Statement on Utility Energy Efficiency Filings, April 2019

Last week, New York’s private utility companies jointly filed their plan for meeting the Governor’s new energy efficiency standard. The energy efficiency standard promises dramatic improvements in energy efficiency programs in New York with the target of reducing electricity and heating fuel use by the equivalent of the amount of energy needed to power and fuel 1.8 million homes. Over 90 organizations participated in events across New York State to discuss how to improve housing conditions and reduce energy costs for the state’s most vulnerable residents. Unfortunately, the utilities filed a vague plan that sidelines the incredible experience and wisdom of low-income people, community organizations, and low-income advocates, demonstrating just how little they care about equity, accountability, or the well-being of low-income New Yorkers across the state.

The utilities should know better. Monday’s filing follows a process lasting many months, in which grassroots groups and community advocates across New York painstakingly educated residents on the issues, mobilized community members to attend seven public forums with state agencies and utilities on energy efficiency issues all across the state, and trusted a process that promised real change and accountability.

The following are some of the recommendations made by these grassroots groups and community advocates at the forums:

  • increase the overall amount of funding available for low and moderate income programs as a proportion of overall funding
  • prioritize renewable heating systems for low-to-moderate income residents, paired with building envelope improvements
  • increase funding to address the home health, safety, and structural deficiencies that are often barriers to energy efficiency retrofits
  • leverage utility discount funding to address some of the root causes of energy unaffordability, such as lack of access to affordable energy efficiency
  • include environmental justice considerations and input from community members with high energy burdens in program design and implementation
  • integrate energy efficiency offerings with rooftop and community solar

Note, for ALL of the above recommendations, NYSERDA and NYS DPS explicitly stated that the utilities would be expected to address them in their filing. Yet, the utilities filed a plan with very little detail or information about how they plan to address these and other recommendations and no specific funding levels for low and moderate income programs. So, it is not simply an affront to the forum process and those who participated, but the utilities’ filing stands in conflict with the expectations of our state agencies. For the full list of recommendations and how responsibility for these recommendations was to be allocated, see page 33 of the report, which you can download HERE).

These groups made this effort because stakes are really high. Energy efficiency is the most cost effective form of clean energy — its the energy we don’t use! It creates warm and healthy homes for families, lower energy bills, and green jobs for local workers. It helps us reduce our carbon emissions, and can mean the difference between being able to pay energy bills or not for many New Yorkers. As housing costs across the state rise, particularly in densely populated urban areas, access to energy efficiency can prevent people from being displaced from their homes and communities.

So far, only 12% of eligible New Yorkers have accessed existing low-income energy efficiency programs over the last 12 years, meaning it would take a century to reach all low-income New Yorkers with energy efficiency. This is inexcusable. In giving input into how the state can improve energy efficiency access for poor and working class people, forum participants were clear that the current programs were inadequate and that new approaches were needed.  

Another main point raised by participants across New York during the public forums was: Don’t waste our time. If you ask us to participate in this process, share our experiences, and give our advice, you should incorporate our input into the final policies and programs. Following these in-depth meetings, the New York State Energy Research and Development Authority (NYSERDA) summarized the concerns and recommendations that came from communities across New York, and filed the recommendations on the record. Subsequently, the Department of Public Service issued an assessment of the recommendations and outlined next steps, stating that the private utility companies were expected to incorporate many of the recommendations into their plans.  

The utility filing on Monday does not incorporate most of our recommendations or even acknowledge them. The utilities have flagrantly disrespected the efforts of everyone who participated in this process. Utilities are asserting their monopoly power to control the outcome of this process instead of deferring to groups that have the on-the-ground knowledge and expertise to ensure low-income efficiency programs actually work and reach people who need them. Even if utilities add more detail in later implementation plans, the lack of specificity in this plan effectively prevents the public from responding in a meaningful or substantial way.

This news risks disempowering all of us, but the story is not over. The Energy Democracy Alliance plans to issue a report card in the coming days to grade the state agencies and the utilities on how responsive they have been to the communities they asked for advice. At the end of the day, we are determined to build an energy system that is democratically accountable to, and centers the needs and perspectives of the people it serves. We look forward to working alongside our members and partners over the next several months to guarantee all New Yorkers a right to energy efficiency.