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Responses to NASEO RFI Implementation Options for Home Energy Rebate Programs

On April 24, 2023, NASEO released our Request for Information - Implementation Options for Home Energy Performance-Based Whole-House Rebate Program and High-Efficiency Electric Home Rebate Program to support State and Territory Energy Offices in program design. This RFI and the responses are not official state or federal actions and should not be construed as such. All respondents were required to acknowledge that responses were appropriate for the NASEO website and public access. Responses to the RFI are posted below in alphabetical order by RFI Response Category. The RFI, website, and posting of the responses do not constitute endorsement of any proposal or information presented.

Responses to RFI Category 1 Comprehensive Program Design

Applied Energy Group

Program goal: The goals of the program design are multifaceted and include driving increased comfort, along with energy and cost savings opportunities for all homeowners meeting program participation criteria, with an emphasis on supporting income-eligible homeowners; engaging with, and reducing energy burden for, those most in need; and increasing grid reliability and delivering energy savings towards carbon reduction goals. Ultimately, the program will drive clean energy market transformation through the use of proven processes and combining technology with data to remove program participation barriers; through investment in awareness and manufacturing; and by driving a cost-effective transition to carbon reduction and energy efficiency.

Stated building type: Single family and multifamily

Income target beyond legislative requirements: None

Rebate program: HOMES and HEEHR

Complete response

Program goal: The primary goal of this program is to seal leaky duct systems to reduce energy usage,
greenhouse gas emissions, and energy costs associated with heating and cooling. Ancillary
benefits include greater satisfaction with HVAC systems, especially heat pumps, due to increased
system efficiency, improved indoor air quality, and resident comfort.

Stated building type: Single family and multifamily residential buildings that have heating and/ or cooling systems with ductwork

Income target beyond legislative requirement: None

Rebate program: HEEHR

Complete response

Beneficial Electrification League

Program goal: The program described below sets forth the concept of a program that leverages rebates
available under HEEHR to improve the efficiency of single-family residential buildings to reduce
the energy burden for low- and moderate-income households, and simultaneously reduce the
greenhouse gas emissions associated with residential housing and strengthen the electric
system.

Stated building type: Single family

Income target beyond legislative requirement: None

Rebate program: HEEHR

Complete response

Program goal: A market transformation without inclusion is not a market transformation at all. As a potential program implementer of state HOMES and HEEHR programs, BlocPower’s program design goals are to: 1) deliver performant and affordable energy efficiency and electrification projects in LMI / Justice40 communities, at scale; 2) deliver projects that result in lower utility bills, improved indoor air quality and health, and greater climate resilience; and 3) create new local, non-exportable jobs in communities that are historically underserved. The program design will accomplish the goals by maximizing impact and adoption of the IRA’s rebate programs within LMI single-family homes and multi-family buildings. BlocPower seeks to achieve a scalable market transformation by leveraging data and software to help states fulfill their rebate program objectives.

Stated building type: Single family and multifamily

Income target beyond legislative requirement: None

Rebate program: HOMES and HEEHR

Complete response

Program goal: Turn policy, regulations and community input into successful energy programs that benefit people and the planet

Stated building type: Single family and multifamily

Income target beyond legislative requirement: None

Rebate program: HOMES and HEEHR

Complete response

Program goal: A seamless customer experience with no application or burdensome documentation, a simple and uniform program design across the state, overcome contractor objections because it can be easily incorporated into their business model, alignment with existing programs, allowing for transparent incentive stacking so that households receive the maximum benefit, geotargeted bonus incentives for customers located in census tracts defined as disadvantaged, reach other HEEHR program goals, such as workforce development, greenhouse gas mitigation, air quality improvements and household cost savings

Stated building type: Single family and multifamily

Income target beyond legislative requirement: None

Rebate program: HEEHR

Complete response

Electric and Gas Industries Association

Program goal: The programs will support market transformation by facilitating an increase in the purchase of heat pumps in place of gas fired furnaces, an increase in building weatherization projects, and the adoption
of home certification standards that tie increases in real estate value to the installation of these
measures.

Stated building type: Single family and multifamily

Income target beyond legislative requirement: None

Rebate program: HOMES and HEEHR

Complete response

Energy Solutions

Program goal: Enable sustained market transformation by: 1) building consumer interest/demand for efficient technologies and other eligible measures; 2) engaging with contractors and the supply chain to increase the industry's capacity for current and future efficiency and electrification programs; 3)collecting data to demonstrate and substantiate the long-term benefits and positive results of electrification and inform subsequent policies and program designs; 4) testing concepts to support large market reach; and 5)setting up a programmatic framework and infrastructure that can be used by states that continue to invest in decarbonization program concepts after HOMES and HEEHR funds run out.

Stated building type: Single family and multifamily

Income target beyond legislative requirement: None

Rebate program: HOMES and HEEHR

Complete response

Program goal: The overarching goal of the proposed program design is to rapidly scale equitable decarbonization by eliminating friction in the implementation of IRA point-of-sale rebates, while also tackling other barriers that prevent low- and moderate-income consumers and disadvantaged communities from accessing clean and efficient technologies.

Stated building type: Single family and multifamily

Income target beyond legislative requirement: None

Rebate program: HEEHR

Complete response

Program goal: The intent of the HOMES measured savings approach is to create a market for measured energy
savings, providing aggregators flexibility to deploy different energy-saving and greenhouse gas reduction
strategies as well as market-based competition that will encourage homeowners to undertake the most cost-effective energy efficiency upgrades.

Stated building type: None

Income target beyond legislative requirement: None

Rebate program: HOMES

Complete response

Franklin Energy

Program goal: Our primary program goals include creating seamless Energy Office and constituent experiences through a locally-based team of experts, proven rebate program delivery processes, and the state-of-the-art enabling technology to efficiently deliver large, complex programs. We are also driven to engage, empower, and oversee contractors to ensure programs grow the local economy while ensure a high quality of work. We prioritize equitable distribution of funds to address the energy burdens faced by low- and moderate-income households, while ensuring public investments are effectively utilized for measurable energy reductions and incentivizing high-quality energy retrofits. By stimulating demand for energy efficiency services and demonstrating transformative outcomes, we foster economic growth and sustainability, particularly in historically underserved areas. With nearly three decades of experience in program implementation, we offer state energy offices a simplified experience, allowing them to focus on their core objectives while we navigate the complexities of program delivery.

Stated building type: Single family and multifamily

Income target beyond legislative requirement: None

Rebate program: HOMES and HEEHR

Complete response

Program goal: None

Stated building type: None

Income target beyond legislative requirement: None

Rebate program: HOMES and HEEHR

Complete response

Program goal: HEEHR’s overall goals are to decarbonize American homes by electrifying key end uses, which will reduce GHG emissions and home energy bills, and transform these end use markets. ICF’s program design supports these goals by leveraging supply chain infrastructure to maximize program impacts through an easy to administer design, and in the process to transform markets, by engaging key supply chain partners, shifting product market shares, and expanding the trained contractor base. Over a multiyear period, the metrics for market transformation would include not only market share increases, but a shift in market perception and behavior, such that the targeted product types become the mainstream choice. This perception would be accompanied by significant drops in retail prices, creating a virtuous circle where the preferred choice becomes the more affordable choice.

Stated building type: Single family, multifamily, and manufactured housing

Income target beyond legislative requirement: None

Rebate program: HEEHR

Complete response

ICF HOMES Measured Savings

Program goal: The HOMES rebate program is intended to upgrade the energy performance of hundreds of thousands of American homes, and in the process transform the nation’s residential energy efficiency market. ICF's program design goals support these broader goals by fostering a market for aggregators who develop consumer awareness and an effective, scalable contractor-based business model that connects payments to actual (measured) energy and GHG savings. The ultimate market transformation goal is to realize enhanced energy performance in all American homes in the coming years.

Stated building type: Single family and multifamily

Income target beyond legislative requirement: None

Rebate program: HOMES

Complete response

ICF HOMES Modeled Savings

Program goal: The HOMES rebate program is intended to upgrade the energy performance of hundreds of thousands of American homes, and in the process transform the nation’s residential energy efficiency market. ICF’s program design goals support these broader goals by fostering a trade ally-based system that uses approved modeling tools to identify and install whole-house efficiency solutions and sustaining this market momentum by building trade ally capacity and consumer awareness. Having fostered similar home performance trade ally markets in several states, we believe this goal is attainable in all states. The ultimate market transformation goal is to realize enhanced energy performance in all American homes in the coming years.

Stated building type: Single family and multifamily

Income target beyond legislative requirement: None

Rebate program: HOMES

Complete response

Program goal: None

Stated building type: None

Income target beyond legislative requirement: None

Rebate program: HOMES and HEEHR

Complete response

Program goal: We see the IRA rebates, particularly the HEEHR program, as a transformative opportunity to open the benefits of electrification to low- and moderate-income households that are often unable to take advantage of rebate programs because of the need for them to cover costs, even if temporarily, out of pocket. Our goal is to provide these households with a delightful and easy-to-use experience that spreads awareness of the programs and their benefits, enrolls households with minimal friction, and delivers benefits quickly.

Stated building type: None

Income target beyond legislative requirement: None

Rebate program: HOMES (income verification only) and HEEHR

Complete response

Recurve Analytics

Program goal: FLEXmarket's primary goal is to deliver high-quality and high-value projects to all participants by aligning aggregator incentives with delivered impacts, streamlining program implementation to reduce overhead, supporting diverse business models for customer service with measure-agnostic flexibility, and ensuring accountability with accessible tracking and monitoring feedback for all parties. In addition, FLEXmarket aims toward foundational market transformation through quantified value, aligned incentives, and visibility into the customer and grid benefits of high-performing buildings .

Stated building type: Single family, multifamily, and manufactured housing

Income target beyond legislative requirement: None

Rebate program: HOMES

Complete response

Rewiring America

Program goal: To achieve lasting impact, SEOs should design and implement rebate programs that
accomplish short-term goals while also building momentum for long-term market transformation.
Specifically, SEOs should design programs that: Maximize positive consumer experiences. SEOs can build popular support for incentive programs by prioritizing comprehensive high-impact retrofit projects that reduce household energy burdens and insulate consumers from volatile fossil fuel markets; maximize positive contractor experiences. SEOs can encourage contractor uptake by
simplifying programs, minimizing friction, and avoiding overly prescriptive requirements; build and expand the pipeline for retrofit projects. SEOs can build the market for retrofit projects by demonstrating the benefits of electrification in low-income communities and
distressed housing stocks. These benefits — backstopped with high-quality, publicly available data gathered from the programs — can consequently inspire the confidence
needed for additional capacity-building and private-sector financing to enter the market.

Stated building type: None

Income target beyond legislative requirement: All funding delivered below 80 percent of area median income

Rebate program: HOMES and HEEHR

Complete response

Rocky Mountain Institute

Program goal: The goals of our program design are to allow the most energy burdened households to rapidly upgrade their properties with minimal administrative burden and upfront cost. This will lower utility bills, result in better indoor air quality (due to beneficial electrification) and reduce GHG emissions.

Stated building type: Affordable multifamily

Income target beyond legislative requirement: All funding delivered below 80 percent of area median income with additional carve outs for extremely low-income and very low-income

Rebate program: HOMES and HEEHR

Complete response

Program goal: TRC’s goal is to develop comprehensive, customer-centric HOMES and HEEHRA Programs tailored to statewide needs and goals. Our framework guides states through questions to inform custom solutions, like:
aligning with Justice40, evaluating how state legislative and regulatory environments could impact the design, determining other factors that require custom approaches. The resulting programs will achieve lasting market transformation even after program funding is expended.

Stated building type: None

Income target beyond legislative requirement: Alignment with Justice40 for HOMES

Rebate program: HOMES and HEEHR

Complete response

Program goal: The goal of our program design is simple: UtilityAPI wants to ensure State Energy Offices have the statewide data infrastructure necessary to enable all their constituents to participate in the HOMES Rebate Program,
along with other Inflation Reduction Actʼs programs and financial incentives more broadly. To achieve this
goal, we propose configuring and launching on a statewide and/or individual utility basis our Utility Data
Exchange Platform.

Stated building type: None

Income target beyond legislative requirement: None

Rebate program: HOMES and HEEHR

Complete response

Program goal: None

Stated building type: None

Income target beyond legislative requirement: None

Rebate program: HOMES and HEEHR

Complete response

Responses to RFI Category 2 Program Elements

Air Conditioning Contractors of America

Preview of suggested program elements: ACCA Quality Installation Certificates

Complete response

American Council for an Energy-Efficient Economy

Preview of suggested program elements: Outreach and participation, consumer protections, low-income weatherization, renter protection, market transformation

Complete response

Applied Energy Group

Preview of suggested program elements: Combing HOMES and HEEHR into one program design, multi-state regional approach, providing income verification to support eligibility qualification and incentive levels, enabling software-based energy savings modeling and field services coordination, HOMES measured savings pathway aggregator/trade ally program delivery solution, VisionDSM portfolio management and tracking system, support for pre-planning activities included under Early Administrative Funds in the ALRD

Complete response

Preview of suggested program elements: Advanced duct sealing as an eligible measure in performance-based HOMES programs

Complete response

Allegheny Science and Technology

Preview of suggested program elements: Program management and monitoring, outreach and communications, strategic stakeholder engagement and partnership development, rebate process planning and strategy, impact analysis, program implementation, leverage existing programs and delivery channels

Complete response

Preview of suggested program elements: BlocMaps is a program planning, execution, and reporting tool that can help State Energy Offices and their program implementers maximize and amplify impact of HOMES and HEEHR investments

Complete response

Building Decarbonization Coalition

Preview of suggested program elements: Marketing, education, and outreach

Complete response

Preview of suggested program elements: Accessible and equitable program design, designing programs for maximum impact, eligible technologies for rebates

Complete response

Preview of suggested program elements: A simple consumer experience, income-qualified consumer experience, ready-made retail solution, approved contractor network, a single system of record and the State Energy Office

Complete response

Community Action Partnership of Oregon

Preview of suggested program elements: Making qualifying low- or moderator-income clients easier, State Departments of Energy must offer coordination and navigation, quality control and accountability, HOMES for low- and moderate-income households, make serious efforts to reach low-income renters

Complete response

Preview of suggested program elements: Include rebates for geothermal heat pumps in home energy rebate programs, pair the HOMES and HEEHR along state and local-level energy efficiency programs, State Energy Offices should align implementation plans with existing energy efficiency and grant programs, states should offer HEEHR for both retrofits and new construction, providing up-front certainty in rebate amounts and eligibility, State Energy Offices should establish pre-approved categories of rebates under the HOMES program for certain measures based om generic modeled energy savings, State Energy Offices should encourage flexibility for contractors and aggregators to utilize historical energy data from a wide variety of sources, including utilities, in-home smart panels and sensors, third-party data providers, customer utility bills, and/or delivery records, States should rely upon existing certifications and training programs as the most effective mechanisms for quality control for heat pump installations, State Energy Offices should leverage common rebate applications, software, and online portals to encourage streamlined program implementation with neighboring states and reduce administrative burdens for contractors operating across multiple jurisdictions, State Energy Offices should streamline rebate processing through technology solutions

Complete response

Preview of suggested program elements: Verify consumer income when processing the rebates, leverage integrated eligibility systems for public assistance programs, Instant ability for homeowners, building owners, and residents to calculate their eligibility for the HOMES and HEEHR programs with minimal data entry, streamlined process for homeowners, building owners, and residents to apply for the programs securely, clear registration process for qualified contractors to benefit from the program, case management system so that state workers can review and approve homeowner, building owner, and contractor information and securely store data, user friendly customer experience for all user types with clear and timely notification system for application process

Complete response

Preview of suggested program elements: Prioritize electrical load center upgrades, focus on the integration of smart technologies, State Energy Officials can work with equipment manufacturers, State Energy Offices collaborate closely on all points-of-sale, consider embedding a required assessment of homes' existing electrical power distribution infrastructure, work with manufacturers to support qualifying installation initiative, consider programs that support retrofits to existing buildings and new construction

Complete response

Environmental and Energy Study Institute

Preview of suggested program elements: Establishing strategic, overarching goals to achieve State-specific objectives, pursuing leveraged financing to achieve economies-of-scale, clearly defining the roles and responsibilities, addressing health and safety concerns, committing and adhering to quick turn-around times, instituting processes that are customer- and contractor-friendly that meet the needs of service-provider business models, leveraging funding with other programs including the U.S. Department of Agriculture Rural Utilities Service’s Rural Energy Savings Program (RESP), linking programs to the ENERGY STAR brand, considering how the programs might also accelerate beneficial electrification in the transportation sector, communicating with neighboring States on program plans, continuously benchmarking programs against initiatives underway in other States

Complete response

Preview of suggested program elements: Income eligibility and verification, effective partnerships and Justice40, Technical assistance, future-proofing

Complete response

Energy Solutions

Preview of suggested program elements: Market engagement, data and reporting, strategic market initiatives

Complete response

ENERGY STAR Labeling Program

Preview of suggested program elements: Prioritize simplicity at all touch points, encourage as many states as possible adopt similar program design and implementation plan, seek dual incentive application paths, DOE provides a universal income eligibility tool, ensure contractors are effectively trained in product technology and sales, immediate eligibility feedback upon submittal of the application, smart phone friendly website or mobile app, strict guidance on payment turnabout time

Complete response

Preview of suggested program elements: Project management oversight elements, fraud risk management program elements, grants management technology

Complete response

Harvest Thermal

Preview of suggested program elements: Allow combined space conditioning and hot water system, technology-neutral, innovation-friendly approach to program design

Complete response

Preview of suggested program elements: Program and plan design, vendor onboarding and management, marketing and outreach, call center, eligibility determination and quality assurance, system and rebate processing

Complete response

International Center for Appropriate and Sustainable Technology

Preview of suggested program elements: 40 percent of rebates be specifically allocation to low-income communities

Complete response

National Propane Gas Association

Preview of suggested program elements: Utilize rebates to fund oil to propane conversions, keep the full fuel cycle in mind, the effects of adding load to the electrical network should be taken into account when considered these initiatives

Complete response

National Consumer Law Center

Preview of proposed elements: Ensuring low-income energy affordability, rebate contracts transactions should avoid replicating the problems of PACE, consumer protections for work preformed under the contract, program monitoring

Complete response

National Housing Trust

Preview of proposed elements: Actively pursue collaborative relationships with state Housing Finance Agencies, aligning and integrating home energy rebates with Housing Finance Agency programs, allow for extended rebate reservation periods to support alignment with the housing finance process

Complete response

Opinion Dynamics

Preview of proposed elements: Developmental evaluation within the program design, implementation, and reporting processes to support evidence-based decision-making as well as provide near real-time feedback to inform continuous improvement

Complete response

Preview of proposed elements: Data acquisition and segmentation to achieve equitable implementation outcomes, personalized program education and outreach to increase program awareness and enrollment

Complete response

Pearl Certification

Preview of proposed elements: Home certification, implementation and pricing, homeowner education and engagement, contractor quality assurance, modeling software

Complete response

Preview of proposed elements: Raising awareness, verifying income eligibility, facilitating the flow of funds

Complete response

Performance Systems Development

Preview of proposed elements: Heat pump toolkit, program management platform, quality assurance services

Complete response

Preview of proposed elements: Large scale analysis of cities and states to help with program design and customer targeting as well as consumer facing tools for customer education and engagement

Complete response

Recurve Analytics

Preview of proposed elements: Operationalizing open source advanced measurement and verification, program optimization/targeting, tracking and monitoring, comprehensive audit trail, secure data management and controlled access

Complete response

Residential Energy and Water Intelligence

Preview of proposed elements: Include the multifamily sector, focus on naturally occurring affordable housing, support jurisdictional development of building energy benchmarking ordinances and building performance standards and time of sale home energy ratings, funding multifamily property and building inventories as part of program planning efforts, planning needs to include whole property energy-use estimates, integrate across silos, funding deep engagement with community-based organizations, outdoor media, program administration and implementation dashboard, public dashboard

Complete response

Resource Innovations

Preview of proposed elements: Experience implementing programs for people with and moderate incomes, proven trade ally network recruitment and management capabilities, established commitments and proven results working with diverse businesses and environmental justice communities, turnkey rebate processing and administration capabilities with an ability to fulfill rebate applications within two business days, best in class integrated data management and reporting software system

Complete response

Rocky Mountain Institute

Preview of proposed elements: Encourage and inform incentive program stacking with home rebate programs, utilize state administrative capacity as efficiently as possible, prioritize low-income households through metrics setting, coordinate with state Housing Finance Agencies, design financing that works for Low Income Housing Tax Credit, minimize income documentation, require tenant protection, do not use home energy efficiency rebates to subsidize new fossil fuel appliances, design the program to include both a measured and modeled pathway, include and regionally align minimum performance criteria, re-evaluate low-income incentive levels, provide low-income rebates up front, train contractors on electrification

Complete response

Preview of suggested elements: Providing sufficient lead time for communities to digest details, retailers may want to consider targeted advertisements for retail locations in low and moderate-income areas, support community based organized on staying updated on the latest information, some utility companies have payment assistance programs that may be leveraged for braiding of funds, categorical eligibility, a more granular definition of area median income, deploy the efficiency and electrification rebates for all eligible income levels under the law simultaneously, require ENERGY STAR appliances for HOMES, allow all product categories outlined in the legislation for HEEHR rebates, provide maximum rebates for eligible products, allow customer to qualify for a HEEHR rebate when converting any non-ENERGY STAR cooking appliance to any ENERGY STAR electric cooking appliance once the ENERGY STAR specification is finalized, State Energy Offices should not limit rebates to US manufactured goods

Complete response

Schneider Electric

Preview of suggested elements: Diversity of eligible hardware, systems based performance incentives, ease of access, diverse network of contractors, income-based compensation measures

Complete response

Preview of suggested elements: Measured energy savings without utility data partnerships

Complete response

Preview of suggested elements: Energy bills should not go up, the cost of improvements should pay for themselves, the installed equipment is viable and correctly sized to the home

Complete response

Preview of suggested elements: Review state-specific decarbonization and environmental goals and estimate the targeted impact of programs, complete a detailed market assessment, engage community organizations

Complete response

Preview of suggested elements: Online marketplace

Complete response

Preview of suggested elements: Program landscape mapping and gap analysis, partner collaboration planning, stakeholder engagement, heat pump market assessment, program design framework, incentives and financing, social and energy equity/LMI, program oversight and implementation support

Complete response

Responses to RFI Category 3 Indication of Vendor Interest

Applied Energy Group

Aptim Environmental Services

Alleghany Science and Technology

Beam, Longest, Neff

Beneficial Electrification League

Building Decarbonization Coalition

Center for Sustainable Energy

Environmental and Energy Study Institute

Electric and Gas Industries Association

Eli Technologies

Energy Solutions

Evergreen Consulting Group

Franklin Energy

HomeWorks Energy

International Center for Appropriate and Sustainable Technology

Opinion Dynamics

Pearl Certification

Promise Network

Performance Systems Development

Recurve Analytics

Residential Energy and Water Intelligence

Residential Energy Services Network

Resource Innovations

Rocky Mountain Institute

Schneider Electric

Service 1st Financial

Contact Maddie Koewler at mkoewler@naseo.org with questions.