While Mass Save’s mission is to further the Commonwealth’s energy efficiency goals, the implementation of its programs has resulted in disproportionate advantages for residents of higher-income municipalities, mainly through an allocation of incentives whose effect is inequitable. For the 2019–2023 period, we found that many residents of lower-income municipalities and municipalities with higher renter percentages have effectively subsidized the energy improvements for residents of net benefit municipalities, which are generally higher-income municipalities that receive more benefits from Mass Save than they contribute to Mass Save.
Furthermore, densely populated urban areas with lower-income households, notably those classified as GCs, bear a heavier financial burden while reaping fewer rewards from the program. This skewed distribution of benefits leads to inequitable outcomes and underscores the need for reevaluating how funding is allocated. The following recommendations present several policy changes which, if implemented, may ensure more equitable access to Mass Save benefits for residents of the Commonwealth.
1. Utility companies should not administer Mass Save.
Public utilities in Massachusetts receive compensation for the transmission and distribution of electricity and natural gas to residents and businesses across the Commonwealth. They are paid for these services on a per unit basis, meaning that they are paid more for each unit of electricity or natural gas they deliver. While their compensation does not directly flow from the commodity (i.e., electricity or natural gas), it is directly linked to how much commodity is used; essentially, the more they deliver, the more money public utilities make.
In July 2008, DPU introduced revenue decoupling to reduce or eliminate the inherent financial disincentive and conflict of interest regarding Mass Save’s goal of energy efficiency.62 Revenue decoupling is a mechanism that separates electric and natural gas utilities’ revenues from customer sales. That is, regardless of the volume of sales, utilities collect the same amount of revenue. In theory, revenue decoupling removes a financial disincentive to promote energy efficiency and conservation, which would otherwise lead to reduced sales, revenue, and earnings.
It is important to recognize that while revenue decoupling may remove a disincentive to implement energy efficiency and demand reduction programs that encourage customers to lower energy use, it still does not incentivize public utilities, which get paid no matter the success or failure of those programs. This lack of incentive may have a negative impact on the companies’ commitment to diligently execute the requirements of the Mass Save program. The issues identified in this report regarding participation by renters, residents of EJ communities, and those in GCs are not new. These problems have been known and persisted for some time, without resolution. These difficult problems could be easier to solve if those charged with administering the program were appropriately incentivized to deliver on Mass Save’s mission.
To resolve this issue with the goal of improving the Mass Save program and helping to ensure public confidence in this program, it is recommended that the Commonwealth consider moving the administration of Mass Save to an independent entity without a direct financial interest tied to use, consumption, and delivery. Such an entity should exist solely to implement energy efficiency, demand reduction programs, encourage customers to lower energy use and demand, and lower energy costs for consumers. It is critical that this program be focused on its mission, structured appropriately, and administered effectively, without the significant financial overhead charged to the program by utilities. For example, Mass Save diverts a large portion of its budget (over 30%, according to available data) from direct energy improvements to marketing, outreach, training, administration, and the incentive payouts to utility companies for meeting goals, which are sometimes self-set. Independent administration of Mass Save, including by public procurement of an administrator, should help reduce these significant overhead costs that reduce the program’s financial resources, to the detriment of investments in energy efficiency in Massachusetts homes and businesses.
2. The Legislature should consider oversight hearings.
Over the four-year 2019–2023 period, the administrative costs for Mass Save exceeded $1.6 billion, for an average cost of $407.1 million per year. For context, if the administration of Mass Save were a state government agency, it would be the 26th largest agency by cost, larger than every state college, all of the Commonwealth’s environmental agencies, and most other state government agencies. Including the program’s nonadministrative costs, Mass Save’s $1.33 billion average annual cost would make it the 12th largest state government agency. Currently, Mass Save is not a governmental agency; however, it does pursue public goals and is funded by ratepayers under the authority of state law.
Given the size, scope, and importance of Mass Save—as well as the problems identified in this report and by others with the program—we recommend that the Legislature use its authority to provide appropriate oversight, including holding hearings regarding the program. Mass Save provides critical services that should help ratepayers and protect our environment; it is imperative that these services be well structured to ensure that the Commonwealth’s public purposes are met in an effective, efficient manner that is in the public’s interest. Oversight hearings would create an appropriate forum for these and other issues to be considered and addressed.
Historically, notwithstanding its mandate to ensure broad-based participation in its programs, Mass Save has overlooked nuances of socioeconomic diversity. High-income households are often in a better position to invest in energy upgrades, such as installing solar panels or upgrading insulation, and thus they are more likely to take advantage of the rebates and incentives provided. In contrast, low-income renters live in properties where the property owners, not the renters themselves, control decisions about energy upgrades. This imbalance highlights the need for policy adjustments that reflect the economic realities of different population segments.
As part of its oversight of Mass Save, we recommend that the Legislature consider the aforementioned imbalances and disparities within Mass Save; particularly, with regard to low-income households, who generally contribute more to Mass Save than they receive in return. Low-income households should not subsidize Mass Save for higher-income households.
Additionally, the Legislature could consider establishing a minimum investment floor for municipalities with high renter percentages, requiring that a minimum amount of program funding be spent in such municipalities in order to address low renter participation rates. Such a policy would help in both distributing benefits to municipalities whose residents have historically had a comparatively lower rates of return on their contributions to Mass Save and also increasing municipal and community engagement in helping solve the issue of renter participation.
3. Solve the issue of renter participation.
It is well established that renters participate in Mass Save at a rate much lower than homeowners. This report has provided additional insight into this, including the negative and inequitable impact of this dynamic on GCs, EJ communities, and lower-income residents. The underlying reasons for this lack of participation are doubtless complex, with the most central of these likely being the lack of incentive for landowners to pay part of the cost for modifications to their properties when all the financial benefits accrue to their tenants.
A variety of methods could be considered to provide landowners with an incentive to make these improvements. We recommend that the Executive and Legislative branches consider this matter and develop an incentive package to address this issue. As shown in this report, the impact of not solving this issue is significant from financial and equity perspectives, as well as from the standpoint of confidence in our state government. It is critical that all residents be provided with the opportunity to benefit from the money they spend on public and near-public services such as Mass Save. At present, we know that some subgroups do not—and functionally cannot—participate, but yet they must pay into a system we know they cannot benefit from. This only increases opposition and resistance to a program that has made significant environmental investments across Massachusetts while seeking to save money for ratepayers.
4. Increase transparency.
As described in this report, utility bills lack transparency regarding Mass Save charges, as well as regarding charges for a number of other items on utility bills. It is recommended that the Commonwealth require plain-language billing that is comprehensible to ratepayers, printed directly on the bill as either a line item or a quick-response code (more commonly known as a QR code) or some other hyperlink that directs ratepayers to plain-language explanations for billing items. Many of the cost items on utility bills are required by state government. These costs should always be clear and understandable to the public, whose officials mandated these charges, using the policymaking authority granted to them by the public.
In order to promote increased transparency on utility bills, the Commonwealth should prohibit bundling charges and instead require itemization of all bill components, including the Mass Save charges on gas and electric bills. In general, any taxes, government-mandated fees, and environmental surcharges should be explicitly labeled, allowing consumers to easily identify what portion of their bill is determined by regulatory requirements. Adjustments, credits, or rebates should be identified, particularly in cases where they offset other charges.
Additionally, utility bills should provide ratepayers with more data about use. Currently, utility bills include comparisons with previous use just for the entire amount due. Instead, the Commonwealth should consider measures to increase transparency, such as requiring monthly comparisons for each line in the standardized breakdown of charges. Notably, during the 2024–2025 winter utility bill crisis, there was widespread confusion regarding the significant increases to residents’ utility bills, which generated considerable grassroots support for more billing transparency.63
Data and access to data are critical to transparency. DPU, as part of its oversight of Mass Save, should require Mass Save to upgrade its data portal with timely and complete datasets going forward. PAs have not been required until the present time to make their full data public, including the disclosure of geographic distribution of contributors and beneficiaries. However, the 2025–2027 plan contains new and important requirements, most notably the provision of municipal-level data, including the total number of customers, the total amount of EEC (in dollars) paid by customers, and the total number of incentives provided by the program, on a yearly basis.64
While a Mass Save data portal does currently exist, it is both outdated and not presented in a way that is easily understandable to the general public.65 Massachusetts’s Mass Save program currently lacks sufficient transparency and accountability, jeopardizing public trust. In order to address this deficiency, the Commonwealth may want to consider approaches used by other states’ energy efficiency programs. For example, New York updates a comprehensive Clean Energy Dashboard each quarter, aggregating electric and gas utility efficiency program results into interactive, easy-to-understand visuals.66 Likewise, California uses a centralized reporting system (known as CEDARS) that provides up-to-date visibility into the state’s efficiency program’s savings, budgets, and cost-effectiveness, with PAs submitting data through uniform templates on a monthly and quarterly basis. CEDAR’s built-in quality checks ensure that the reported results are complete and reliable.67 Vermont’s model goes further by emphasizing data completeness and credibility—Efficiency Vermont delivers granular annual reports that are rigorously verified, and state law even mandates an independent audit of reported savings every three years to validate accuracy.68
Additionally, the Commonwealth should consider options to capture participation metrics in order to appropriately evaluate Mass Save. For example, Mass Save may be able to track ratepayer engagement with its programs, including measuring how many people of various socioeconomic profiles participate in specific programs such as residential weatherization, improvements to heating, ventilating, and air-conditioning (more commonly known as HVAC), or language-access services. Mass Save has doubled its statewide budget for its low-income program from the previous cycle, with $1.2 billion scheduled over 2025–27.69 However, increasing the budget does not itself address the program’s systemic issues, such as increasing renter participation. Currently, Mass Save tracks income metrics but does not systematically collect demographic information from individual customers (such as age, race, ethnicity, or preferred language).70 Instead, Mass Save analyzes publicly available data sources, like the US census, to infer demographic characteristics at the community level.
Guidance from the Massachusetts Department of Public Health encourages the collection of such data to improve service delivery and address distribution disparities in state programs.71 Collecting this information could help Mass Save tailor its services more effectively to meet the needs of diverse populations.
Finally, Mass Save should consider upgrading its complaint process by funding a separate, dedicated, and easily accessible system for participants to report issues related to Mass Save programs, services, and vendors. This complaint mechanism should be fully compliant with the Americans with Disabilities Act and include robust language-access capabilities to ensure equitable access for all residents, regardless of ability or language proficiency. To enhance transparency and accountability, an independent entity should collect and publicly share complaint data, highlighting trends and actions taken. This information should also be shared with the Massachusetts Attorney General’s Office, which has oversight responsibilities related to consumer protection and program integrity. This approach could ensure that residents’ concerns are heard and addressed.
| Date published: | September 22, 2025 |
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