The Missouri Energy Efficiency Investment Act (MEEIA) cycle 4 regulatory processes for the two largest electric investor-owned utilities (IOUs) in the state have finally reached their conclusions. These dockets have played out slowly over the past two years. Ameren Missouri originally submitted their intent to file MEEIA Cycle 4 programs with the Missouri Public Service Commission (PSC) in October 2022, with Evergy filing in April 2023. After the proceedings, the approved programs for both utilities went into effect on January 1, 2025.

Although this is the fourth full set of programs the electric IOUs have applied for since the passage of MEEIA in 2009 - not including MEEIA cycle 3 extensions – the final MEEIA 4 programs pale in comparison to previous plans. After extensive testimony and negotiations between intervening parties in the dockets, the resulting settlement agreements outline a much smaller scope of programs than originally proposed.  

The timelines of both dockets are outlined below. 

Ameren Missouri – docket EO-2023-0136 

• October 17, 2022: Ameren submits their intent to file MEEIA Cycle 4 programs with the Missouri PSC.
• March 27, 2023: Ameren files their application for demand-side programs under MEEIA, outlining a $366.75 million budget over the program years 2024-2026.
• April 6, 2023: PSC Staff + Office of the Public Counsel (OPC) reject Ameren’s proposed procedural schedule and schedule a prehearing conference, setting off negotiations.
• May 2, 2023 - August 17, 2023: Parties begin to discuss extending the previous MEEIA 3 plan into 2024 and outline a workshop process to collect relevant data and testimony.
  • August 3, 2023: In docket EO-2018-0211, Ameren’s MEEIA cycle 3 docket, some parties – Ameren, PSC Staff and OPC - filed a Non-Unanimous Stipulation and Settlement to extend Ameren Missouri's current MEEIA 3 Plan for year 2024.
  • August 23, 2023: The Commission approved the Stipulation and Settlement which went into effect on September 2, 2023.
• January 25, 2024: Ameren submits an amended application for demand-side programs under MEEIA and direct testimony from Ameren representatives.
• March 1, 2024: Parties from intervenors, PSC Staff and OPC submit direct testimony.
• April 26, 2024: Parties from intervenors, Ameren, OPC, and PSC Staff submit rebuttal testimony.
• May 30, 2024: All Parties file surrebuttal testimony.
• July 10, 2024: PSC Staff submit the List of Issues, List and Order of Witnesses, Order of Opening Statements and Order of Cross-Examination on behalf of all Parties, after several extensions in filing deadlines.
• July 17, 2024 – July 18, 2024: Parties submit their Statements of Position on the list of issues.
• July 22, 2024 – July 25, 2024: Evidentiary Hearings are held.
• August 9, 2024 – September 16, 2024: Parties file a series of requests for extension of the procedural schedule as they discuss the case, attempting to reach a settlement agreement, which are subsequently granted by the Commission.
• October 11, 2024: Ameren, OPC, and intervenors submit a Joint Motion to Suspend Procedural Schedule, notifying that they have reached an agreement on the terms of a settlement, noting that PSC Staff do not agree but do not object.
• October 30, 2024: Ameren and other Parties file a Non-Unanimous Stipulation and Agreement, outlining a total budget of $125.03 million and a more limited set of programs.
• November 6, 2024: PSC Staff respond to the Stipulation, outlining their concerns but choosing not to object.
• November 14, 2024: The Commission approves Ameren Missouri’s amended MEEIA Cycle 4 plan as laid out in the Non-Unanimous Stipulation and Agreement.
• December 11, 2024: The Commission approves of program details – including the Technical Resource Manual (TRM) and Deemed Savings Table (DST), Program Templates and Incentive Ranges – but only for those measures previously approved by the Commission, as requested by PSC Staff.
• January 15, 2025: Upon receiving no objections from other Parties regarding Ameren’s request, the Commission approves the inclusion of the additional measures from Ameren’s Motion in Ameren Missouri’s MEEIA 4 Plan.
• January 15, 2025: Parties submit their first Joint Status Report on the Statewide MEEIA Feasibility Study as agreed upon in the approved Stipulation and Agreement.
• January 30, 2025: Ameren requests the approval of their updated TRM and DST.

Note: This docket has not yet been closed, and we anticipate there may be additional responses. 

Evergy Missouri – dockets EO-2023-0369 (Metro) and EO-2023-0370 (West) 

Note: Evergy proceeds through separate but concurrent dockets for each of their regions – Metro and West. In this blog we will link to the Metro docket (EO-2023-0369) but there are parallel filings in the West docket (EO-2023-0370).

• April 24, 2023: Evergy submits their intent to file MEEIA Cycle 4 programs with the Missouri PSC.
• January 16, 2024: Evergy submits a Status Report that the Parties to the docket are discussing procedural options and expect to file the proposed procedural schedule soon.
• March 21, 2024: The Commission sets the Procedural Schedule
• April 29, 2024: Evergy files their application for demand-side programs under MEEIA, outlining a $213.24 million budget over the program years 2025-2028, along with direct testimony from Evergy representatives.
• May 24, 2024: Parties from PSC Staff and OPC submit direct testimony.
• July 9, 2024: Parties from intervenors, Evergy, OPC, and PSC Staff submit rebuttal testimony.
• August 20, 2024: All parties submit surrebuttal testimony.
• August 23, 2024: PSC Staff submit the List of Issues, List of Witnesses, Order of Opening Statements and Order of Cross-Examination on behalf of all Parties.
• August 27, 2024: Parties submit their Statements of Position on the list of issues.
• August 30, 2024: Parties submit a Joint Motion to Suspend Procedural Schedule as they attempt to reach a settlement agreement, which is subsequently granted by the Commission, cancelling the evidentiary hearing.
• September 27, 2024: Evergy and other Parties file a Non-Unanimous Stipulation and Agreement, outlining a total budget of $69.5 million and a more limited set of programs. Although PSC Staff were not signatories to the agreement, they did not object to the filing in their response.  
• December 11, 2024: The Commission approves Evergy Missouri’s amended MEEIA Cycle 4 plan as laid out in the Non-Unanimous Stipulation and Agreement and related compliance tariff sheets.
• March 6, 2025: Evergy submits a revision to their associated tariffs, which now await Staff response.

Note: This docket was reopened after previously being closed, and we anticipate there will be additional responses, as directed. 

There were some arguments put forth during the proceedings in the testimony that were not correct. Notably, EE opponents continued to raise the ‘principal-agent problem’ as a reason to curtail EE plans. Opponents stated that contractors are poorly installing or unnecessarily upselling HVAC systems. If that is a problem, the solution should be better regulation and enforcement of high-quality contractor offerings under EE programs to ensure proper work is done and savings are actually achieved. If a building in Missouri could benefit from energy efficiency upgrades – which, as noted in testimony, is highly likely due to the lack of a statewide building code and limited enforcement of local building codes – then the Commission should enable those upgrades to occur by incentivizing EE programs. Giving consumers access to increase the efficiency of their homes and commercial buildings provides an opportunity to reduce their energy bills and improve the livability of these spaces, granting deeper consumer choice and control. Eliminating EE programs does not solve the problem that there may be unscrupulous contractors implementing energy efficiency upgrades in the state. Instead, this may reduce the number of skilled contractors who would be incentivized to do high quality work under stricter requirements of utility administrated EE programs. There are much clearer solutions to this issue, such as requiring accurate equipment sizing using technology like blower door tests or Fault Detection and Diagnostics tools.

Some parties also challenged the perceived duplicative funding for programs enabled through federal legislation like the Inflation Reduction Act (IRA) and Bipartisan Infrastructure Law (BIL). Assuming they are able to continue, IRA programs – such as the Home Energy Rebates – provide limited and temporary funding that will quickly be expensed and only apply to certain measures. To eliminate utility energy efficiency programs rather than allow Missouri consumers to stack incentives and make the most of these historic, one-time investments, would be extremely short sighted. There are multiple solutions to the challenge of attributing savings to co-delivered incentive programs. Northeast Energy Efficiency Partnerships outlined these different attribution models in their report, Expanding the Energy Savings Pie, and many Midwestern states have already established attribution methods that make sense in their respective state environments. We encourage the Commission, Staff and other parties to review the strategies presented in this research and come up with a model that makes sense for Missouri.

Although we are disappointed to see energy efficiency programs being scaled back in Missouri, we are heartened that the Commission ultimately saw value in continuing some EE and demand response (DR) programs in the state, especially at a time when demand for reliable energy is rapidly increasing. As the state continues to see the impacts on the grid of increased electrification measures, generative AI and machine learning, and data centers it would be wise to encourage more efficient energy usage to minimize capacity strain. While neighboring Kansas implements its first set of energy efficiency utility programs, Missouri is disinvesting in the lowest cost resource of the energy system. 

However, the future of EE programs in the state is undetermined and we will soon learn more. In part two of this blog, we will dig into the “Statewide MEEIA Feasibility Study” established in the settlement agreements with the major electric IOUs. We will also review the EE program administrator models across the Midwest as Missouri considers a change to how their programs are run.