The EPA Clean Power Plan’s Opportunity and Challenge

Rule favors more low-income community investment: When EPA’s August rule was issued, low-income advocates including the National Community Action Foundation, the National Consumer Law Center, Consumers’ Union and the Environmental Justice Forum learned they had won much of the policy they had requested in their public comments on the program: a federal commitment to low-income community efficiency programs, low-income representation in the state planning process and environmental justice tests for the plans.

EPA will keep a reserve of carbon emission allowances to match the savings from qualifying efficiency programs in or for low-income communities. Solar and wind projects will also receive a match, but a lower one. This is the CEIP, Clean Energy Incentive Program.

Federal Policies -The Devilish Problem of Details Remains: EPA’s decision-making process remains open following the announcement of these general commitments. In October, EPA issued a series of technical questions about how to set up sound CEIP criteria and implementation processes; it asked for public and group input through four open conference calls and in comments to be submitted by December 15. This is a non-regulatory process and, therefore, input and dialogue, while all recorded and eventually published, can continue in small as well as larger group discussions. Our understanding is all the calls raised as many or more questions to EPA as they included recommendations.

Your thoughts? Questions for EPA? Many State WAP associations and some agencies have expressed interest in shaping EPA policy about what makes a sound and legitimately beneficial CEIP. We energy folks at EOS wrestling with learning Clean Air regulatory policy in order to support National Community Action Foundation and its advocacy partners’ comments on EPA’s policy requirements for state plans that seek the CEIP incentives/rewards; another essential question concerns states that refuse to submit a Clean Power Plan at all. They will be governed by a plan EPA makes and carries out FOR them. What should the federal framework for a sound, EPA-run CEIP look like?

If there is sufficient interest shown by reader’s responses to this inquiry, EOS will try to  setup a call among WAP agencies and other local or state organizations next week to discuss answers to the EPA request for input about the CEIP; And then we will invite EPA experts to another call to answer the concerns and questions gleaned from the first call so that the network’s responses to EPA can be clear and, perhaps, united. Write us if interested to info@opportunitystudies.org with a list of your issues and the days you cannot join a call.

Future steps: EOS will be creating materials to help Weatherizers participate in all phases of your state plan development through 2016 and perhaps later.

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