Acadia Center Submits Comments to Connecticut DEEP about Weatherization

Weatherization of our residential housing stock will be critical to achieving an affordable clean energy future in Connecticut.

Four years ago the Connecticut General Assembly made a smart move when they required the state’s Conservation and Load Management Plans (“C&LM Plan”) to take steps to weatherize eighty percent of the state’s residential units by 2030. The statute, however, did not include a definition of weatherization, so the Connecticut Department of Energy and Environmental Protection (DEEP) along with stakeholders developed a draft definition in the fall of 2012.

The definition endorsed three possible approaches for defining a building as weatherized: a prescriptive approach (looking for the presence of certain building elements on a checklist), a performance approach (comparing the home’s energy performance against an equivalent modeled home), and a rating approach (using the U.S. Department of Energy’s Home Energy Score). Nothing was ever finalized, however, and two and a half years later DEEP has just recently issued a revised draft of the definition.

The latest definition is much weaker than the first and if approved would not help the state track the condition of its existing housing stock for weatherization purposes. For instance, the definition selects a Home Energy Score value that may allow as much as 60% of existing homes to qualify as weatherized. Worse, homes without wall or ceiling insulation could be considered as weatherized, even though those two building elements are typically viewed as key to any weatherization treatment.

Today Acadia Center issued comments on the definition, recommending that DEEP strengthen it and allow the state to take advantage of all of the economic and environmental benefits that can be achieved through weatherization. Acadia Center’s comments focus on five key points:

• DEEP should establish a weatherization standard so that regulators, policymakers, the General Assembly, stakeholders, and the public can track and measure our progress over time towards the 80% weatherization policy goal, but it should be stronger than what they have proposed.
• DEEP should use a modeling approach as the standard – like the Department of Energy’s Home Energy Score – rather than having multiple options that can lead to conflicting results and confusion.
• If DEEP uses the Home Energy Score, the appropriate score needs to be determined with respect to the existing Connecticut residential building stock.
• If DEEP uses the Home Energy Score, adjustments or accommodations for larger homes should not be made, since the score is based on something close to a typical or average home, any reduction in score for large homes should be balanced by a corresponding increase in scores for smaller homes.
• DEEP’s weatherization standard should be used for policy tracking purposes only, in other words, to measure progress towards the 80% weatherization goal, but not to enforce compliance on homeowners.

Weatherization can provide many important benefits to the state’s residents and economy – reduced energy costs, increased energy independence, and less carbon pollution – but only if it’s done effectively, and with these recommendations Acadia Center hopes to ensure that it is.

Acadia Center’s comments to DEEP are available here.

Bill Dornbos is the Director of the Connecticut Office and Senior Attorney for Acadia Center.  Bill focuses on advancing policy and regulatory solutions that seek to transform the energy system and move Connecticut towards a climate-safe, sustainable future. Recent work includes advocating for expanded investment in cost-effective energy efficiency for all fuels and analyzing greenhouse gas emissions trends in the Northeast.