Comments on sessions related to the LMI Portfolio and New Efficiency New York proceeding
Re: Case 18-M-0084 – In the Matter of a Comprehensive Energy Efficiency Initiative and Case 14-M-0094 – Proceeding on Motion of the Commission to Consider a Clean Energy Fund
Dear Secretary Phillips,
We, the undersigned parties, are writing to highlight concerns about low-and-moderate income (LMI) and disadvantaged community (DAC) stakeholder engagement within the proceeding. These concerns are particularly pertinent as the upcoming PSC mandated Statewide LMI Portfolio Stakeholder Engagement Session on August 1, 2024 approaches.
We appreciate that NYSERDA and the Program Administrators acknowledge that stakeholder engagement is crucial for the success of the Statewide LMI Portfolio, particularly during the critical interim review for the 2026-2030 program period. However, the Notice Announcing Statewide LMI Stakeholder Webinar appears to be simply an obligatory checkbox style effort in a broader context of poor engagement practices within the proceeding.
We do not believe the exclusively virtual webinar format is adequate or conducive to achieving meaningful community engagement. For the reasons set out below, we respectfully request that the PSC ensure in-person stakeholder options are offered for all future stakeholder engagement sessions related to the LMI Portfolio and New Efficiency New York proceeding, with a rotation of in-person locations to ensure upstate and downstate are equally served. We appreciate that additional capacity may be needed to effectively orchestrate and conduct such hybrid events. We are concerned that the lack of robust engagement strategies will continue to marginalize voices that should be uplifted in a proceeding meant to facilitate their decarbonization journey.
In-person stakeholder engagement is considered a best practice for meaningful community engagement; this is well-documented throughout community planning practices. With the design and review of the New Efficiency: New York LMI portfolio for 2026-2030 underway, it is all the more critical that stakeholders and communities are being engaged effectively in order to incorporate recommendations and lessons learned into program design and implementation going forward. Limited or less-effective community engagement throughout the current LMI Implementation Plan leads to future implementation plans that do not effectively overcome the existing barriers and do not incorporate co-designed solutions.
Respectfully, the LMI portfolio proposals for 2026-2030 are still largely lacking details and do not adequately address barriers for LMI households. This is an area where stakeholders can provide valuable insight. In a virtual webinar format, stakeholders are often unable to see each other to cross-collaborate and learn from others’ contributions and insights, stakeholders’ questions and feedback are often curated and not always shared with all of the participants. The ability to connect with program administrators and across different stakeholder interests is much more limited, creating a further sense of disconnection. These limitations in the virtual sessions lead to more challenges in building transparency, relationships, and equitable engagement. Such limitations are exacerbated when features like the visibility of the Q&A function are disabled, when meetings aren’t recorded for later viewing, or when content isn’t made accessible or available in a timely fashion.
We have seen these concerns play out, for example, in the recent technical conferences by NYSERDA and the Program Administrators held on February 2 and 8 of this year. Stakeholders participating virtually had very limited opportunities to engage and interact with the presentations. Many of the questions submitted by virtual participants were not posed in the room and not answered. Participants were not able to see who else was attending virtually and how their questions and/or comments might be aligned across the group. In contrast, attendees who were present in the room were able to ask the questions they wanted to ask and receive live answers to their concerns, and then follow-up on any areas needing further explanation. This also enabled stakeholders present in the room to connect and collaborate with other participants and foster a sense of stakeholder community and engagement. If attendees had been aware how little their engagement would be considered through the online process, they likely would have chosen to attend in person in order to be demonstrably heard.
This is not just an issue with those two technical conferences. Stakeholders continuously experience massive limitations when no in-person option is offered at other NYSERDA-led meetings, such as the Residential Market Advisory Group, and the Inflation Reduction Act Solar for All and HEEHRA meetings.
While we recognize the convenience of virtual stakeholder sessions, we also know that they have significant limitations. Given the importance of the July 20, 2023 Order and subsequent directives to program administrators regarding the direction of the New Efficiency: New York initiative, perhaps most importantly to the LMI portfolio, we submit that such sessions are not just procedural checkpoints but pivotal moments to deepen trust amongst stakeholders and build constructive collaboration that lead to concrete improvements in portfolio performance.
We respectfully request that in-person sessions are incorporated into stakeholder engagement strategy in order to ensure venues are accessible and inviting for all community representatives, particularly those from LMI backgrounds. All future Statewide LMI Portfolio stakeholder engagement sessions, and related New Efficiency: New York stakeholder sessions, should include the option for in-person attendance or a follow-up in-person session, and work toward geographic equity between upstate and downstate territories. We would be happy to have more intentional dialog and discuss opportunities for revising the current stakeholder engagement efforts and strategy, as the proceeding continues.
Sincerely,
Rebekah Morris-Gonzalez
Director of Climate Initiatives
Pratt Center for Community Development
Adam Flint
Director of Clean Energy Programs
Network for a Sustainable Tomorrow (NeST)
Eric Walker
Senior Policy Manager for Energy Justice
WE ACT for Environmental Justice
Malak Nassereddine
Senior Manager, Utility and Regulatory Policy
Building Decarbonization Coalition
Avni Pravin
Deputy Director
Alliance for a Green Economy
Lisa Marshall
Director of Organizing and Advocacy
New Yorkers for Clean Power
Daphany Rose Sanchez
Executive Director
Kinetic Communities Consulting
Deb Peck Kelleher
Deputy Director
The Alliance for Clean Energy New York
Betta Broad
Director, Advocacy & Organizing
Association for Energy Affordability
Martha Sickles
Principal
Urbecon LLC