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CUB's comments on 2027-2029 utility energy programs

August 18, 2026
Carmen Carruthers
energy efficiency graphic with calculator, two light bulbs, a model of a house and a pen

Have you ever taken advantage of an appliance rebate offered by your utility? Do you participate in utility programs designed to reduce your energy usage? Have you ever received an email from your utility analyzing your energy usage, with tips to be more energy efficient? 

If so, you’ve taken advantage of energy efficiency programming made available through the ECO Act. Between 2022 and 2023, ECO estimated to have saved Minnesota businesses and residents over $321 million in energy costs – through efficiency upgrades, rebates for projects, and ideas to change your behavior and reduce your energy use. 

The vast majority of utilities in Minnesota are, by law, required to provide these programs, which are primarily funded by ratepayers through a line item on your monthly energy bill. This summer, CUB and a range of other stakeholders are reviewing and providing recommendations on Minnesota's investor-owned utility’s plans for energy efficiency programs over the next three years. CUB takes seriously how programs are administered, how funds are used, and how energy savings are being measured. Keep reading to learn more about the 2027-2029 ECO triennial plans and what stood out to CUB. 

What’s a triennial plan? 

Every three years, Minnesota’s investor-owned utilities present their “triennial plan” for review and approval by the Department of Commerce (the Department). The triennial plans include the utilities’ proposals for all of the energy efficiency programs they plan to offer over the next three years. Throughout the review process, members of the public and interested organizations are invited to submit feedback and recommendations on the utilities’ proposals before the Department makes its final determination. This is the second triennial plan CUB has engaged with and submitted comments on.  

Triennial plans are wide-ranging, covering programs for residential, income-qualified, multifamily, and commercial customers. CUB’s initial comments focused on residential, income-qualified, load management, and efficient fuel switching categories.   

Utilities spend months preparing their triennial plans, which must meet certain criteria set by the Department around required spending and cost-effectiveness.   

CUB’s Comments 

CUB was pleased to see many utilities build on improvements made in the last triennial by continuing to offer key rebates on efficiency improvements and equipment, expanding options around efficient fuel switching, and increasing spending and incentives for income-qualified programs. 

CUB actively engaged in stakeholder discussions throughout the triennial plan development process, encouraging utilities to propose programs that result in meaningful energy savings and increased comfort. Efficiency programs make the most difference when they are broadly accessible, uniformly implemented, easy to navigate, and serve ratepayers regardless of income or living situation.

Here are some specific programs and concepts CUB focused on in our initial comments: 

  • Investing in pre-weatherization: Weatherization projects, including insulation and air sealing, are a key component of increasing the efficiency of the home. Before those projects can be carried out, pre-weatherization work may be needed. For example, removing asbestos or dealing with mold issues must be addressed before further building work can be done. CUB encourages utilities to provide additional investment towards pre-weatherization projects, which can help ensure that all ratepayers can realize actual energy efficiency savings. 
  • Modernizing and updating load management programs: Load management is a technique used to shift when and how we use our energy. The goals can be to both reduce total energy use and/or to shift use to times when energy generation is abundant and less expensive. This can help customers save money in the long run by helping to avoid additional investments in generation or increased distribution capacity. In our comments, we encourage utilities to think ahead about how their air conditioning load management programs could best serve customers today and in the future. As more and more Minnesotans opt to replace their AC units with more efficient heat pump alternatives, investing in load management programs that work with both types of equipment would be beneficial and more cost-effective.   This is especially important as utilities begin planning to phase out traditional central air conditioner rebates. 
  • Prioritizing fuel-switching efforts: Efficient fuel switching programs provide incentives for customers to replace existing equipment with equipment that uses a different fuel type, resulting in fewer greenhouse gas emissions. A common example is replacing a household's natural gas heating system or central AC unit, with an electric air-source heat pump. These upgrades can help customers transition to more efficient and cleaner technology, and may result in money saved over time. CUB recommends utilities provide robust offerings for efficient fuel switching measures that align with market trends and our state’s climate goals. 
  • Workforce development and contractor education: With all of the energy efficiency work needed now, and in the future, robust workforce development will be essential. CUB supports continued investment in these initiatives and encourages utilities to provide education on electrification measures in addition to more traditional energy efficiency deployment. 
  • Evaluating the effectiveness of behavioral programs: Utility home energy reports are also a program offering through ECO. These reports often come in the form of an email communication comparing your energy use to your neighbors, or you receive specific tips for how to improve your home energy use. While customer education and awareness of energy usage can be a motivating factor in reducing it, we recognize it can be difficult to capture the actual savings materialized from these communications. CUB requests that utilities actively evaluate the effectiveness of their behavioral programs to ensure they accurately measure the actual benefits accrued through those offerings, and that those benefits are commensurate with the cost of delivery the programs. In particular, we question the extent in which these communications result in behavioral changes and/or direct steps to make energy efficiency upgrades in the home. 

Conclusion and Next Steps 

CUB has spoken to thousands of consumers across the state and worked closely with Minnesotans trying to save money, save energy, and make their homes more efficient, healthy, and comfortable.  We regularly refer consumers to utility ECO program offerings and are grateful to have an opportunity to influence their development in order to best serve consumers across the state.  

Individuals and organizations can still submit a comment on any utility ECO triennial plan until August 31. To submit a public comment, you can send an email to consumer.puc@state.mn.us or complete the online form here. Be sure to reference the relevant docket number for the utility plan you wish to comment on. You can access each of the utilities’ proposed plans below. 

Following the current comment period, the Department of Commerce staff will publish a draft decision on September 29, for which there will be a final opportunity to submit public comments until October 14.  The final decision is expected to be issued by November 13.  We intend to provide updates on this process in the upcoming months. 

Utility Proposed ECO Triennial Plans: 

 

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