Comments to Massachusetts Energy Efficiency Advisory Council

“Now that Program Administrators have acknowledged entire communities and customer segments have not been served through existing efforts, they must be required to address this stain on the program with effective solutions targeted at excluded groups and geographies. We urge both immediate steps through a mid-term modification (or other short-term vehicle) and assiduous efforts in the upcoming planning period for the 2022-24 Three Year Energy Efficiency Investment Plan. These solutions, articulated perhaps through your new Equity Working Group, must go beyond token measures and initiatives, and most importantly must allow for the PAs to sustain significant financial penalties if they fail yet again to deliver tangible improvements. It is high time that in addition to aggregate climate emissions reductions, the Mass Save program’s success be measured also by its degree of geographic saturation and general equitability across communities.”