Right to Efficiency
New Yorkers should not have to make a choice between housing that is healthy, efficient or affordable
Right now, the New York State Energy Research and Development Authority (NYSERDA) and the Public Service Commission (PSC) are conducting meetings across the state to solicit feedback on the state’s proposals for implementing its new energy efficiency standard, with a specific focus on how the concerns of low-income ratepayers can be fairly addressed by this process and statewide energy policy more broadly. As an alliance of community groups, renewable advocates, and members of working class communities and communities of color, we are here to make sure that ratepayers – and specifically ratepayers from communities that pay a disproportionate share of income on energy bills – are leading the decision making process on energy efficiency, and to showcase how energy efficiency impacts the lives of everyday New Yorkers via our own stories. We are calling on NYSERDA and the PSC to meet the following demands:
1. Forty percent of spending on energy efficiency measures should go to initiatives and projects that benefit low-to-moderate-income ratepayers. In a state where forty percent of people are classified as low-to-moderate income, this is a clear requirement for any equitable funding plan. The Clean Energy Fund (CEF) should fund projects in those communities that have been the most burdened by fossil fuel generation, and stand to benefit most from carbon and co-pollutant mitigation strategies, which will ensure that residents are able to not just survive but thrive.
2. Energy efficiency programs must be accessible for low and moderate income households regardless of a household’s FICO score, utility bill payment history, or upfront capital. NYSERDA and the PSC should adopt inclusive tariff-based on-bill financing schemes, such as Pay As You Save (PAYS), which have proven viable, cost effective, and equitable in other regulated utility jurisdictions, and can overcome traditional barriers to capital and credit faced by low income households, communities of color, and small businesses.
3. Energy efficiency measures should be implemented through transparent, equitable and accountable partnerships with community benefit organizations. Energy efficiency programming, whether administered by NYSERDA or the regulated utilities, should be community-based, streamlined, and offered in coordination with the delivery of other social and community services. A community-based one-stop approach can improve access to vital services, including energy efficiency programming and financing, as well as culturally sensitive education around the benefits of energy efficiency and healthy homes, and it may therefore be beneficial to subcontract outreach and education services for underserved communities to community-based organizations that are responsive to the priorities, particular needs, and aspirations of community members.
4. We need a “holistic and healthy homes” approach that addresses the multiple stressors of living in inadequately insulated housing. Energy efficiency program should seek to couple efficiency upgrades with healthy homes improvements, such as Integrated Pest Management (IPM) and environmental hazard mitigation/remediation (including mold, lead, asbestos, radon). In addition, energy efficiency investments should support, either directly or indirectly through leveraged and braided funding, costs associated with structural building repairs to roofs and foundations that are needed in order to enable the installation of efficiency measures.
5. Energy efficiency measures cannot further drive displacement through municipal capital improvements or higher energy bills for low income communities, and should improve the housing security of low income residents. Energy efficiency investments are a key driver of housing affordability for vulnerable renters and homeowners, and can help to stabilize housing costs in neighborhoods that are undergoing gentrification. Property owners making energy efficiency upgrades should be prevented from increasing rents and displacing tenants via Major Capital Improvements (MCIs) and other increases for rent-regulated households. NYSERDA and the Public Service Commission should create incentives and penalties for utilities to help prevent displacement.
6. The PSC and NYSERDA must create an incentive structure that makes compliance real for landlords and utilities, via both positive incentives and penalties for noncompliance. We are proposing bold but necessary measures for ensuring all New Yorkers have access to energy efficiency measures, and the Public Service Commission and NYSERDA must be willing to create financial consequences for landlords and utilities that do not live up to their commitments.
7. We don’t want NYSERDA or the PSC to waste the time and energy of members of vulnerable communities. If low-income ratepayers and community members are going to contribute to the formation of energy efficiency policy on an ongoing basis, there must be specific and transparent mechanisms for ensuring that their contributions will be heard and followed.
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