Comments on VCS Methodology for Weatherization of Single and Multi-Family Buildings , Maine State Housing Authority

CRS comments on VCS’s proposed Maine State Housing Authority Methodology for Weatherization of Single and Multi-Family Buildings. CRS recognizes the value of energy efficiency measures as a vital means to reduce GHGs and mitigate the effects of climate change, and applauds the Maine State Housing Authority for taking the initiative to introduce such an important program. However, this methodology in its current form allows for double counting, and certain energy efficiency measures under the proposal will not result in any real reductions in GHG emissions due to the presence of a cap and trade on CO2 emissions in Maine. CRS recommends that the methodology be limited to only include emission reductions from efficiency measures outside of electricity consumption, such as measures that will result in reduced natural gas consumption for central heating.