Protecting and strengthening energy efficiency programs in Massachusetts and Rhode Island have been core components of Green Energy Consumers’ advocacy for years. We urge utility efficiency administrators and state officials to build energy efficiency programs that have ambitious energy savings targets, incorporate equity, and invest in deep, innovative efficiency measures.

This summer marks a pivotal moment in energy efficiency programs in Rhode Island: 2020 has already seen the publication of an Efficiency Programs Potential Study—that is, the first study in ten years to identify new efficiency opportunities—as well as a revision of the regulations governing efficiency programs. Now, National Grid, alongside stakeholders (including Green Energy Consumers), is working to draft the next Three Year Efficiency Plan, which will guide the programs from 2021 through 2023.

Unfortunately, the first draft of the 2021 – 2023 Three Year Plan is insufficient to meet RI policy goals or comply with state law that efficiency programs be “cost-effective, reliable, and environmentally responsible.”

Past Efficiency Program Plans

Utility-administered efficiency programs reduce emissions by allowing consumers to use less energy from fossil fueled sources. They pay for themselves through increased grid reliability, avoided grid infrastructure, and avoided cost of additional energy.

Over the past decade, Rhode Island’s efficiency programs have become nation-leading. They were largely responsible for the transformation of Rhode Island’s lighting market away from inefficient incandescent bulbs to long-lasting, low-energy LEDs. They have also reduced emissions from natural gas and heating fuels by incentivizing efficient appliances and encouraging weatherization—among countless other achievements.

Every three years, National Grid and energy stakeholders (including the Office of Energy Resources, the Division of Public Utilities, Green Energy Consumers, and others) lay out their goals for the next three years of energy efficiency planning. While developing the last three year plan back in 2017, we knew that energy efficiency programs were in transition across the country. The transformation of the lighting industry, which had been the driver of savings for the prior two three year plans, was almost complete. For the efficiency programs to continue achieving a similar level of excellence, they would need to go beyond the low hanging fruit of lighting efficiency.

So, over the course of the 2018 – 2020 Three Year Plan, the efficiency programs delved into a number of new initiatives, like active demand management (e.g. grid-connected smart thermostats in the ConnectedSolutions program, or alerts warning customers of peak days); a pilot incentivizing Zero Net Energy buildings in new construction; and a 100% landlord incentive to encourage more weatherization in Rhode Island’s rental units. However, the conversion of incandescent lights to LEDs remained the bread and butter of the efficiency programs. Even in 2020, long after LEDs have become the norm, the success of these programs has still hinged upon the amount of incandescent bulbs that National Grid can take credit for replacing.

Further complicating the last three year plan was the lack of information available to the Company and stakeholders in developing the programs. Program plans are built off of “Potential Studies,” which evaluate and identify the opportunities for increased energy efficiency in the state. The last Potential Study was completed in 2010 and was largely obsolete by development of the 2018 – 2020 Three Year Plan. Essentially, stakeholders were flying blind as they sought out opportunities for energy savings over the last few years.

What’s Different This Year?

As the development process for the 2021 – 2023 Three Year Plan approached, it looked like things might be different: the savings well from lighting has almost entirely dried up, and the efficiency program administrators now have experience in a number of other initiatives in a number of other areas, like heating electrification, demand response, and advanced energy management. Further, a new Potential Study, which looked at efficiency opportunities from 2021 – 2026, revealed a huge amount of potential for savings from heating and cooling in the state’s buildings. Finally, the 2020 Heating Sector Transformation Report—as well as climate crisis common sense—dictates that Rhode Island must ramp up investment in efficiency now to meet our long-term climate goals.

The 2021 – 2023 Three Year Plan should demonstrate:

• Ambitious energy savings targets in line with the targets approved by the
  Public Utilities Commission this spring
• Attention to building equitable access into the programs
• A focus on energy savings from new areas and the areas with the most opportunity, especially heating and cooling

The first draft circulated to stakeholders largely fails on all three counts. The savings targets in the draft are barely half of the PUC-approved targets, which the Potential Study indicated were achievable and which the Company agreed to pursue earlier this spring. And the draft plan barely touches on how the programs can better identify and serve under-served groups, like renters and low income energy consumers.

Prior program plans encouraged electrification of home heating and cooling systems. Unfortunately, this plan is severely hindered by the Public Utility Commission's position against providing support to customers with heating oil and propane to install high-efficiency, cold climate heat pumps. Rhode Island policymakers need to reconcile the PUC ruling with the need to transform the heating sector.

The current (bad) draft plan will be discussed by the Energy Efficiency and Resource Management Council on August 20^th, and a revised plan will be discussed on September 17^th. The EERMC is set to vote on the plan on October 8^th; the Public Utilities Commission will make a final decision in December. Look out for opportunities to make your voice heard on this important plan as it develops!