Center comments on the Clean Energy Incentive Program

Environment

By Lauren Kolojejchick-Kotch, former staff member

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 well-being 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 below.

Clean Energy Incentive Program Comments

December 15, 2015

U.S. Environmental Protection Agency
EPA Docket Center, Mail Code: 28221T
1200 Pennsylvania Ave., NW
Washington, DC

Comments of the Center for Rural Affairs to the U.S. Environmental Protection Agency (EPA) to provide feedback on the design and implementation of the Clean Energy Incentive Program (CEIP) under the Clean Power Plan (CPP), Docket No. EPA-HQ-OAR-2015-0734

To whom it may concern,

The Center for Rural Affairs offers comments on the Clean Energy Incentive Program (CEIP) under the Clean Power Plan (CPP), [Docket No. EPA-HQ-OAR-2015-0734]. The Center for Rural Affairs is a private nonprofit, established in 1973 and based in Lyons, Nebraska. The Center works to promote social and economic justice, environmental stewardship, and strengthen rural communities. A significant part of this work is engaging with people about the decisions that affect the future of their communities and the quality of their lives. For communities that rely heavily on natural resources, climate change poses a significant threat to their economic future and community well-being. These communities also stand to benefit from significant investment in energy efficiency and renewable energy.

1. General comments on the Clean Energy Incentive Program

The Center for Rural Affairs applauds the effort undertaken in the Clean Energy Incentive Program to reinforce the critical role of renewable energy in the Clean Power Plan and in our communities, while attempting to address historic and persistent inequality by prioritizing low-income energy efficiency investments. The CEIP incentivizes early investments and putting the wellbeing of people and communities first. This is an important component of a landmark regulation.

The CEIP would reward states like Nebraska for developing largely untapped clean energy potential. Nebraska has 918 GW of annual wind energy generating potential (118 times current demand), earning the ranking of 4th largest potential for wind development in the county, according to the National Renewable Energy Laboratory. ACEEE regularly ranks Nebraska in the lowest third nationally for energy efficiency policy, while at the same time ranking 7th for per capita energy consumption.

2. Definition of "low-income community" for eligible energy-efficiency projects should consider rural low-income communities.

According to a Natural Resources Defense Council report, the average U.S. household spends 2.9 percent of its income on electricity bills, while low-income households spend 8.3 percent. The discrepancy is even greater in rural areas, where a higher percentage of families live below the poverty line (17.7%), and energy costs end up comprising a larger portion of a households’ expenses -- in the Midwest, the working poor consume up to 26% more energy per year. 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. Many 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, and they should be considered in the low income definition for CEIP energy efficiency projects.

3. Comments on criteria used to define eligible renewable energy and energy efficiency projects:

In rural communities, all sectors (residential, commercial, etc.) could benefit from participating in the CEIP, particularly in regard to energy efficiency implementation. Rural electric cooperatives serve 93%, or 327 of the nation’s 353 persistent poverty counties, according to the National Rural Electric Cooperative Association. 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.

The intersection of poverty with race, geography, and community size, to name a few, should be considered. Disadvantaged communities have many different faces, and these distinctions deserve special attention. The Center for Rural Affairs encourages the EPA to consider the impact that poverty has on entire communities, and therefore, define eligibility geographically, and not simply by sector. 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.

4. “Commencement” of eligible projects for the CEIP, Allowance Allocation:

The EPA should consider shifting the CEIP window in order 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. There is a high cost to these delays 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.

It is important to consult those who will be installing, financing, and maintaining renewable energy systems. These decision impact a wide range of individuals, business and intuitions.

5. Additional Comments:

We would support an extension on the CEIP 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. If allotted the additional time, we can provide more thoughtful comments on this important component of the Clean Power Plan.

Thank you for the opportunity to comment on the proposed role and for taking the time to consider our comments and considerations. If you have any questions or require further information please contact us.

Respectfully submitted,

Lauren Kolojejchick-Kotch
Policy Program Associate
Center for Rural Affairs