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Momentum Q1 | 2026

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A quarterly update on the building decarbonization movement

Q1 | 2026

Authors
Kristin George Bagdanov, PhD, Associate Director of Research
Kevin Carbonnier, PhD, Associate Director of Analytics

About Our Research
BDC tracks and analyzes policies, trends, and data to accelerate the building decarbonization movement. We synthesize qualitative and quantitative data to produce rigorously researched, substantively contextualized, equitably cited, and endlessly shareable resources that help move our movement forward. We believe that research only becomes knowledge when it’s shared, so please pass along these resources to your communities and help us equitably decarbonize our buildings and neighborhoods. Read more about our research philosophy, resources, and reports.


Table of Contents

I. The Big Picture
II. Market Momentum
III. Neighborhood Scale
IV. Gas System Costs and Affordability
V. The Thermal Transition
VI. Looking Ahead
VII. Methodology


I. The Big Picture

What happened this quarter in the building decarbonization movement

From the ever-expanding energy demand of data centers and AI-driven campaigns to weaken appliance standards, to the growing list of repealed regulations intended to protect public health and the environment, 2026 looks different from the future many of us envisioned when we began working on building decarbonization.

Progress, however, is rarely linear. While some areas appear to be regressing, others reveal surprising innovation, momentum, and durability across the United States.

Federally funded home energy rebates, for example, remain active in a dozen states and the District of Columbia (tracked by the Atlas Building Hub). A national consensus is forming around the importance of energy affordability. States are reforming rate structures, scrutinizing unnecessary capital expenditures by utilities, and—in the case of New Jersey—even freezing rates temporarily.

This report cuts through the noise to highlight those lasting shifts: the proceedings, legislation, protections, and investments that signal steady, if uneven, progress in the unfolding thermal transition.

Read on for the full report and download the executive summary below.

Executive Summary

Overview

Here are major events and actions shaping building decarbonization in the first quarter of 2026:

Market momentum

Gas system costs and affordability

Utility regulation and the shift away from gas expansion

State action to scale equitable electrification

II. Market Momentum

Demonstrating the durability of decarbonization

Equipment SalesFigure 1: Heat pump and fossil fuel furnace shipment trend

Figure 1: Heat pump and fossil fuel furnace shipment trend

2025 was a slow year for the HVAC market overall. Tariffs, the refrigerant transition, and affordability concerns all contributed to lower equipment sales, especially for air conditioners. Even amid that slowdown, heat pumps outsold fossil fuel furnaces for the fourth year in a row, another sign that the shift toward clean and efficient electric heating is proving durable.

In new construction, the market continues to move even faster. For example, in California, builders are increasingly choosing all-electric homes, avoiding gas service line and connection costs while pairing new buildings with highly efficient heat pumps. Heat pumps are 3-5 times more efficient than gas appliances, making them an important driver of long-term building decarbonization.

We expect heat pumps to continue gaining market share, driven by all-electric new construction, stronger economics from incentives and emerging heat pump rate designs, and consumer interest in replacing aging HVAC systems with equipment that can both heat and cool.

Figure 2: Heat pump and air conditioner shipment trend

Figure 2: Heat pump and air conditioner shipment trend

A second milestone emerged in late 2025. Although air conditioner sales typically fall in the winter, monthly air conditioner sales dropped below heat pump sales in September 2025 for the first time. That crossover may not hold through the summer, when air conditioner demand peaks, but it is still a notable marker of the market’s direction. Over the last decade, equipment sales have steadily shifted away from one-way air conditioners toward two-way heat pumps that provide both heating and cooling. If that trajectory continues, annual heat pump sales could surpass annual air conditioner sales within the next few years.

The Thermal Workforce

As states translate climate commitments into heat regulation, financing, and market mandates, the success of the thermal transition increasingly hinges on workforce capacity. A managed gas transition requires a diverse and skilled labor force. We use the term thermal workforce to describe the full spectrum of workers who deliver heating and cooling to buildings across fossil fuel and clean energy systems, rather than dividing this workforce into “fossil fuel” and “clean energy” categories.

This framework recenters decarbonization around the delivery of thermal services instead of the fuels behind them, aligning workforce planning with how heating systems actually evolve over time. Rather than treating clean energy and fossil fuel jobs as exclusive or opposing, the thermal workforce framework recognizes these ends of the energy spectrum as part of a continuum focused on providing reliable, affordable, and increasingly clean thermal service.

The thermal workforce includes gas utility workers, pipeline and utility construction crews, and drillers, alongside electricians, plumbers, HVAC technicians, insulators, and other building energy professionals. It spans union and non-union labor, large utilities and small contractors, and urban and rural communities. Importantly, it reflects the reality that the transition from fossil fuel heat to clean heat will occur over decades and will require workers who can operate across systems during the transition period.

The chart below illustrates the workforce segments most directly implicated in the shift from fossil heating to electrification and thermal energy networks.

Figure 3: (Left) Total thermal workforce employment. (Right) Thermal workforce by category.

Figure 3: (Left) Total thermal workforce employment. (Right) Thermal workforce by category.

Altogether, these occupations represent approximately 4.5 million workers nationwide, a workforce that has steadily grown over the past two decades. Collectively, this diverse workforce represents a deep pool of skilled workers who are capable of delivering safe and efficient heating and cooling under evolving technologies and policy frameworks.

The scale and alignment of this workforce also carry direct affordability implications. Labor shortages or skill mismatches can slow electrification projects and increase installation costs, particularly as demand accelerates. Workforce planning is therefore a core affordability and implementation strategy in the thermal transition. As regulatory reform accelerates, workforce planning is moving from a peripheral workforce development issue to a central pillar of building a durable future of clean heat.

Supporting the Thermal Workforce in Colorado

Power Ahead Colorado landing page

A recurring barrier to heat pump deployment is not necessarily demand but contractor availability and capacity. In January 2026, Power Ahead Colorado (an ambitious program led by the Denver Regional Council of Governments to reduce the environmental impact of the region’s building sector) and the Building Decarbonization Coalition launched the Colorado Contractor Hub, a free, centralized digital workspace designed to help Colorado heat pump contractors grow their businesses and accelerate adoption.

Built around contractor needs, the Hub bundles customer leads, training (with reimbursement for training costs), a one-stop guide to rebates/incentives and permitting, a technical resource library, and a curated marketplace of third-party tools—plus an AI assistant to answer questions on incentives, codes, licensing, and program requirements. It also offers a free Small Business Scaling Program to support companies expanding into electrification and weatherization.

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III. Neighborhood Scale

Scaling up building decarbonization, block by block 

Our neighborhood-scale project map tracks projects across North America, ranging from fully decarbonized neighborhoods to early plans to transition from fossil fuels. This crowdsourced map is constantly being updated with new projects and we need your help to keep it current. Please submit neighborhood-scale projects for consideration here. 

Not included: It does not include all-electric neighborhoods that did not transition away from fossil fuels, or that are within communities with zero-emissions building standards. To learn where local and state governments are encouraging and requiring all-electric buildings, please visit our Zero Emissions Building Ordinance Tracker!

This map shows growing momentum to decarbonize existing neighborhoods by transitioning them from aging gas infrastructure to clean energy infrastructure.

See our full Neighborhood Scale Map on our webpage for additional information and functionality.

How to Finance a Thermal Energy Network

Thermal energy networks (TENs) are long-lived, infrastructure-scale projects, so financing is less about finding one pot of money and more about matching the right tool to the right project phase and asset. Early dollars tend to support feasibility, community engagement, and design; long-term dollars (like bonds) tend to pay for long-lived assets like borefields and distribution piping; and ongoing revenue tools (like tariffs or service contracts) keep operations stable and affordable over time.

A practical financing roadmap (from concept to operations) includes:

  • Feasibility to Pre-development: grants, public programs, technical assistance, and philanthropy to do the scoping, engineering, and engagement work.
  • Capital stack and ownership: combine tools (often bonds/green banks + SRFs + grants, sometimes TIF), then pick the ownership/governance model that determines what funding is available (public, PPP, cooperative, etc.).
  • Build and operate: finance by component (thermal resource, network, energy center, customer connections), then recover costs through on-bill tariffs, service contracts, or revolving repayment with ongoing community accountability.

To learn more, read our full report here.

thermal energy network

Illustration of a thermal energy network

Project Highlight: CKenergy Cooperative, OK

CKenergy Cooperative in western Oklahoma offers a powerful proof point for utilities interested in TENs: namely, that even without a shared thermal network (its territory is too rural for connected piping), utility-led geothermal heat pump deployment can improve system economics and affordability at scale. By helping install ~1,650 geothermal heat pumps across a co-op serving ~27,000 customers (18,000 of which are residential), CKenergy reduced peak demand, improved load factor, and lowered wholesale power costs: benefits that flow to all members, not just the households that adopt geothermal.

  1. ~27,000 customer meters served (≈18,000 residential)
  2. ~1,650 geothermal heat pump systems installed (homes, schools, and commercial buildings)
  3. Member-funded “rider” model covered early incentives: roughly $4–$5/month for a typical household (temporary, not permanent)
  4. Incentives + financing helped overcome upfront costs: about $3,625/ton in rebates; optional loans up to $15,000 at 6% (4–7 years)
  5. Program became self-sustaining after ~12 years as reduced wholesale power purchases replaced the need for the rider
  6. Affordability outcome: “We haven’t had a rate increase in eight years, and we are years away from one now,” said Boyd Lee, retired VP of Strategic Planning, CKenergy and founder of Outside the Box Geo

To learn more, read our full case study.

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IV. Gas System Costs and Affordability

How gas system spending is driving energy costs

The U.S. gas system is increasingly expensive, aging, and inefficient—and over the last decade, gas utility spending has shifted from business-as-usual investment to an era of accelerated capital expansion.

Gas utility spending on distribution infrastructure has more than tripled since 2010. If utilities had continued the pre-2010 pace of investment instead of dramatically accelerating spending, customers would have saved an estimated $130 billion, or $1,723 per household with gas in the U.S.

Figure 4: National Gas Utility Spending on Distribution Infrastructure

Figure 4: National Gas Utility Spending on Distribution Infrastructure 

Because every dollar of direct capital spending translates into $2 to $3 in ratepayer costs over the life of the asset due to financing costs and shareholder returns (Synapse), each additional year of accelerated spending creates at least $40 billion in excess lifetime costs.

At the same time, gas use is not keeping pace with spending. Over the past decade, residential gas consumption was flat, while the number of residential customers grew only 8.5% (EIA 1, 2). The result is a top-heavy gas delivery system: an expanding asset base with accelerating capital costs that must be recovered from a relatively stagnant pool of customers. In fact, according to the American Gas Association (AGA), the share of infrastructure (and its related costs) per customer has roughly doubled over the last decade (AGA, “Gas plant per customer”). In other words, as customers are utilizing the gas system less, gas utilities are investing—and charging customers—more.

Figure 5: Residential gas customer and consumption trend

Figure 5: Residential gas customer and consumption trend

Meanwhile, a growing share of customer bills is paying for the system itself rather than the gas customers actually use. In 2024, about two-thirds of a typical household’s monthly gas bill paid for infrastructure and delivery, while only one-third paid for the fuel (NPR; US EIA citygate, residential data). While some delivery charges vary with usage, a significant portion consists of fixed charges, meaning that even if a customer used no gas, these charges would still appear on the monthly bill.

Figure 6: National gas utility bill composition

Figure 6: National gas utility bill composition

In 2025, gas bills rose 60% faster than electric bills and four times faster than inflation (BLS). That same year, gas utilities requested $3.83 billion in rate increases, reflecting continued investment, especially in pipeline replacement programs (S&P Global). Meanwhile, newly released data from the 2024 RECS survey, show that one-third of households experienced some form of energy insecurity, with one in four households needing to reduce or forgo food or medicine to pay their energy bills. In addition, a 2025 Consumer Reports survey found that 68% of households said their finances were strained to some degree by electricity and gas bills, while 23% said they were very strained (Consumer Reports). 

Figure 7: Consumer price index change, Dec 2024 to Dec 2025

Figure 7: Consumer price index change, Dec 2024 to Dec 2025

Because nearly every end-use in homes and businesses can be served by electricity, there is little justification for continuing to expand and over-invest in two parallel energy delivery systems, especially when one is already showing signs of declining utilization and rising per-customer costs. This period of accelerated gas spending now represents a critical point of intervention: decisions made today will determine whether ratepayers continue funding expensive gas assets that are used less and less, or whether these investments begin to shift toward strengthening and modernizing the electric grid that every building ultimately depends on.

V. The Thermal Transition

From fossil fuels to clean thermal infrastructure

The thermal transition is the long-term evolution of the thermal sector toward cleaner, more affordable, and more efficient ways of delivering heating and cooling. It offers an inclusive framework for understanding the future of heat: a shift away from the legacy fuels and systems that once defined the heating industry and toward modern solutions that support cleaner air, healthier communities, and lower energy bills.

In this section, we track the legislation and regulatory proceedings helping manage the transition from the gas system to clean thermal infrastructure, including electrification and thermal energy networks.

2026 Legislation

A sample of bills that are enabling the thermal transition

State / Bill

Description

Categories

California, Industrial Heat and Jobs Act (AB 2088)


🟡 In Progress

Enables gas utilities to serve customers with a thermal energy network. Also requires the CPUC to initiate a proceeding to establish a regulatory framework for TENs.

Thermal energy networks, obligation to serve

California, Residential Heat Pump Systems (SB 222)


🟡 In Progress

Standardizes the heat pump permitting process by creating a pathway for automated permitting, caps permit fees, and establishes guardrails on setback and noise limits.

Permitting, electrification

Illinois, Gas Appliance Labeling (HB4272)


🟡 In Progress

Requires a warning label on natural gas appliances that are manufactured on or after January 1, 2027

Labeling, consumer protections

Illinois, POWER Act (SB4016/HB5513)


🟡 In Progress

Establishes consumer protections that minimize the impact of data centers on utility bills and water usage. Also requires data centers to pay into a Public Benefits and Affordability Fund

Data centers, consumer protections

Indiana, Electric Utility Affordability (HB1002)


🟡 In Progress

Establishes performance-based ratemaking, requires electric utilities to provide assistance to low-income qualified households, and creates a summer disconnection moratorium for low-income qualified households.

Affordability, rate reform, consumer protections 

Maryland, Maryland Strategic Energy Investment Fund – Required Uses – Building Electrification and Transportation Electrification (SB622)


🟡 In Progress

Requires the use of the Maryland Strategic Energy Investment Fund for providing loans and grants for building electrification.

Funding, building electrification

Minnesota, Utility Thermal Energy Network and Jobs Act (SF4281)


🟡 In Progress

Authorizes regulated gas and electric utilities to implement and cost recover TENs beyond pilots, extends gas consumer protections to TENs customers, and sets priority zones for TENs siting including environmental justice communities. 

Neighborhood-scale thermal energy networks, obligation to serve

New York, Pipelines Leaks & Safety Act (A10071/S9075)

🟡 In Progress

Requires gas utilities to produce publicly accessible maps indicating planned work on aging pipeline infrastructure and directs the public service commission to designate neighborhood priority decarbonization zones.

Gas system planning

Washington, Authorizing Community Scaled Weatherization Projects (HB2338)


🟡 In Progress

Expands what projects can be funded by state programs to include improvements such as energy efficiency, weatherization upgrades, and structural repairs. This allows building condition and energy performance to be addressed at the same time.

Energy efficiency, funding 

Future of Gas

The “Future of Gas” is an evolving policy framework used to describe the questions, assumptions, and arguments surrounding the long-term sustainability of the methane gas system. Researchers, state energy offices, legislators, and utility regulators have used the phrase to describe policies, reports, and proceedings since at least 2019. Advocates have also applied it retroactively to highlight the growing number of regulators and legislators critically examining the gas system’s longevity.

Future of Gas Proceedings

Since 2020, 15 proceedings that we consider to address the future of gas have been opened across 13 states and D.C. Currently, 11 proceedings are active, though not all have had recent activity. These proceedings have led to key insights on the inequitable distribution of methane pollution, the risks of business-as-usual gas system growth, and the urgency of reforming outdated policies. A managed, neighborhood-scale transition off the gas system requires clear decarbonization targets to halt expansion, limit reinvestment, and right-size the system.

For a comprehensive list of Future of Gas proceedings, including closed and inactive dockets, see BDC’s public tracker.

The “Future of Gas” is an evolving policy framework used to describe the questions, assumptions, and arguments surrounding the long-term sustainability of the methane gas system. Researchers, state energy offices, legislators, and utility regulators have used the phrase to describe policies, reports, and proceedings since at least 2019. Advocates have also applied it retroactively to highlight the growing number of regulators and legislators critically examining the gas system’s longevity.

Future of Gas map

Figure 8: Summary of Future of Gas proceedings

Back to Top

Q1 Future of Gas Proceeding Highlights:

  • The managed gas transition is moving from policy direction to regulatory decision-making: California has designated 151 potential neighborhood decarbonization zones; Massachusetts is adjudicating line extension allowances and service obligations; and Maryland has entered the testimony phase of its Future of Gas proceeding.
  • Who pays for the gas transition is emerging as the defining policy question: California is developing rules for pilot cost recovery and cost allocation; Massachusetts and Maryland are both moving to eliminate gas line extension subsidies; and Maryland’s Future of Gas proceeding is also building the record on stranded asset risk, gas system expansion, and long-term ratepayer impacts.
  • Utilities are increasingly required to justify gas pipeline investments against non-gas-pipeline alternatives: Utilities in New York are filing a geographically specific NPA proposals and Massachusetts and Maryland are embedding NPA standards into long-term gas planning.
  • The “obligation to serve” gas is being reexamined under climate law: Massachusetts is evaluating whether gas service may be retired without unanimous consent; Maryland’s Future of Gas proceeding is examining potential limits on system expansion and how climate statutes affect long-term gas planning; and D.C. stakeholders are pressing for climate-aligned gas planning and a reassessment of Washington Gas’s long-term role under the District’s climate laws.
  • Regulators are developing the analytical tools needed for long-term gas system transition planning: Maine is developing a structured GHG evaluation matrix; Minnesota has established the carbon-cost scenarios utilities must use in their first gas IRPs; and Illinois commissioned a statewide decarbonization pathways study to establish comparable cost and scenario modeling across utilities.

SB1221 priority zones

Figure 9: Initial SB 1221 Neighborhood Decarbonization Zones, 2025
Source: CPUC Decision 25-12-042, Appendix B. 

Q1 FOG Proceeding Activity

State

Recent Activity

California

Order Instituting Rulemaking to Establish Policies, Processes, and Rules to Ensure Safe and Reliable Gas Systems in California and Perform Long-Term Gas System Planning (R. 24-09-012)


(Part 2, 2024-present under 24-09-012)


(Part 1, 2020-2024 under R.20-01-007)

The CPUC’s “Future of Gas Part 2” rulemaking (R.24-09-012) is intended to guide California’s long-term transition away from the gas system while advancing near-term decarbonization actions. The proceeding implements SB 1221 (2024), which authorizes up to 30 voluntary neighborhood-scale decarbonization pilots and modifies the gas “obligation to serve” by allowing utilities, with CPUC approval, to reduce the customer consent threshold to no less than 67%. The rulemaking is structured in phases addressing interim actions, long-term gas planning, and SB 1221 implementation, including required mapping of planned pipeline replacements and designation of priority decarbonization zones.

In 2025, utilities submitted 10-year pipeline replacement maps and proposed priority zones, drawing criticism from advocates for lacking sufficient building-level and customer data to enable meaningful community engagement. In December, the CPUC designated 151 initial Priority Neighborhood Decarbonization Zones (PNZs) at the census tract level, prioritizing areas with demonstrated local support and a significant concentration of planned gas main replacements, and supplementing them with high-scoring environmental and social justice communities. The Commission emphasized that these are “initial” zones and committed to updating them by the end of 2026, while requiring utilities to conduct outreach and host public information sessions in early 2026.

Workshops throughout the year also focused on advancing non-pipeline alternatives (NPAs), including cost-effectiveness and cost recovery frameworks. The Commission must now establish clear NPA and pilot selection policies ahead of the July 2026 deadline for utilities to apply to run neighborhood-scale decarbonization pilots.

Planned Pipeline Replacement Maps: 

Q1 2026:

Priority Neighborhood Decarbonization Zones (PNZs)

  • At the end of 2025, the CPUC designated 151 initial PNZs, identified at the census tract level (Appendix A and B of Decision 25-12-042). The utilities have updated their pipeline replacement maps (above) to reflect the PNZs. 
  • The methodology for selecting PNZs included:
  • Local support: Census tracts where local governments or community organizations requested designation (929 tracts initially identified).
  • Pipeline replacement concentration: Tracts where ≥10% of gas mains are scheduled for replacement (2028–2035), narrowing to 139 tracts.
  • Geographic cap: A 25-tract cap per county to avoid overrepresentation (affecting Alameda and San Diego).
  • Environmental & Social Justice (ESJ) communities: Added 12 additional tracts in capped counties that ranked in the top 25% of CalEnviroScreen 4.0, bringing the total to 151
  • PNZs may be refined and updated over the course of the next year, with the CPUC finalizing them by the end of 2026.

Outreach: Utilities must perform outreach to affected communities in the PNZs and document compliance and outreach efforts by April 1, 2026.

  •  

Third Amended Scoping Memo (March 2026)

  • On March 4, 2026, the Third Amended Scoping Memo refined the SB 1221 pilot issues the Commission will consider. The ruling separates two related questions that had previously been bundled together: (1) what utilities must show regarding communication and collaboration with local governments, community organizations, contractors, and other relevant entities; and (2) how utilities must demonstrate property-owner consent and adequate notification to property owners, affected customers, and tenants, including master-metered customers. This signals that the Commission is moving from broad pilot design toward more specific application requirements around community engagement, notice, and consent. Comments were due March 10, 2026, with reply comments due March 17, 2026.

ALJ Ruling on Cost Recovery (March 2026)

  • On March 17, 2026, the ALJ requested additional stakeholder input on one of the most consequential unresolved SB 1221 issues: how utilities should recover costs for behind-the-meter (BTM) zero-emission alternatives used in neighborhood-scale pilots. The ruling asks parties to address whether Public Utilities Code Sections 663(b)(8) and 663(b)(9) conflict; whether BTM implementation costs should be recoverable from gas ratepayers; whether such costs should be treated as current expenses or regulatory assets; and what amortization period, depreciation schedule, and rate of return should apply. The ruling also lays out three candidate approaches: (1) recovery with carrying costs at the utility’s cost of debt, (2) regulatory asset treatment with a reduced return, or (3) cost recovery paired with a performance-based shareholder incentive tied to outcomes such as miles decommissioned, customer conversions, budget performance, and avoided gas system costs. Comments were due March 27, 2026, with reply comments due April 3, 2026.

CSU Monterey “Lessons Learned” Report

  • Also in the docket, PG&E filed its required “Lessons Learned” report in January 2026 on its withdrawn CSU Monterey Bay (CSUMB) zonal electrification project. The report provides one of the most detailed post-mortems to date on a proposed neighborhood-scale gas transition project and surfaces several structural issues likely to shape SB 1221 implementation.
  • Major Challenges identified by PG&E included: 
    • Timeline and Project Complexity: The near-term timeline for safety-related gas pipeline replacement conflicted with the complexity of coordinating outreach, tenant consent, and construction across 400+ individual housing units. PG&E concluded that future zonal electrification projects must assume longer planning, negotiation, and litigation timelines and avoid aligning projects too closely with urgent safety-driven replacement schedules unless regulatory risks are fully accounted for.
    • Revenue Requirement Analysis Disputes: Parties disagreed over the projected ratepayer impacts on both gas and electric customers. PG&E concluded that future electrification proposals must present complete lifecycle revenue requirement analyses for all alternatives—including full asset lives, overheads, lost gas revenues, and system cost shifts—and incorporate contingencies for unexpected costs such as asbestos remediation.
    • Cost-Effectiveness Framework Disagreements: There were significant disputes over PG&E’s benefit-cost analysis. Indicated Shippers (representing large fossil fuel producers and refiners) argued that when full lifecycle costs and fixed system cost shifts were properly accounted for, the project’s benefit-cost ratio would fall below 1.0. The case underscored the need for standardized cost-effectiveness methodologies to avoid relitigating assumptions in each project.
    • Regulatory Treatment of Behind-the-Meter (BTM) Assets: Parties disputed PG&E’s proposal to treat electrification investments in customer-owned appliances as regulatory assets eligible for a rate of return. PG&E’s report ultimately concludes that the Commission should affirm its prohibition against regulatory asset treatment for BTM appliances not owned and operated by the utility, and that future electrification proposals should consider alternative ratemaking approaches that align with cost-causation principles and avoid imposing unjust or unreasonable costs on remaining gas customers.
    • Cost Allocation and Ratepayer Equity: There was also disagreement over PG&E’s proposal to recover electrification costs entirely through gas distribution rates. Intervenors argued that allocating costs to remaining gas customers raised equity and affordability concerns and that the Commission should establish clearer, uniform cost-recovery policies for neighborhood-scale decarbonization projects rather than litigating allocation on a case-by-case basis.

What’s Next:

  • March-April 2026: Parties will brief two key implementation questions for SB 1221 pilots: what utilities must show on outreach, notification, and consent in pilot applications, and how BTM costs should be recovered, amortized, and compensated.
  • Spring-Early Summer 2026: The Commission is expected to clarify pilot program rules, including application requirements related to community engagement and consent, as well as cost recovery treatment for behind-the-meter investments.
  • July 2026: Utilities will submit applications for up to 30 neighborhood-scale decarbonization pilots under SB 1221.
  • Mid-Late 2026: The Commission will evaluate pilot applications while advancing long-term gas transition planning, including scenario modeling, demand forecasting, stranded asset considerations, and coordination with electric planning.
  • By December 31, 2026: The Commission will update and finalize the list of PNZs.

D.C.

In the Matter of the Implementation of Electric and Natural Gas Climate Change Proposals (FC # 1167)

(2020-present)

Related docket on integrated system planning: FC #1182

The DC Public Service Commission (DCPSC) opened Formal Case No. 1167 in 2020 following the AltaGas–Washington Gas Light (WGL) merger, after required climate business plans were deemed insufficient to demonstrate alignment with the District’s climate goals. Guided by the expanded mandate of the 2018 CleanEnergy DC Omnibus Act, the proceeding examines whether utilities are meeting the District’s energy and climate commitments. In response to Order No. 22313 (Oct. 2024), which required revised 15-year Climate Solutions and Climate Business plans, advocates urged the Commission to adopt Integrated Distribution System Planning (IDSP) and to separate electric and gas planning into distinct dockets. The PSC subsequently opened a new IDSP docket (FC-1182) while continuing the Future of Gas inquiry under FC-1167 (Order No. 22339). In March 2026, the PSC also opened the Integrated Natural Gas Distribution System Planning (“INGDSP”) for gas utilities (FC-1187).

In 2025, the Commission advanced both proceedings. It established an IDSP working group focused on load forecasting, DER transparency, resilience, electrification, and equity, with a report due in April 2026. Meanwhile, WGL filed its 15-year gas emissions reduction plan in the Future of Gas docket, drawing criticism from the Office of People’s Counsel and Sierra Club for failing to demonstrate meaningful emissions reductions, adequately incorporate electrification, or fully assess customer and climate impacts.

Q1 2026:

Procedural Developments

  • The Commission granted additional extensions for comments on Pepco’s 15-Year Climate Solutions Plan, pushing initial comments to March 2, 2026, and reply comments to April 1, 2026.

Gas Planning Reform Proposal

  • The DC Government (OAG) filed a proposal outlining a formal long-term, climate-aligned gas planning framework for Washington Gas, including scenario modeling, NPA analysis, and stranded asset evaluation.

Coordination & Implementation Oversight

  • The DC Sustainable Energy Utility Advisory Board raised concerns that Pepco’s proposed energy efficiency and demand response programs may duplicate DCSEU offerings and bypass required coordination.

Cost Allocation & Governance Questions

  • Stakeholder filings reflect growing focus on who oversees electrification programs, how gas transition costs are allocated, and how electric and gas planning processes intersect.

What’s Next:

  • March–April 2026: Initial and reply comments due on Pepco’s 15-Year Climate Solutions Plan and Electrification Study.
  • Spring–Mid 2026: Commission review of Pepco’s plan, including potential action on electrification program approval, coordination with DCSEU, and rate impact considerations.
  • 2026 (ongoing): Consideration of the DC Government’s proposed long-term, climate-aligned gas planning framework for Washington Gas, including scenario modeling and stranded asset analysis.
  • Late 2026 (anticipated): Potential Commission guidance or structural reforms on integrated gas transition planning and electrification governance.

Illinois

The Future of Natural Gas and issues associated with decarbonization of the gas distribution system (Docket # 24-0158)

(2024-present)

In March 2024, the ICC launched a statewide Future of Gas proceeding to examine how Illinois gas utilities’ infrastructure plans align with the state’s decarbonization and electrification goals. Following initial workshops in 2024, Phase 2 is now underway, culminating in a report due in early 2026. Phase 2B (March 2025) established two working groups: one narrowed more than 100 proposed decarbonization pilots (including neighborhood electrification, thermal energy networks, industrial heat pumps, and alternative fuels), while the other is evaluating pathway feasibility and economic impacts.

Q1 2026: 

Procedural Developments

  • The ICC extended Phase 2 of the Future of Gas proceeding to December 31, 2026, granting Staff additional time to complete remaining workstreams. This marks the second major schedule extension, effectively converting the proceeding into a multi-year planning process.

Decarbonization Pathways Study

  • Staff issued an RFP to commission a formal statewide decarbonization pathways study, expected to take ~6 months.
  • The study is intended to produce consolidated cost estimates, scenario modeling, and comparative pathway data after workshop efforts failed to produce consensus metrics.
  • Stakeholders will have the opportunity to revise Phase 2C proposals after study completion.

Legislative & Regulatory Reform (Phase 2C)

  • Staff received 79 legislative and regulatory proposals from 16 entities related to gas system decarbonization.
  • The schedule extension allows consolidation and narrowing of proposals before formal evaluation.

Gas Planning Governance Shift

  • The Commission rescinded prior directives requiring long-term gas infrastructure plans in Peoples Gas and North Shore rate cases, following appellate rulings.
  • Long-term gas transition planning is now centralized in the Future of Gas Docket rather than litigated piecemeal through rate cases.

What’s Next:

  • Mid-2026: Completion of the commissioned decarbonization pathways study and release of results for stakeholder review.
  • Mid–Late 2026: Stakeholders revise and consolidate legislative and regulatory proposals informed by pathway modeling.
  • Late 2026: Staff prepares and submits the Phase 2 Facilitator Report synthesizing pilot recommendations, pathway analysis, and reform proposals.
  • By December 31, 2026: Commission concludes Phase 2 and determines next steps, including potential rulemakings, pilot authorizations, or legislative recommendations.

Maine

Inquiry Regarding Future of Natural Gas (Case No. 2025-00145)

(May 2025-present)

The Maine Public Utilities Commission (MPUC) opened a new Future of Gas proceeding to examine how gas utility regulation should align with the State’s statutory greenhouse gas reduction goals (Notice of Inquiry). Maine law requires economy-wide emissions reductions of 45% by 2030 and 80% by 2050 (from 1990 levels), and carbon neutrality by 2045. The Commission is tasked with facilitating emission reductions consistent with these targets while ensuring safe, adequate, and reasonably priced service.

The inquiry seeks to develop a framework to evaluate the climate impacts of gas infrastructure investments and supply commitments, assess alignment with state climate targets, and examine potential future pathways for methane gas. Initial scope comments (June 2025) revealed a clear split among stakeholders: gas utilities emphasized renewable natural gas (RNG) and hydrogen, while the Office of the Public Advocate, the Governor’s Energy Office, and labor and climate groups supported exploration of thermal energy networks (TENs) and other non-pipeline alternatives.

In 2026, the proceeding shifted from high-level inquiry to active framework development, with the Commission considering adoption of a structured evaluation methodology to guide future gas investment decisions.

Q1 2026:

Initial Workshop (Jan. 21, 2026)

  • E3 reviewed Future of Gas frameworks from other states.
  • OPA presented a proposed matrix-based scoring tool to evaluate gas investments.

OPA Proposed Evaluation Matrix

  • The OPA proposed four core categories: policy/regulatory alignment, cost (including stranded asset risk and rate impacts), technical feasibility, and energy justice.
  • Also incorporates CO₂ and methane impacts, cross-fuel effects, peak demand reduction, reliability, and equity considerations.
  • Uses a high/medium/low scoring system (with optional weighting) to compare supply-side (RNG, hydrogen, pipeline expansion) and demand-side (electrification, demand response) alternatives.

The Workshop discussion focused on whether to formalize climate-aligned evaluation criteria, how to compare alternatives consistently, and how to integrate stranded asset and rate impact analysis into decision-making.

Post-Workshop Procedural Order (Feb. 13, 2026)

  • The Commission invited written comments (due by March 6, 2026) on adopting a matrix-based framework, refining evaluation criteria, required data and methodologies, and integration with long-term gas planning.

What’s Next:

  • Spring 2026: Commission review and potential decision on formalizing a GHG evaluation framework.
  • Spring–Summer 2026: Anticipated follow-up workshop.
  • Later in 2026: Possible issuance of guidance or an order establishing a structured framework for evaluating gas investments.

Maryland 

New: Case No. 9707


(First petition filed in Feb. 2023; second petition in May 2025; Order 91791 to open Future of Gas investigation within docket issued in August 2025)


 

In February 2023, Maryland’s Office of People’s Counsel (OPC) petitioned the Public Service Commission (PSC) to open a Future of Gas proceeding to evaluate whether gas utility planning, practices, and rates remain “just and reasonable” and consistent with the public interest (pg. 7). Following public comments in 2024 and a renewed OPC petition in 2025, the PSC issued an order on June 13, 2025 signaling its intent to eliminate gas line extension allowances (LEAs) for new connections. The PSC reasoned that subsidies encouraging gas system expansion may conflict with Maryland’s climate goals and obscure the true cost of gas service. Staff were directed to propose LEA regulations by December 1, 2025, to be addressed through Rulemaking 92.

On August 20, 2025, the PSC formally opened a comprehensive Future of Gas proceeding (Order 91791) within Case No. 9707 to examine the long-term role of natural gas in light of Maryland’s greenhouse gas reduction and electrification commitments. Citing the Climate Solutions Now Act and the Next Generation Energy Act, the Commission will evaluate:

  • Gas system planning practices
  • Rate design reforms
  • Stranded asset risk
  • Limits on system expansion
  • Non-pipeline alternatives and alternative fuels
  • Leak repair practices
  • Integration of emerging technologies and demand-side strategies
  • The impact of STRIDE reforms on gas investment decisions
  • Whether maintaining current gas consumption levels is compatible with state climate targets

Q1 2026:

Procedural Developments:

  • In Order No. 92189, the PSC revised and clarified the Special Master’s discovery rulings in Case No. 9707, affirming broad discovery into gas system planning, demand forecasts, and stranded asset risk. The Order reinforces that the Future of Gas proceeding will develop a full evidentiary record on climate alignment and ratepayer impacts as the case moves into its testimony phase.

Line Extension Allowance Reform:

  • The proposed new gas line extension allowance (LEA) regulations were issued on December 1, 2025.
  • The draft regulations would require any person requesting new gas service to pay the full cost of extending gas mains or service lines and explicitly prohibit utilities from subsidizing gas extensions or including customer-funded extension costs in rate base.
  • The purpose of this reform is to eliminate subsidies for gas extensions and ensure that costs are borne by the customers who cause them, minimizing stranded asset risk and aligning with cost-causation principles

Comments on Draft LEA Regulations

Dozens of comments were filed in support or opposition of the proposed LEA reforms. 

  • Opponents (including gas utilities, business associations, chambers of commerce, realtors, restaurant groups, and some legislators) argued that LEAs are not subsidies but economically justified revenue-based investments. They warned that eliminating LEAs would increase housing and development costs, harm affordability and economic competitiveness, restrict consumer energy choice, and disproportionately impact new homebuyers and businesses.
  • Supporters (including consumer advocates, local governments, and environmental organizations) argued that LEAs socialize infrastructure risk across ratepayers, mask the true cost of gas expansion, and are inconsistent with Maryland’s climate laws. They contended that requiring full upfront payment protects existing customers from stranded asset risk and aligns gas policy with the state’s greenhouse gas reduction goals.

What’s Next (Future of Gas [#9707] & LEA Reform [RM 92])

  • Winter–Spring 2026: Gas distribution companies will file testimony (February), followed by initial and reply testimony from Commission Staff, OPC, and other parties (May), which will build the evidentiary record on gas system planning, rate design, stranded asset risk, non-pipeline alternatives, and climate alignment.
  • Summer 2026: Parties will file rebuttal testimony (July), which will further refine disputes over system expansion, demand forecasts, cost allocation, and compatibility with Maryland’s climate statutes.
  • Fall 2026: Parties will submit final statements and arguments (September-October) to the Special Master.
  • December 2026: The Special Master will issue a report to the Commission, and parties will file comments before year-end.
  • Parallel Rulemaking (RM 92): The Commission will consider and may finalize new gas line extension allowance (LEA) regulations requiring full customer payment for new gas extensions, which is a decision that could significantly reshape gas system expansion policy.

Massachusetts

The Future of Gas (Docket #: 20-80)

(2020-present) 

Utility Climate Compliance Plans: (25-40, 25-41, 25-42, 25-43, 25-44, 25-45)

In its landmark December 2023 order in the “Future of Gas” docket, the Massachusetts Department of Public Utilities (DPU) established a new standard for gas system investment consistent with the state’s net-zero by 2050 mandate. The DPU shifted the burden of proof to gas utilities, requiring them to demonstrate that non-pipeline alternatives (NPAs) are either not cost-effective or infeasible before proceeding with major gas infrastructure investments, including full pipeline replacements. This marked a departure from business-as-usual gas expansion and laid the groundwork for reassessing long-term stranded asset risk and ratepayer exposure.

In 2024, the DPU turned to reforming gas line extension allowances (LEAs). Utilities were directed to report on their LEA practices, and in a February 5, 2025 memorandum, the Department proposed eliminating LEAs by requiring new customers to pay the full cost of connecting to the gas distribution system. The proposal further stated that “no costs associated with a new service or line extension shall be deemed prudently incurred and, thus, eligible for inclusion in an LDC’s rate base” (Feb. 5, 2025 Memorandum). Implementation is occurring through the 2025 Climate Compliance Plan (CCP) dockets (D.P.U. 25-40 through 25-45), covering Eversource, National Grid, Liberty, and Unitil.

In a subsequent Interlocutory Order, the DPU proposed a simplified policy to eliminate LEAs and clarified that final determinations would be made within these CCP dockets. Utilities sought a stay, citing procedural concerns, but the Department directed them to file revised tariffs by October 20, 2025 reflecting removal of LEAs.

At the same time, the Department is evaluating how the state’s 2024 climate law (S. 2967) reshapes the gas “obligation to serve,” including whether utilities may retire gas service in favor of electrification or thermal energy networks, and whether neighborhood-scale decarbonization projects can proceed without unanimous customer consent. The central question is whether the obligation to serve guarantees indefinite gas service upon request, or whether the DPU may permit targeted retirement of gas infrastructure where adequate non-gas alternatives exist. This issue is critical to whether neighborhood-scale electrification or thermal energy network projects can proceed without unanimous customer consent.

Q1 2026:

Line Extension Allowances: 

  • The DPU’s Revised Straw Proposal on gas line extension allowances (LEAs) was filed on August 26, 2025. The proposal requires new gas customers to pay 100% of their own gas connection costs, eliminating gas line extension subsidies borne by existing gas ratepayers. 
  • The utilities submitted joint testimony and their revised tariffs on Oct. 20, 2025. 
    • The utilities argued that existing LEA/CIAC policies are not subsidies, but revenue-based cost-allocation mechanisms that already require new customers to pass an economic test to ensure incremental costs are covered.
    • They contend that eliminating LEAs would cause new customers to pay twice–once through full upfront interconnection costs and again through distribution rates that recover system-wide infrastructure costs.
    • The utilities warned the proposal could increase housing and development costs, disproportionately affect certain communities, and push some developers toward higher-emitting fuels (e.g., oil or propane) if electrification is not feasible.
    • They also raised legal and implementation concerns, including ambiguity around what qualifies as a “technically feasible alternative,” how the burden of proof would be applied, and whether revised tariffs could conflict with nondiscrimination and ratemaking principles.
  • In response, advocates argued that:
    • The existing LEA/CIAC policies function as de facto subsidies that socialize the long-term risk of new gas infrastructure across all ratepayers.
    • They contend that even if new customers pass an economic test, those projections rely on long-lived gas demand assumptions that may not hold under Massachusetts’ net-zero 2050 mandate, creating stranded asset risk for remaining customers.
    • Eliminating LEAs is framed as aligning gas policy with the DPU’s 2023 Future of Gas order, which places the burden of proof on utilities to demonstrate that non-pipeline alternatives (NPAs) are not cost-effective or feasible before investing in new gas infrastructure.
    • Advocates argue that requiring full customer payment for new connections sends an appropriate price signal, reflecting the true cost of gas expansion rather than masking it through rate base recovery.
    • They reject the “double payment” argument, asserting that distribution rates recover shared system costs, while new interconnection infrastructure is incremental and should be borne by the customer causing it.
    • Advocates dispute the claim that eliminating LEAs will necessarily push customers toward oil or propane, arguing that policy should prioritize electrification and clean alternatives consistent with state climate law.
    • Finally, they argue that continuing to incentivize new gas connections undermines long-term decarbonization planning and exposes existing ratepayers—particularly low- and moderate-income customers—to future cost shifts as the gas system contracts.

Obligation to Serve:

  • In an August 26, 2025 Hearing Officer Memorandum (D.P.U. 25-40 through 25-45), the DPU formally raised how the state’s 2024 climate law (S. 2967) reshapes the gas utilities’ obligation to serve. The amended statute directs the Department to consider greenhouse gas reductions, the availability of “adequate substitutes,” and allows it to “vary the uniformity of the availability of natural gas service.”
  • The memo asks whether electrification or thermal energy networks may legally substitute for gas service and whether unanimous customer consent is required before retiring a gas line segment.
  • The utilities argued that the obligation to serve remains a longstanding statutory duty requiring them to provide gas service upon request, except in traditional circumstances (e.g., nonpayment or safety). They argue that:
    • S. 2967 did not fundamentally alter this duty and that allowing involuntary termination of gas service for climate reasons would conflict with statutory protections, raise due process concerns, and potentially implicate constitutional property rights.
    • Any change to the obligation to serve must come explicitly from the Legislature, not through administrative reinterpretation, and that a single “holdout” customer cannot be forced off gas service because neighbors prefer electrification.
  • In response, advocates and state agencies argued that:
    • S. 2967 broadened DPU authority to align service obligations with the Commonwealth’s net-zero 2050 mandate.
    • The statute’s reference to “gas or electricity” and “adequate substitutes” implies electrification can legally replace gas service where feasible.
    • That treating the obligation to serve as absolute would entrench stranded asset risk and allow a minority of customers to block neighborhood-scale decarbonization projects.
    • That the DPU may condition or relieve utilities of gas service obligations where adequate non-gas alternatives exist and that the public interest now includes climate compliance and protecting ratepayers from long-term system contraction costs.

What’s Next (LEAs & Obligation to Serve)

  • 2026 (CCP Litigation Continues): Parties will continue litigating elimination of LEAs and the scope of DPU authority under S. 2967.
    Mid-2026 (anticipated hearings): The DPU will evaluate the Revised Straw Proposal and clarify the “technically feasible alternative” and consent standards.
  • Late 2026 (anticipated CCP Orders): The Department is expected to resolve LEA reform and define how the obligation to serve applies in a managed gas transition, with potential for appellate review.

Minnesota

In the Matter of a Commission Evaluation of Changes to the Natural Gas Utility Regulatory and Policy Structures to Meet State Greenhouse Gas Reduction Goals (Docket #: G-999/CI-21-565)

(2021-present)

In 2021, the Minnesota Legislature directed the Public Utilities Commission (PUC) to evaluate changes to natural gas regulatory structures needed to meet or exceed the state’s greenhouse gas reduction goals. The Commission opened the Future of Gas docket (G999/21-565) to implement this directive. Much of the early work proceeded through gas utilities’ Integrated Resource Plan (IRP) proceedings, culminating in March and October 2024 orders addressing modeling assumptions, emissions pathways, and planning transparency.

In January 2025, the Commission reset the scope and timeline, returning focus to the Future of Gas docket. Current informational hearing topics include winter reliability, renewable natural gas (RNG), hydrogen and other alternative fuels, hybrid heating rate design, and updates from the Thermal Energy Network (TEN) Work Group. In parallel, the Commission initiated review of gas line extension allowance (LEA) policies before a comment period evaluating changes to rates to promote heat pump affordability and evaluate and address stranded asset risks as a result of electrification. The LEA comment period closed September 9, 2025, with a decision still pending. The rate and stranded asset comment period will follow at an undetermined date.

Q1 2026:

Regulatory Cost of GHG Emissions (Gas IRPs – Xcel, CenterPoint, MERC):

  • After a late-2025 comment process, the Commission adopted a three-scenario environmental compliance cost framework in January 2026.
  • Utilities must now model:
    • No new GHG compliance costs
    • A methane-only scenario applying $13/metric ton CO₂e to upstream methane beginning in 2030 and distribution-system methane beginning in 2035
    • A broader scenario that retains the methane costs and adds end-use CO₂ costs of $5–$75/ton starting in 2030
  • This resolves the initial dispute over whether the regulatory cost should reflect methane compliance only or a broader carbon-cost framework and gives utilities a defined modeling structure for their first gas IRPs.

Thermal Energy Network (TEN) Work Group:

  • The TEN Work Group submitted its final report on January 5, 2026, examining regulatory pathways, barriers, and public benefits of gas utility–owned thermal energy networks.
  • The Commission opened a public comment period to inform legislative review.
  • Any further action depends on the 2026 legislative session.

What’s Next:

  • LEA Reform Decision (Pending 2026): The anticipated 2025 order has not yet been issued.
  • First Gas IRP Filing: Xcel Energy is scheduled to file Minnesota’s first gas IRP in July 2026; CenterPoint is expected to file in July 2027; MERC is expected to file in July 2028.
  • Rate Design Review (Pending): The Commission has indicated it will take up a separate stakeholder process on rate issues tied to affordability, equity, electrification, and stranded costs. No major rate design decision appears to have been issued yet.

New York

Proceeding on Motion of the Commission in Regard to Gas Planning Procedures (Docket # 20-G-0131)

(2020-present) 


Associated dockets: 24-G-0248, 23-G-0676, 23-G-0437, 23-G-0147, 22-G-0610 

The New York gas planning docket (20-G-0131) originated in response to gas moratoria concerns but has since evolved into a statewide framework for managed gas transition planning. The PSC now requires each gas utility to file a Long-Term Gas Plan (LTGP) every three years in separate utility-specific dockets.

Each LTGP must include at least one scenario with no new traditional gas infrastructure, quantify greenhouse gas impacts, evaluate non-pipeline alternatives (NPAs), and provide updates on demand forecasts, electrification progress, and system risks.

In 2025, utilities submitted updated LTGPs and annual reports reflecting expanded electrification and NPA strategies. The Commission intensified scrutiny, issuing directives to curb gas demand growth, strengthen NPA deployment, improve forecasting methodologies and bill impact analyses, and align long-term planning more closely with New York’s Climate Leadership and Community Protection Act (CLCPA) mandates.

Q1 2026:

Central Hudson Gas & Electric (23-G-0676):

Targeted NPA Implementation (End of 2025):

  • Following the PSC’s July 17, 2025 Order, Central Hudson filed a Non-Pipeline Alternative (NPA) proposal for the constrained Poughkeepsie–Newburgh pipeline segment.
  • The proposal seeks to defer a $373,800 pipeline reinforcement by achieving a 5.6% winter peak-hour load reduction through electrification, demand response, and efficiency.
  • The project would require targeted load relief during extreme winter peak hours.
  • The filing marks a transition from planning analysis to geographically specific NPA deployment under Commission direction.
  • No additional substantive filings have occurred in Q1 2026.

New York State Electric & Gas Corporation and Rochester Gas and Electric (23-G-0437): 

  • No Q1 2026 Filings

ConEd and Orange and Rockland Utilities (23-G-0147): 

  • No Q1 2026 Filings

National Grid (24-G-0248):

  • Filed a Demand Forecast Update (Dec. 2025) incorporating updated electrification, efficiency, and local law impacts; the Reference Case still shows modest long-term design-day growth, while accelerated electrification scenarios significantly reduce demand.
  • Submitted its Annual Moratorium Outreach & Communications Plan update, outlining customer engagement and mitigation strategies in constrained downstate areas.
  • Filed community engagement plans and meeting summaries for Brooklyn (CB1 / Greenpoint), reflecting PSC directives to incorporate environmental justice and local input into long-term gas planning.
  • The central dispute remains whether National Grid’s planning assumptions justify continued firm capacity investments or whether more aggressive electrification and NPA deployment should drive system contraction.

National Fuel Gas Distribution Corp. (22-G-0610):

  • No Q1 2026 Filings

Liberty Utilities (St. Lawrence Gas) Corp. (20-G-0131):

  • ​​Filed an updated Natural Gas Moratorium Outreach and Communications Plan (Dec. 29, 2025) outlining notification procedures, stakeholder engagement, and customer protections for potential service moratoria.
  • The plan details required communications with state officials, municipalities, contractors, and affected customers, along with publication of alternative energy resources and NYS Clean Heat contacts.
  • Incorporates forthcoming PSC-approved Customer Bill of Rights provisions.
  • No additional substantive Q1 2026 activity.

What’s Next (Long-Term Gas Plans)

  • Forecast & Capacity Review: The PSC will assess whether updated demand forecasts justify continued firm capacity investments under CLCPA-aligned electrification pathways.
  • NPA Expansion: Utilities may be directed to strengthen or expand non-pipeline alternative deployment where peak growth assumptions remain contested.
  • Reporting & Bill Impact Oversight: Ongoing LTGP review will focus on customer gas terminations, bill impacts, and alignment with the no-new-infrastructure scenario requirement.

Future of Heat Regulation

Q1 Highlights

  • California is piloting a tariff-on-bill financing model designed to electrify homes without relying on traditional consumer loans, with the goal of expanding access to clean energy upgrades for renters and lower-income households who face upfront cost and credit barriers.
  • Massachusetts is shaping utility rate design around affordability and electrification through its seasonal heat pump rate, new energy-burden-based bill protections, and a proposed geothermal service rate to scale thermal energy networks within gas planning.
  • New York is deploying  low- and moderate-income programs for electrification and energy efficiency through 2030
  • Maryland is advancing clean heat on two fronts with a Clean Heat Standard for fuel suppliers and a zero-emission heating equipment standard to establish both emissions accountability and long-term market transformation in the thermal sector.
  • The D.C. PSC has scaled down Washington Gas’s accelerated pipeline replacement plan while opening a new integrated gas system planning docket to complement the District’s existing electric system planning and Future of Gas proceedings.

 

State / Rule or Regulation

Recent Activity

Category

California, Rulemaking Regarding Building Decarbonization (R. 19-01-011)


(2019-present)

The Building Decarbonization Rulemaking was opened in 2019 following the passage of SB 1477, which provided cap-and-invest funding for two building electrification pilot programs: the Building Initiative for Low-Emissions Development (BUILD) Program and the Technology and Equipment for Clean Heating (TECH) Initiative. 

The proceeding has since evolved beyond oversight of the original pilot programs into a broader forum for implementation lessons, zonal decarbonization concepts, and coordination across related CPUC proceedings. Activity at the end of 2025 and beginning of 2026 focused on procedural extensions, PG&E’s CSU Monterey Bay zonal electrification “lessons learned” report, and a Commission-convened workshop on best practices and future pathways for scaling building decarbonization. PG&E’s March 2026 workshop report underscores that the proceeding is now being used to surface cross-cutting implementation barriers, such as customer complexity, workforce constraints, remediation needs, affordability concerns, and the need for better coordination across funding streams, grid planning, and related rulemakings. 

Q1 2026:

  • Procedural deadline extended: In November 2025, the CPUC extended the statutory deadline for the proceeding from December 31, 2025 to July 31, 2026.
  • Workshop report filed (March 2, 2026): PG&E filed its report on the January 21–22, 2026 Building Decarbonization Best Practices and Future Pathways Workshop
  • Workshop findings highlighted implementation barriers: Across panels, recurring themes included customer complexity and trust, workforce shortages, remediation needs, affordability concerns, right-sizing strategies to avoid unnecessary electrical upgrades, and the need for stronger coordination across agencies, utilities, local governments, and community-based organizations. The report also reflects growing interest in zonal decarbonization and networked geothermal as longer-term scaling pathways, while noting differing views on funding approaches and equity implications of ratepayer-funded behind-the-meter investments.
  • Zonal electrification lessons remain central: In January 2026, PG&E also filed its Commission-directed “lessons learned” report on the CSU Monterey Bay zonal electrification proposal, and the workshop report builds on that by reinforcing that future scaling will depend on simpler customer pathways, clearer funding structures, workforce readiness, and coordination with long-term gas planning.

What’s Next:

  • Proceeding coordination and policy development: The workshop report is likely to inform remaining work in this proceeding as well as related CPUC dockets on gas planning, energy efficiency, cost-effectiveness, DER integration, and financing.
  • Potential action on scaling pathways: The workshop surfaced recurring themes—such as zonal decarbonization, networked geothermal, affordability protections, and diversified funding—that could shape the Commission’s next steps on long-term building decarbonization strategy.
  • Proceeding deadline: Remaining issues must be resolved before the July 31, 2026 statutory deadline.

line extension allowances, rebates and incentives; grid management; workforce

California, 

OIR to Investigate and Design Clean Energy Financing Options for Electricity and Natural Gas Customers 

(R. 20-08-022)



Rulemaking 20-08-022 was instituted in 2020 to evaluate financing strategies that could support larger-scale investments in clean energy improvements. In 2023, the CPUC directed utilities to propose expanded tariff-on-bill (TOB) financing programs—sometimes referred to as Inclusive Utility Investment (IUI)—which allow customers to repay the cost of clean energy upgrades, such as heat pumps, through a charge on their monthly utility bill rather than paying the full cost upfront.

The model is designed so that projected energy savings offset the incremental on-bill charge, lowering upfront barriers and expanding access to electrification, particularly for renters and lower-income households.

In 2024, the IOUs submitted a joint TOB proposal, which was evaluated by a third party and released for stakeholder comments in May 2025. Ultimately, only Southern California Edison’s pilot was approved. The proceeding was closed following the final decision in December 2025.

Q1 2026:

Proposed Decision (Issued October 31, 2025)

  • Approved a modified SCE Tariff On-Bill (TOB) pilot (two-year, ~$7.2 million, up to 200 participants).
  • Denied the TOB pilots proposed by SDG&E, SoCalGas, and SVCE.

Key Elements of the Approved (Modified) SCE Pilot

  • Budget: $7.19 million for up to 200 participants over two years.
  • Funding Source: Public Purpose Programs Charge (ratepayer-funded).
  • Bill Neutrality Requirement: Annual estimated energy savings must equal or exceed the Decarbonization Charge.
  • Tariff-Based Charge: Charge tied to the meter, transferable to successor customers, consistent with SB 1112.
  • DFPI Review: SCE directed to seek a determination from the Department of Financial Protection and Innovation (DFPI) on whether the pilot constitutes a lending program.

Comments on Proposed Decision

  • Advocates urged inclusion of CARE/FERA customers and small businesses and requested clarification that TOB is not consumer debt
  • Consumer groups supported seeking DFPI review but questioned whether statutory language fully shields the Decarbonization Charge from lending or debt collection laws.
  • SDG&E requested authority to close TOB memorandum accounts following denial of its pilot.

Final Decision

  • The Commission adopted the Proposed Decision (with modifications), formally approving SCE’s modified TOB pilot and denying the other utility proposals
  • The proceeding was closed following issuance of the decision.

What’s Next:

  • SCE will implement the limited TOB pilot, including DFPI consultation and post-pilot evaluation.

inclusive utility investment, tariff-on-bill, clean energy financing, equity

California


OIR for Oversight of Energy Efficiency Portfolios, Policies, Programs, and Evaluation.


(R.25-04-010)

Natural Gas Energy Efficiency Incentives Policy

In April 2025, the CPUC opened R.25-04-010 as the successor to the long-running energy efficiency rulemaking, establishing a new forum for oversight of energy efficiency portfolios, cost-effectiveness policy, and program administration.

Of central concern is the reconsideration of ratepayer-funded incentives for gas-burning appliances. In late 2025, staff proposed further phasing out gas EE incentives where viable electric alternatives (VEAs) exist.

Q1 2026: 

  • Utilities, environmental groups, and consumer advocates filed opening and reply comments (Jan. 2026) on the Staff Proposal.
  • Advocates broadly support accelerating the phase-out of gas appliance incentives, particularly in new construction and where electric alternatives are available.
  • Gas utilities argue the Commission must continue funding cost-effective gas efficiency measures under Public Utilities Code §454.56 and dispute how VEAs should be defined (PCT vs. TRC, treatment of infrastructure costs).

What’s Next:

  • The Commission is expected to issue a Proposed Decision on natural gas incentive policy in 2026.
  • The ruling will clarify how VEAs are determined, how cost-effectiveness tests apply, and whether California will further restrict or eliminate ratepayer-funded incentives for gas-burning appliances.
  • The outcome will shape how energy efficiency portfolios align with the state’s broader gas system transition and electrification policies.

gas subsidies, energy efficiency

Colorado, Black Hills Clean Heat Plan (23A-0633G)

A January 2025 Decision by the Colorado Public Utilities Commission marked a pivotal moment in the state’s Clean Heat Plan implementation, raising the question of whether a gas-only utility can be required to meaningfully pursue beneficial electrification (BE) alongside traditional gas efficiency programs. The case stems from Colorado’s 2021 Clean Heat statute (SB21-264), which requires gas utilities to reduce greenhouse gas emissions through approved clean heat portfolios. 

Q1 2026: 

Procedural Developments

  • The Commission held an en banc evidentiary hearing (Oct. 27–29, 2025) to examine legal authority, modeling, and the role of beneficial electrification (BE).
  • Black Hills, Staff, UCA, and CEO filed a Second Settlement Agreement; SWEEP opposed.
  • Post-hearing briefs were filed November 14, 2025.

Second Settlement Agreement

  • Shortens the action period to 2026–2027 and sets a $12.4M budget within the 2.5% cost cap.
  • Maintains demand-side management (DSM) as the primary clean heat resource, with limited renewable natural gas (RNG), advanced methane leak detection (AMLD), a small beneficial electrification (BE) pilot, and a thermal energy feasibility study.
  • Adds a $300,000 Electrification Study to evaluate BE costs and bill impacts in Black Hills’ gas-only territory.

Key Dispute

  • Settling Parties: Support a cost-capped plan focused on DSM and studies before scaling BE.
  • SWEEP: Urges rejection of the settlement and proposes a ~$28.5M plan centered on expanded DSM and BE, exceeding the cost cap.

What’s Next:

  • The Commission will decide whether to approve the settlement or require greater investment in BE.
  • If approved, Black Hills will implement the 2026–2027 plan and file a combined DSM/CHP in 2027.

clean heat standards, electrification, managed gas transition

D.C.

In The Matter Of The Investigation Into Washington Gas Light Company’s Strategically Targeted Pipe Replacement Plan

(Case # 1179)

Washington Gas Light’s accelerated pipeline replacement program (formerly ProjectPIPES) remains under active scrutiny as the District weighs safety, climate alignment, and ratepayer risk.

In December 2022, WGL filed its PIPES 3 proposal, a five-year, $671.8 million plan. In June 2024, the Public Service Commission of the District of Columbia (DC PSC) dismissed it, directing the utility to refocus on high-risk pipe replacement and better align with the District’s climate goals. WGL refiled in September 2024 as the Strategic Accelerated Facility Enhancement (SAFE) Plan, proposing $215 million over three years to replace 12.4 miles of main and 3,608 service lines, with continued recovery through the existing surcharge mechanism. Consumer advocates argued the revised plan still failed to adequately evaluate non-pipeline alternatives (NPAs), including electrification, and did not sufficiently address stranded asset risk. Rather than approving SAFE immediately, the Commission extended the existing surcharge through the end of 2025 with a $34 million spending cap and moved the case into an evidentiary phase focused largely on WGL’s JANA risk model.

In March 2026, the Commission approved a modified SAFE plan, cutting WGL’s proposed budget by roughly 30 percent and imposing tighter annual caps, threshold-based cost recovery, and enhanced reporting requirements. At the same time, it opened a new Integrated Natural Gas Distribution System Planning proceeding (“INGDSP”, Case # 1187), signaling that future gas replacement spending will be evaluated within a broader long-term gas planning and decarbonization framework.

Q1 2026: 

  • Modified SAFE Plan Approved (March 4, 2026): The Commission approved a modified three-year SAFE plan, reducing WGL’s proposed budget from $215 million to $150 million and setting annual caps of $45 million, $50 million, and $55 million for the next three years, respectively.

  • Cost Recovery and Oversight Tightened: The Commission retained the surcharge but added annual recovery thresholds ($10M for year 1, $12.5M for year 2, and $15M for year 3) and expanded reporting requirements, including JANA risk model outputs, annual project lists, and compliance filings.

  • NPA Review Elevated; New Planning Docket Opened: WGL must now evaluate NPAs before including projects in annual replacement plans and justify why alternatives, including pipeline abandonment, are insufficient. The Commission also opened a new integrated gas planning docket (FC 1187) to address longer-term gas infrastructure planning and risk management.

What’s Next:

  • WGL’s modified SAFE plan will proceed under tighter annual caps, threshold-based cost recovery, and expanded reporting. 
  • WGL must submit annual project lists supported by quantified risk reduction analysis and evidence that NPAs are insufficient. 
  • The new INGDSP proceeding (FC 1187) will begin developing a longer-term framework for aligning gas distribution planning with the District’s climate laws and electrification trajectory; it will establish a working group by June 2026 and a report for establishing the scope of the proceeding will be submitted by the end of the year. 

accelerated pipeline replacement, NPAs

D.C.

Integrated Distribution System Planning (“IDSP”)

FC 1182

The D.C. PSC opened Formal Case No. 1182 in late 2024 to create a more coordinated, transparent, and climate-aligned framework for electric distribution planning. The docket responds to long-running concerns that Pepco’s planning, load forecasting, and DER integration processes are too fragmented and insufficiently aligned with the District’s clean energy goals. In July 2025, the Commission directed that an IDSP Working Group be convened to develop recommendations on load forecasting, data transparency, DER valuation and hosting capacity, and resilience, electrification, and equity.

Q1 2026:

  • Working Group launched: The first IDSP Working Group session was held on February 11, 2026, led by E3.

  • DOEE/OPC framework filed: DOEE and OPC proposed a detailed IDSP framework built around a three-year cycle, annual updates, scenario-based forecasting, granular planning data, affordability analysis, and stronger stakeholder review.

  • Core issues emerging: Early sessions and filings show growing focus on forecasting future electrification and DER adoption, feeder-level transparency, hosting capacity, Non-wires Alternatives (NWAs), and integration of resilience, equity, and climate goals into planning.

What’s Next: 

  • The working group will continue technical sessions through summer 2026, with a final report expected in August. 
  • The Commission will then determine the requirements for Pepco’s first formal IDSP filing and how the new framework will interact with future rate cases and climate-related proceedings.

Integrated system planning, electric system

Illinois

Informal Process following Docket No. 24-0081,

Illinois Commerce Commission

 

Following the ICC’s February 2025 order requiring Peoples Gas to evaluate non-pipeline alternatives (NPAs) as part of its pipeline replacement strategy, an independent facilitator convened a seven-part workshop series between September and December 2025. The final summary report synthesizes workshop discussions, stakeholder proposals, and areas of agreement and disagreement.

This process represents Illinois’ most formal effort to date to evaluate how non-pipeline alternatives could be integrated into Peoples Gas’ pipeline replacement planning.

Q1 2026:

Workshop Outcomes & Key Themes

Stakeholder NPA Proposals Presented

  • NPA proposals were submitted by stakeholders and presented during Workshop 3 (Oct. 29, 2025), with Peoples Gas responding in Workshop 5 (Nov. 20, 2025).
  • Proposals focused on identifying hydraulically severable pipe segments, prioritizing lower-risk areas for NPA pilots, and sequencing replacements to allow time for electrification alternatives.

Candidate Identification & Near-Term Actions

  • Illinois PIRG (via Groundwork Data) recommended that Peoples Gas identify and publish a preliminary list of NPA candidate projects by mid-2026, drawn from pipe segments scheduled for replacement in 2029–2035.
  • Recommendations included establishing interim NPA targets, sequencing suitable pipe segments later in the retirement schedule, clarifying flexibility around the 2035 retirement deadline, and prohibiting new gas connections in potential NPA zones.

Affordability Debate Over Gas Line Extensions

  • Ameren Illinois opposed framing the elimination of gas line extensions as a “no-regrets” action, arguing it could raise affordability concerns by concentrating infrastructure costs on fewer customers.
  • Peoples Gas noted there was no consensus among stakeholders on proposed near-term actions.

Community Engagement

  • The facilitator conducted targeted outreach to community-based organizations, including dedicated meetings to increase participation and awareness of NPA opportunities.

Workshop Takeaways

The workshop process did not produce consensus on immediate NPA implementation but did:

  • Surface specific criteria for identifying candidate NPA projects (hydraulic feasibility, customer density, timing alignment);
  • Establish a framework for integrating NPAs into pipe retirement planning; and
  • Highlight key policy tensions around affordability, timelines, and gas system expansion.

What’s Next:

  • Continued Utility-Led Engagement: Stakeholders may continue discussions after Peoples Gas hires an NPA consultant and develops an evaluation framework.
  • Future of Gas Proceeding (Docket 24-0158): NPA-related legislative and regulatory proposals are under discussion in Phase 2C, with further updates expected in 2026 following a statewide decarbonization pathways study.
  • Formal Commission Action: NPA authority and implementation questions may be addressed in the new decarbonization pilots docket opened January 21, 2026, and/or in Peoples Gas’s pending rate case (Docket 26-0065).

non-pipeline alternatives

Maryland


Clean Heat Standard

Governor Wes Moore’s 2024 Executive Order established a Clean Heat Standard (CHS) requiring Maryland’s thermal sector to reduce emissions from heating delivery services and transition to clean heating technologies, including zero-emission equipment (e.g., heat pumps), weatherization, and cleaner fuels.

A foundational component of the policy is The Heating Fuel Provider Program Rule, which creates the data infrastructure necessary to set enforceable emissions reduction targets.

Q1 2026:

Heating Fuel Provider Reporting Rule Finalized (Dec. 2025)

  • In December 2025, the Maryland Department of the Environment (MDE) finalized regulations for the Heating Fuel Provider Reporting Program (COMAR 26.11.44), effective December 22.
  • Beginning in 2026, approximately 175 heating fuel companies must submit quarterly, county-by-county delivery data, with initial reports due by April 2027.
  • The reporting framework establishes the emissions baseline needed for MDE to set credible reduction targets for obligated fuel providers under the full Clean Heat Standard.
  • By requiring standardized reporting across the heating fuel market, Maryland is moving from executive directive to measurable implementation, enabling transparent tracking of fossil fuel use and laying the groundwork for enforceable decarbonization obligations.

What’s Next:

  • MDE will use reported data to inform target-setting and program design for obligated fuel providers.
  • Additional Clean Heat Standard rulemaking and legislative activity are expected in 2026 as the state shifts from baseline measurement to compliance requirements.

clean heat standards, electrification

Maryland


Zero Emission Heating Equipment Standards (ZEHES)

Following Governor Moore’s 2024 Executive Order, the Maryland Department of the Environment (MDE) began developing regulations to phase out fossil fuel heating equipment and address harmful nitrogen oxides (NOx) and greenhouse gas (GHG) emissions from the building sector.

MDE is jointly developing the rule with the Northeast States for Coordinated Air Use Management (NESCAUM), using the 2024 NESCAUM Model Rule as a foundation. The regulation, known as the Zero-Emission Heating Equipment Standard (ZEHES), is intended to transition Maryland’s heating market toward zero-emission technologies while incorporating flexibility and consumer protections.

Q1 2026:

Rule Design Advancing (Dec. 2025)

  • In December 2025, the ZEHES Program Design Subcommittee met to address key flexibility provisions, including exemptions, waiver processes, and enforcement mechanisms.
  • NESCAUM presented draft proposals aligned with the 2024 Model Rule and is working to ensure consistency with Maryland’s regulatory requirements.
  • Subcommittee work continued through Q1 2026, with meetings in February and March refining flexibility measures, contractor engagement strategies, and affordability considerations.
  • Early focus on waiver and enforcement structure positions the rule to be administratively durable and legally defensible as Maryland shifts heating markets toward zero-emission equipment.

Contractor Working Group Launched

  • In the first quarter of 2026, the Maryland Clean Heat Coalition established a biweekly Contractor Working Group to facilitate real-time feedback between the HVAC installation market and the regulatory process.
  • Core objectives include identifying market barriers related to financing, equipment availability, customer education, and compliance clarity. Additionally, we aim to develop a workforce support roadmap for MDE.
  • In March 2026, NESCAUM held targeted stakeholder sessions with manufacturers and contractors to inform revisions of the Model Rule.

Scope Considerations Expanding

  • The subcommittee is evaluating whether to include an air-conditioning-to-heat-pump replacement pathway within ZEHES or through a related regulation.
  • Leveraging AC replacement cycles could significantly expand emissions reductions while reducing customer disruption and cost.

Equity & Program Alignment

  • Coalition partners are advocating for accelerated timelines for new construction, strong equity provisions, and coordination with related policies such as EmPOWER incentives and low- and moderate-income (LMI) protections.
  • Aligning ZEHES with existing incentive and efficiency programs is intended to reduce bill impacts and support an affordable transition as fossil fuel equipment phases down.

What’s Next:

  • Refinement of flexibility and compliance proposals through early 2026.
  • Broader stakeholder engagement in Q1 2026.
  • Initiation of formal rulemaking through publication in the Maryland Register.
  • Continued coordination with Clean Heat Standard development and related 2026 legislative priorities.

electrification, equipment standards

Massachusetts


Eversource Geothermal Rate Case (DPU 25-86)

On September 17, 2025, NSTAR Gas (Eversource Energy) filed a petition seeking approval of a regulatory framework and new geothermal rate to develop networked geothermal systems in new construction projects in its service territory.

The filing follows the Department’s 2023 policy decision in D.P.U. 20-80-B and recent statutory changes that explicitly authorize gas companies to make, sell, or distribute networked geothermal energy.

The proposal seeks to establish a structured process for evaluating geothermal alongside natural gas in new developments and to create a dedicated geothermal rate for participating customers.

Under the proposed framework:

  • Participating customers would take service under a new geothermal rate in lieu of traditional gas distribution charges. The rate will be sized by tonnage, and be comparable to existing gas rates.
  • Revenues collected from geothermal customers would flow through the Geothermal Energy Provision (GEP) of the Company’s Local Distribution Adjustment Clause (LDAC), while the differential between geothermal system costs and geothermal rate revenues would be supported—up to a $15 million cap over five years—by Eversource Gas customers.
  • Developers could compare geothermal and gas on a side-by-side basis using a contribution-in-aid-of-construction (CIAC) framework, with an expedited regulatory review process for qualifying projects.
  • If approved, the framework would move networked geothermal from pilot status to a structured, rate-regulated offering embedded within gas utility planning.

The filing is structured as a Tier 2 proceeding and includes testimony from both a Geothermal Panel and a Rates Panel.

Q1 2026:

  • Petition Filed (Sept. 17, 2025): Eversource formally requested approval of the regulatory framework and geothermal rate.
  • Regulatory Framework Details Filed: The Company submitted pre-filed testimony and illustrative bill impacts demonstrating how up to $15 million in geothermal support would affect existing customers.

What’s Next:

  • DPU Review of Authority & Cost Recovery: The Department will determine whether the proposed framework is consistent with D.P.U. 20-80-B and the 2024 statutory amendments authorizing geothermal activity by gas companies.
  • Public Comment: A virtual hearing will occur at 7:00pm Eastern Time on April 8, 2026. Written comments are due to the Department not later than the close of business (5:00pm Eastern Time) on Monday, April 13, 2026.
  • Decision on Subsidy Cap & Rate Design: The DPU must decide whether to approve the proposed $15 million customer contribution cap and the new geothermal rate structure.
  • Project Implementation (If Approved): Approval would allow Eversource to move forward with qualifying new-construction thermal energy networks under an expedited “Notice to Proceed” process and apply the new geothermal rate to participating customers.

thermal energy networks, rates

Massachusetts

Inquiry by the Department of Public Utilities on its own Motion into Energy Burden with a Focus on Energy Affordability for Residential Ratepayers

(D.P.U. 24-15)

In January 2024, the Massachusetts Department of Public Utilities (DPU) opened an inquiry to examine residential energy burden and improve affordability for electric and gas customers. “Energy burden” is defined as the share of a household’s annual income spent on utility bills; for example, a 4% energy burden target means combined annual electric and gas bills are calibrated not to exceed roughly 4% of household income under modeled usage assumptions.

Following extensive stakeholder comments, workshops, technical sessions, and model development, the DPU issued a Phase I Order on February 17, 2026 establishing a new statewide framework for tiered low-income discount rates. The Order represents a structural shift from flat percentage discounts to an income-tiered model explicitly tied to target energy burdens.

Q1 2026:

Phase I Order (Feb. 17, 2026)

  • Establishes statewide Six-Tier, Energy-Burden-Based Discount Framework that aligns with Home Energy Assistance Program (HEAP) definitions (≤100% Federal Poverty Level [FPL] through >200% FPL up to 60% SMI).
  • Requires uniform statewide assumptions, creating consistency across electric and gas utilities.
  • Embeds affordability targets directly into rate design rather than relying on flat percentage discounts.

Energy Burden Targets Embedded in Rates

  • Lowest tier (≤100% FPL):
    • 4% total energy burden
      • 2% electric + 2% gas heating (0.5% for non-heating gas)
  • Remaining five tiers:
      • 6% total energy burden
        • 3% electric + 3% gas heating (0.75% for non-heating gas)
  • By anchoring discounts to explicit income-based thresholds, the DPU shifts affordability policy from flat assistance levels to outcome-based bill protection.

Discount Floors

  • Minimum discounts of:
    • 25% for electric utilities
      15% for gas utilities
  • These floors prevent higher-income tiers from losing all assistance while still aligning discounts with energy-burden targets.

Implementation & Phase-In Protections

  • Utilities must file compliance plans within 60 days.
  • Tiered rates must take effect by November 1, 2026.
  • Customers receiving reduced discounts will see changes phased in gradually (no more than 5 percentage points every six months).

RAAF Reform (Cost Recovery Shift)

  • Low-income customers will no longer pay the Residential Assistance Adjustment Factor (RAAF).
  • Costs will instead be recovered from “all other customers,” consistent with statute.
  • The DPU signaled support for potential statewide cost recovery, though legislation would be required.

Moderate-Income Discount (Next Phase)

  • The Order acknowledges new statutory requirements to develop a moderate-income discount framework, to be addressed in Phase II rulemaking.

What’s Next:

  • Utility compliance filings due within 60 days.
  • Phase II continues (enrollment, verification, outreach, moderate-income framework).
  • Program review approximately 12 months after implementation.
  • Potential legislative action on statewide cost recovery.

rates, affordability, energy burden

New York, 

Energy Efficiency and Building Electrification proceedings


14-M-0094: Proceeding on Motion of the Commission to Consider a Clean Energy Fund

18-M-0084:  In the Matter of a Comprehensive Energy Efficiency Initiative

25-M-0248: In the Matter of the 2026-2030 non-Low- to Moderate-Income Energy Efficiency and Building Electrification Portfolio

25-M-0249: In the Matter of the 2026-2030 Low- to Moderate-Income Energy Efficiency and Building Electrification Portfolio

The Energy Efficiency and Building Electrification proceeding, formerly referred to as “New Efficiency: New York (NE:NY),” is the state’s $5 billion portfolio of ratepayer-funded energy efficiency and electrification incentive programs. These offerings were under regulatory review by the NYS Public Service Commission to improve program design, spending, and accountability.

On May 15, 2025, the Commission established two new proceedings—one for Low- and Moderate-Income (LMI) programs (25-M-0249) and one for market-rate programs (25-M-0248)—authorizing approximately $1 billion per year for 2026–2030 in energy efficiency and clean energy solutions, including building electrification. Administered by the state’s investor-owned electric and gas utilities and NYSERDA, nearly one-third of the funding ($1.57 billion) is dedicated exclusively to LMI programs.

Following the May 2025 orders, the Commission advanced implementation of the broader Clean Energy Fund (CEF), including approval of the 2026–2030 Innovation & Research (I&R) portfolio and modifications to the New York Green Bank (NYGB). Together, these actions shape the innovation, financing, and market infrastructure supporting building electrification through 2030.

Q1 2026:

Clean Energy Fund (14-00549) 

Procedural Developments

  • PSC approved the 2026–2030 Innovation & Research (I&R) portfolio and issued an order modifying NY Green Bank (NYGB).

Innovation & Research Portfolio (Oct. 2025)

  • Authorized $412.3M through 2030, including investments in advanced buildings, fuels transition, and grid modernization.
  • Sets targets of $1.7B leveraged funding and 110 products commercialized.

NY Green Bank Modifications (Jan. 2026)

  • Establishes a $250M building decarbonization investment target (including $100M for affordable housing).
  • Increases disadvantaged communities commitment from 35% to 40% of capital.

Market-Rate / Non-LMI Programs (25-M-0248)

Procedural Developments

  • Utilities filed updated System Benefits Charge (SBC) statements to implement 2026–2030 Non-LMI EE/BE collections effective January 1, 2026.
  • SBC now explicitly itemizes Non-LMI EE/BE as a distinct portfolio component, alongside Clean Energy Fund and Innovation & Research charges.

Implementation Updates

  • The statewide NYS Clean Heat Program, which provides heat pump incentives, is now restricted to single-family homes and small residential buildings (1–4 units), with multifamily and C&I electrification shifted to utility-run programs.
  • Electrification spending capped at 50% of electric portfolio budgets.

LMI Programs (25-M-0249)

Procedural Developments

  • Parallel SBC filings implemented LMI EE/BE surcharge collections beginning January 1, 2026.
  • Cost recovery clarified through the November rehearing order and embedded in updated SBC structures.

Implementation Oversight

  • DPS Staff issued a compliance letter requiring more detailed budgets, savings targets, participation metrics, and incentive structures before full approval of the LMI Implementation Plan.
  • Program administrators permitted limited budget access to ensure continuity beginning January 2026 while revisions were finalized.

What’s Next: 

LMI and Non-LMI Programs

  • Revised implementation plans to be finalized following Staff directives.
  • Updated program offerings to launch in early 2026.
  • Annual SBC reconciliations and collections continue through 2030.
  • Staff to convene evaluation and performance tracking discussions in 2026.

Clean Energy Fund

  • NYSERDA to file an I&R Operating Plan; NYGB begins implementing new sector targets in 2026.

energy efficiency, electrification, LMI programs

New York, Utility Thermal Energy Network and Jobs Act (UTENJA) 22-M-0429

Since being directed by the 2022 UTENJA law, New York utilities have been exploring how they can use thermal energy networks to decarbonize entire neighborhoods across the state. There are currently 10 proposed pilot projects under PSC review. The proceeding has moved from feasibility analysis to detailed engineering design, lifecycle cost validation, and customer protection planning, positioning several pilots for potential Stage 3 construction decisions.

Q1 2026:

Procedural Developments

  • Several utilities filed revised and supplemental Stage 2 engineering plans, including updated system designs, cost estimates, and construction sequencing.
  • DPS issued a Notice Soliciting Comments due in Q1 2026 on final engineering design and customer protection plans.
  • Utilities continue filing monthly progress and expenditure reports as pilots advance toward potential Stage 3 construction.

Engineering & Cost Analysis

  • Lifecycle Cost Analyses (LCCAs) compare TEN pilots to Business-as-Usual, ASHP-only, and GSHP scenarios over a 25-year period.
  • The Buro Happold “Optimal Scenarios” study reinforces projected $8M–$75M lifecycle savings versus ASHPs, depending on project scale and building mix, and finds lower lifecycle emissions in most modeled cases.

Stakeholder Comments

  • In comments responding to the DPS notice on Stage 2 engineering and customer protection plans, stakeholders emphasized:
    • Bill protections and cost containment
    • Clear participation terms
    • Transparent cost allocation
    • Workforce safeguards

What’s Next:

  • PSC review of Stage 2 engineering and customer protection filings.
  • Determinations on whether individual pilots may advance to Stage 3 (construction).
  • Continued monthly progress and expenditure reporting.
  • Potential additional stakeholder process if further revisions are required prior to Stage 3 authorization.

thermal energy networks, workforce, neighborhood scale

 

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VI. Looking Ahead

What to watch for in the year ahead

  • The heat pump crossover could signal a lasting market shift. In 2026, we will see whether heat pumps can continue to outsell air conditioners. 
  • The refrigerant transition will shape the HVAC market this year. With higher-GWP equipment phased out as of January 1, 2026, the coming months will show how smoothly manufacturers, contractors, and consumers navigate the transition.
  • Future of Gas proceedings continue to advance. In California, Massachusetts, Maryland, New York, and D.C., regulators are increasingly being asked not just to study the gas transition, but to make real decisions about planning, rates, and future investment.
  • Neighborhood-scale transition pilots are getting closer to real implementation. In California, utilities are expected to submit plans for up to 30 neighborhood-scale decarbonization pilots beginning in July 2026, while New York’s UTENJA pilots are advancing toward Stage 3 construction decisions.
  • Massachusetts is approaching decisions on two of the country’s most consequential gas reforms. Regulators are expected to decide whether to eliminate gas line extension subsidies and how far the state can reinterpret the gas “obligation to serve” under climate law—decisions that could determine whether neighborhood-scale transition projects can move forward without requiring unanimous customer consent.
  • Maryland’s Future of Gas proceeding could help turn analysis into enforceable policy. This year will build the evidentiary record through testimony, rebuttal, and final statements, while the Commission also weighs reforms to gas line extension rules that would require new customers to pay the full cost of new gas hookups.
  • D.C. is making notable progress on the managed gas transition. Alongside its Future of Gas proceeding and its recent move to scale back Washington Gas’s accelerated pipe replacement program, the District is now developing separate electric and gas planning processes that could help align long-term utility planning with climate goals.
  • Affordability-focused reforms are continuing to take shape. Massachusetts utilities are preparing to implement new energy-burden-based discount rates, while New York continues refining its 2026–2030 electrification and efficiency portfolios. This year should also provide an early test of how Massachusetts’s new heat pump rate performs through its first heating season. These reforms will help show whether states are moving beyond clean heat ambition toward policies that actually lower costs and expand access.

 

VII. Methodology

  • Heat pumps vs. furnaces and air conditioners: Data directly from AHRI monthly shipment reports, combining gas and oil furnaces into a single “fossil fuel furnaces” category. 
  • Gas utility spending: Data from AGA through 2023 (latest available). We establish the pre-2010 baseline by averaging inflation adjusted distribution spending from 1990-2009, then calculate the area between actual spend vs. baseline from 2011-2023 to get to $130 billion. In 2023, “excess” over the baseline is $20B, which we apply the 2-3x factor of ratepayer costs to get to “at least $40B” in lifecycle costs per year. 
  • Gas bill proportions: Using data from EIA, we compare total residential delivered cost of gas vs. citygate price. The citygate price is the commodity cost while the remainder cover delivery costs. 
  • Residential gas stats: From EIA, we plot residential gas consumption and consumers, adding a linear trendline for consumption over the plotted data and calculate the average annual growth of 0.9% for consumers over the plotted time period. 

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