HPC Files Comments on New Efficiency: New York

On July 16, 2018, the Home Performance Coalition (HPC) provided comments on New Efficiency: New York, an ambitious energy efficiency initiative announced recently by the New York State Energy Research & Development Authority (NYSERDA) and the NY Dept. of Public Service (DPS). 

HPC’s comments recommended three policy innovations to address problems faced by home performance contractors and businesses in New York: 1) adopting more open, transparent and easy to use data standards to lower contractor costs; 2) reforming and modernizing cost-effectiveness testing and the way EE programs are funded by NYSERDA, DPS and utilities; and 3) improving workforce development and training programs for home performance contractors.

Data Standards

HPC saluted NYSERDA and DPS’s adoption of national open data standards such as the Home Performance Extensible Markup Language (HPXML), but also urged them to do more to help home performance contractors in NY realize the benefits of HPXML adoption. HPC suggested policies to reduce the amount of paperwork and reporting headaches for contractors that included working more closely with the 15 software companies using HPXML and developing consistent state-wide and program-wide reporting standards. HPC also recommended that NYSERDA and DPS adopt HPXML for its low- and moderate-income residential programs.

National Standard Practice Manual

HPC’s comments on New Efficiency New York also applauded NYSERDA’s recent decision to reform its benefit cost-effectiveness tests. NYSERDA now incorporates societal costs and benefits to evaluate some utility investments in energy efficiency programs. HPC encouraged NYSERDA to use the National Standard Practice Manual (NSPM) to further reform NY’s cost-effectiveness testing approaches. When states properly account for all relevant costs and benefits for both the utility system and customers – energy efficiency programs receive the appropriate (and more attractive) evaluations under state funding formulas.

Workforce Development Training Programs

Finally, as part of a broad coalition of residential energy efficiency organizations including the Building Performance Institute (BPI), the Building Performance Contractors Association of New York State (BPCA) and Efficiency First (EF), HPC filed joint comments that call upon NYSERDA to pursue multiple strategies supporting training and expanded opportunities for employment in energy efficient home improvement trades. Those recommendations include: a renewed focus on the residential retrofit market using NYSERDA’s Industry Partnership Approach to capitalize on prior NY workforce development investments; an expansion of current vocational school initiatives under the Clean Energy Fund; and other training opportunities for energy efficiency workers at all stages in their career paths, such as Secondary Vocational and Post-Secondary Technical Education, Apprenticeships, on-the-job training, Instructor Training and expanded job placement services.

HPC, BPI, BPCA, and EF hope to work closely with the NYSERDA and DPS on the various technical and policy issues surrounding the implementation of the New Efficiency, New York initiative in the coming weeks and months.