• DPU Docket 23-93 •
“PETITION OF THE BERKSHIRE GAS COMPANY FOR APPROVAL OF MID-TERM MODIFICATIONS OF ITS 2022-2024 ENERGY EFFICIENCY PLAN”
Comment filing deadline: 5:00 PM, January 8, 2024
WHAT THE DOCKET IS ABOUT
Berkshire Gas is filing for a surcharge increase to bolster it’s energy efficiency programs. They underestimated the amount of people who wanted to take advantage of the heat pump offers, and are looking for budget increases to keep it going. This is a proposed “Mid-Term Modification” to the Three-Year Efficiency plan. It’s a patch for this last year of the current three year plan to keep the program flush.
WHY FILE COMMENTS
While rapid adoption of heat pumps is what we definitely want to see, there are concerns with their “Mid-Term Modification” (MTM) plan and with how the DPU handled notification requirements for the hearing.
Among some of the concerns with the MTM plan:
– It will raise rates for gas customers across the board, same percentage for income eligible and regular residential customers (1.52 percent). Any increase in the efficiency surcharge should be tiered to lower the financial burden on income-eligible households.
– So far, the wide majority of electrifications have been “partial”, i.e. the heat pump installations are of a type that are insufficient to totally replace gas use, not the more environmentally helpful whole house electrification of heat. Whole house electrification provides the most greenhouse gas reduction per efficiency $ spent.
– 73% of the heat pump installations so far have been for non-EJ, regular Residential level customers. They should be aiming for no less than 40% EJ customer, not the 27% they’re reached so far.
– The increased funding would also be used to incentivize gas-to-gas replacements for heating and hot water in the Commercial and Industrial Sector.
– It calls for a far larger increase in funding for regular Residential efficiency programs than for the income eligible program.
Concerns with DPU’s handling of the notification process:
– This was initially filed with the DPU on August 28th, 2023.
– Order of notice for a hearing was filed November 21st.
The requirements for notification were:
Copies of the Notice were served no later than close of business on November 27, 2023
(1) the service list in The Berkshire Gas Company, D.P.U. 21-120 (2022);
(2) the members of the Energy Efficiency Advisory Council;
(3) the Mayor, Select Board Chair, Town Clerk, and City Clerk, as applicable, for each municipality in its service territory; and
(4) on any person who has asked to be notified by the Company.
In addition, the Company posted the Notice on their website at and published the Notice in the Boston Globe on November 29, 2023.
– Even though BEAT and other similar grassroots organizations are on proceedings notification contact lists with other departments under the Executive Office of Energy and Environmental Affairs, we found out about the December 15th hearing and the fact that no members of the public spoke on Friday, Dec. 22, only because a Berkshire County reporter noticed the hearing announcement on the City of Pittsfield website and published an article.
– The hearing for this was held on December 15th, in Boston & via Zoom. No members of the public were there to comment.
This notification procedure did NOT include any notice directly to affected community members or any grassroots or advocacy organizations that work with them. The DPU’s notificaiton request contains none of the requests to share information with directly community members and grassroots organizations as other the EEA departments like MEPA, DEP and DCR are now required to do under the Office’s Environmental Justice Protocol.
We filed a complaint to DPU about the Dec. 29 comment deadline. They extended the deadline on this proceeding to January 8th, 2024, and have mentioned intent to change their notification process.
COMMENT SUBMISSION INSTRUCTIONS
Comments may be filed no later than the close of business (5:00 p.m.) on Monday, January 8, 2024.
All comments should be submitted to the Department in .pdf format by e-mail attachment to dpu.efiling@mass.gov and elyssa.klein@mass.gov.
The text of the e-mail must specify:
(1) the docket number of the proceeding (D.P.U. 23-93);
(2) the name of the person or company submitting the filing; and
(3) a brief descriptive title of the document.
Written comments also should be submitted to the Company’s attorneys, Emmett Lyne, Esq., at elyne@richmaylaw.com, Leah Cohen, Esq., at lcohen@richmaylaw.com, Joseph Dorfler, Esq., at jdorfler@richmaylaw.com, and David Lyons, Esq., at dlyons@richmaylaw.com and the service list in D.P.U. 23-93.
The Department strongly encourages public comments to be submitted by email. If, however, a member of the public is unable to send written comments by email, a paper copy may be sent to:
Mark D. Marini
Secretary, Department of Public Utilities
One South Station, Boston, Massachusetts, 02110.
BEAT has prepared comments to be filed on January 8th.
We are accepting endorsing organizations who wish to sign on.
Sign-Ons are being accepted through end of day, Friday, January 5th.
Please USE THIS FORM to sign on.
PRESS ON THE MATTER SO FAR:
» BEAT Pushback Extends Comment Deadline on Berkshire Gas Hike
By Brittany Polito, iBerkshires Staff
January 2, 2024
» Berkshire Gas Requests ‘Energy Efficiency’ Budget Increases
By Brittany Polito, iBerkshires Staff
December 20, 2023