Climate Policy Heats Up
On June 16th, EPA released a Proposed Rule on the Clean Energy Incentive Program (CEIP) Design Details. The CEIP is designed to help states that want to participate (it is not required) and meet their carbon emissions reduction goals by providing additional credits for early action on renewable investment and low-income energy efficient and solar measures.The CEIP Proposed Rule provides an important opportunity to gain additional clarity and further improve this important aspect of the CPP, and HPC strongly supports this continued dialogue between EPA and interested stakeholders.
The concept of the CEIP was released with the original Clean Power Plan draft and the HPC joined many stakeholders in providing comments to EPA in December 2015 in an effort to assist them on the design of the program. HPC was glad to see EPA recognized the additional benefits of energy efficiency and the need to incentivize energy efficiency within the context of the Clean Power Plan (CPP) as well as our recommendation for a broad definition of "low-income community." While energy efficiency is the quickest, cleanest, and cheapest means of addressing America's CO2 emissions, the up-front costs associated with making these advanced investments leave most of the energy efficiency potential untapped. There are still changes to the draft CEIP design that HPC will be submitting to EPA. With 36% of America's electricity use in the residential sector, it is imperative that the reduction of residential energy consumption be a part of clean power plan compliance pathways.
HPC will be providing additional comments (due November 2) on the CEIP Proposed Rule. We will expand upon each of our original comments, some of which were addressed in the CEIP Proposed Rule and some of which warrant additional comment. For example, we continue to recommend that energy efficiency be provided an additional credit for early action on parity with renewable energy in the CEIP. A "negawatt' saved of carbon intensive resources is equal to the climate as a kilowatt of renewable energy earned. We will also provide comments on a few of the new aspects laid out in the CEIP Proposed Rule, including the addition of solar to in the low-income communities portion of the program. Energy efficiency can be expensive but is also needed in low income communities and we will request more than two additional credits to help provide incentives to those communities. In addition, HPC feels that homes should first be made energy efficient before adding solar generation - after all, using solar panels to power incandescent light bulbs and inefficient air conditioners blowing cooled air out leaking windows is not sound policy design. Solar and energy efficiency should be applied by looking at the whole-house and making smart energy decisions.
Watch the newsletter for a copy of HPC's CEIP comments as well as the HPC upcoming report on utilizing energy efficiency in existing residential buildings to meet Clean Power Plan targets.
Written by Kara Saul-Rinaldi
Vice President of Policy & Government Affairs
Home Performance Coalition
Follow on Twitter #WheresKaraSR
 Clean Energy Incentive Program Design Details, Proposed Rule. RIN 2060-AS84. 81 FR 42939. Herein referred to as "CEIP Proposed Rule."
 Comments submitted on behalf of the Home Performance Coalition and Efficiency First (December 15, 2015) available at: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2015-0734-0075
Annual Energy Outlook 2015 with Projects to 2040. U.S. Energy Information Administration. April 2015. Page A-18, Table A-8 notes 1,391 billion kilowatt hours (kwh) in residential electricity consumption out of 3,836 billion kwh in total electricity consumption in 2013 (the real date of the report).