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Performance is a proxy for ensuring the job was done right Measured savings offers big consumer protection benefits

David Kolata
David Kolata VP of Policy, Sealed

Before joining Sealed as the Vice President of Policy last June, I spent nearly two decades leading the Citizens Utility Board (CUB) in Illinois as its Executive Director. At CUB, we advocated for all Illinois consumers — including holding utilities accountable by making sure energy prices were reasonable and helping consumers use less energy by adopting greener ways of heating and cooling their homes. 

I share my background because we now have a tremendous opportunity to help people all across the country make their homes more energy efficient while saving money. Simply put, with the Inflation Reduction Act (IRA) Home Energy Rebates we can transform the energy efficiency market. 

And if we do it right, we can take consumer protection to the next level by shifting the performance risk of weatherization and electrification projects from households to the private sector.  

To truly protect consumers, states should include the measured savings pathway of the Home Efficiency Rebate (HOMES) Program.

Every state is required to include a consumer protection plan as part of its IRA rebate funding application to the U.S. Department of Energy. To truly protect consumers, states should include the measured savings pathway of the Home Efficiency Rebate (HOMES) Program. In fact, the importance of measured savings to consumers across the country is one of the main reasons I joined Sealed.

Consumer protection includes accurate energy savings predictions

With the measured pathway of the HOMES program, performance is built in. That’s because rebates are only provided based on actual, quantified energy savings. As we’ve covered before, a focus on performance can help drive contractor and consumer adoption of efficient technologies. And with the measured pathway it is aggregators, not consumers or contractors, that take the hit if energy savings fail to materialize.   

Fundamentally, then, measured savings shifts project-performance risk from the customer to aggregators and other market actors—a massive consumer protection benefit, and one that is particularly important for low-income households. 

Electrifying homes has great potential to improve the environment, create healthy homes, and in most cases lower household heating bills. But regardless of what pathways states choose, in some situations, switching to technologies like heat pumps can increase overall energy bills—an especially pertinent issue for low-income households.        

As states draft their consumer protection plans, bill impacts should be front of mind. We encourage states to require disclosure of potential bill impacts to low-income customers at a minimum. Energy billing data and analytics have crucial roles to play in both the modeled and measured pathways and this data can be used by aggregators like Sealed to provide important information to consumers, enabling smart decisions.    

Performance is a proxy for comfort, health, safety, and more

Performance is key for another reason: it’s a proxy for ensuring the job was done right. For example, if a home is properly retrofitted with insulation and a heat pump, the homeowner is likely to notice that, in addition to saving energy, their home is more comfortable, that their family can breathe easier as a result of improved indoor air quality, and that their home is safer. The list could go on and on.

Ensuring that retrofits actually achieve the expected energy savings is therefore a proxy for the comfort, health, and safety benefits of home weatherization and electrification projects.

Ensuring that retrofits actually achieve the expected energy savings is therefore a proxy for the comfort, health, and safety benefits of home weatherization and electrification projects. And that performance, and the resulting benefits, can only be guaranteed through the measured pathway. 

Measured savings offers grid reliability benefits — which is good for consumers

Measured savings also offers big grid reliability benefits—which is critical for ensuring that lights stay on and that energy prices are affordable for consumers. After all, the cheapest kilowatt hour is the one not used.

As more people install heat pumps, EVs, and rooftop solar, we are moving to a more decentralized energy system. All of these new machines and technologies are great for the planet and for people’s health, and they can be coordinated to provide value to the grid. 

Enter virtual power plants

By prioritizing building up VPPs, utilities can spend more time on helping consumers adopt energy efficiency and electrification technologies, instead of spending ratepayer and taxpayer money on polluting power plants and pipelines. 

VPPs can serve the exact same function as traditional power plants. By prioritizing building up VPPs, utilities can spend more time on helping consumers adopt energy efficiency and electrification technologies, instead of spending ratepayer and taxpayer money on polluting power plants and pipelines. 

But there’s also this: Grid operators — be they utilities or Regional Transmission Organizations (RTOs) —require demand resources be measured just like supply resources. Operators won’t just take efficiency savings on faith or trust an energy model. Efficiency savings must be proven, and that’s where measured savings comes in.

Measured savings in the HOMES program can therefore be a “down payment” on the robust participation of residential energy efficiency in VPPs. 

Enabling a more reliable grid goes hand in hand with protecting consumers. Look at it this way: If energy efficiency is not measured, and it takes longer to set up VPPs, then we end up in a situation where we need to build more transmission infrastructure or prolong the life of an old power plant more than we need to — which will involve spending more money and hiking rates. 

No doubt new transmission and other infrastructure investments are needed as we move forward in the energy transition. But to fully protect consumers and maintain a reliable grid we need to maximize the benefits of distributed energy resources like energy efficiency. 

Bottom line: focusing on consumer protection when it comes to the IRA rebates is vital (which is why the DOE is requiring states to address it). Including the measured pathway is an essential part of protecting consumers as states roll out these IRA rebates.

April 16, 2024