We applaud the effort in the Clean Energy Incentive Program to reinforce the critical role of renewable energy in the Clean Power Plan and in our communities, especially by prioritizing low-income energy efficiency investments. The program incentivizes early investments and puts the wellbeing of people and communities first. This is an important component of a landmark regulation.
States like Nebraska would be rewarded for developing largely untapped clean energy potential. Nebraska has the 4th largest potential for wind development in the county. But we rank in the lowest third of the nation for energy efficiency policy, while ranking 7th for per capita energy consumption.
The average U.S. household spends 2.9% of its income on electricity bills, while low-income households spend 8.3%. The discrepancy is even greater in rural areas, where a higher percentage of families live below the poverty line (17.7%). It is essential that low-income and rural Americans are consulted as key constituents and consultants in the planning process.
Low-income rural communities are among the most vulnerable to climate impacts, as well as changes in electricity costs. Many houses in rural America are in poor condition, and are in great need of weatherization and improvement. Communities of faith in rural areas have seen a rise in those who need help with their electricity bills.
Rural low-income people are among the groups that will bear the largest burden of electricity rate changes. They should be considered in the low income definition for CEIP energy efficiency projects.
In rural communities, all sectors (residential, commercial, etc.) could benefit from participating in the Clean Energy Incentive Program, particularly for energy efficiency implementation. Rural electric cooperatives serve 93%, or 327 of the nation’s 353 persistent poverty counties. Of the 42 million Americans served by cooperatives, an estimated 4 million live in persistent poverty counties. One of these counties in Nebraska is Thurston County, which is primarily the Omaha Indian Reservation.
Rural energy providers and all sectors of electricity consumers should to be eligible to participate in the CEIP and earn renewable energy and energy efficiency allowances, based on services they provide and the populations they serve.
It is important that distribution of allowances provides incentive for both energy efficiency and renewable energy investments, and that distribution is done justly, according to need. That need exists in both rural and urban communities.
The EPA should consider shifting the program’s window to incentivize early and continuous investment in energy efficiency and renewable energy. Utilities are already putting planned projects on hold so that they can qualify for incentives under the CEIP.
These delays come at a high cost, and they should be avoided. Allowances should be awarded when reductions are demonstrable. It is important to ensure that we have an accurate account of reductions achieved.
Finally, we support an extension on the comment period by 30-60 days. We value the opportunity to engage and would like to have time to talk with everyday rural Americans and share their thoughts.
Our full comments on the Clean energy Incentive Program are attached below as a pdf.