Comments on Rhode Island’s 2025 Climate Action Strategy Executive Summary
RI Climate Strategy summary comments_Acadia Center
- Meeting the Moment with Courage, Action, and Accountability
- Lack of Transparency in Development of 2025 Climate Strategy Not Conducive to Meaningful Stakeholder Engagement
- Lack of Transparency Regarding Assumptions Underpinning Both the “Current Policy Scenario” and “Potential Carbon Reduction Strategies” Raises Concerns and the Distinction Between the Two is Muddled
- The Biodiesel Heating Oil Act Presents an Extremely High Level of Risk to the State That is Not Addressed in the 2025 Climate Strategy
- Alternative Fuels Appears to be A Core Decarbonization Strategy for Delivered Fuels but Not The Gas Distribution System, Highlighting the Inconsistent Approach to Biofuels as a Building Decarbonization Strategy
- RES Compliance Tradeoffs: RECs vs. In-State Renewable Energy Deployment
- Concerns That Carbon Reduction Strategy Emissions Avoided Methodology Overstates Impact of New England Heat Pump Accelerator and Minimizes the Urgency of Enacting Complimentary Building Decarbonization Strategies
- Managing Uncertainty Around Advanced Clean Cars and Advanced Clean Trucks Implementation and the Need for State-Level Backup Pathways to Lock in Transportation Emissions Reductions
- Additional Risk from Federal Fuel Economy and GHG Standard
- Grid Constraints as a Structural Risk to the Vehicle Electrification Pathway
Acadia Center Comments on DOER’s Ratemaking Straw Proposal as Presented to the Electric Rate Task Force
Ratemaking Straw Proposal Comments
The comments made the following points:
- There is a clear and urgent need to plan, in preparation for the completed rollout of advanced metering infrastructure (AMI), for utility-specific time-of-use (TOU) rates that can be implemented as soon as possible to allow the affordability benefits of the AMI investment to flow to electric distribution company (EDC) customers, and the Proposal lays out a reasonable starting position.
- DOER should provide or perform analysis specific to MA’s EDC territories, particularly regarding bill impacts to LMI customers, in the upcoming proceeding.
- DOER should clarify the envisioned interaction of its TOU proposal with extant income-eligible discount rates.
- Acadia Center recommends focus on customer protections and education in TOU rate implementation, including shadow billing for all customers and bill stabilization for LMI customers for a year.
- It is unclear whether a fixed charge increase would be net beneficial or not, and Acadia Center reserves support until more specific analysis is provided.
- Acadia Center strongly supports eliminating reconciliation mechanisms wherever legally possible and transitioning the relevant costs back into base rates. Acadia Center recommends, for any reconciliation mechanisms that cannot be legally eliminated, consideration of a sharing mechanism that expose EDC shareholders to the benefits and risks of under- or over-spending by sharing the benefits of good EDC management and the costs of bad EDC management with customers who have no alternative option.
- Acadia Center expresses cautious openness to recoupling as a mechanism to incentivize electrification and increase competition between EDCs and LDCs for heating customers, while ensuring that core principles for incentivizing energy efficiency are preserved/not unduly watered down, particularly to the extent recoupling can serve as a replacement for an attrition relief mechanism in the EDCs’ multi-year rate plans. However, the potential for a split incentive issue around EE and DERs is significant, and, as such, Acadia Center recommends examining the potential advantages and drawbacks of a 3rd party EE program administrator, as well as additional analysis of the MA market and customer bills.
- Rather than discontinuing stay-out provisions entirely, as the Proposal prefers, Acadia Center recommends consideration of optional stay-out provisions linked to performance incentive mechanisms (PIMs) such that only an EDC participating in a multi-year rate plan with a stay-out provision can receive rewards attached to PIMs.
- Acadia Center supports consideration of additional PIMs beyond those in the Proposal, including but not limited to: A grid efficiency PIM (measuring relative % utilization on- and off-peak, ideally targeted as granularly as possible) and a peak load reduction PIM (setting a baseline peak load then providing a reward for decreasing it or penalty for increasing it, with a baseline that decreases over time).
- Acadia Center strongly recommends that a fulsome investigation of the process required to implement a TotEx regime be incorporated into the Proposal.
Acadia Center Comments on Maine Non-Wires Alternatives Docket
Acadia Center Comments in Response to NWA NOI
The comments made the following recommendations:
- The statutory definition of NWAs should be amended to make explicitly clear that any rightsizing of a wired solution that meets the system need, including alternate routing, deferring the upgrade, and any combination thereof with a GET or other alternate infrastructure, technology or application, is included. This amendment would forestall argumentation over the exact slate of technical solutions over which the NWA coordinator has purview.
- The exclusion for review of small Asset Condition Projects should be removed.
- The utility’s Integrated Grid Plan should specifically coordinate with and incorporate as possible planned NWA reviews.
- The Commission should continue to advocate, per statute, for least-cost solutions to bulk power system needs, and for nontransmission alternatives to be considered comparably to transmission.
- The Commission should lay out in an Order the appropriate flow of information from the utility to the NWA coordinator, rather than relying on a MOU negotiated by the OPA and CMP.
- Pool transmission facilities projects identified by ISO-NE should be exempted from the NWA coordinator process.
Public Comment on Rhode Island Energy’s 2026 Annual Energy Efficiency Plan
25-37-EE Public Comment_Acadia Center_12-10-25
Acadia Center offered written and verbal comments before the Rhode Island Public Utilities Commission (PUC) on Docket No. 25-37-EE, regarding Rhode Island Energy’s 2026 Annual Energy Efficiency (EE) Plan.
As was highlighted throughout Acadia Center’s participation in the annual planning process, the organization reiterated that the downward trend in EE budget is shortsighted and to the detriment of Rhode Island homes and businesses.
- Impact of 2026 Plan Cuts to Benefits, Savings and Jobs
- Energy Efficiency Key Defense to Rising Energy Costs
- Energy Efficiency As Lowest Cost Resource
- Efficiency Must Expand to Act on Climate
In part due to Acadia Center’s analysis and advocacy, the Energy Efficiency Council (EEC) presented a proposal for additional savings before the PUC in Docket No. 25-37-EE. Acadia Center urged the PUC to adopt the additional savings proposal of the EEC.
Acadia Center Submits Comments on the Draft Standards and Guidelines for Cumulative Impacts Analysis (CIA) in Massachusetts
Comments on Cumulative Impact Analysis_Acadia Center
Acadia Center and Fellow Advocates Write House Energy Affordability Bill Letter to the Massachusetts House of Representatives
House Energy Affordability Bill Letter to House
Acadia Center Submits Reply Comments with CLF on ESMP Phase II investigation
ESMP Phase II reply comments_CLF_Acadia Center
Acadia Center’s Comments on Rhode Island Heat Pump Accelerator
RFI response_OER heat pump accelerator_Acadia Center
Acadia Center Submits Comments on the Draft Standards and Guidelines for Community Benefit Plans (CBPs) and Community Benefits Agreements (CBAs)
Comments on Draft Standards and Guidelines for CBAs and CBPs