impede implementation of efficient LED and induction street lighting technology.
The streetlight market is divided into customer-owned and utility-owned sub-markets. For customerowned street lights, the current program offers technical assistance to address equipment selection and site
considerations and both custom and prescriptive incentive options. The first cost of LED technology was
a barrier to achieving cost-effective product eligibility in the initial period of the first Three Year Plan,
199
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 205 of 274
however, the price of LED street light technology has fallen dramatically in 2012, making broader
application of this technology more feasible. In response, several PAs have embarked on major retrofit
initiatives for municipalities in their territories and others are evaluating similar efforts.
The utility-owned street lighting market has the additional challenge of addressing regulated street lighting
rate tariffs. A PA Street Lighting Efficiency Working Group will be convened in Q4 2012 with PAspecific follow up with relevant areas of each organization taking place to collaboratively address
regulatory and technical issues. Upon a successful resolution of the tariff issues involving utility owned
streetlights, the PAs plan to have a formalized program rolled out across the state within six months. The
PAs plan to provide a status update to the Council in Q4 2012.
Expanded Service Offerings: The Program Administrators place a high priority on bringing offerings to
customers that are timely, uncomplicated, cost-effective, consistent, and tailored to their needs and
investment criteria. The Program Administrators currently provide dedicated customer account
management for their largest customers and Direct Install (“DI”) services for small businesses where the
opportunities are cost effective. The intent of the expanded service offerings initiative is to improve the
customer experience and broaden service offerings by exploring new delivery pathways for both small and
medium sized customers, as well as for larger customers who choose a more limited engagement in energy
efficiency. The hope is that this will lead to greater and deeper program participation, while managing
costs. The new delivery pathways may include:
•
A web based portal to provide one-stop-shopping for customer efficiency opportunities including
information on energy efficiency measures targeted to specific segments. A requirements document
will be developed by the fourth quarter of 2012, with initial implementation targeted for the end of Q2
2013.
•
Self-assessment through the internet portal to provide a more interactive experience where a customer
can be guided to independently assess their individual operations, benchmark themselves against
similar businesses, and learn about energy efficiency opportunities available to them without requiring
an on-site visit. A requirements document is planned for Q2 2013 with rollout anticipated for early
2014.
•
Personal assistance via web-based (chat) or telephone support services that would screen potential
customers/facilities to identify services that best address their specific needs. This screening may lead
200
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 206 of 274
to a referral back to the self-service portal, or lead to more interaction in advance of scheduling
additional individualized services. This additional level of service will benefit from earlier experiential
learning from the customer portal. Writing of a requirements document is targeted to commence by
the Q3 2014 with an anticipated roll out in 2015.
•
Fee-Based On-site assessment will be developed to evaluate energy efficiency opportunities when
savings potential appears limited and/or customer commitment to implementation is uncertain. The
fee structure will be designed to ensure that it is not a barrier to participation, but engages the customer
to encourage implementation. This on-site assessment may lead to a DI vendor visit or the provision
of other services available through the C&I Retrofit Program. Development of the fee structure will
commence in the fourth quarter of 2012 with roll out anticipated for the first quarter of 2013.
Community-Based Implementation: For the smallest customers, challenges exist for both the customer
and the Program Administrators given limited incremental savings opportunities relative to the cost of
acquisition. For the customer, there is often insufficient economic motivation to take part in available
energy efficiency services. For the Program Administrators, the implementation costs are relatively large
compared to the potential savings. Although the intent is to serve a broad base of customers through the
self-service portal, there are opportunities to scale efforts through a version of the tested Main Streets or
community-based campaign model. This model targets geographical areas with high densities of small
customers in order to achieve economies of scale in implementation cost. Typically such models include
roll-out for a predetermined campaign period, during which customers in the defined area are offered a
limited suite of services at little or no charge. These measures might include lamp and ballast retrofit,
spray valves, exit sign retrofits and other energy efficiency measures that lend themselves to simple, rapid
bulk delivery in a small to medium retail corridor. Larger opportunities are identified and referred to the
traditional DI initiative for follow-up. Customers not able to participate during the promotion are also
referred back to the traditional program offerings for later participation.
Several field tests have been conducted using this model with variations in delivery and demographic
location. To date, third-party promotion and delivery field tests have produced dramatically lower
participation and customer satisfaction rates than PA-based delivery models. Given these results, the PAs
intend to pursue the PA-driven model for the next phase of community-based campaigns. It should also be
noted that although streamlined delivery in these field tests did reduce the impacts of a higher incentive,
costs were approximately 15% higher than the traditional Direct Install program. Fully scaled,
201
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 207 of 274
expectations are that this effort could have about a 5% increase in savings for the customer class serviced
under DI.
By Q1 of 2013, a list of suitable geographical areas will be identified for each PA service territory for
community-based campaign delivery. Sequencing will be determined based on several factors including
soft roll-out, ramp up and integration into overall marketing/promotional activities. Milestones and
success indicators will also be established and included in the plan. In Q2 of 2013, a Request For Proposal
for services will be created and released. Rollout is targeted for Q4 of 2013 and continuing through 2015.
Although this effort has been field tested, measurements of customer satisfaction, customer acquisition
rates, costs and other program impacts will be reviewed at various milestones and appropriate corrections
will be implemented.
Market Segmentation: In order to achieve greater participation and savings, the Program Administrators
will increasingly use market segmentation to inform go-to-market strategies. Customers will be divided
into meaningful segments according to a variety of characteristics including usage and demand and
industry classification. Based on the specific characteristics of defined segments, marketing approaches,
delivery systems, value propositions and offerings can be customized to better meet the needs and interests
of individual companies in those segments.
The healthcare sector is a specific market segment in which the PAs have already initiated an analysis of
efficiency opportunities. The Massachusetts Technical Advisory Committee (“MTAC”) has engaged the
Fraunhofer Center for Sustainable Energy Systems to identify efficiency opportunities in the healthcare
industry with a specific focus on large medical equipment. A contract has been signed between MTAC
and Fraunhofer for analysis to be completed in the first quarter of 2013. After completion of this analysis,
sharing with key stakeholders, and appropriate implementation action, MTAC will determine the next area
of healthcare efficiency to be analyzed with a focus on opportunities common to small and large healthcare
facilities.
Segmentation by size, as measured by energy usage and/or demand, plays a dominant role in determining
the appropriate delivery model, with the largest customers supported by dedicated account executives
while smaller customers are supported by a network of direct install vendors. An increasingly important
tool available to account executives managing the largest C&I customers is the Memorandum of
Understanding (“MOU”)/Strategic Energy Management Plan (“SEMP”). An MOU offers a way to
202
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 208 of 274
document a commitment between the customer and PA to work together to achieve mutually stated goals
through specific actions that are tailored to the customer’s facilities over a multi-year planning horizon.
As such, an MOU can set the stage for achieving deeper and more comprehensive energy efficiency
savings, and is more likely to succeed than a “one measure” or “one year” approach. Typically, MOUs
include participation by upper management, the establishment of specific, very aggressive energy
efficiency saving targets, and measurement and verification strategies to document savings throughout the
target facilities.
Segmentation by industry classification, which enables greater insight into the mix of end uses, energy
intensity and decision making criteria is invaluable for developing value propositions and offerings and
creating marketing materials and messaging. For example, hospital facilities have much different
operating characteristics and business drivers than grocery stores. Urban hospitals tend to be large,
campus-like operations with large energy loads and a wide range of end uses. They have a relatively high
level of in-house energy and engineering expertise, and longer-term planning horizons. By comparison,
grocery facilities are considerably smaller, operate in a single building, and their energy usage is
dominated by refrigeration and lighting They have little or no on-site energy and engineering expertise,
and they operate in an industry with very small margins and thus have much shorter planning horizons and
tighter requirements for making financial investments in energy efficiency. As a result, approaching
hospitals and grocery stores in the same way, with the same energy efficiency message and project offer is
not likely to lead to equally successful results.
As mentioned previously, the results of the Point 380 analysis have been and will continue to be used to
inform PAs “go-to-market” strategies by identifying industries, building types and end uses representing
significant efficiency opportunities and thus warranting relatively greater attention. Additionally, some
PAs are exploring strategic outreach to specific segments of their customer base in collaboration with
industry partners who have demonstrated success in the identification of comprehensive energy efficiency
opportunities leading to greater depth and comprehensiveness of savings in specific segments. By way of
example, some PAs are currently developing go-to-market approaches that combine elements of
prescriptive, custom and upstream offerings for the grocery segment. The PAs plan to have these
approaches in the market before year-end 2013.
Lessons learned from these and related efforts will continue to be shared with view toward identifying best
practices that can be adopted by the broader PA team.
203
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 209 of 274
Property Management/Real Estate Segmentation: The PAs have identified several barriers that have
limited full participation in energy efficiency opportunities in the property management/real estate
segment. These barriers include but are not limited to:
•
Identifying individual tenants (and associated decision makers) in buildings with multiple tenants
•
Cost effectively engaging multiple, sometimes small, tenants leasing space in a single building
•
Identifying decision makers in buildings with one property management entity and a different
ownership entity
•
Split incentives between the customer paying the bill and the entity actually using the energy
•
Identifying single building LLCs that may be part of larger ownership entity
The PAs are exploring tactics to overcome these barriers, working within the C&I Management
Committee in development of a project plan to be presented to the Council in Q2 of 2013.
Gas and Electric Integration: The Program Administrators have made a tremendous amount of progress
in their efforts to integrate electric and gas energy efficiency services with a view toward enhancing the
customer participation experience, focusing on increased comprehensiveness (i.e., going deeper), and also
reaching more customers (broader). Efforts to date have included program design modifications, a clear
focus on integration in both the Commercial and Industrial Management Committee and working groups,
the development of express tools and custom screening tools that facilitate joint consideration of both
electric and gas opportunities, annual training for PA staff and the vendors that support efforts, and
stakeholder engagement that has included, but was not limited to, vendor open houses, energy expos, and
the Appreciative Inquiry Summit that took place in May 2012. These efforts have fostered a strong and
dynamic culture where a focus on integrated facility-wide energy efficiency opportunities has replaced the
electric or gas measure driven approach that was previously more prevalent in the field. The PAs are now
addressing their customer’s total energy needs. This includes gas, electric, oil, propane and other non
energy impacts such as water and sewer savings.
The PAs are committed to further integration of their gas and electric energy efficiency services for
commercial and industrial customers. In support of these efforts, the PAs are continuing to focus on
204
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 210 of 274
training for both PA staff and for the trade allies that support efforts. Ongoing training will focus on
knowledge regarding both electric and gas energy efficiency technologies and practices, skills to identify
appropriate sites where an energy efficiency investment is appropriate, and training on the process for
coordinating across PA organizations. The PAs anticipate that this focus on training will further enhance
their seamless delivery of services and will promote deeper and broader acquisition of energy savings.
Gas Savings: Given historically low natural gas prices (currently 30 percent below 2011 levels and 80
percent below 2008 levels), customer motivation to reduce natural gas usage has diminished significantly.
As a result, the PAs are focusing on identifying new strategies that will support the achievement of savings
goals proposed in this Plan by overcoming this barrier to participation. In July of 2012, the Gas
Subcommittee of the C&I Management Committee convened a strategy session to explore new and
improved approaches to increasing gas savings both in the near-term and over the course of the next three
years. In addition to these ongoing efforts to improve and streamline cross-PA collaboration in
overlapping service territories, the PAs are planning the addition of gas technologies to the upstream
delivery model in late 2012/early 2013. With the possible inclusion of additional gas measures in the DI
program, and the proposal to restrict access to technical assistance funding unless gas technologies are
considered, the Gas Subcommittee intends to develop additional recommendations for PA-wide
consideration and implementation, including such strategies as the introduction of enhanced incentives for
customers to make gas energy efficiency investments a more attractive investment.
The PAs C&I programs will continue to support and assist their customers who operate steam boilers for
both space heating and for process steam. The PAs promote custom solutions for boiler replacement or
burner upgrade when they are shown to be cost effective. Comprehensive steam trap surveys are also
encouraged with the cost of surveys co-funded when appropriate. Depending on the number of traps,
steam system operating pressure, or the customers need for a rapid repair, the customer can follow either
the custom incentive option or the prescriptive rebate option. Boiler controls, boiler room upgrades and
heating pipe insulation are also part of this measure offering.
Program Consistency and Best Practice Sharing: The Program Administrators recognize statewide
consistency to be an important priority. Likewise, it is important that innovation be encouraged by
individual PAs so that costs and results can be evaluated in a limited, low-risk environment, with the
results then shared and scaled up statewide as appropriate and practicable. The C&I Management
Committee serves as the central forum for sharing of individual innovation proposals and results and for
205
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 211 of 274
determining how to best propagate successful approaches consistently statewide. The C&I Management
Committee regularly reviews its processes and operations in order to continuously optimize the balance
between innovation and consistency and will continue these efforts over 2013-2015.
Five Largest Gas and Electric Customers Accelerated Rebate Pilot: Sections 5 and 54 of An Act
Relative to Competitively Priced Electricity in the Commonwealth, St. 2012, c.209, approved August 3,
2012, requires the PAs to implement a pilot program for their five largest gas and electric customers based
upon specific customer locations in their respective service territories known as the voluntary accelerated
rebate pilot program. Customers electing to participate shall be eligible for financial support of up to 100
per cent of the cost for qualified energy efficiency measures, as determined by the Program Administrator,
using criteria included in the Three Year Plan. In addition, up to 15% of any accelerated rebate may be
used for other improvements that support energy efficiency improvements made under a program
approved by the department or emission reductions, including, but not limited to, infrastructure
improvements, metering, circuit level technology and software. Total rebate levels for participating
customers in any year of the pilot program shall not exceed 90 per cent of the amount the customer was
charged for energy efficiency programs during calendar year 2012. The Program Administrator will retain
at least 10 per cent of the customer’s energy efficiency funding contributions for administration costs. The
five largest customers of a PA for these purposes will be determined based on their 2011 usage.
A customer that elects to participate in the voluntary accelerated rebate pilot program in 2013 may
aggregate rebates in amounts not to exceed 270 per cent of the amount charged to that customer for energy
efficiency programs in calendar year 2012. A customer that elects to participate after January 31, 2013 but
before January 31, 2014 may aggregate rebates in amounts not to exceed 180 per cent of the amount
charged to that customer for energy efficiency programs for calendar year 2012. Participants in this pilot
will not be eligible to receive incentives through any other energy efficiency program beginning in the
years they participate in the pilot through 2015.
Each PA will determine the amount of funding available to each eligible customer and will determine the
effect the pilot will have on the funding for other customers. The PAs have budgeted accordingly prior to
for this Plan. Since participating customers may receive 100% of the cost of approved projects, the cost of
savings in each PA’s portfolio of programs will rise compared to what it would be without the pilot. This
effect is likely to be more pronounce for smaller PAs than for larger PAs.
206
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 212 of 274
Projects funded through this pilot, including funding for “other improvements” described above, will be
screened for cost-effectiveness using the TRC Test as required by the Department of Public Utilities.
Approved projects will be required to have a projected benefit cost ratio of at least 1.0.
The application process for pilot participants will be the same as for all other retrofit program participants.
Customers will not be required to make a copayment but may choose to if their project is more costly than
their available funding in the pilot. Customers seeking a technical assistance study will need to fund those
assessments themselves without efficiency funds.
The PAs must reserve the right to revisit overall savings goals and costs in the event of participation in the
Rebate Pilot by large customers. Specifically, and as provided in the Term Sheets, pursuant to An Act
Relating to Competitively Priced Electricity in the Commonwealth (2012), the PAs will be offering a new
Accelerated Rebate Pilot Program for the first time. In the event of impact from this pilot program or a
new municipal aggregator program, the applicable PA shall have the opportunity to make appropriate
adjustments to its costs and savings goals based upon the nature of its customers’ participation, subject to
the Council review under G.L. c. 25, Sec. 21(c) and the approval of the Department.
Marketing Overview
Target Market:
The target market is all non-residential customers - commercial, industrial, governmental, and
institutional. Multi-Family (residential) customers will be channeled through the separate residential
Retrofit program described separately in this filing.
Strategy:
While a variety of marketing approaches will be employed, the consistent experience of the Massachusetts
PAs, and their counterparts nationwide, is that the most successful avenue to reach non-residential
customers is through one-on-one communication through account executives (in partnership with trade
allies), who can both identify gas and electric opportunities and gauge customer interest in pursuing these
opportunities, based on the individual PAs knowledge of their customers’ business requirements and
investment criteria and horizon. The PA account managers leverage their intimate, long-term relationships
with customers and their knowledge and analysis of customer data (energy use, demand, sector analysis,
207
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 213 of 274
etc.). Trade allies such as equipment vendors, consulting engineers and energy service companies, or
“channel partners” are additional key actors in promoting, identifying, and delivering services to
customers. Account managers conduct dual sales calls, open houses, training, and new product and
service demos with trade allies. All Mass Save programs are “open”, allowing significant flexibility to
vendors and customers in determining the optimal implementation strategy and partners for their particular
project. The Program Administrator experience with non-residential customers has established that this
kind of one-on-one “relationship marketing” is most successful in moving businesses and
institutional/government customers to action.
In addition to channel partners, Program Administrators will also leverage closer alliances with turnkey
installation contractors. These are firms that have been chosen through a formal bid solicitation and act as
agents to the Program Administrators in performing specific program functions. Program Administrators
use these firms to strategically market to specific customers, sectors and/or technologies. While channel
partners provide marketing and maintain customer flexibility, turnkey installation contractors allow for
targeted, coordinated sales along with pre-approved turn-key solutions to customers.
In 2013 the Program Administrators plan to expand the statewide website and statewide media marketing.
Additional marketing approaches may be used by one or more Program Administrators to increase
participation and capture deeper, broader savings with their customers. These could include: direct mail,
seminars and training sessions, breakfast meetings, webinars, participation in trade shows and conferences,
co-marketing through trade industry, public interest and civic groups that represent the target market and
have extensive outreach capabilities, “earned media” articles in professional and trade publications, and
informational meetings with energy service companies (“ESCO”) and other contractors and potential trade
allies.
In addition, Program Administrators expect to supplement these strategies with broad-based radio, print
and email outreach. Email alerts and other low-cost means to reach customers will also be used to
advance customer participation. Program Administrators are currently using on-line communications to
bring new and emerging technologies to the attention of their customers. Other social marketing
techniques will be used to increase customer awareness of program services and the means to access these
services. All these strategies will be integrated into a common marketing plan that will identify key
drivers, objectives, strategies, and tactics to increase customer participation.
208
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 214 of 274
Technologies/Incentives The following is a list of targeted end uses, recommended technologies, and incentives offered:
Targeted End
Use
Lighting &
Lighting Controls
Efficient lamp
technologies
Lighting &
Lighting Controls
Efficient Lighting
Fixtures
Lighting &
Lighting Controls
Lighting Controls
Motors & Drives
Efficient Motor Drive
Systems
Efficient HVAC systems
HVAC
Equipment
Energy
Management
Systems
Compressed Air
& Unique
Industrial
Processes
Furnaces &
Boilers
Steam
Opportunities
CHP
Technology
Energy Management
Systems
Compressed Air systems
Advanced Gas
Technologies
Steam Traps, Boiler
Control Upgrades,
Burners, Boiler Room
Optimization
CHP
209
Incentive
Financial incentives cover a portion of the total installed
project costs, typically by providing up to 50% of labor
and equipment costs, or by incentivizing the installed
costs down to the equivalent of a fixed payback period.
Financial incentives may also include co-funded
engineering and commissioning studies and/or design
incentives covering a portion of incremental
architectural and design costs for efficiency
improvements. Each PA retains the ability to adjust
incentives to address unique barriers encountered when
working with customers.
Smaller non-residential customers (up to 300 kW) will
continue to be served through the DI initiative where
turnkey services are available for the identification and
installation of cost-effective measures, primarily
lighting, refrigeration, spray valves, faucet aerators,
thermostats, shower heads and some pipe insulation.
Incentives for DI participant tend to be higher than for
other Retrofit participants, typically 70% of installed
cost on average.
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 215 of 274
Site Specific
Energy Recovery
Custom Measures Ventilation Units
(ERVs)
Site Specific
Dehumidification and
Custom Measures Humidification
Additionally:
Additional custom measures are supported after evaluation through MTAC and internal PA engineering
analysis. The Program Administrators anticipate that some incentives will be adjusted higher to support
emerging or underutilized technologies in order to accelerate market acceptance and sales volume. Over
time, this strategy is intended to bring down the cost of these measures, and thus the incentive
requirements. Incentives for more accepted efficient electric and gas end use technologies may also be
increased when they are used in combination with other measures to promote broader and deeper savings.
This is the so-called “Multi-Measure Incentive.”
Delivery Mechanism
Program Administrator staff, trade allies and project administrators perform most sales, marketing,
program administration, and implementation functions. In some cases, internal staff is supplemented by
external trade allies. In addition, outside contractors are retained for technical review of applications, onsite energy analysis, technical and design assistance for comprehensive projects, project commissioning
services, and the actual installation of measures and, where appropriate, turn-key services.
Special Notes
210
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 216 of 274
SECTOR
PROGRAM
COMMERCIAL &
INDUSTRIAL
NEW CONSTRUCTION
Program Overview
ADMINISTERED BY
в—Џ
JOINT
ELECTRIC & GAS PAs
PA - SPECIFIC
The C&I New Construction program is designed to optimize the efficiency of new equipment, building
design and systems in new construction and major renovation of commercial, industrial, institutional and
government facilities. Other energy efficiency opportunities are also addressed through this program,
including the initial purchase of equipment and equipment replacement upon failure. This program focuses
on offering a comprehensive set of electric and gas efficiency options that are specific to the needs of each
unique facility. The program also addresses the limited window of opportunity available to install premium
grade replacements when equipment fails or is near the end of its useful life. The Program Administrators
partner with advocates, building scientists, and regulators to ensure that the best practices in building design
and equipment specifications are introduced and used, resulting in the beneficial evolution of building
requirements.
New Enhancements:
Expanding Upstream Initiatives: The upstream model leverages existing distributor networks and
infrastructure to influence thousands of customers and contractors, cost-effectively accelerating the
introduction and sale of more efficient equipment, helping to transform markets. This streamlined approach
accelerates the adoption of more efficient technologies by removing or reducing the initial cost hurdle at the
point of sale without the need for the end user to submit paperwork or rebate forms. It complements the
traditional downstream approach in which Program Administrators work directly with customers and
installers but, importantly, is able to reach a broader pool of savings opportunities at a much lower cost than
would be possible through the traditional downstream approach.
Additionally, influencing the replacement-on-failure market through traditional marketing approaches can be
very costly. Using an upstream approach in which marketing is focused primarily on distributors can be a
much less costly alternative in cases where deemed savings can be applied to discrete equipment purchases.
In addition, it virtually eliminates the need for educating downstream market actors.
211
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 217 of 274
The Program Administrators began the new upstream approach in November 2011, focused specifically on
LED screw-in and both compact and linear fluorescent lamps. Using this model, the PAs have partnered
with electrical distributors and lighting manufacturers to offer LED and reduced wattage linear fluorescent
lamps to Massachusetts non-residential facilities. The goal is to transform the market from less efficient
standard lighting technology to more efficient technologies such as reduced wattage linear fluorescent and
LEDs.
The Program Administrators plan to expand this model with other technologies within the replacement-onfailure market. Current plans call for an assessment of appropriate gas technologies to offer through an
upstream approach that will be undertaken during the summer of 2012. Additionally, the selection of a
partner to provide support in gas upstream efforts will take place in the fall of 2012, with program rollout in
Q1 2013.
Property Management/Real Estate Segmentation: The Program Administrators are developing a
comprehensive “go-to-market” strategy for the commercial office market with the goal of achieving higher
savings in this segment.
Program Design
In 2013-2015, the Program Administrators will continue to expand and improve upon current suite of
212
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 218 of 274
services offered within the New Construction Program:
Technical Assistance (“TA”) Services: The provision of timely, high-quality, independent technical
advisory services to design teams is central to the achievement of comprehensive savings in new
construction. The TA Services component of the program provides technical support matched to the specific
requirements of each project and the needs of each design team. Services may include detailed energy
modeling of the performance of the proposed building using various configurations of design and
equipment, targeted studies and recommendations for specific building components or systems, or
specialized technical studies, such as proposed industrial process improvements and compressed air projects.
In general, study proposals will be assigned to, and performed by TA consultants who have been selected as
preferred vendors through a competitive procurement process by the Program Administrators. TA
consultants will be assigned by the PA based on an assessment of their expertise with the technology under
consideration. Customers can also elect to use a TA provider of their own choosing, as long as the cofunding Program Administrator approves the firm’s qualifications and cost-estimate. Non-preferred vendors
must comply with the same level of detail and quality as preferred vendors.
In many instances, customers may have both gas and electric equipment options for a particular end-use. In
order to (a) encourage more comprehensive, integrated, and balanced consideration of all the energy
efficiency options available, and (b) ensure that customers have open choices, the gas and electric Program
Administrators delivering the statewide program will provide coordinated TA studies. In general, the study
costs will be cost-shared between the gas and electric Program Administrators according to the proportionate
share of the analysis and/or opportunities found through the analysis regarding each form of energy.
Advanced Buildings Core Performance is a comprehensive, prescriptive program for small commercial
new construction built around delivering the New Building Institute’s national Advanced Buildings
Program.
The Advanced Buildings Core Performance Guide applies proven and available energy efficient technology
and building science to the design of commercial and institutional buildings in the 10,000–100,000 square
foot range. The Core Performance criteria address better performance characteristics in the building
envelope, dedicated mechanical heating, cooling and lighting systems, multiple demand control ventilation
practices, indoor air quality improvements, and domestic hot water system efficiency. These criteria are
213
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 219 of 274
based on the results of 30,000 energy modeling evaluations of three major building prototypes (retail, office,
and school), with four high-efficiency thermal and HVAC system permutations for each prototype. That
analysis identified a package of consistent strategies (the “core” in Core Performance) leading to predictable
energy savings across all climate zones. In Massachusetts, application of all Core Performance criteria will
result in buildings with energy savings that exceed the Massachusetts Energy Code by 20-30 percent. In
addition, peak energy reduction techniques will be employed to allow participants with either third-party
energy supplier time sensitive rate offerings or those enrolled in the ISO-NE Price Response Program
additional savings opportunities. Core Performance is accepted by the US Green Buildings Council as an
alternative pathway to achieve the energy and environment points required to qualify a smaller building for
Leadership in Energy and Environmental Design (“LEED”) certification.
Program Administrators may provide: technical assistance consultants to assist customer design teams to
incorporate all the Core Performance features in their buildings, incentives (presented to the customer in
easy-to-comprehend $ per square foot (sift) terms), independent third party verification of Core Performance
compliance, and recognition via certification of the building as an “Advanced Building” as well as ancillary
publicity as jointly agreed to by the Program Administrator and the client.
The Core Performance model is best applied in small office, retail, public assembly, and school/preschool
applications. (The benefits diminish in lodging, large multi-family and assisted living circumstances.) The
economics are based on buildings with central mechanical cooling systems. Building owners and their
design teams must agree to comply with all of the essential requirements of the program (the “core”) in order
to participate, and they may select other features (“Enhanced Performance Strategies”) to exceed the base
savings potential.
In the second half of 2012 the cost-effectiveness of the New Buildings Institute program brand will be
reviewed and compared to alternatives. By the end of 2012 a recommendation for best practice will be
presented to the C&IMC for implementation in 2013.
Performance Lighting: The Program Administrators promote high performance lighting technologies and
design practices that are either more efficient than standard practice and/or the requirements of the
Massachusetts Building Code through incentives for better lighting design. The Performance Lighting
option promotes the thoughtful combinations of energy efficient lighting fixtures and lighting controls in
214
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 220 of 274
site-specific lighting designs that produce quality lighting using lower watts per square foot than the current
commercial Massachusetts building code.
Gas Technology and Application: The Program Administrators will continue to jointly deliver state-wide
initiatives that target high efficiency heating, water heating, and kitchen equipment and control systems.
Program Administrators will continue to identify and evaluate high efficiency gas technologies, as well as
energy saving electric technologies, as joint offerings to customers.
Property Management/Real Estate Segmentation: The Program Administrators are developing a
comprehensive “go-to-market” strategy for the commercial office market with the goal of achieving higher
savings in this segment. This effort includes working with leading real estate consulting firms to understand
building stock, key industry actors, and market characteristics, in order to better sub-segment the market and
identify strategies to target these sub-segments with offerings that address specific needs. These efforts are
being targeted comprehensively through an MOU strategy. In order to achieve persistence, multi-year
corporate engagement is critical. NSTAR and National Grid have been working with several large
commercial property owners/operators and are currently testing some of these concepts. By second quarter
of 2013, progress will be reviewed and actions adjusted in response to lessons learned.
In parallel, National Grid and NSTAR are also progressing on the Office of the Future effort. National
collaboration has provided several initial technical projects focused on system integration techniques to
provide deeper savings. Although cost effective, these projects were several orders of magnitude more
costly than traditional approaches. Opportunities to fine tune the balance between budgets and savings exist.
NSTAR and National Grid are in talks with several commercial property owners to implement up to 12
projects which will guide efforts forward. An external project manager and consultant team has been
retained. With buy-in from property owners, implementation will be targeted for 2013 and results available
for review and presentation to the council in 2014.
Codes and Standards: The PAs plan to pursue a codes and standards initiative in the C&I New
Construction Program. Activities under this initiative will be tracked by the PAs so there is better
understanding of budgets for future funding cycles.
The theory behind a codes and standards effort is that the PAs can provide support to improve compliance
215
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 221 of 274
with building energy codes and appliance standards. As codes become increasingly stringent, the building
community (owners, developers, contractors, architects, engineers) is struggling to interpret requirements
and to comply with building codes. The recently completed Massachusetts commercial code compliance
study highlighted that on average, commercial buildings met only 80% of the energy code requirements. The
C&I New Construction program has had successful history of promoting, educating, and delivering energy
efficient measures in the past. For these reasons, the PAs are in an advantageous position to support code
compliance and code enhancement through energy codes training and education as they work closely with
policy makers and trade allies. The PAs’ efforts could supplement the efforts of code enforcement officials
who may be challenged to fully enforce the energy use provisions, where their focus is more on health and
safety related aspects of the code. Existing infrastructure could also be leveraged to provide the research and
advocacy required to promote increased codes and standards. The PAs plan to act as a conduit to influence
and recommend increases and improvements to new stretch codes and appliance standards. Through their
relationship with contractors, developers and the design community, the PAs will be able to support the
implementation of those improvements going forward. This should result in the realization of the energy
savings that are lost when newly constructed buildings are not 100 percent compliant with the locally
applicable building code. The PAs could expand upon existing incentive-based new construction program
outreach efforts to target various stakeholders.
The Program Administrators plan to introduce efforts to assist in encouraging the adoption of and
compliance with more stringent building energy codes and appliance efficiency standards during the 20132015 program cycle. The intent is to claim the additional savings generated through the unique efforts
attributable to PA actions. The potential paths to achieving savings through codes and standards efforts by
the PAs include:
1. Compliance Support for Base and Stretch Code: The PAs would work with local builders,
contractors and building enforcement officials to increase the number of homes complying with the
locally applicable energy code, generally either the IRC (International Residential Code) version
adopted statewide, or the Stretch Code. Activities may include targeted trainings, outreach and
technical support in the form of code ambassadors and circuit riders, compliance documentation tool
development, and review support. Looking ahead, additional infrastructure needs to be developed to
support the next iteration of requirements for residential new construction. Starting in 2013, the PAs
plan to begin the strategic identification of jurisdictions that would benefit from code compliance
support.
216
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 222 of 274
2. Stretch Code Development Support: The PAs will support the DOER’s development of a stretch
code that exceeds statewide minimum requirements and is adopted by local governments. A
coordinated approach by the PAs will provide technical support for the DOER’s development of the
next round of stretch code (potentially 2015 version) to avoid duplicative efforts and costs.
3. Appliance Standards Advocacy: The objective here would be to accelerate the development and
adoption of targeted new residential appliance standards as the selected appliances and their
advanced levels of efficiency start to become established as current good practice in the marketplace.
PAs would provide support, which may include the technical resources necessary for assessment of
potential appliance standards and advocacy either at the state or regional/federal level. Market and
technical potential studies (in coordination with NEEP and ASAP) for a handful of commercial
appliances will begin in 2013 and may include outdoor lighting and circulation pumps for boilers.
Evaluation, Savings, Attribution of Codes and Standards: The PAs will collaborate with the stakeholders on
development of an evaluation plan that will enable the measurement and attribution of savings from these
efforts to the PAs for the 2013-2015 program cycle. A detailed evaluation plan, along with an appropriate
attribution methodology, will be developed in 2013. Qualitative as well as quantitative research would be
planned for in 2013 and 2014 to evaluate ongoing initiative efforts and will be used for savings projections
that can potentially be claimed within this three year cycle and future cycles.
Marketing Overview
Target Market:
The target market is all time-dependent gas and electric energy efficiency opportunities in the C&I sector –
commercial, industrial, institutional, and government customers. Key market actors are architects,
engineers, commissioning agents and owners/ developers of new buildings, and manufacturers and
distributors of energy efficiency gas and electric technologies.
Strategy:
Projects involving new construction have significantly different dynamics than retrofit projects. New
construction typically requires longer lead-times and involves more decision makers and influencers than
retrofit projects. In addition, while retrofit projects typically involve turn-key vendors selling a project
specifically on efficiency attributes, a parallel market actor does not exist in new construction. Products are
217
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 223 of 274
usually specified, not sold.
While the customer is still a key decision maker, it is critical that all stakeholders are included and are
informed and influenced toward a common goal of energy efficiency. Although this process starts with the
customer and the architect, the final design/product may be changed (value-engineered/alternate
specification) by the design engineer or general contractor. To address these dynamics, specific outreach
strategies are designed for each of these stakeholder groups. Extensive one-on-one communication is the
primary outreach strategy – building relationships by partnering on successful projects and adding value
ensures commitment to energy efficiency. This direct marketing is supported through other channels
including brown bag educational seminars, formal training such as Labs21, newsletters, and open houses.
Direct marketing pieces have been developed to pursue new construction leads identified through such
publications as the REED Construction Database and New England Construction News. Additional
marketing approaches used by one or more Program Administrators include direct contact with customers
identified through trade publications and advertising in local trade publications, seminars and training
sessions. The statewide website and statewide media marketing will continue to build overall awareness of
the program.
For time-dependent projects involving replacement of failed or end-of-life equipment, marketing efforts
focus on customers and equipment vendors rather than on developers and designers. Program
Administrators market the equipment replacement track to customers and vendors through extensive one-onone communication. Supplemental marketing efforts include distribution of promotional material (such as
case studies), attendance at trade shows and conferences, breakfast meetings, and other customer and vendor
focused training seminars. Program Administrators are exploring innovative ways to work with equipment
distributors and installers to help them in promoting energy-efficient equipment and systems to their
customers.
Technologies/Incentives
The following is a list of targeted end uses, recommended technologies, and incentives offered:
Targeted End Use
Lighting
Equipment &
Lighting Controls
Technology
Efficient Lamp
Technologies
218
Incentive
All Program Administrators’ financial
incentives structures will be consistent. Both
prescriptive incentives (fixed amounts for
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 224 of 274
Lighting
Equipment &
Lighting Controls
Lighting
Equipment &
Lighting Controls
Motors & Variable
Speed Drives
HVAC Equipment
HVAC Equipment
HVAC Equipment
HVAC Equipment
HVAC Equipment
Energy
Management
Systems
Compressed Air &
Unique Industrial
Processes
Compressed Air &
Unique Industrial
Processes
Furnaces & Boilers
Building Envelope
Direct/Indirect Lighting
Fixtures
specific measures) and custom incentives
(based on the unique energy savings criteria
of a project) are available. Financial
incentives typically cover up to 75 percent of
Lighting Controls
incremental labor and equipment costs.
Prescriptive financial incentives are offered
Efficient Motors and Motor for selected lighting, motor, variable
frequency drive, HVAC measures, heating
Drive Systems
and water heating, controls and commercial
Efficient Cooling Systems
kitchen equipment. Other cost effective
Efficient Chillers and
measures are promoted with custom
Controls
incentives based on the incremental
Dehumidification
equipment and installation labor costs of
ERVs
installing high efficiency equipment
Refrigeration Systems
compared to standard efficiency equipment,
Energy Management
or brought down to an equivalent of a fixed
Systems
payback period.
Compressed Air
Process Improvements
Advanced Gas
Technologies
Building Envelope
Measures
Additionally:
Additional custom measures are supported only after evaluation through MTAC and internal PA engineering
analysis. Design incentives covering a significant portion of incremental architectural and design costs
219
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 225 of 274
associated with comprehensive energy efficient designs are promoted to encourage comprehensive
participation. Program Administrators also combine efforts and co-fund targeted engineering and
commissioning studies.
Delivery Mechanism
Program Administrators will work together to market and implement the program through a unified and
cohesive statewide effort to maximize the acquisition of potential energy savings (gas and electric) in the
ongoing market for new facilities and replacement equipment in the Commonwealth.
Special Notes
220
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 226 of 274
G.
Pilots & Hard-to-Measure Efforts
1.
Pilots
The Program Administrators will continue to explore new efforts during the 2013-2015
Plan to determine if a pilot would be a useful tool for studying a new effort. A key goal of any
pilot is that pilots yield data that assist in determining if the approach explored in the pilot should
be implemented on a larger, statewide scale, as a full program, or an element of a program.
2.
Hard-to-Measure Efforts
a. Residential Research and Development (“R&D”)
In the continued efforts to explore new technologies and measures through the MTAC, as well as
proactive research and development into areas of interest, the PAs propose a consolidated R&D
effort to (a) support the work of the MTAC, and (b) pursue technologies of interest in order to
remain at the top of the “innovation curve.” The hard-to-measure efforts described below are
envisioned to be allocated specifically to the R&D budget line items (see 08-50 tables). For
residential innovations/enhancements within a planned initiative, please refer to the initiative
enhancement sections within each Program.
From 2013-2015, the PAs have an interest in supporting the following as well as new
technologies that may present themselves during the three-year cycle:
30
•
Residential Lighting Controls – Although many evaluations have affirmed the value of
lighting controls in commercial settings (including multi-family), there is a national
interest in assessing the level of savings in lighting controls. The National Electric
Manufacturers Association (“NEMA”) in association with the Consortium for Energy
Efficiency (“CEE”) has started to explore this work. This effort provides PAs the
opportunity to test measures such as dimmers, occupancy sensors, and vacancy sensors in
an effort to include this technology in the residential programs. This effort will also
assist with compatibility issues of lighting controls with efficient lighting such as CFLs
and LEDs.
•
Clothes Dryers – Residential “white goods” have historically provided consumers and
PAs significant opportunities for energy savings. These savings are directly attributed to
the technological advancements and testing procedures introduced into the appliance
marketplace, such as refrigerators and clothes washers, over the last decade. Yet, during
this same time period clothes dryer energy usage testing procedures remained inadequate
and outdated. However, the Department of Energy has recently introduced new clothes
dryer testing procedures affording the PAs a new opportunity to test the potential energy
savings in residential electric and gas clothes dryers. While the Energy Factor (“EF”) 30
has been developed for different tier levels by technology (including heat pumps), the
PAs would like to affirm the level of savings as well as applicability in the market in a
limited number of homes before launching the Residential Consumer Products Initiative.
Energy Factor is a measure of the overall energy efficiency of an appliance or equipment.
221
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 227 of 274
•
H.
Smart Thermostats – Home controls such as smart thermostats have recently been
highlighted in the news and technology publications. Some of these home controls can
be accessed through smart phones and other mobile devices, thus enabling end-users
greater control of their major appliances and the potential of achieving energy savings
while away from their home. While some efforts have taken place on specific products,
there are new entrants into the market such as the “Nest” that have been lauded with great
public interest. Determining criteria as well as testing multiple models may help the PAs
to garner more savings while engaging with consumers at a new level.
Public Education and Marketing Activities
The Program Administrators plan to focus on creating a culture of sustainability within
the Commonwealth using public education and marketing as key tools in this effort. The focus
will be on creating powerful, engaging, and motivating education and marketing strategies that
will increase awareness of the benefits of energy efficiency and drive increased participation in
the available energy efficiency programs and services. Proposed public education and marketing
strategies will take into account the unique motivational differences between residential and nonresidential customers.
Support of the Mass Save mark and statewide brand is an important priority. The PAs
commit to statewide marketing efforts that include the prominent integration and placement of
the Mass Save mark as the statewide brand. PAs will include the Mass Save mark on statewide
program, outreach and marketing materials and will include a link to the Mass Save website on
the portion of their Company websites that is focused on energy efficiency services in
Massachusetts, except where expressly limited by internal corporate website policies. PAs, in
collaboration with DOER and the Council, will conduct an evaluation of the effectiveness of all
joint statewide branding efforts to ensure that such brands support clear and recognizable
messages that help promote program awareness. Such an evaluation will be completed by the
end of 2013 and submitted to the Council.
The strategies and messages developed for statewide energy efficiency education,
outreach and marketing will augment the efforts already in use and will attempt to complement
and leverage program-specific marketing and individual PA efforts across the Commonwealth.
1. Marketing Plan Overview
Introduction
In order to achieve the aggressive goals set forth in this Plan, the Program Administrators
will continue to undertake a comprehensive energy efficiency public education and awareness
outreach campaign. The core goals of the Program Administrators in any public education and
promotion campaign include: reaching the maximum level of residential and business customers
possible; providing messages that are not overly technical and that clearly describe the benefits
of energy efficiency; exploring targeted marketing to unique or specific communities throughout
the state (including communities where English is not the primary language); utilizing diverse
media (e.g., internet, bill inserts, television, radio, billboards, public transit) to disseminate
222
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 228 of 274
consistent and clear messages; and ensuring that the various strategies work together to
ultimately achieve deeper and broader savings.
The key elements of the Program Administrators’ marketing plan for 2013 -2015 are set
forth below. As part of this discussion, the Program Administrators also note efforts that they
undertook during 2010-2012. It is worthwhile to remember that as the first plan kicked off there
was no statewide PA brand or integrated PA statewide website in existence. Reviewing the
marketing activities for 2010-2012 illustrates how rapidly the marketing of energy efficiency
programs has expanded in a short time and provides a basis for comparison and possible
improvement by understanding what marketing efforts have worked well.
The ultimate goal of these educational, community outreach, and marketing efforts is to
develop a broad system of communication with Massachusetts citizens and businesses and
deliver comprehensive energy efficiency programs. Through an array of effective messages and
valuable information resources, the Program Administrators commit to engaging with a large
portion of the population to assist in delivering value to residential and business customers and to
assist in obtaining the aggressive energy efficiency goals set forth in this Plan.
Mass SaveВ®
In 2010, the PAs joined together to bring energy efficiency programs to the
Commonwealth through a statewide PA brand. As sponsors of the Mass SaveВ® service mark, the
intent of the PAs was to complement their individual PA brands when communicating with
residential and C&I customers about energy efficiency programs.
The Program Administrators are the owners of the Mass SaveВ® word service mark. The
purpose of a trademark or service mark is to identify goods and services as originating from a
single source. Trademarks, in effect, represent the goodwill that a business has built up through
its history of offering quality goods and services. A word mark is the most common form of
trademark and simply consists of a word or group of words. The Program Administrators have
rights to the word mark Mass Save, having obtained federal registration of it on August 29, 2006.
In addition, the PAs developed and registered a design mark. A design mark consists of a
pictorial or geometric representation that is used to identify goods or services. It can also be
combined with words or phrases. In the PAs’ design mark, the words “Mass Save” appear under
an image of buildings with the sun in the background. The PAs obtained two separate federal
trademark registrations for the new design in 2011. One registration was obtained for the design
mark with a tagline “Savings though Energy Efficiency.” The other registration was for the
design mark without this tagline. For examples of these marks, please refer to the cover page of
this Plan.
Under trademark law, the PAs must monitor and control the use of their marks in order to
maintain them and to prevent inferior energy efficiency services from diminishing them.
Throughout the three-year period of the initial plan, the PAs’ have overseen significant
monitoring efforts with respect to the Mass Save mark to identify unauthorized uses of the
223
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 229 of 274
service mark. Legal measures have been successful to
stop such unauthorized uses and thus the integrity of
the mark has been protected.
Highlights from 2010-2012
During the initial three-year plan, the PAs
made great strides forward in statewide marketing and
consistency. In 2010, the PAs joined together to
market energy efficiency services on a statewide basis
through use of the Mass Save service and design
marks. Since 2010, the PAs have been educating and
communicating with their customers as to: (1) who
and what Mass Save is; and (2) what it means for the
customer.
In addition, a single website was created as a
central repository to educate customers and provide
access to energy efficiency program information and
participation. The launch of this statewide website
devoted to the PAs’ energy efficiency efforts is almost
easily taken for granted now, but it was a major and
unprecedented undertaking and satisfied a core
Council priority. The existence and operation of this
website demonstrates the commitment of the PAs to
working together for the benefit of customers
throughout the Commonwealth.
A marketing
contractor was also hired to prepare communications
through creative material development, media
planning and buying as well as execution, to educate
customers about energy efficiency and to help the PAs
successfully convey who and what Mass Save is.
•
•
The Statewide Marketing Working Group,
which is discussed in Section III.A.4.b above,
leveraged the information learned from
independent research to create effective
communications for the launch of the first
Mass Save campaign.
The communications plan included Red Sox
Radio-WEEI and HGTV Green Home in
Plymouth in addition to various statewide
media outlets. The WEEI Mass Savers contest
was launched with winners selected based on
how they implemented energy saving measures
in their home. A separate web portal was also
224
Mass SaveВ® &
Program
Administrators’
Logos Appeared
Throughout
Massachusetts
Regardless of
Service Territory
In 2012, the Program Administrators
executed a statewide awareness
campaign to educate customers
about the many ways they can save.
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 230 of 274
developed in support of the Mass Savers contest through WEEI.
•
The Mass Savers contest was also extended to the business community with each PA
selecting customers who achieved energy savings. These businesses were honored at an
awards event at Fenway Park. These case studies were later showcases of PA efforts.
•
Public Relations included: Mass Saver stories, which were circulated through various
local papers, and community outreach at a number of local events throughout
Massachusetts.
•
The 2010 Campaign was a 2011 AESP Winner for Outstanding Marketing and
Communications.
•
C&I Sector Sheets were created and posted on MassSave.com following the
identification of some key target markets.
•
C&I Case Studies were created and posted on MassSave.com showing true collaboration
among the PAs, in that no matter which PA generated the case study, all PAs brands were
included in the piece.
•
C&I advertising was added to the marketing mix featuring selected customer testimonials
from the 2011 Mass Savers Awards.
•
E-Source Award Winner for C&I advertising.
•
Multi-language communications were in the market for the first time under this initiative
in Portuguese.
•
Social Media efforts were implemented for both sectors including: a dedicated LinkedIn
page targeted at businesses and a Facebook page.
•
Google paid search to refine key words in communications.
•
Online campaign activities included paid search and online banner advertising.
•
Creative for Residential and C&I had a consistent look, feel and messaging to optimize
the PAs’ exposure and media dollars in the market.
•
Through the EM&V team, and with councilors, the PAs executed a Pre-Campaign
Awareness study in January/February/March with a post campaign study scheduled for
August when the campaign concludes so the PAs can benchmark and evaluate the
effectiveness of their messaging and media planning. Initial findings show that the PAs
are beginning to have an impact and it suggests that consistent use of the PA and Mass
Save marks add clarity to the customers’ understanding of the Mass Save mark. In the
Statewide Marketing Campaign, the PAs and Mass Save marks consistently appear
together throughout the Commonwealth regardless of service territory. This EM&V
effort demonstrates the PAs’ commitment to using EM&V as a tool – at appropriate
intervals and with independent expert assistance – to hone and enhance marketing efforts.
•
MassSave.com has been refreshed to include elements from the advertising campaign to
provide consistent messaging for the customer and to increase the positive experience
customers will have when entering the website. The Appreciative Inquiry Summit
content is posted and will be updated periodically and new case studies will continue to
225
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 231 of 274
be added. The PAs plan to re-energize the C&I portion of the website this year and will
address other enhancements after a Request For Proposal (“ RFP”) is completed.
•
Mass Save Style Guidelines were created and executed in an effort to create consistency
and control of the marks’ uses in the market, to support our objective to educate
customers about who and what Mass Save is and to protect against
unauthorized/deceptive use of the PAs’ intellectual property and brands.
For additional marketing information, see Appendix I, including a Campaign Calendar
and creative material.
EM&V Results from Massachusetts Umbrella Marketing Evaluation Report (June 19, 2012)
In developing their marketing campaign for the 2013-2105 energy efficiency investment
plan, the PAs will take into consideration the results of Massachusetts Umbrella Marketing
Evaluation Report conducted by Opinion Dynamics Corporation. In this report, Opinion
Dynamics Corporation presents findings from its evaluation team’s 2011 evaluation activities,
which were designed to establish baseline Mass Save campaign awareness in advance of the
2012 marketing campaign. Umbrella Marketing Report at 8. Opinion Dynamics reports that
“[t]he ultimate goal of the Massachusetts Umbrella Marketing Campaign is to raise customer
awareness of energy efficiency programs and energy saving opportunities so that they install
energy efficient equipment through PA programs and/or change behaviors.” Id. Opinion
Dynamics explains that “the specific goals of this program are (1) to educate audiences about the
need for and benefits of energy efficiency, (2) to increase awareness of Mass Save, and (3) to
drive Massachusetts residents to participate in sponsored energy efficiency programs.” Id.
Opinion Dynamics observes that “[t]his program does not have explicit energy saving goals.” Id.
Opinion Dynamics reports that the “campaign is designed and implemented by a team of
stakeholders including representatives from each of the PAs,” and that DOER has served in an
advisory role since 2010, with the PAs keeping DOER informed of Mass Save statewide
marketing activities. Id.
Based on its research, Opinion Dynamics established several baselines, including:
•
Over one-third (39%) of residential customers have seen or heard the term Mass Save.
•
Awareness of general utility and energy efficiency service provider programs was
significantly higher than awareness of Mass Save among the residential population (74%
vs. 39%).
•
Both residential and commercial customers aware of Mass Save overwhelmingly think of
it as a utility or energy efficiency service provider effort (52% among residential and
53% among commercial).
•
More than half of residential customers who are aware of Mass Save think of it as a PA
effort.
•
Residential customers primarily think of Mass Save as a resource for energy efficiency
information (46%), or associate it with rebates for equipment (20%).
•
Overall, commercial customers had a lower level of Mass Save awareness.
226
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 232 of 274
•
Those commercial customers who were aware of Mass Save were also more likely to
know about the MassSave.com website. A similar percentage of commercial and
residential customers are aware of the website (17%).
See Umbrella Marketing Report at 5-7, 16, Appendix D.
Marketing for 2013-2015
The key themes for the Statewide Marketing efforts for the 2013-2015 planning cycle are
as follows:
•
Statewide Marketing’s role is to define who and what Mass Save is and what it means to
the customer.
•
Statewide Marketing will take a strategic approach to message and graphically tie in the
PA Brand Logos with the Mass Save mark to create a strong association and clarity of
message.
•
Statewide Marketing will utilize the segmentation work identified by the RMC and
C&IMC so we can better an more consistently target customers from a program and
statewide awareness level.
2013-2015 Planning:
After selecting an advertising agency for the next two years, the PAs will undergo a complete
review of how they intend to meet their objectives, which include:
•
Educate customers as to who/what Mass Save is and what it means for them.
•
Create awareness and understanding of Mass Save as a trusted statewide resource for all
customers’ energy efficiency needs.
•
Educate customers about the opportunities to save energy and motivate them to take
action.
For 2013-2015, the PAs expect the following:
•
An RFP was issued in July for 2013-2015, which was driven by the Statewide SubCommittee and executed by one PA on behalf of the team. A document outlining the
PAs’ needs/requirements, agency list and schedule was developed and approved by the
team, with the evaluation kick-off slated for August. Interviews of RFP finalists are
scheduled for October 2012. The goal is to hire an advertising agency that can manage
all aspects of the communications plans.
•
Key deliverable date: lead agency hired in Q4 2012.
•
The Statewide Marketing Committee will continue to meet monthly and will continue to
keep DOER informed of developments and continue informal discussions concerning the
PAs’ statewide marketing efforts.
•
The PAs’ communications strategy by sector will be more diverse and targeted and yield
an improvement in awareness.
227
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 233 of 274
•
From a market research perspective, the PAs will work with the EM&V team to do a
pre/post campaign study. Through the PAs’ advertising agency, they will implement
copy testing for all advertising materials before going into market to ensure that their
messaging is meaningful to the target and that the channels the PAs elect to use are
appropriate. There are applicable EM&V studies underway. The Phase II Umbrella
Marketing study, which was conducted in 2012, will be included in the 2011 Annual
Report. A follow-up study, which will include post-campaign analysis, is planned for
2012. For additional discussion see Section I.G.3.
•
Mass Save Style Guidelines will be re-evaluated by the PAs with the agency to determine
their effectiveness and usability and will be re-issued following this refinement.
•
MassSave.com will be evaluated for content and usability and improvements made and a
team established to maintain its integrity.
•
The PAs will continue to feature all the PAs’ brands in conjunction with the Mass Save
marks per the findings from the Umbrella study and consistent with their goal to convey
who and what Mass Save is.
•
The PAs will continue to track their campaign effectiveness in terms of driving customers
to the website and refreshing content.
Maintenance of Complementary Individual Efforts
While working diligently on the statewide public education efforts, the PAs will also
continue to maintain customer awareness, satisfaction, and participation goals and accordingly
the PAs will also continue outreach efforts utilizing customer representatives and account
executives (who enjoy one-on-one/person-to-person relationships that are especially important in
the C&I sector) and PA-specific efforts that complement and are consistent with statewide
efforts and the findings of the 2012 Umbrella Marketing Report.
2. Community Engagement
Over the course of the 2010-2012 Three-Year Plan, the Program Administrators worked
on a variety of community-based outreach and marketing initiatives throughout the
Commonwealth. These efforts were primarily driven by local community advocates and leaders
from various communities, in collaboration with PAs, who provided project management and
technical support. While the overall results and successes of these outreach activities varied, it
became evident that community engagement is an important component to enhancing the PAs’
ability to achieve greater program participation and energy savings. Additionally, community
engagement may help the PAs reach hard-to-reach and hard-to-serve customers, as well as
additional multi-family customers. The PAs express their appreciation of the efforts of their
dedicated colleagues in community engagement initiatives and of their commitment to working
together to find the best ways to serve harder to serve constituencies.
The PAs also recognized over the last three years there is no “one size fits all” outreach
model, but rather there is a need to employ a variety of creative engagement mechanisms. Some
examples of these include:
228
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 234 of 274
•
development of customized engagement plans with consideration of actual demographic
and sector mixes unique to that particular community/municipality
•
inclusion of performance based savings goals
•
more holistic approaches that include city or town governing officials being the voice and
driver for municipal buildings, local business, and residential participation
•
engaging community-based organizations committed to aiding in the delivery of energy
efficiency services in what might be considered traditionally harder to serve and/or
ethnically diverse neighborhoods
•
continued focus on addressing barriers to participation that have been identified by
community-based organizations
•
multi-lingual outreach strategies
While there are still many details and challenges that lie ahead in rolling out specific
engagement plans over the course of the next three years, the PAs are committed to the evolution
of community-based engagement activities as an integrated component of our overall marketing
and outreach strategies.
Successful community-based engagement is based on development of key strategies to
address the specific needs and goals of a particular community and/or community outreach
group. Ideally, these strategies should include an outreach model whereby all sectors of the
community are included and a holistic “A to Z” approach is taken. An “A to Z” approach
encompasses the entire city or town whereby partnerships are established with various governing
officials and community groups to promote broad-based participation including local businesses,
municipal buildings, and residential consumers. Examples of this approach include:
•
Establishing energy saving goals and priorities specifically tailored for an individual
community that includes measurable and achievable results.
•
Partnering with community-based organizations to develop effective outreach and
program delivery strategies that incorporate a performance-based incentive mechanism.
•
Using existing PA educational and schools programs to support community messaging to
parents, local businesses, and city/town officials.
•
Partnering with local officials to identify/target high-use municipal buildings and schools
for energy efficiency upgrades as well as to showcase completed projects.
•
Partnering with local businesses, equipment suppliers, and industry related contractors to
promote program participation and energy savings opportunities including use of local
workforce when and where appropriate.
•
Partnering with local city/town media outlets as a vehicle for messaging and maintaining
community relations.
229
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 235 of 274
However, the PAs recognize that while engaging the entire community would be ideal,
there are other opportunities to engage at a smaller scale based on the particular needs of a local
municipality. This may involve working with local community outreach advocates to target
specific areas of opportunity. Examples of this include demographically based efforts related to
the following characteristics: known hard to serve customers, ethnically diverse neighborhoods
that may be at a disadvantage for participation due to housing stock, predisposition to having
pre-weatherization barriers, income constrained customers, and renter status.
Recent
partnerships with organizations such as the Green Justice Coalition, the City of Boston aka
Renew Boston, Chelsea Collaborative, Chinese Progressive Association, and the Marion Institute
& P.O.W.E.R of New Bedford proved to be an effective means of engaging ethnically diverse
populations.
Community-based pilots developed during the last three-year plan provided valuable
lessons and were instrumental in profiling outreach challenges and barriers to participation that
exist in certain communities. Over the course of the next three years, the PAs plan to continue
working closely with community organizations and advocates to enhance outreach experiences
as a means to increase program participation levels. These efforts will include developing
creative solutions to aid in minimizing known barriers. Some examples of these may include but
are not limited to pre-weatherization incentives, equity based incentive structures, non-owner
occupied multi-unit building incentives, and measure packaging incentives to promote deeper
savings.
While the PAs acknowledge there are varying sizes and scopes for community-based
engagement efforts, there is also acknowledgement that there are basic core components
necessary to be effective and successful for any community outreach endeavor. The following is
an outline of these core components.
•
Partnerships – establishing partnerships with key community-based organizations,
advocates, and municipal officials is one of the most important components to any
community engagement effort. Though there were many lessons learned with
previous community pilots, one thing that did stand out was without strong
partnerships there cannot be successful community-based campaigns. The “boots on
the ground” approach by community advocates is essential to building the necessary
relationships within a community to encourage and support program participation.
•
Market Segmentation – although not widely used for marketing and outreach efforts
during the last three-year plan, market segmentation will be a critical component for
future marketing and outreach efforts. Identifying and defining customer segments
provides significant opportunities to target consumers/communities based on key
analytical and demographic data. Once defined, market segmentation can be used as
both a marketing and outreach tool to help identify and target based on certain criteria,
such as traditionally hard-to-serve/diverse neighborhoods, housing type,
property/ownership type, and energy use.
•
Participation Barriers – one of the key lessons from previous community-based pilots
was that, while there are common barriers across all sectors and market segments,
230
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 236 of 274
there tends to be a greater concentration of barriers in urban areas. Some examples of
these barriers include:
o
o
o
o
housing stock - pre-weatherization based barriers
income based
language
renter/landlord
Over the course of the next three years, the PAs plan to develop and implement key
strategies to help minimize these barriers with a common goal of increasing program
participation and achieving greater energy savings for our consumers.
•
Performance-Based Goal Setting - is also an important component of future organized
community-based outreach efforts. It is common practice to gauge the success of any
marketing or outreach campaign based on actual participation rates and attributed
energy savings. Therefore, setting priorities and savings/measure goals for these
community-based efforts is one of the best ways to achieve and measure overall
success. The PAs plan to develop and implement a performance-based goal structure
as a driver for successful community-based outreach efforts.
In summary, the PAs consider community engagement an integral component of our
various program delivery models over the course of the next three years. The PAs recognize the
value that community-based outreach plays in driving program participation and helping our
consumers achieve deeper savings. The PAs also recognize, as noted, there is no “one size that
fits all” community engagement model. However, despite differences in size and scope the PAs
are committed to working with various community organizations and partners over the course of
the next three years to further these marketing and outreach endeavors. Ultimately, the success
of these community-based activities will be measured on delivered energy savings. Thus the
PAs believe incorporating a performance-based incentive mechanism is one of the best ways to
achieve and measure success.
3.
Schools/Education Program
Although residential education efforts have varied by Program Administrators over the
years, the PAs believe that a more collaborative approach on education would enhance all of our
efforts in increasing consumer awareness of the importance of energy efficiency as the next
Three-Year Plan is implemented. The key objective of the Residential Education initiative will
be to offer an array of school-aged education programs and enhanced consumer education.
Efforts for consumer education will focus on educating customers on the benefits of
investing in energy efficiency products and services and the multitude of energy efficiency
initiatives available to them. The PAs plan to work with DOER, educational institutions, the
statewide marketing working group, and PA marketing departments to develop educational and
promotional strategies. Efforts for school-aged education will initially focus on expansion of
existing PA, and in many cases, award winning school programs. As PAs have the opportunity
to review the recommendations from the Appreciative Inquiry Summit, those recommendations
will help shape the residential education initiative.
231
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 237 of 274
Strategies
While some of the PAs have established educational initiatives, the following provides
examples where the PAs may collaborate in delivering educational outreach strategies including,
but not limited to:
•
Sponsor energy efficiency related classroom presentations and activities to schools K-12.
•
Direct educators and children to educational resources available online to help educate
children about energy safety and conservation.
•
Participate in the youth awards programs and sponsor science fairs and other elementary
and secondary educational curriculum in collaboration with DOER, Massachusetts
Department of Education, and schools throughout the Commonwealth. These efforts
could include teacher and community workshops such as the NEED Project.
•
Encourage school administrators and parent/teacher organizations to participate in
available fundraising activities such as the “Change a Light, Change the World”
fundraiser – an educational program where students learn the benefits of efficient lighting
and other technologies and are encouraged to sell these products as a way to raise funds
for their school.
•
Explore the development of programs for youth group summer camps promoting energy
conservation and behavioral change.
•
Partner with community-based organizations to educate and promote energy efficiency
through energy fairs, sponsorships, and community specific outreach.
•
Participate in various external energy efficiency employee awareness events.
•
Direct customers to on-line calculators and web tools to learn more about home energy
usage and to offer energy saving recommendations including information on available
initiative incentive offers.
Targeted Marketing
The Program Administrators will work to develop energy efficiency marketing messages
aimed at residential customers, educators, students, parent/teacher organizations and community
groups. Proposed collateral will highlight the many benefits of investing in energy efficiency,
savings that can be generated by individual efficiency measure upgrades, behavioral changes,
and testimonials from past program participants. The PAs will employ a variety of media
sources for messaging such as bill inserts, bill messages, customer newsletters,
www.masssave.com, direct mail, employee and business partnerships, newspapers, social media
outlets and educator workshops.
The Residential Education Initiative will also focus on developing curricula encouraging
students to work within their communities on energy conservation issues. The PAs believe
educating school-aged children about energy saving benefits is paramount in making today’s
students the responsible citizens of tomorrow.
232
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 238 of 274
I.
Evaluation, Monitoring & Verification
1.
Introduction
This section proposes a framework for evaluation and monitoring for the three-year plan
period, 2013-2015. The section begins by outlining the enhancements from the initial three-year
plan and then discusses the EM&V regulatory framework and research areas, the PAs’
evaluation and monitoring strategies, and high-level evaluation budget levels. Finally, there is a
discussion of the Program Administrators’ specific evaluation and monitoring priorities and
activities planned for each research area.
2.
EM&V Enhancements
For the 2013-2015 Plans, the Program Administrators and the Council’s Consultants have
identified several enhancements to the current EM&V framework. These enhancements are
intended to improve the framework and make evaluation efforts more streamlined and
transparent with the goal of improving the precision and usefulness of the studies.
The Program Administrators and the Council’s Consultants agree that these
enhancements to the evaluation framework will help streamline the EM&V process and increase
administrative efficiencies, while also creating added flexibility to better address stakeholder
research priorities and resource constraints in a timely manner. The specific enhancements
proposed include:
•
Evaluation Management Committee: In 2012, the Program Administrators and the
Council’s Consultants created an Evaluation Management Committee (“EMC”)
similar to the C&I and Residential Management Committees. The EMC serves as a
steering committee for statewide evaluation issues, providing guidance and direction
to each of the evaluation research areas. The EMC will also help plan, prioritize and
delineate the research studies to be undertaken over the three-year plan period. For
additional information on the EMC, see Section III.A.4.b.
•
Research Areas:
The PAs, Council Consultants and the EMC worked
collaboratively to determine that the range of evaluation activities for 2013-2105
should be divided into three statewide research areas as follows: (1) Residential;
(2) Commercial & Industrial; and (3) Special and Cross Cutting. This change
collapses the current six research areas into three broader categories. The research
areas will continue to be organized primarily by target markets, which will help to
maximize the statewide effectiveness of EM&V while at the same time presenting
minimal overlap among research areas.
•
Contracting: The Program Administrators propose that the contracts in any research
area may be awarded to one or more evaluation contractor, depending on the needs of
the Program Administrators and the expertise and qualifications of the evaluation
contractors available. This structure will maintain both a continuity of evaluation
contractor presence in each research area, where appropriate, while still fostering
creativity and competition among evaluation contractors.
233
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 239 of 274
3.
EM&V Resolution
On September 8, 2009, the Council approved its EM&V Resolution, which is quoted in
full below:
The Energy Efficiency Advisory Council recognizes that the deployment of the
energy efficiency programs by the electric and gas Program Administrators
(“PAs”), in support of the mandates of the Green Communities Act, is expected to
produce energy savings and related benefits to the Commonwealth that involve
the expenditures of unprecedented levels of customer and public monies. It is
therefore critical that the programs be evaluated, measured, and verified in a way
that provides confidence to the public at large that the savings are real and in a
way that enables the Program Administrators to report those savings to the
Department of Public Utilities with full confidence. There is a need to ensure both
the reality and the perception of the independence and objectivity of EM&V
activities, as well as the need to help ensure consistency, timeliness, and
credibility of the results.
The Council also recognizes that the evolution of more uniform statewide
programs necessarily leads to greater use of statewide evaluation studies as well
as other organizing principles.
Accordingly, the Council adopts the following principles and policies -- divided
into the topics of policy /authority and implementation -- regarding the evaluation,
measurement, and verification of energy efficiency programs:
POLICY/AUTHORITY
Decision Making:
•
The EEAC will assume an oversight role over the EM&V activities of the
Program Administrators to ensure the objectivity and independence of those
activities, and the perception of such, and to help ensure consistency,
timeliness, and credibility. While PAs and EEAC Consultants (acting on
behalf of the EEAC) will continue to work diligently to reach a consensus on
evaluation issues, where there are areas of difference that may arise that
cannot be resolved through consensus during the on-going interactive process
between the EEAC Consultant and the PA evaluation staff, authority for
decision-making will reside with the EEAC or its Designee.
•
Appeals: To enable the Program Administrators to fulfill their responsibility
to report program savings to the DPU with full confidence, an appeals process
shall be established, through which the PAs may bring decisions made by the
Council or its Designee for review and resolution. This process will be
implemented through the formation of a standing evaluation committee
(“Standing Committee”) of the Council, whose responsibility in this area will
be to hear the matter under dispute and rule so that the study may proceed in a
234
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 240 of 274
timely way. In general, it is expected that this review process will be
completed within 72 hours once an issue is elevated to the Standing
Committee. 31
•
Resolution of Disputes: This Standing Committee will consist of three voting
members of the Council, including DOER. Consistent with general Council
proceedings, the Standing Committee will include and consult with, in both
deliberations and decision-making, a representative of both the PAs and the
EEAC consultant team, neither of whom shall have a vote in the standing
committee. The Committee will review the issues related to the disputed
matter, hear from the PA evaluation staff and EEAC Evaluation Consultant
(the “principals”), and make a determination on the outcome of the matter.
The decision will be recorded, along with a description of the applicable
issues. The participants in the appeal will sign the record of the decision,
indicating their acceptance of, the representation of the issues and of the
decision. In exceptional cases, where the PAs perceive there to be significant
risk to their ability to manage the energy efficiency programs in the near term,
the PAs will note their disagreement with the decision of the Standing
Committee on the record of the decision and reserve the right to immediately
petition the DPU on the Standing Committee’s decision. The PAs shall be
able to submit any such documents to the DPU in conjunction with the filing
of the Energy Efficiency Plans and Annual Reports. The DPU will be able to
review the record of this decision in its review of Plans and Annual Reports.
IMPLEMENTATION
31
•
A. Statewide Focus: Impact evaluations, and other studies, should be
performed at a statewide rather than an individual Program Administrator
level to the maximum extent possible, while enabling to the extent necessary
results at the Program Administrator level. It is recognized that circumstances
could occur where a service territory specific or non-statewide evaluation or
study would be appropriate. Such EM&V activities should only be
undertaken following an assessment of the need and value of a non-statewide
study and agreement between the PA evaluation staff and EEAC Evaluation
Consultant.
•
B. Research Areas: The range of evaluation activities should be divided into
5 to 7 semi-permanent statewide research areas, each oriented primarily to
specific target markets (e.g., residential retrofit, large C&I), each with a longterm research and contract manager from the PAs, an independent evaluation
contractor to conduct the studies under a long-term contract, and the EEAC
Evaluation Consultant. The PAs and the EEAC Evaluation Consultant shall
jointly prepare a statewide research management plan to carry this out. The
EEAC Evaluation Consultant shall have the opportunity to comment on the
The establishment of this process is still an open action item. A proposal for a Standing Committee was an
agenda item discussed at the Council’s March 13, 2012 meeting. To date, however, there has been no need
for an appeals process as any disputes have been amicably resolved.
235
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 241 of 274
proposed assignments of the PA research area managers. The EEAC will have
the authority to remove assigned research area managers if they do not
perform effectively in accordance with pre-established objective standards for
research area managers. Those standards will be developed jointly by the
EEAC Consultant and the PAs.
•
C. Evaluation Planning: The research area managers and EEAC Evaluation
Consultant will jointly prepare a proposed statewide evaluation plan and
illustrative budget and submit it to the EEAC for approval. 32 We expect that
this plan will be reviewed and updated annually. Consideration will be given
to regional EM&V activities and FCM requirements, and will be responsive to
DPU directives about EM&V in the development of the evaluation plan.
•
D. Coordination of Studies: All studies 33 in which Massachusetts PAs
participate should be included in the statewide evaluation plan for the
purposes of coordination of evaluation and promotion of consistent methods,
and conducted by the research area independent evaluation contractors. Some
studies, however, may be excluded from the statewide research area contracts.
The EEAC Consultant and PAs will develop guidelines for assessing which
studies may be excluded from the statewide research contracts and will apply
them as necessary to identify mutually agreed upon studies that will be
conducted outside of the statewide evaluation contracts. Research area
managers, the PAs, and the EEAC Consultant should make every effort over
time to determine if these studies may be included in research area contracts.
Under the circumstances where a study is not included in a research area
contract, the appropriate research area manager shall manage the study and
represent Massachusetts statewide evaluation interests in the execution of the
study. The EEAC Evaluation Consultant may participate in regional
evaluation projects directly, upon the direction of the EEAC.
•
E. Integration: Electric and gas evaluation efforts should be fully integrated
to the maximum extent possible. Each of the statewide research areas should
cover both electric and gas evaluation efforts.
•
F. Contracting: The Program Administrators will be the main mechanism
for contracting with the independent evaluation contractors.
•
G. Implementation: As is current practice, statewide evaluation studies will
be coordinated by staff from Program Administrators, with a lead from one of
them (the “Study Manager”), and an EEAC Evaluation Consultant. This will
enable Program Administrators and the EEAC to collaboratively provide their
expertise in the planning, scoping, management, review of methods and draft
32
The DPU has the ultimate authority to review and approve each PA’s energy efficiency plan, including its
evaluation plan and budget.
33
Some Massachusetts PAs are multi-jurisdiction utilities and may propose expanding some Massachusetts
studies to include those other jurisdictions, where appropriate. If mutually agreed-to by the research area
manager and the Council Consultant, these cross-jurisdictional efforts will proceed.
236
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 242 of 274
protocols, and review, acceptance, and application of results of the individual
studies. In many cases the Study Manager and the statewide research area
manager will be the same individual. The Study Manager shall manage study
efforts so that the approved evaluation study budgets are not exceeded. 34 The
EEAC Evaluation Consultant should have the authority to recommend to the
EEAC removal of the assigned Study Manager if they do not perform
effectively in accordance with pre-established objective standards for Study
Managers. Those standards will be developed jointly by the EEAC
Consultant and the PAs.
•
H. Communication and Documentation:
The Study Manager will
communicate regularly with the EEAC Evaluation Consultant about issues
related to study execution. The Study Manager will document decisions made
in the course of a study, for potential review by the EEAC, DOER, the DPU,
and/or any other party.
We expect and encourage the PAs to perform the evaluation roles assigned to
them in this framework in an effective and timely way.
We recognize that there are details that remain to be worked out under this
framework and that the framework may evolve over time. We encourage the
EEAC Consultant and PAs to continue discussions on these topics to establish an
effective process that leads to high quality and useful evaluation results, mindful
of the need to maintain public confidence in the overall conduct of these
programs. The process, roles and responsibilities should be reviewed and
modified, as necessary, after twelve months first, and bi-annually thereafter.
4.
Descriptions of Research Areas
Consistent with the EM&V Resolution and experience over the last two plus years
implementing the initial three-year plan, the Program Administrators, Council’s Consultants and
EMC worked collaboratively to develop and refine three market research areas. These research
areas are organized primarily by target markets, which design is intended to help maximize the
statewide effectiveness of EM&V, while presenting minimal overlap among areas. The research
areas identified are as follows:
a) Residential
Originally, this research area consisted of three separate categories: Residential Retrofit
and Low Income, Residential Retail Products, and Residential New Construction Residential
Retrofit and Low Income. Residential still includes these categories, but as a single overarching
research area. As currently defined, the residential research area would include residential
34
At times, the scope of an evaluation study is modified for good reasons. The Study Manager and the EEAC
Consultant agree to review proposed changes in scope with the Standing Committee when the change in
scope is likely to lead to an increase in study cost of more than 10% or to adversely affect the study
timeline.
237
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 243 of 274
cooling and heating equipment, residential heating and water heating, residential and low income
retrofit 1-4 including weatherization, and residential and low-income retrofit (and new
construction) multi-family programs; residential lighting and appliance programs; and residential
and low income new construction and major renovations programs.
b) Commercial & Industrial
This research area previously consisted of two separate categories: Non-Residential
Large Retrofit and New Construction and Non-Residential Small Retrofit. Commercial &
Industrial still includes these categories, but as a single overarching research area. As currently
defined, the C&I research area would include C&I small retrofit, direct install initiatives, future
programs that may target small non-residential customers, C&I new construction (small and
large) and major renovations, as well as large C&I retrofit programs and initiatives.
c) Special and Cross-Sector Studies
This research area reflects the fact that not all studies will fall into the two market
categories above, and some studies may be cross-sector in nature. Some types of studies in this
research area could include: cross-sector free ridership and spillover studies, non-energy
impacts, behavioral programs, community-based pilots, and marketing, public education, and
outreach activities.
5.
Transition to Statewide Plan
The Program Administrators overcame many obstacles during the last three-year plan to
transition from individual evaluation efforts to the current statewide approach.
Although some research was already being evaluated on a statewide basis, most was not
and some had never before been conducted. The PAs successfully implemented an evaluation
plan to transition to a statewide framework and build the platform for the robust evaluation
framework that exists today in Massachusetts. In making this transition, the PAs overcame
challenges related to (a) conducting the necessary studies to evaluate the 2009-2011 calendar
year programs; (b) working with individual Program Administrators’ procurement departments
to adjust to the new framework that required large multi-year umbrella RFPs covering all studies
in a given research area on a much larger dollar scale then employed before (e.g., some RFPs
may involve $5 million - $10 million of work over a three year period); (c) increased
coordination between Program Administrators; (d) coordinating the old and new evaluation
efforts; (e) differences in program tracking systems; (f) long-standing differences in evaluation
methodologies and approach; and (g) hiring additional staff to manage the increased focus on
EM&V. Some challenges still remain, but experience has informed the PAs about how to better
coordinate planned studies with those being conducted by Program Administrators in other
states, as well as studies being performed regionally under the NEEP EM&V Forum, and thus
avoid unnecessarily duplicating studies.
6.
Evaluation Budgets
238
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 244 of 274
As set forth in the Term Sheets, by agreement with the Council’s consultants, DOER, and
the Attorney General, the Program Administrators will allocate at least $69.2 million for
combined electric and gas evaluation and market research over the three years of the Plan. This
Plan calls for three-year EM&V budgets of nearly $70 million, somewhat over the base level
called for in the Term Sheets. The evaluation and market research budget was based on several
factors, including historical evaluation costs and an expected higher cost of evaluation activities
for codes and standards initiatives and the quantification of market effects. Although historical
evaluation costs may have been less than evaluation budgets for some programs, the natural lag
of evaluation costs needs to be taken into account when developing the evaluation budget for the
three-year plan. Since evaluation activities typically occur after program implementation
activities, evaluation costs can lag up to several years.
7.
Types of Evaluation Functions
EM&V refers to the systematic collection and analysis of information to document the
impacts of energy efficiency programs and improve the effectiveness of these programs. EM&V
includes the following types of studies:
•
Measurement and Verification refers to the measurement of gross savings
achieved in individual buildings.
•
Impact Evaluation refers to the measurement of net or gross savings achieved
within overall program populations.
•
Market Evaluation refers to the measurement of the effects that programs have on
the structure and functioning of their target markets.
•
Process Evaluation refers to the systematic assessment of programs for the
purpose of documenting their operations and developing recommendations to
improve their effectiveness.
•
Market Characterization or Assessment refers to the systematic assessment of
energy efficiency markets for the purpose of improving the effectiveness of
programs targeting those markets.
•
Evaluation of Pilots refers to EM&V activities intended to assess the
effectiveness of pilot programs, determine their potential for full-scale
implementation, and develop recommendations for any changes in program
approach. Under the new framework, evaluation of pilots will occur under the
research area most closely related to the market being targeted.
8.
Specific Evaluation and Monitoring Activities for 2013-2015
In consultation with the Consultants and the EMC, the Program Administrators will
explore a wide range of topics over the next planning phase to address the EM&V needs of all
stakeholders as well as any policy and planning initiatives of the Commonwealth that will
require EM&V support.
239
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 245 of 274
The Program Administrators and Consultants recognize the need for a strategic long-term
EM&V plan for the Three-Year Plan period. In order to achieve this, it is the intention of the
EMC to hold planning summits in early 2013 for each of the three research areas. Doing so will
enable the Program Administrators and Consultants to strategically identify evaluation needs for
the coming Three Year Plan. This will also allow the Program Administrators and Consultants
to plan future evaluation efforts subject to the Department’s direction in D.P.U. 11-120.
In addition to the strategic planning process outlined above, the Program Administrators
have committed to evaluating the following specific projects over the course of the Three-Year
Plan:
•
Codes and Standards: It is the intent of the Program Administrators to support the
proposed Residential and Commercial & Industrial Codes & Standards initiatives
with appropriate, timely evaluation. Codes & Standards evaluation plans will be
developed after program planning is complete.
•
Behavioral & Outreach Initiatives: The Program Administrators will continue to
support behavioral and outreach initiatives, assessing the program effects on both
electric and gas customers.
•
Quantification of Market Effects: Subject to the Department’s direction in
D.P.U. 11-120, the Program Administrators propose to undertake studies to quantify
market effects and naturally occurring energy efficiency, as well as identifying
baseline and program-induced market changes. 35
The first round of approximately 45 statewide EM&V studies was completed between
2010 and 2011. The second round of approximately 30 statewide EM&V studies has been
completed and included in the 2011 Annual Report filed in August 2012 (D.P.U. 12-51
through D.P.U. 12-61). It is expected that the results of the second round of studies will
inform the third round of EM&V studies, to take place between 2012 and 2013.
In addition to the statewide EM&V studies that were included in each PA’s 2011
Annual Report, a list of impact evaluation results that were finalized by the date of this Plan
(but not included in the 2011 Annual Reports) follows. Please see Appendix P for the full
studies.
35
As explained in the PAs’ comments on net savings, which were filed jointly with other stakeholders,
naturally occurring energy efficiency refers to customers who took action, but would have taken the action
without an energy efficiency program. In-program naturally occurring energy efficiency corresponds to
free ridership. See Joint Savings Comments, Exh. A, D.P.U. 11-120, Phase I (May 7, 2012).
240
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 246 of 274
Study #
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
Residential Studies
Massachusetts 2011 Baseline Study of Single-family Residential New Construction
Home Energy Services: Contractor Charettes in Support of Lost Opportunity Metric
Home Energy Services Impact Evaluation
Results of the Massachusetts Onsite Compact Fluorescent Lamp Surveys
Massachusetts Residential Retail Products: Consumer Electronics Saturation
Massachusetts Consumer Electronics Potential Qualitative Research Study
Residential Pilot Studies
Wi Fi Programmable Controllable Thermostat Pilot Program Evaluation
Impact Evaluation of the 2011-2012 ECM Circulator Pump Pilot Program
Impact Evaluation of the 2011-2012 Boiler Reset Control Pilot Program
Commercial & Industrial Studies
Small Business Direct Install Program: Pre/Post Lighting Occupancy Sensor Study
Code Compliance Baseline Study
Special & Cross-Cutting Studies
Commercial and Industrial Non-Energy Impacts Study
K - 12 Energy Efficient Education Program Literature Review Findings
Post-Secondary Energy Efficient Education Program Literature Review Findings
Detailed Findings from CLC Smart Home Energy Monitoring Pilot Interim Impacts
Evaluation
An Estimate of Direct Full Time Equivalent (FTE) Employment in 2011 Supported
by Mass Save Energy Efficiency Programs
The Program Administrators are continuing to determine the proposed studies for the
next three years. The below table includes studies that are in progress or have been planned.
These studies and schedules are tentative and subject to change based, among other things,
on the results of in-progress evaluation studies. The current list of proposed studies is as
follows:
Proposed Studies
Status
Residential Studies
Residential New Construction - Net Impact Study
Residential New Construction - Incremental Cost Study
Residential Cooling & Heating Equipment (Cool Smart) - Net to Gross Study
Residential High Efficiency Heating Equipment (HEHE) - Net to Gross Study
Residential Lighting - Shelf Stocking Survey
Residential Lighting - Supplier Interviews
Residential Lighting - Regional Operating Hours Study
Residential Retrofit - Preweatherization Barrier Initiative Pilot
Residential Retrofit - Focused Potential Study
Residential Retrofit - Realization Rate Calibration
In Progress
In Progress
In Progress
In Progress
Planned
In Progress
Planned
In Progress
In Progress
Planned
241
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 247 of 274
Low Income - Programmable Thermostat and Lighting Operating Hours
Study
Residential Pilot Studies
2012 Lighting Controls Pilot
Commercial & Industrial Studies
Small C&I - Billing Analysis
Large C&I - Prescriptive Measure Impact Evaluation (VSDs)
Large C&I - Study to assess the mid-sized C&I customers
Large C&I - 2011 CHP Impact Evaluation
Large C&I - Custom Electric Impact Evaluation (Refrigeration, Motor, Other)
Large C&I - 2011 Custom Gas Impact Evaluation
Large C&I - 2011 Prescriptive Gas Impact Evaluation
Large C&I - Upstream Lighting Impact & Process Evaluation
Large C&I - C&I Customer Profile
Large C&I - Existing Building Market Characterization
Large C&I - Lighting Controls Scoping Study
Large C&I - Whole System Approach Assessment
Large C&I - New Construction Market Characterization
Large C&I - Prescriptive Measure Impact Evaluation (Lighting)*
Large C&I - Boiler Baseline Study
Special & Cross-Cutting Studies
Community-Based Initiative - Study of Northampton/Pittsfield pilot
Residential Smart Energy Monitoring Pilot - Impact Evaluation (CLC)
Umbrella Marketing - Post-Campaign Study
C&I - Net to Gross (Gas)
J.
In Progress
In Progress
In Progress
In Progress
Detailed
Planning Phase
In Progress
In Progress
Detailed
Planning Phase
Detailed
Planning Phase
In Progress
Detailed
Planning Phase
Planned
Planned
Detailed
Planning Phase
Planned
In Progress
Detailed
Planning Phase
In Progress
In Progress
In Progress
Planned
Technical Reference Manual
The Massachusetts Technical Reference Manual for Estimating Savings from Energy
Efficiency Measures (“TRM”) documents how the energy efficiency Program Administrators
consistently, reliably, and transparently calculate savings resulting from the installation of
prescriptive energy efficiency measures. The TRM provides methods, formulas, and default
assumptions for estimating energy, peak demand, and other resource impacts from energy
efficiency measures. The TRM, which did not exist until the PAs developed the initial threeyear plan, is an excellent example of how the PAs work together, share data and best practices
and work to develop common assumptions that reflect state-of the-art EM&V results.
242
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 248 of 274
Building on the important new practices developed in the 2010-2012 plans, the Program
Administrators have developed a statewide Plan TRM, which contains planning assumptions for
each program year. The Plan TRM will be submitted along with each Program Administrator’s
three-year plan. This Plan Version TRM incorporates updates from all of the most recent
evaluation study results, as well as updates to baseline standards and new measures. The Plan
TRM is the basis for savings set forth in this Plan. The development and use of the TRM reflects
an important success of the Program Administrators’ ongoing 2010-2012 effort. Revised
versions of Plan Version TRM for 2013-2015 would be shared with the Consultants and LEAN.
K.
Performance Incentives
On January 28, 2010, the Department issued the Orders on the three-year energy
efficiency plans, which included the Electric Order in dockets D.P.U. 09-116 – D.P.U. 09-120
and the Gas Order in D.P.U. 09-121 – D.P.U. 09-128. The Orders approved most aspects of the
performance incentive mechanism proposed by the Program Administrators in their 2010-2012
Plans. 36 However, for certain aspects of the proposal regarding the allocation method of the
statewide pool and performance metrics, the Department ordered the Program Administrators to
work further with the Council and re-file these components with the Department for its review
and approval. For 2011, the Program Administrators worked closely with the Council in order to
update the allocation method in compliance with the Orders, as well as to propose updated
performance metrics. As a result of this effort, a comprehensive settlement was achieved on this
and other matters, which was filed on April 15, 2011, and is currently pending before the
Department (See D.P.U. 10-141 – 10-150). Similarly, for 2012, the Program Administrators
used the extensively reviewed 2011 method and performance incentive model as a basis for 2012
performance incentive allocations and updated performance metrics. Performance incentive
proposals applicable to 2012 efforts were filed with the Department on October 28, 2011 and are
also pending (See D.P.U. 11-106 through D.P.U. 11-116). For 2013-2015, the Program
Administrators have retained the performance incentive model that has been effective and fully
reviewed related to efforts in the initial three-year plan, with the incentive pool comparatively
reduced in accordance with the Term Sheet, which sets forth an integrated approach to savings,
budgets, and incentives. 37 In this discussion, the Program Administrators also summarize the
2013-2015 performance incentive amounts in the following manners: statewide; by component;
and by Program Administrator.
I.
Summary of the Orders on Performance Incentives in the Initial Three-Year Plan.
In the Electric Order and the Gas Order, the Department noted its support of the
following elements of the proposed incentive design:
1. The proposed statewide incentive pool.
a. The electric statewide incentive pool goals equal $22 million in 2011 and $25.5
million in 2012, assuming that goals on a statewide basis are equal to the goals
established by the Council. Electric Order at 93. The actual incentive pool can be
36
37
See Electric Order, at 93-125, 165, and 168-169; Gas Order at 79-115, 168-169, and 172-173.
If savings or budgets are materially altered, the PAs necessarily reserve their right to adjust incentive
approaches.
243
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 249 of 274
adjusted up or down according to actual goals. Id. at 111. The Department
approved the statewide goals. Id. at 112.
b. The gas statewide incentive pool goals equal $4.5 million in 2011 and $5.5
million in 2012, assuming that goals on a statewide basis are equal to the goals
established by the Council. The actual incentive pool can be adjusted up or down
according to actual goals. Gas Order at 100. The Department approved the
statewide goals. Id. at 101.
2. The structure of the proposed incentive mechanism includes three components: the
Savings Mechanism (focusing on the dollar value of benefits); the Value Mechanism
(focusing on the dollar value of net benefits); and Other Performance Metrics.
a.
3.
The three-pronged structure of the incentive mechanism was approved in the
Electric Order at 113, 124 and the Gas Order at 101-102, 114. The Department
noted that similar mechanisms have been approved in the past.
Common payout amounts under both the Savings and Value Mechanisms.
a. The approval for common payout rates in the Electric Order is found on pages
113-114 with reference to Table D at 96.
b. The approval for common payout rates in the Gas Order is found on pages 102103 with reference to Table C at 83.
4. The proposed allocation of the statewide incentive pool to each Program Administrator
(excluding Cape Light Compact (“CLC”)) for 2010 but not for 2011 or 2012.
a. The allocation of the statewide electric incentive pool to each Program
Administrator was based on that Program Administrator’s contribution to the
statewide savings goals as expressed in MWh. However, the allocation for each
of the three components was not consistent among the Program Administrators;
the savings component amount was allocated on the basis of the dollar value of
savings, the value component amount was allocated on the basis of the dollar
value of net benefits, and the performance metrics component was derived to total
the overall allocation method based on savings goals. Although the Department
approved the allocation of the components for 2010, the Program Administrators
were directed to revise the allocation method for 2011 and 2012 so that, to the
extent possible, the revised allocation method would result in (1) uniform
statewide payout rates for the savings and value components, and (2) an allocation
of incentive dollars across the three components for each Program Administrator
that, on a percentage basis, approximates the statewide allocation across the three
components, as endorsed by the Council and approved by the Department. See
Electric Order at 114-116.
b. The allocation of the statewide gas incentive pool to each Program Administrator
was based on a similar methodology. This methodology produced some
anomalous results for certain Program Administrators that required special
adjustments. Similar to the electric side, the Department approved the gas
Program Administrators’ component allocation for 2010, but the Program
Administrators were ordered to revise the allocation methodology in 2011 and
2012. See Gas Order at 103-105.
244
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 250 of 274
c. A revised allocation methodology was proposed in the 2011 mid-term
modification filings settlement proposal. The revised methodology was created
following extensive discussions with the Council, and addresses the concerns of
the Department, as noted in the Orders.
5. Specific limitations on how EM&V results would be used to determine performance for
both the electric and gas Program Administrators. Electric Order at 124; Gas Order
at 114.
However, the Department did not accept: (1) the proposed allocation method for 2011
and 2012 as mentioned above; or (2) the proposed performance metrics for 2010, stating that it
did not accept an EM&V “Omnibus Metric,” and directed the Program Administrators to include
a financing and funding metric. 38 The Department further ordered that a cap on the earned
incentive mechanism apply both in total and by component. The cap by component and overall
has been set at 125% of Design level performance. 39
II.
Allocation Proposal for 2013 – 2015
The Program Administrators propose the following allocation method for 2013-2015,
based directly on the method set forth in each Program Administrator’s 2011 and 2012 mid-term
modification. Similar to the 2011 and 2012 allocation methodology, in 2013-2015, the statewide
incentives for the savings component of the incentive pool are allocated on the basis of the dollar
value of benefits using common payout rates as approved by the Department. The statewide
incentives for the value component of the incentive pool are allocated on the basis of the dollar
value of net benefits using common payout rates as approved by the Department. The statewide
incentives for the performance metric component of the incentive pool are allocated on the basis
of the forecasted 40 amount of net benefits. The total incentive is the sum of the three
components. This methodology was followed for allocating the incentive dollars among
Program Administrators, as well as to each sector and to each program.
This proposed allocation model results in a similar distribution of each Program
Administrator’s incentives among the three components. The proposed payout rates for 20132015 remain constant for all Program Administrators 41 and for each year in the Plan.
38
In response to the Electric Order and the Gas Order, the Program Administrators filed a revised
performance metric proposal on March 12, 2010. The Department subsequently approved the revised
performance metrics on August 10, 2010 with the exception of the Deeper Savings metric. On September
14, 2010 the Program Administrators filed a compliance filing in regard to changing the baseline year of
that metric.
39
The Program Administrator proposals had thresholds for the savings and value incentive mechanisms of
75% of design or target level performance.
40
Once approved, these target amounts are to remain constant regardless of the actual net benefits achieved.
In other words the performance metric target does not change once the program year has started. This
allows for certainty in planning and forecasting for the Program Administrators as they are aware of the
value of the metrics and the work involved.
41
Except CLC, which does not participate in performance incentives.
245
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 251 of 274
Distribution of Performance Incentive for Electric Program Administrators in 2013 – 2015:
Percent of Total Incentive
State
Savings
Value
Metrics
Total
Residential
14.0%
8.1%
3.2%
25.4%
Low Income
2.5%
1.1%
2.5%
6.2%
C&I
39.5%
25.7%
3.2%
68.4%
Total
56.0%
35.0%
9.0%
100.0%
National Grid
Savings
Value
Metrics
Total
Residential
13.5%
7.8%
3.3%
24.6%
Low Income
2.5%
1.1%
2.6%
6.2%
C&I
39.4%
26.5%
3.3%
69.2%
Total
55.5%
35.4%
9.1%
100.0%
NU
Savings
Value
Metrics
Total
Residential
14.5%
8.6%
3.2%
26.3%
Low Income
2.5%
1.1%
2.5%
6.1%
C&I
39.4%
24.9%
3.2%
67.6%
Total
56.5%
34.6%
8.9%
100.0%
Unitil
Savings
Value
Metrics
Total
Residential
10.1%
4.7%
3.0%
17.8%
Low Income
3.5%
1.2%
2.3%
7.0%
C&I
45.6%
26.7%
3.0%
75.3%
Total
59.2%
32.5%
8.3%
100.0%
246
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 252 of 274
Distribution of Performance Incentive for Gas Program Administrators in 2013 – 2015:
Percent of Total Incentive
State
Savings
Value
Metrics
Total
Residential
25.1%
12.5%
3.2%
40.8%
Low Income
7.8%
4.3%
2.5%
14.6%
C&I
23.1%
18.2%
3.2%
44.6%
Total
56.0%
35.0%
9.0%
100.0%
National Grid
Savings
Value
Metrics
Total
Residential
24.8%
10.1%
3.2%
38.1%
Low Income
9.2%
6.1%
2.5%
17.7%
C&I
22.8%
18.2%
3.2%
44.2%
Total
56.8%
34.4%
8.8%
100.0%
NSTAR
Savings
Value
Metrics
Total
Residential
21.8%
11.0%
3.2%
36.1%
Low Income
6.6%
2.8%
2.5%
12.0%
C&I
28.0%
20.8%
3.2%
52.0%
Total
56.5%
34.6%
8.9%
100.0%
Columbia
Savings
Value
Metrics
Total
Residential
30.4%
20.6%
3.4%
54.4%
Low Income
5.5%
1.8%
2.6%
10.0%
C&I
18.0%
14.2%
3.4%
35.6%
Total
53.9%
36.7%
9.4%
100.0%
Unitil
Savings
Value
Metrics
Total
Residential
14.4%
4.7%
3.2%
22.2%
Low Income
7.7%
0.3%
2.5%
10.4%
C&I
35.5%
28.7%
3.2%
67.4%
Total
57.6%
33.7%
8.8%
100.0%
Berkshire
Savings
Value
Metrics
Total
Residential
21.9%
9.5%
3.5%
34.9%
Low Income
7.4%
4.8%
2.7%
14.9%
C&I
23.5%
23.3%
3.5%
50.2%
Total
52.8%
37.5%
9.7%
100.0%
NEG NA &FR
Savings
Value
Metrics
Total
Residential
26.1%
14.2%
3.3%
43.6%
Low Income
8.7%
3.9%
2.5%
15.2%
C&I
20.7%
17.3%
3.3%
41.3%
Total
55.5%
35.5%
9.0%
100.0%
247
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 253 of 274
III.
2013 - 2015 Performance Metrics
The Program Administrators continue to include performance metrics as a component of
the incentive mechanism based on a desire by the Council to retain metrics and set forth as an
element of the Term Sheets supported by DOER, the Attorney General, and the PAs in the
context of a negotiated, integrated agreement. The Council and the Program Administrators
have not yet come to an agreement on either the performance metrics or the number of
performance metrics. Accordingly, the percentages among the components of the incentive
mechanism (Savings, Value, and Performance Metrics) may change slightly to reflect the final
number and meaningfulness of the performance metrics.
The Program Administrators plan to work collaboratively with the Council to develop a
limited number of performance metrics applicable to efforts in 2013-2015. A supplemental
filing to include the agreed-to performance metrics along with an update to the performance
incentive models if necessary will be submitted to the Department upon completion of that
effort.
If the Department does not approve performance metrics as a component of the incentive
mechanism, the Program Administrators will reallocate the incentive dollars for performance
metrics to the Savings and Value mechanisms. Disapproval of a specific performance metric by
the Department will not result in a reduction in the statewide incentive pool.
IV.
Statewide Incentive Pool for 2013-2015
Statewide, the design level incentive is set at $80,000,000 for electric efforts and at
$16,000,000 for gas efforts (the design level incentive pool can vary up or down from these
amounts based on the relative level of annual energy savings, statewide, in the Three Year Plan
compared to the annual savings goal set for design purposes). These amounts flow from
discussions with the Council and the Term Sheets and are tied to agreed-to annual energy
savings targets, budgets, and expectations about the expected cost of annual savings statewide.
The statewide incentive pool will not change as a result of changes to avoided costs that may
occur during the term of this Plan.
IV.
Summary of 2013-2015 Incentives
The models set forth as Exhibit 1, Appendix J-1 (Electric) and Exhibit 1, Appendix J-2 (Gas)
provide calculations of the 2013-2015 incentives based on the three-year Plan proposals of each
of the Program Administrators for electric and gas, respectively. For the electric Program
Administrators this is a 24 page exhibit and for the gas Program Administrators this is a 36 page
exhibit. The calculations are described briefly below. Additionally, a summary of the 20132015 incentives is provided below.
A.
Calculation Exhibits
248
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 254 of 274
Exhibit 1, Appendix J-1 (Electric) provides the derivation of the 2013-2015 electric
incentives at the Design level of performance. Similarly, Exhibit 1, Appendix J-2 (Gas) provides
the derivation of the 2013-2015 gas incentives at the Design level of performance.
Pages 1 and 2 of both Appendices J-1 and J-2 are input pages that summarize each
Program Administrator’s 2013-2015 goals, benefits and costs (excluding performance
incentives). The common payout rates used to derive projected Design level incentives under the
savings and value components are also noted on this page. The Program Administrators note
that if avoided costs change compared to what has been used here, either as a result of orders
issued by the Department in D.P.U. 11-120 or due to a study where avoided costs are updated,
the common payout rates applicable under the savings and value components will need to be
updated. However, those changes will not impact the size of the incentive pool or Program
Administrator-specific design level incentives.
Page 3 derives the value of the performance metric pool. As described above, the 20132015 statewide performance incentives are adjusted by the percentage of the actual targets to the
Council recommended statewide targets. At a statewide level for both electric and gas, 56% of
the incentive has been allocated to the Savings Mechanism, 35% to the Value Mechanism, and
9% has been allocated to performance metrics, all in accordance with the Term Sheets. To
determine the payout rate under the Savings Mechanism, the adjusted statewide incentive pool is
multiplied by 56%, the portion of the statewide performance incentives allocated to the savings
component, and then that amount is divided by the projected dollar value of benefits statewide
from proposed efforts. Similarly, to determine the payout rate under the Value Mechanism, the
adjusted statewide incentive pool is multiplied by 35%, the portion of the statewide performance
incentives allocated to the value component, and then that amount is divided by the projected
dollar value of net benefits statewide from proposed efforts. The remainder of the adjusted
statewide incentive pool, 9%, is allocated to performance metrics.
Similar to 2011 and 2012, the Program Administrators are proposing to allocate the
statewide funding for performance metrics to each Program Administrator on the basis of
forecasted net benefits. Through negotiations in 2011, the Program Administrators further
allocated the performance metrics to each sector as follows: 36% to residential, 28% to lowincome and 36% to Commercial & Industrial. These sector allocations were maintained in 2012
and in this Plan but may be adjusted when specific performance metrics are developed as noted
above.
Page 4 derives adjusted thresholds for performance percentages under the savings and
value mechanisms for Program Administrators who have agreed to goals in excess of the targets
recommended by the Council in a given year. For those Program Administrators, the threshold
level of performance is based on achieving 75% of the savings that correspond to the percent of
sales goal for the Program Administrator in the year in 2013 or 2014 and 80% of the savings that
correspond to the percent of sales goal for the Program Administrator in 2015. For Program
Administrators with savings goals at or below the Council recommendations, the threshold for
performance in 2013 and 2014 is 75% of Design and in 2015 is 80% of Design.
249
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 255 of 274
Pages 5 to 20 of the electric appendix and Pages 5 to 32 of the gas appendix provide the
calculation of potential Design level incentives under the savings mechanism, the value
mechanism, and performance metrics on a statewide basis (excluding CLC) and for each
individual Program Administrator. Lines 1 through 3 determine the savings amount by
multiplying the dollar value of benefits by the savings mechanism payout rate. Lines 4 through 6
determine potential Design level incentives under the value mechanism by multiplying the dollar
value of net benefits by the value mechanism payout rate. Lines 7 through 9 provide the
derivation of potential Design level incentives for the performance metrics by using the
forecasted amount of net benefits multiplied by the factor derived on page 2. Line 10 provides
the total performance incentive. Lines 11 through 16 provide the derivation of potential Design
level incentives for hypothetical performance metrics in each sector. This information is
provided for illustrative purposes only as actual performance metrics, including the number of
metrics in each sector, have not yet been determined.
Pages 17 - 24 of the electric appendix and pages 30 - 36 of the gas appendix provide
summary information about performance incentives by sector and by component of the incentive
mechanism.
Exhibit 1, Appendix J-1 (Electric) and Exhibit 1, Appendix J-2 (Gas) do not show how
the performance incentives are further allocated to specific programs for benefit/cost screening
purposes. The program allocation assumptions are summarized below:
•
The savings component amount is allocated to programs on the basis of program dollar of
benefits.
•
The value component amount is allocated to programs on the basis of program dollar of
net benefits.
•
On a preliminary basis, the sector level performance metric funds have been allocated to
all programs in the sector based on net benefits. Once specific performance metrics
proposals are developed, the allocation will be updated to take into account the focus of
the specific metrics.
•
Any programs with negative allocations (efforts with projected costs without identified
projected savings) are reallocated to other programs within the sector.
B.
Summary
A summary of the threshold, design, and exemplary performance incentive amounts by
component of the proposed incentive mechanism for 2013-2015 is provided for each electric and
gas Program Administrator, below.
250
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 256 of 274
Electric:
Summary of 2013 - 2015 Performance Incentives by Program Administrator
National Grid
Savings
Value
Metrics
Total
Threshold(1)
16,689,790
10,654,464
2,768,721
30,112,975
Design
22,054,750
14,077,039
3,625,276
39,757,065
Exemplary
27,568,438
17,596,299
4,531,594
49,696,331
NU
Savings
Value
Metrics
Total
Threshold(1)
16,927,569
10,383,791
2,689,823
30,001,183
Design
22,360,686
13,713,847
3,521,303
39,595,836
Exemplary
27,950,858
17,142,309
4,401,629
49,494,795
Savings
Value
Metrics
Total
Threshold(1)
319,330
175,726
44,693
539,750
Design
416,074
228,808
58,485
703,367
Exemplary
520,092
286,010
73,107
879,209
Unitil
Note: (1) For National Grid and NU, the threshold amount under the Savings and
Value mechanisms is equal to 75% of the EEAC recommended goal for the
Company in 2013 and 2014 and to 80% of the EEAC recommended goal for the
Company in 2015. For Unitil, the Threshold amount under all components is
equal to 75% of Design in 2013 and 2014 and to 80% of Design in 2015. The
Thresholds for Metrics are set at 75% of Design in 2013 and 2014 and at 80% in
2015 for all Program Administrators.
251
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 257 of 274
Gas:
Summary of 2013 - 2015 Performance Incentives by Program Administrator
National Grid
Savings
Value
Metrics
Total
Threshold(1)
3,437,954
2,082,114
551,820
6,071,888
Design
4,614,457
2,793,101
718,770
8,126,328
Exemplary
5,768,071
3,491,377
898,462
10,157,911
NSTAR
Savings
Value
Metrics
Total
Threshold(1)
1,580,561
968,849
253,214
2,802,624
Design
2,091,624
1,281,783
329,830
3,703,237
Exemplary
2,614,530
1,602,228
412,287
4,629,046
Savings
Value
Metrics
Total
Threshold(1)
1,357,432
923,630
236,751
2,517,813
Design
1,771,089
1,204,643
308,793
3,284,525
Exemplary
2,213,862
1,505,803
385,991
4,105,656
Savings
Value
Metrics
Total
Threshold(1)
69,688
40,853
10,626
121,167
Design
90,665
53,019
13,797
157,481
Exemplary
113,331
66,274
17,246
196,851
Savings
Value
Metrics
Total
Threshold(1)
179,830
128,048
33,128
341,005
Design
234,156
166,533
43,096
443,785
Exemplary
292,695
208,167
53,870
554,731
NEG NA &FR
Savings
Value
Metrics
Total
Threshold(1)
122,255
78,081
19,898
220,234
Design
159,401
101,790
25,938
287,129
Exemplary
199,251
127,238
32,422
358,911
Columbia
Unitil
Berkshire
Note: (1) The threshold level of performance for Savings and Value is equal to 75% in
2013 and 2014 and 80% in 2015 of Design unless goals for the Program Administrator
exceed EEAC recommendations in the year. If goals for the Program Administrator
exceed those recommendations, the threshold level is equal to the adjusted threshold
percentage of Design as shown on Pef Met Pool Lines 44 - 49. The threshold level of
performance for Metrics for all Program Administrators is 75% in 2013 and 2014 and
80% in 2015.
252
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 258 of 274
L. Cost Recovery
1.
Overview
The Program Administrators emphasize that cost recovery, including the recovery of a
performance incentive, and, for those PAs without a Department-approved decoupling
mechanism, LBR, is a critical element of this Plan. In order for the Program Administrators to
pursue the aggressive goals set forth in this Plan, it is essential that the cost-recovery process
provide a full and fair opportunity for the Program Administrators to be made economically
whole for aggressively pursuing sales-reducing energy efficiency efforts and to earn a reasonable
return on this investment based upon their performance and achievement. While Department
approval of the proposed Plan should ensure cost-recovery of Plan related costs, LBR, and
performance incentives, the details related to cost-recovery mechanisms will be addressed in
separate proceedings and may be affected by orders to be issued by the Department in D.P.U. 11120.
Pursuant to the GCA, the Department must approve a fully reconciling funding
mechanism if, after reviewing a Program Administrator’s proposed Plan, it determines that the
Plan ensures that the PA has identified and shall capture all energy efficiency and demand
reduction resources that are cost effective or less expensive than supply. G.L. c. 25, В§ 21(d)(2).
As part of this determination, the Department must approve recovery of all expenditures for the
Program Administrator’s energy efficiency measures that are screened through the costeffectiveness test described herein in Section III.A.3. G.L. c. 25, § 21(d)(2). In the event that
program costs exceed available revenue sources, the Department must approve a fully
reconciling funding mechanism to ensure that the costs for all cost-effective energy efficiency
measures are recovered from customers. G.L. c. 25, В§ 21(b)(3). The funding sources available
for electric energy efficiency programming are discussed in Section III.C. See G.L. c. 25, В§ 19;
G.L. c. 25, §§ 21(b)(2)(vii) and 21(d)(2); D.P.U. 08-50-B Guidelines §§ 3.2.1 and 3.2.2.
Therefore, in reviewing a Program Administrator’s proposed Plan, the Department must
assure that the Program Administrator is able to implement all Plan offerings that are found to be
cost-effective, even if the costs associated with providing those offerings are in excess of the
established funding sources provided for in the statutorily-authorized energy efficiency charge
(equal to 0.250Вў per kilowatt hour for electric Program Administrators) and through other
sources. G.L. c. 25, В§ 19.
a. Mechanisms Specific to Electric Program Administrators
In this context, the electric distribution companies have each filed with the Department
proposed tariffs or modifications to their respective energy efficiency charge tariffs that include
an EERF factor to recover and reconcile their respective energy efficiency costs in a particular
program year with the revenue it receives through: (1) the statutorily-authorized energy
efficiency charge; (2) participation in the FCM; (3) proceeds from participation in cap-and-trade
programs such as the RGGI; (4) for electric PAs without a Department-approved decoupling
mechanism, LBR; and (5) proceeds available from other private or public funds that may be
available for energy efficiency or demand resources, as appropriate. This is consistent with the
Legislature’s mandates established in G.L. c. 25, §§ 19 and 21. In addition to costs associated
253
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 259 of 274
with program implementation and performance incentives, and consistent with Department
directives, each electric Program Administrator’s respective energy efficiency tariffs will also
include, for those Program Administrators without an approved decoupling mechanism, recovery
of LBR. The factor is calculated as the sum of a Program Administrator’s energy efficiency
costs, net of that Program Administrator’s energy efficiency revenues (from sources outlined
above), divided by the forecasted kilowatt-hour sales for the previous calendar year. 42
The electric Program Administrators will submit new EERFs annually for calendar years
2013, 2014, and 2015 during the course of the implementation of this Three-Year Plan. 43
b. Mechanisms Specific to Gas Program Administrators
In Revenue Decoupling, D.P.U. 07-50-A, at 83-84 (2008), the Department determined
that allowance of LBR recovery for gas companies through the term of the initial three-year
energy efficiency plans is consistent with the Department’s expectation that, with limited
exceptions, distribution companies will be operating under decoupling plans by year-end 2012.
However, those distribution companies that are subject to Performance-Based Ratemaking or
rate plans that extend past 2012, and that do not voluntarily terminate such plans before their
expiration, will be allowed to recover LBR through the remainder of their existing rate plans.
D.P.U. 07-50-A at 83-84. In this context, and consistent with the standard that governs the
calculations for and recovery of LBR, those gas Program Administrators’ respective energy
efficiency tariffs will also include recovery of LBR. 44 For gas companies, LBR is defined as the
non-gas portion of a gas utility’s base rates that is lost between rate cases as a result of reduced
sales cause by the implementation of demand-side management programs. Boston Gas
Company, D.P.U. 90-17/18/55, at 139 (1990).
The costs associated with LBR, for gas Program Administrators for whom an approved
revenue decoupling mechanism is not in effect, will continue to be reconciled through the energy
efficiency surcharge (“EES”) calculation included in each Program Administrator’s local
distribution adjustment clause (“LDAC”). The EES is applied to therm sales of a particular
company to recover from firm ratepayers any demand side management program costs and
associated expenditures. Included in that calculation is a determination of the Program
Administrator’s lost margins, determined by multiplying the rate category therm savings by the
respective rate category recovery rate. Where applicable, the gas Program Administrators will
include their LBR calculations for calendar year 2013 in their respective PA-specific Plan filings
42
LBR recovery with respect to NSTAR Electric will be consistent with the terms and conditions of the
Settlement Agreement among NSTAR Electric, Northeast Utilities, DOER and the Attorney General dated
February 15, 2012 and filed in docket D.P.U. 10-170.
43
The DPU is investigating potential changes related to how the EERF is set in DPU 11-120. If changes are
enacted, the PAs will comply with those directives.
44
The base year measurement dates for LBR (and related recovery logistics) vary by PA.
254
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 260 of 274
with the Department, and will submit new LBR calculations annually for calendar years 2014
and 2015 during the course of the implementation of this three-year statewide Plan. 45
2.
Calculation of EERF 46
The electric Program Administrators calculate their EERF estimates in the following
manner; as directed in the Department’s orders on the Program Administrators’ 2009 energy
efficiency programs (see, e.g., Cape Light Compact, D.P.U. 08-113; Fitchburg Gas & Electric
Light Company, D.P.U. 08-116; National Grid, D.P.U. 08-129; NSTAR Electric Company,
D.P.U. 08-117; Western Massachusetts Electric Company, D.P.U. 08-118).
•
Funds collected through the SBC, FCM, and RGGI are allocated to each customer sector
in proportion to the sector’s kWh consumption. However, consistent with G.L. c. 25
В§ 19(c), at least 10 percent of the amount expended for electric energy efficiency
programs shall be spent on low-income energy efficiency efforts;
•
The EERF charged to low-income customers is calculated by dividing (1) the amount of
EERF revenue required to fund the low income programs, by (2) total company-wide
(i.e., the sum of all customer sectors) kWh sales;
•
The EERF charged to residential customers is calculated as the sum of (1) the amount of
EERF revenue required to fund residential programs divided by total residential kWh
sales and (2) the low-income EERF, as described above; and
•
The EERF charged to C&I customers is calculated as the sum of (1) the amount of EERF
revenue required to fund C&I programs divided by total C&I kWh sales and (2) the lowincome EERF, as described above.
3.
Department Proceedings in D.P.U. 11-120 (Phase II)
The Department’s review of certain energy efficiency matters, including simplifying cost
recovery approaches is ongoing, with the Department having put forward a straw proposal in
D.P.U. 11-120 (Phase II) and revised energy efficiency guidelines on September 21, 2012. The
final results of the Department’s ongoing efforts in D.P.U. 11-120 (Phase II) may create
enhancements in cost recovery approaches which would be implemented by the Program
Administrators on a prospective basis. The Program Administrators note their appreciation of
the effective technical sessions that had been convened and led by the Department in D.P.U. 11120 (Phase II).
45
LBR recovery with respect to NSTAR Gas will be consistent with the terms and conditions of the
Settlement Agreement among NSTAR Gas, Northeast Utilities, DOER and the Attorney General dated
February 15, 2012 and filed in docket D.P.U. 10-170.
46
The Program Administrators note that this Plan is not establishing the details of the EERF or LBR
recovery. Details of the EERF formula and amount have been determined in separate Department
proceeding(s).
255
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 261 of 274
4.
Residential Conservation Services Surcharge
Gas PAs currently collect their Residential Conservation Services (“RCS”) surcharge in
annual filings pursuant to G.L. c. 164 App. §§ 2-1 through 2-10, 220 C.M.R. §§ 7.00 et seq. As
enacted on August 3, 2012, section 32 of an Act Relative to Competitively Priced Electricity in
the Commonwealth, St. 2012, c. 209, (“Energy Act of 2012”), states that if a utility includes RCS
as part of an energy efficiency investment plan filed pursuant to G.L. c. 25, В§ 21, the utility shall
have satisfied the requirements of subsection (b) of section 7 of chapter 465 of the acts of 1980,
as most recently amended by chapter 164 of the acts of 1997. Accordingly, this Plan includes
proposed operating budgets for the RCS program, having been combined with the Home Energy
Services core initiative in the Whole House program. Consequently, the gas Program
Administrators propose to eliminate the separate gas RCS surcharge and allow recovery of RCS
funds through their respective energy efficiency surcharges, consistent with how the electric PAs
currently recover their RCS charges.
M.
Mid-Term Modifications
The Program Administrators continue to view the three-year planning and review process
as an opportunity to anticipate and analyze a wide range of possibilities in developing the Plan.
The Program Administrators, however, have also recognized that planning flexibility during the
three-year term (the “Term”) is critical. It is during the Term that Program Administrators
monitor and evaluate the effectiveness of various programs and make determinations that certain
enhancements, reallocations, or modifications may be appropriate to best achieve the Plan’s
energy efficiency goals. Having planning flexibility allows ongoing revisions and enhancements
to the Plan in order to reflect in-the-field conditions, actual achievements, technological
advances and state-of-the-art techniques without unduly inhibiting Program Administrators with
the need to seek advance regulatory review and approval (with accompanying administration
costs and implementation delays).
While the Program Administrators welcome flexibility to make ongoing revisions and
refinements, the Program Administrators also appreciate the importance of transparency and
oversight. The Department has balanced these interests in formulating the governing guidelines
for Plan modifications, as set forth in its Order in D.P.U. 08-50-A. Indeed, the Department
expects that Program Administrators will make minor modifications as a matter of course but
that significant modifications will require Department review and approval. D.P.U. 08-50-A
at 61. More specifically, D.P.U. 08-50-A expressly authorizes the Program Administrators to
make modifications, reallocations and enhancements to their individual plans during the term of
those plans (including, without limitation, budgetary reallocations and additions or subtractions
of program measures). However, any such modification, reallocation or enhancement shall be
submitted to the Department (with a copy to the Council) for the Department’s review and
approval (with the advance opportunity for the Council to comment and work with the Program
Administrators) if the contemplated modification, reallocation or enhancement meets any of the
following prescribed conditions:
(1) the addition of a new program or the termination of an existing program; (2) a
change in a program budget of greater than 20 percent; (3) a program
modification that leads to an adjustment in savings goals that is greater than 20
256
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 262 of 274
percent; or (4) a program modification that leads to a change in performance
incentives of greater than 20 percent.
D.P.U. 08-50-A at 64; D.P.U. 08-50-B Guidelines В§ 3.8.2. 47
Subsequent to D.P.U. 08-50-A, the Department provided further guidance regarding the
need for Department approval of proposed mid-term program modifications. Specifically, in
D.P.U. 10-106, the Department addressed the implementation of the modification thresholds
contained in the D.P.U. 08-50-B Guidelines, noting that “the Department implemented
Guidelines В§ 3.8.2 with the intent that Program Administrators are required to seek Department
approval for a program budget modification that is 20 percent greater than the program’s threeyear budget.” D.P.U. 10-106, at 6-9, emphasis added.
As the Department expressly recognizes, it was the intent of the Legislature to establish a
three-year cycle for budgeting, planning, and regulatory review of energy efficiency programs.
Id. As such, the Program Administrators propose to apply the D.P.U. 08-50-B Guidelines, as
clarified by the Department in D.P.U. 10-106, supra, to program modifications that lead to
savings adjustments during the three-year term of the Plan. This will allow Program
Administrators continued flexibility to make adjustments to programs that are necessary to
promote innovation and efficiency without being unduly burdened by the administrative process.
Indeed, retaining the flexibility to make changes and reallocations within the 20 percent
bandwidth over the three-year term of the Plan is critical. Having flexibility with budgets
without having the same flexibility for program modifications over the three-years of the Plan is
counterproductive. Requiring annual review for program modifications will come at a
substantial administrative cost and could have the unfortunate effect of inhibiting valuable
innovation. The Program Administrators propose that the interpretation of the D.P.U. 08-50-B
Guidelines, as expressed by the Department in D.P.U. 10-106, should be broadly construed to
apply to both budget and program modifications that adjust savings goals. Such an application
will ensure regulatory oversight but permit the Program Administrators to remain agile and
responsive in implementing state-of-the-art energy efficiency programs for the benefit of
customers during the three-year term of the Plan. 48
The Program Administrators are pleased that the Department recently initiated an
investigation in D.P.U. 11-120 to consider specific revisions to the D.P.U. 08-50-B Guidelines
addressing the mid-term modification process, which is discussed in more detail below. It is the
goal of the Program Administrators to balance the need for flexibility with respect to program
implementation, budgeting and savings over the three-year term of the Plan with the need for
regulatory review of modifications. The Program Administrators are encouraged that through
47
While D.P.U. 08-50-B Guideline В§ 3.8.1 contemplates the requests for plan modifications to accompany a
Program Administrators’ annual report filing, the Program Administrators, during the 2010-2012 Term,
have filed modification requests through a separate subsequent filing.
48
The Program Administrators note that, in adopting the appropriate flexibility provided by the Department
in D.P.U. 10-106, they are not proposing that such flexibility apply to any of the mandatory low-income
program funding levels established in G.L. c. 25, В§ 19(c). Any modification of such levels would only be
undertaken with advance approval from the Department after an opportunity for Council participation and
after discussions with LEAN.
257
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 263 of 274
this stakeholder process adjustments to the mid-term modification process will result to better
accomplish this balance. The Program Administrators anticipate utilizing any enhanced MTM
process that is ultimately developed in D.P.U. 11-120 (Phase II) on a prospective basis.
N.
Database Issues
The Council has identified defining and encouraging better data analytics and access as a
priority. See Council Resolution Concerning its Priorities for 2012 (February 14, 2012); Council
Resolution Concerning its Priorities for 2012 (July 23, 2012). One of the Council’s action plan
items is “Enablement for statewide data management and statewide data reporting in a consistent
and timely manner.” With respect to statewide data management and analytics priorities, the
Program Administrators will continue to collaborate with the Council to explore and develop
options that are timely, appropriate and efficient for all users. As discussed below, there are
ongoing discussions on database issues with the DOER and other interested parties. The PAs
look forward to continuing to work with DOER and other interested parties on these challenging
issues.
Moreover, it is important to understand and acknowledge that presently there are several
ongoing key data activities. First, the PAs are currently reporting statewide data in a consistent
and timely manner (see Appendix L at 2-3). Over the course of the initial three-year plan (20102012), the PAs have provided, ten quarterly reports (through the second quarter of 2012) with
statewide (or “rolled up”) data and data from individual PAs, 49 seven monthly “data dashboards”
which provide key snapshots of core metrics in a timely basis, 50 and detailed annual reports filed
by each PA for 2010 and 2011. In general, each PA’s Annual Report contains over 20 tables and
is over 600 pages, with detailed EM&V attachments. The PAs have also provided numerous
statewide/rolled up D.P.U. 08-50 data tables, which provide information on both an individual
PA and statewide basis. The D.P.U. 08-50 tables contain numerous separate tabs, each
developed through a public process and designed to provide detailed information on all key
aspects of energy efficiency program delivery by the PAs. All information and data as noted
above is filed with the Council and Department, is publicly available and benefits customers,
regulators, researchers, academics and other entities interested in seeking to understand and
emulate Massachusetts’ success in energy efficiency.
Further, DOER currently maintains the PARIS statewide database. In addition to the data
reporting noted above, each PA provides extensive information for inclusion in the PARIS
database. The PAs devoted substantial time and resources working cooperatively with DOER in
populating and maintaining the PARIS database throughout the initial three-year plan term and
will continue to do so. In particular, the PAs provide program, end use and measure level detail,
annual and lifetime savings, budgets and benefits for annual plans and annual reports each year.
There are nevertheless limitations to DOER’s use of the current PARIS system.
49
The quarterly reports contain a narrative summary of activities undertaken by the Program Administrators
in the relevant quarter (“qualitative report”), along with quantitative quarterly report information attached
to the report as Attachment A (pertaining to electric Program Administrators) and Attachment B (pertaining
to gas Program Administrators). For 2012, the filing of the qualitative and quantitative reports was
consolidated. Prior to 2012, these reports were filed in separate months.
50
The data dashboards are filed in months when there is no quarterly report due.
258
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 264 of 274
Additionally, with this Plan filing, the PAs are also providing additional summary tables
in a user-friendly format that provide key data on a statewide and PA-specific basis for 20132015, including savings, costs, and BCR information.
With respect to the possibility of establishing a uniform tracking system for energy
efficiency data, the Department has encouraged the parties to determine if it is practicable to
establish a uniform system that is efficient, reliable, and useful to all parties. Massachusetts
Electric Company, D.P.U. 10-98, at 16 (2011); Western Massachusetts Electric Company,
D.P.U. 10-90, at 21 (2011); Fitchburg Gas and Electric Light Company, d/b/a Unitil, D.P.U. 1089 at 17 (2011). The PAs have worked collaboratively and proactively with DOER to address its
database concerns, both before and since the Department’s Orders. The PAs remain committed
to working with DOER to develop an enhanced database that is efficient, reliable, and useful. 51
Some of the relevant dates and forums include:
DATE
November 8,
2011
FORUM
Database
Symposium
convened by
DOER
November 28,
2011
DPU 10-98,
DPU 10-90,
DPU 10-89
(2011)
DOER/PA
meeting
January 5,
2012
January 31,
2012
PA Feedback
February 27,
2012
Executive
Committee
Meeting
DOER/PA
meeting
April 3, 2012
51
ISSUES
PAs attended a database symposium at the request of DOER,
along with many other stakeholders, which focused on the type
of data stakeholders would like to get from PAs. The PAs
discussed the type of information that is available, including
PARIS and D.P.U. 08-50 tables, and constraints with regard to
providing certain information.
DPU stated that it “encourages the parties to develop a uniform
energy efficiency program data tracking system that is
efficient, reliable, and useful to all parties, to the extent
practicable.”
DOER explained its proposal for a new statewide database
(“PARIS 2.0”), which was not intended to build off the current
PARIS database.
PAs provided a response to DOER’s proposal (see Appendix L
at 8-13). Among other issues, the PAs emphasized the need to
clearly identify the data that is sought (and the reasons why
that data is sought). The PAs stated that any approach should
leverage the deep wealth of data already tracked and available;
be mindful of cost, privacy issues, and individual PA tracking
systems (in which the PAs have made significant financial
investments); and identify a means of funding such a project.
At an executive committee meeting of the Council, DOER
clarified that it is not necessarily committed to PARIS 2.0 and
is instead looking for the PAs to consider other paths forward.
Small PA group met with DOER to better understand DOER’s
purpose for a database and discuss the best approach to moving
forward. The meeting was productive and may lead to a
collaborative solution to the Commonwealth’s near-and-long-
The PAs have collectively included $500,000 of funding for a statewide database in their annual budgets
for each of the next three years. See Section III.D and Appendix A.
259
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 265 of 274
April 6, 2012
May 1, 2012
PA Reply
Comments,
2010 Annual
Reports
Executive
Committee
Meeting
May 3, 2012
PA Feedback
May 18, 2012
Executive
Committee
Meeting
Executive
Committee
Meeting
June 22, 2012
term data requirements.
PAs describe their good faith efforts to address database issues.
Discussion about database issues in which DOER states its
intention to host a webinar to provide information on available
database platforms. The AG questioned whether the purpose
and content of the database had been clarified as those issues
would drive the platform that would be needed.
PAs provide a power point to DOER to clarify the problem to
be solved and identify the next best steps with database issues
(see Appendix L at 1-7).
DOER discusses possible webinar on database issues. AG
offered to bring in folks from Teradata to explain data
integration, data quality and data granulation but not as a pitch.
The Council will likely convene a webinar on database matters
(very broad overview of what databases can effectively do) on
either July 25 or July 26. [to be rescheduled]
To develop an effective/optimal data system that is efficient, reliable, and useful to a
variety of entities, all interested parties need to clearly identify (1) the data to be collected,
(2) the purposes for which the data are needed, and (3) by whom the data would be used.
Understanding and defining these requirements is critical to considering appropriate solutions.
Failure to conduct this critical scoping exercise will unnecessarily increase costs and potentially
result in the development of a database incompatible with existing PA database infrastructure
and is not useful to interested parties. The PAs have made significant financial investments in
their database infrastructure, the costs of which have been borne by their customers. The costs of
a new database/tracking system need to be determined, discussed and optimized. The funding,
function and purpose for such a database needs to be clearly identified, and all efforts should be
taken to minimize costs, while ensuring quality and utility of the new system. This discussion
should consider the deep wealth of data already tracked and available and must be mindful of
cost, privacy issues, and differences in individual PA tracking systems. If the objectives, funding
sources, cost estimates, privacy protections and necessary data have been clarified, the
discussion on a uniform database could proceed to identify possible cost-effective solutions.
In sum, the PAs have compiled and shared on a timely and coordinated basis extensive
energy efficiency data. The process to address additional data collection will continue to benefit
from further thought and discussion. No party should minimize the level of work, resources and
costs that will be entailed in this effort. The PAs remain active participants in this ongoing
effort.
O.
Effect of Investigation D.P.U. 11-120 on Three-Year Plans
As discussed in Section II.G, the Department has opened up an investigation to examine
issues associated with the Program Administrators’ three-year energy efficiency plans.
260
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 266 of 274
D.P.U. 11-120, Phases I and II. Phase I is examining issues related to reasonably anticipated
CO2 compliance costs and net savings. Phase II is investigating issues related to MTMs, Annual
Reports, and energy efficiency surcharges (“EES”). For the reasons discussed below, the
outcome of these investigations may affect the PAs’ final Plan.
1.
Phase I
a. CO2 Compliance Costs
The Department is considering whether or not reasonably anticipated carbon compliance
costs have been incorporated into the avoided costs used to value energy efficiency program
savings. On August 10, 2012, the Department declined “to adopt an interim proxy value for
carbon dioxide to be used in the cost-effectiveness determination of energy efficiency
programs,” but stated that its investigation is ongoing and will not conclude until after
Department review of the Plan is complete. D.P.U. 11-120-A at 18. The Department’s ultimate
assessment of this issue could lead to changes in the avoided costs that are used to assess the
value of projected savings from Plan efforts. As a result, changes in the Plan may be needed to
comply with the Department’s ultimate direction on this issue.
b. Savings
The Department is considering changes to the way in which net savings are estimated.
The Department recently held that, in determining net savings, the PAs must continue
“retroactive” application of updated gross savings impact factors, but that updated net savings
impact factors would be applied prospectively. D.P.U. 11-120-A at 15-16. The current Plan
incorporates this application of evaluation study results. In addition, the Department supports
alternative “approaches to determining net savings that look at effects that occur over multi-year
periods and across programs” and intends to convene a working group to explore a market-based
approach. D.P.U. 11-120-A at 13. The current Plan incorporates savings estimates that reflect
current practice. If an alternative approach is adopted by the Department, then projected savings
from Plan efforts may need to be updated.
2.
Phase II
Phase II contemplates changes to reporting requirements, the criteria for an MTM filing,
EES filings and the incentive mechanism. On September 21, 2012, the Department issued and,
invited all interested persons to file comments on, its proposed revisions to the energy efficiency
guidelines (“Revised Guidelines”), which the Department explained are based on the discussions
at the technical sessions and in the initial comments. Interested parties filed initial comments on
the Revised Guidelines on October 15, 2012. The Program Administrators filed joint comments
generally in support of the Revised Guidelines.
The current Plan does not factor in any of the changes currently under consideration. If
the Department ultimately adopts changes in any of these areas, elements of the Plan may need
to be updated.
261
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 267 of 274
P.
All Cost-Effective Energy Efficiency and GHG Emissions Reductions
1.
Summary
Three-year energy efficiency plans in Massachusetts are governed by the statutory
framework set out in the Green Communities Act. As discussed more below, the GCA requires
the PAs to acquire all cost-effective energy efficiency, with consideration of sustainability, and it
is this mandate that frames the Department’s regulatory review of energy efficiency plans. G.L.
c. 25, §§ 19(a), 21(a), 21(b)(1), 21(b)(2).
Energy efficiency is also a key strategy within the Massachusetts Clean Energy and
Climate Plan for 2020 (“CECP”). Pursuant to the Global Warming Solutions Act (“GWSA”),
the Commonwealth of Massachusetts has set a goal of reducing greenhouse gas emissions from
the 1990 business as usual level by 25% by 2020 and 80% by 2050. All cost-effective energy
efficiency delivered through the three-year energy efficiency plans accounts for 7.1% of these
reductions, as part of a suite of policies set forth in the CECP. In support of both the mandate of
all cost-effective energy efficiency provided for in the GCA and the greenhouse gas reduction
goals established by the GWSA, the PAs will utilize full and diligent effort to meet their
established savings goals as set forth in this Plan and participate in developing strategies to assist
the Commonwealth of Massachusetts in meeting its CECP goals.
While the Program Administrators are committed to achieving GHG reductions in a
manner consistent with the Commonwealth’s climate plan goals, they must do so within the
confines of the regulatory requirements of the GCA and other laws governing the Department’s
protection of electric and gas customers. For example, the Department does not allow the
Program Administrators to include environmental externalities as a benefit when determining
cost-effectiveness. Only reasonably anticipated compliance costs can be included in the avoided
costs used to value energy savings. Even so, while the calculations are preliminary and need to
be reviewed with DEP, the PAs believe that they are on track to meet or exceed the GHG
reductions that are scheduled to take effect in 2020. See Table in Section III.P.3 below.
In acquiring all available energy efficiency, the PAs must implement both cost-effective
and sustained efforts that take into account customer bill impacts and the CECP does not
supersede or abrogate the Department’s regulatory authority or the Council’s role with respect to
three year plans under the GCA.
2.
GCA
The Green Communities Act was signed into law on July 2, 2008, and requires the
Program Administrators to develop energy efficiency plans that will “provide for the acquisition
of all available energy efficiency and demand reduction resources that are cost effective or less
expensive than supply.” G.L. c. 25, §§ 19(a), 21(a), 21(b)(1), 21(b)(2). Similarly, the GCA
charges the Department with ensuring that electric and natural gas resource needs are first met
through all cost-effective energy efficiency resources as a means to reduce costs to all customers.
262
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 268 of 274
G.L. c. 25, В§ 21(a); 52 G.L. c. 25, В§ 21(d)(2). 53 The GCA specifically requires cost-effectiveness
screening for energy efficiency programs. G.L. c. 25, §§ 19(c), 21(b)(3). 54 The GCA also
specifically requires “a sustained and integrated statewide energy efficiency effort.” GL c. 25,
В§ 22(b).
Although the requirement to provide for the acquisition of all available cost-effective
energy efficiency resources is not discretionary, the Department has recognized that the Green
Communities Act requires sustainability of effort and affords discretion regarding the rate at
which Program Administrators must acquire these resources. Gas Order, D.P.U. 09-121 through
D.P.U. 09-128, at 71 and Electric Order, D.P.U. 09-116 through D.P.U. 09-120, at 85.
According to the Department, the Green Communities Act states that such acquisition should be
achieved through a sustained effort. Id. citing G.L. c. 25, В§ 22(b).
Determining a reasonable pace for a sustained acquisition requires the Program
Administrators and the Council (in developing the Three-Year Plans) and the
Department (in reviewing the Three-Year Plans) to strike an appropriate balance
between several factors, including: (1) identifying the potential level of costeffective resource currently available; (2) exploring ways in which this level can
be increased; (3) assessing the capability of the energy efficiency vendor and
contractor industry to support increased program activity; and (4) assessing the
capacity of the Program Administrators to administer increases in program
activity efficiently and effectively. The Department must take into consideration
an additional factor: the rate and bill impacts that result from increased program
activity.
Gas Order at 71-72 and Electric Order at 85-86.
3.
GWSA/CECP
The Global Warming Solutions Act (“GWSA”) 55 took effect in August 2008 and
mandates certain reductions in GHG emissions in the Commonwealth. G.L. c. 21N, В§ 4(a). 56 To
implement these reductions, the GWSA requires the Secretary of the Executive Office of Energy
52
The GCA states: “To mitigate capacity and energy costs for all customers, the [D]epartment shall ensure
that…electric and natural gas resource needs shall first be met through all available energy efficiency and
demand reduction resources that are cost effective or less expensive than supply.” G.L. c. 25,
В§ 21(a)(emphasis added).
53
Likewise, the GCA also requires the Department, in approving the PAs’ three-year energy efficiency plans,
to ensure that the PAs “have identified and shall capture all energy efficiency and demand reduction
resources that are cost effective or less expensive than supply.” G. L. c. 25, § 21(d)(2) (emphasis added).
54
The GCA requires energy efficiency programs included in PAs’ three-year plans to “be screened through
cost effectiveness testing which compares the [economic] value of program benefits to the program costs to
ensure that the program is designed to obtain energy savings and system benefits with value greater than
the costs of the program.” G.L. c. 25, 21(b)(3) (emphasis added).
55
Global Warming Solutions Act of 2008, Acts of 2008, chapter 298, and as codified at G.L. c. 21N.
56
The GWSA requires GHG emissions reductions in the amount of: (1) ten to 25 percent from 1990 levels by
2020; and (2) at least 80 percent of 1990 levels by 2050. G.L. c. 21N, В§ 4(a).
263
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 269 of 274
and Environmental Affairs (“EEA”) to establish the CECP. G.L. c. 21N, §§ 3(b), 4(a). Pursuant
to the GWSA, the Secretary of EEA established a limit on GHG emissions for the year 2020 at
25 percent below 1990 levels (CECP at ES-7; Secretary of EEA Determination of Greenhouse
Gas Emission Limit for 2020 (December 28, 2010)). 57
The CECP anticipates that an integrated portfolio of existing and proposed policies 58 will
reduce carbon dioxide emissions below 1990 levels. See CECP at ES-5 & ES-7, Figure ES-5. 59
For each policy, the CECP projects estimated GHG reductions below 1990 levels (CECP at ES6). Neither the GWSA nor the CECP imposes on industries or sectors exact numeric targets that
they must achieve to contribute to the stated emissions reduction goals.
57
This limit is based on an analysis of: (1) 1990 GHG emissions and projected 2020 business-as-usual
emissions; (2) estimated GHG reductions from state and federal policies enacted since 2007; and
(3) estimated GHG reductions from the implementation of additional cost-effective policies through 2020
(CECP at 88-92).
58
The policies include five categories: buildings, electricity supply, transportation, non-energy emissions,
and cross-cutting (CECP at ES-6).
59
In a mid-range scenario, the CECP expects to reduce carbon dioxide emissions 27% below 1990 levels.
See CECP at ES-5 & ES-7, Figure ES-5. The CECP projects that policies enacted during the Patrick
Administration, including the Green Communities Act, will alone reduce GHG emissions 18% below 1990
levels. See CECP at ES-5 & ES-7, Figure ES-5.
264
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 270 of 274
The CECP projects that energy efficiency policy, existing as of 2010, will reduce GHG
emissions approximately 7.1 percent below 1990 levels (i.e., five percent from electric energy
efficiency programs and 2.1 percent from gas and oil energy efficiency programs) (CECP at ES6, 18). As one tool, the energy efficiency goal is expressed in terms of millions of metric tons of
carbon dioxide emissions (“MMTCO2E”) avoided for a total anticipated reduction of
6.7 MMTCO2E in 2020 (CECP at ES-6, Table ES-2, 18-19). As reflected in the preliminary
table below, the PAs submit that the savings targets embodied in their energy efficiency plans for
2013 – 2015 support CECP goals related to energy efficiency. 60
2012
2013
2014
2015
2020
(2012 MTM)
(Nov 2
Plan)
(Nov 2
Plan)
(Nov 2
Plan)
(CECP
Goal) 61
MMTCO2E
Electric
5.28
6.10
6.17
6.46
6.7
MMTCO2E
Gas
1.52
1.10
1.76
1.61
6.7
MMTCO2E
Combined
6.8
7.21
7.94
8.07
6.7
The PAs note that GHG calculations are complex and reflect multiple data points and
input assumptions. The PAs have benefitted from discussion of CECP matters with DEP and
emphasize that all calculations regarding CECP compliance are preliminary and subject to
60
GHG reductions in this table can be found in the Master PA Summary tab of the related D.P.U. 08-50
tables, measured in short tons. The 08-50 tables are based on net savings. However, the PAs believe that
adjusted gross savings, which have not been adjusted for free-ridership or spillover rates, better reflect
actual GHG reductions and are more appropriate for CECP purposes. Savings are still being achieved even
though PAs cannot claim them for GCA and energy efficiency purposes as being a result of Plan activities.
The PAs report adjusted gross savings to ISO-NE for all planning and reliability purposes related to
competitive wholesale energy markets.
61
Combined Gas/Electric Goal.
265
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 271 of 274
review with DEP, which has not checked these calculations. Last, and as noted above, while the
PAs are proud to be material actors in helping the Commonwealth achieve goals under the
CECP, and to be proposing higher savings goals and incrementally higher savings trajectories for
each of 2013, 2014 and 2015 as requested by the Council. While the CECP does not control or
usurp the goal setting process of the GCA, the PAs will participate in developing strategies to
assist Massachusetts in meeting its CECP goals.
Q.
An Integrated NSTAR Electric /WMECo Three-Year Energy Efficiency Plan
For the 2013-2015 term, NSTAR Electric Company (“NSTAR Electric”) and Western
Massachusetts Electric Company (“WMECo”) (together, the “Companies”) are seeking approval
of a single Three-Year Plan. Given that each company’s Three-Year Plan are consistent with the
Statewide Three-Year Plan currently in development, separate plans would have been
substantially similar in any event. However, the Companies are confident that implementing
energy efficiency programs through a single plan will not only fulfill each company’s energy
efficiency obligations, but also provide the potential for administrative and regulatory
efficiencies over time, while imposing no adverse impacts on the customers of either company.
Below is a brief overview of the NSTAR Electric/WMECo energy efficiency plan
integrating key aspects of energy efficiency program implementation including: Savings Goals;
Program/Pilot Design and Implementation; Program Budgets/Spending; Cost Effectiveness;
Funding; Performance Incentives; EM&V; and MTMs.
1. Savings Goals
The Settlement Agreement between NSTAR Electric, NSTAR Gas Company, WMECo
and the DOER approved by the Department in D.P.U. 10-170 requires NSTAR Electric and
WMECo to increase their aggregate energy efficiency savings target as of January 1, 2013 to at
least 2.5% of retail sales annually through energy efficiency, so long as there is no material
change in the framework for assessing the success of the program and associated incentives, or
providing for program funding. NSTAR/NU Merger, (NSTAR/WMECo/DOER Settlement
Agreement at Article 2.3, NSTAR/WMECo/DOER/AG Settlement Agreement at Articles
2(3)(Base Rate Freeze) and 2.7 (Lost Base Revenues)). This annual commitment will remain in
place until the expiration of the Base-Rate Freeze period (i.e., through January 1, 2016).
Accordingly, pursuing these savings goals through a single plan is consistent with these goals.
2. Program/Pilot Design and Implementation
The 2013-2015 Three-Year Plan contemplates uniform electric energy efficiency
programs across Massachusetts. The PAs “will continue to explore new efforts during the 20132015 Plan to determine if a pilot would be a useful tool for studying a new effort. A key goal of
any pilot is that pilots yield data that assist in determining if the approach explored in the pilot
should be implemented on a larger, statewide scale, as a full program, or an element of a
program.” Statewide 2013-2015 Energy Efficiency Plan at 219. Consequently, pursuit of these
goals through separate energy efficiency plans presents unnecessary administrative and
regulatory burdens on the Companies that could be eliminated through a single plan and
streamlined regulatory review.
266
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 272 of 274
3. Program Budgets/Spending
The NSTAR Electric and WMECo energy efficiency budgets are structurally identical as
prior differences have been addressed over the 2010-2012 period. Accordingly, maintaining
separate budgets through separate energy efficiency plans presents unnecessary administrative
and regulatory burdens on the Companies that could be eliminated through an integrated budget
and plan and streamlined regulatory review. Spending for each operating company for the 20132015 term will continue to be tracked separately in each operating company’s respective
accounting systems. The costs for common resources will be allocated according to planned net
benefits.
Moreover, implementing common programs through a common budget may create
opportunities for cost savings through reduced PP&A, integrated marketing and evaluation,
while preserving proportionate spending among the service areas. With respect to low-income
energy efficiency programs, the Companies will maintain their spending on such programs at a
minimum of 10 percent of the integrated budget, as required by law. Operational differences in
the low-income programs will be reconciled in cooperation with LEAN.
4. Program Cost-Effectiveness
The Companies’ respective energy efficiency programs are designed to be cost-effective,
as measured by the Department’s Total Resource Cost test. The Companies will demonstrate in
their Three Year Plan filing with the Department that the programs will also be cost effective if
integrated, and present cost effectiveness analyses under both scenarios to support this
conclusion.
5. Funding/Cost Recovery
a. Funding
Given that the GCA makes funding sources for energy efficiency programs uniform for
electric PAs, an integrated plan should not present any issues with respect to the structure and
sources of program funding. First, a statewide formula exists for allocating RGGI proceeds to
individual PAs. Second, forward capacity auctions from 2013-2015 have already occurred, and
the proceeds from such auctions are based on the individual PA’s energy efficiency assets and
how they are bid into forward capacity auctions. Finally, although the carryover amounts for
NSTAR Electric and WMECo differ, as noted previously, the Companies will track and allocate
funds appropriately.
b. Cost Recovery
Although the Companies’ plan will integrate key aspects of energy efficiency goals
outlined above, the Companies are not proposing at this time to consolidate energy efficiency
cost recovery tariffs. LBR recovery with respect to NSTAR Electric is governed by the terms
and conditions of the Settlement Agreement among NSTAR Electric, NSTAR Gas, NSTAR,
267
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 273 of 274
WMECo, Northeast Utilities, DOER and the Attorney General dated February 15, 2012 and
approved by the Department in D.P.U. 10-170 (April 4, 2012). Lost revenues associated with
WMECo’s energy efficiency programs are recovered through WMECo’s decoupling mechanism.
6. Bill Impacts
In recognition of the fact that the acquisition of all cost-effective energy efficiency could
require funding above that provided through existing funding sources (i.e., the SBC, FCM, and
RGGI), the GCA provides that PAs may collect additional revenue from ratepayers through a
mechanism such as the EES. G.L. c. 25, В§ 19(a). Given that the energy efficiency cost recovery
tariffs for the Companies are not proposed to be integrated, the Companies do not anticipate
adverse bill impact issues arising in the context of plan integration. To the extent that plan
integration results in cost savings over time, bill impacts collectively could decrease.
7. Performance Incentives
The GCA provides that the Statewide Plan shall include a proposed mechanism that
provides incentives to PAs based on their success in meeting or exceeding the goals in the plan.
G.L. c. 25, В§ 21(b)(2). The Companies will follow the performance incentive mechanism
addressed in the electric Term Sheet developed in collaboration between the Program
Administrators, the Attorney General and the DOER, which is substantially similar to the
mechanism addressed in the Memorandum of Agreement executed by the Program
Administrators and other settling parties in D.P.U. 10-146. The total dollars available for
incentives which would fund the statewide incentive pool will not be affected by an integrated
plan, assuming no changes in savings, nor would the percentage allocation of the statewide
incentive pool to the savings, value and metrics components, or the statewide payout rates, given
that these incentive components are negotiated on a statewide basis. Performance incentives
would be calculated based on the performance of the integrated plan, with any performance
metric incentive allocated to individual operating companies according to planned net benefits.
8. EM&V
The Department’s Guidelines require each Three-Year Plan to include an evaluation plan
describing how the PA will evaluate the energy efficiency programs during the course of its plan.
Guidelines § 3.5. The Department’s Guidelines are intended to create a collaborativelydeveloped (between the EEAC and the PAs), statewide EM&V strategy. The Companies will
use the same EM&V strategy and apply EM&V results similarly during the 2013-2015 period.
Accordingly, EM&V strategy and application will not be affected by plan integration.
9. MTMs
In D.P.U. 08-50-A and the D.P.U. 08-50-B Guidelines, the Department directed the PAs
to seek Department approval for certain specified MTMs, including adding or terminating a
program, and changes in a program budget, savings goals, or performance incentives of greater
than 20 percent. D.P.U. 08-50-A at 64; D.P.U. 08-50-B Guidelines at В§ 3.8.2. Subsequent to
D.P.U. 08-50-A and B, the Department provided further guidance regarding the need for
268
D.P.U. 12-100 to D.P.U. 12-111
Three-Year Energy Efficiency Plan 2013-2015
November 2, 2012
Exhibit 1
Page 274 of 274
Department approval of proposed mid-term program modifications. Specifically, in Cape Light
Compact, D.P.U. 10-106 (2011), the Department clarified that PAs are required to seek
Department approval only for a program budget modification that is 20 percent greater than the
program’s three-year budget.
The Department is currently considering modifications to the D.P.U. 08-50 Guidelines
with respect to MTM filings. See D.P.U. 11-120 (Phase II). Under an integrated plan, the
Companies intend to apply the Department’s MTM Guidelines to the integrated budgets, savings
and performance incentives of the two Companies, and with respect to the addition or
termination of an integrated program.
R.
The Special Inclusion of Blackstone
Blackstone Gas Company (“Blackstone”) is a natural gas distribution company currently
serving approximately 1,415 residential and 157 C&I customers in Blackstone and a portion of
Bellingham and Wrentham, Massachusetts. Because of the very small size of its customer base,
Blackstone will participate in a subset of the programs discussed in this Plan based upon
customer needs. Blackstone’s budgets, savings, benefits, and other data have not been included
in the statewide D.P.U. 08-50 tables or anywhere else in this Plan. For 2013 to 2015, Blackstone
has a total budget of $215,060 and total annual savings of 72,167 therms, and total lifetime
savings of 1,043,627 therms. Blackstone will not be seeking performance incentives. Currently,
Blackstone provides energy efficiency services related to RCS, which programs have been
incorporated into the Home Energy Services core initiative in this Plan pursuant to the Energy
Act of 2012, as well as certain customer equipment rebates. In 2013-2015, Blackstone will work
with its local CAP agency pursuant to an MOU to deliver low-income programming, and has a
budget for C&I projects if they arise. Although Blackstone has a very small customer base, the
special inclusion of Blackstone in the statewide plan reflects the spirit of the Green Communities
act to expand energy efficiency efforts.
269
Was this manual useful for you? yes no
Thank you for your participation!

* Your assessment is very important for improving the work of artificial intelligence, which forms the content of this project

Download PDF

advertisement