EEAC council members, consultants, and advocates flagged underservice of LMI and renter populations repeatedly from 2015 onward. The State Auditor's 2025 findings were the predictable result of structural choices visible in the program's own budget documents.
Mass Save budget by sector across plan cycles
The paper trail: what EEAC saw and when
June 2015 — National Grid MTM
LI Hard-to-Measure cut 37%; Residential Products boosted 29%
Budget shifted from LMI to general residential. LI program had "no savings associated with them." EEAC approved the modification.
April 2018 — EEAC Meeting
Councilor Wambui: PAs are not making moderate-income a priority
"Studies downplayed the significant needs." Suggested tying performance incentives to moderate-income. PAs couldn't produce participation data when asked.
2021 — Customer Profile Study
Renter-occupied housing: strongest negative participation correlation (-0.42)
2013-2019 data proved what advocates had said for years. Owner-occupied, single-family, higher-income had the strongest positive correlation.
April 2024 — C-Team 2025-27 Review
"Plans are just that — plans"
C-Team noted moderate-income plans weren't followed in 2022-2024. Only 21% of incentives reach renters. Income Eligible ADM budget: $0.
Sept 2025 — State Auditor
EJ communities pay 151% more; benefits decrease as renter % rises
"Undermines its mission by widening inequality." The structural failure documented in primary sources since 2015 became public.
The structural pattern
Massachusetts had the data, the advocacy, and the oversight infrastructure to prevent the equity gap — and it still happened. The EEAC process shows that even when councilors raise alarms (Wambui 2018, Chretien 2018), when studies prove the disparity (Customer Profile Study 2021), and when consultants warn "plans are just plans" (C-Team 2024), the program structure can still systematically underserve LMI households. The gap widened over a decade of documented concern — suggesting that awareness alone does not produce equity outcomes without binding accountability mechanisms.
Sources: 2015 MTM — National Grid Electric Mid-Term Modification Request, June 25, 2015, filed in D.P.U. 15-152 (EEAC document). 2018 EEAC — Meeting Minutes, Apr 25, 2018, ma-eeac.org (Wambui, Chretien, Boyd testimony). Customer Profile Study — 2013-2019 Massachusetts Residential Customer Profile Study (2021), p. 82 (correlation coefficients). 2024 C-Team — "2025-2027 Draft Plan — Consultant Team Initial Review," Apr 24, 2024, slides 12-14 (renter data, $417M gap, "plans are just plans"). 2025-2027 Plan budgets — slides 8, 17, 25, 34, 47 (sector budgets, LI overview, ADM). State Auditor — DiZoglio, "Who Pays and Who Gains?" Sept 29, 2025, mass.gov/audit.