Listening sessions held by the Department of Environmental Protection around the state are gathering comments on EPA’s Clean Power Climate Plan to help Pennsylvania develop a plan for meeting those requirements. 

Lisa Robinson, Executive Director of the nonprofit Energy Coordinating Agency in Philadelphia presented these comments at the September 30 session--

Thank you for the opportunity to testify today on Pennsylvania’s compliance with EPA’s Clean Power Plan.  I am Liz Robinson, Executive Director of the Energy Coordinating Agency.

ECA is a nonprofit organization dedicated to helping people save energy and working with others toward a sustainable, equitable energy future.  ECA coordinates and administers energy efficiency, education, heating, home repair and bill payment assistance programs for Pennsylvanians, particularly for low income households.

ECA also trains men and women from very diverse backgrounds to the national standards and certifications required for jobs and careers in energy efficiency and environmental remediation.

ECA enthusiastically supports the Clean Power Plan and believes that Pennsylvania can achieve its goal of reducing carbon emissions to the levels required under the Clean Power Plan by 2030.

Pennsylvania already has considerable experience and success  in a range of clean energy resource development, including: energy efficiency, solar, wind, hydro and biomass, as well as natural gas cogeneration.

By designing our Clean Power Plan carefully, Pennsylvania can maintain very affordable energy costs and high reliability for all customer classes, create tens of thousands of new local jobs, develop our indigenous clean energy resources to a much larger scale, and really accelerate the transition to a cleaner energy economy.

The key will be careful planning to lay the proper infrastructure in place to enable us to achieve optimal results.  We will need to take full advantage of the infrastructure, institutional experience and capacity that we have in place in Pennsylvania and build on these to achieve the scale required.

Energy Efficiency

Energy efficiency needs to play a central role in our compliance with the Clean Power Plan for a number of reasons:

1. EE is the least expensive form of energy.  Its deployment at scale will enable the state to maintain affordable costs for all customers, not just for the end users who reduce their consumption.  By reducing upward pressure on rates, EE reduces cost for all ratepayers.

2. EE creates more jobs per kwh than any other form of energy.  Essentially all of these jobs are local, unlike those in many extractive industries, and thus this means employment for citizens all across the Commonwealth.

3. EE is the cleanest resource, and thus will help us reach our goals as quickly as possible.

4. EE improves reliability by reducing load, both peak load, and total load on the distribution system.  This in turn improves the life expectancy of the distribution system.

5. EE can also be “harvested” all across the state, improving buildings in cities and towns, lowering costs for schools, municipalities, businesses and industry.  It is THE most democratically distributed resource in the state.

Clean Energy Incentive Program

The CEIP offers significant potential benefit for Pennsylvania by giving double credit for early action on energy savings from low income communities.

Given Pennsylvania’s existing Low Income Usage Reduction Program (LIURP) and the Weatherization Assistance Program, we have strong statewide capability to ehlp meet the goals of the CPP.

There is apparently considerable concern in some quarters that the CPP could cause rates to rise significantly.  The best way to insure that low income communities are not negatively affected by the CPP is to expand their participation in energy efficiency programs and activities.

One of the most cost effective opportunities is to improve the coordination of the Weatherization Assistance Program and LIURP. 

The Weatherization Assistance Program (WAP)  could carry into low income homes that it is already weatherizing, many more electricity conservation devices such as LEDs, high efficiency refrigerators, etc., thus providing deeper savings to the customer in an extremely cost effective manner.

The same is true for better coordination between electric and gas LIURP programs.  These programs go into the same homes to deliver different measures.  Coordinating them would eliminate the duplication of transaction costs: such as scheduling, auditing, and inspection, and reduce trips to the house and inconvenience to the customers, all while providing better service and deeper savings.

Pennsylvania’s Weatherization Assistance Program (WAP) now has the most highly trained and qualified energy auditors anywhere.  These auditors and inspectors now meet the new national Home Energy Professional (HEP) standard.  They are the most highly trained building science professionals period.

Let’s take advantage of this human resource and bring even more value into our communities.

The EPA has left quite a bit of latitude to states to define “low income” and “low income communities.”  Not only does this mean that Pennsylvania could offer a definition which includes both single homes and multi-family buildings, and both owner and tenant occupied buildings, but one that is more inclusive than the current LIURP eligibility standard of 150 percent of poverty.

It may be that EPA would be open to efforts to improve energy efficiency in entire low income communities, and include small businesses such as corner stores, nonprofits and others in an Energy Empowerment Zone.

Pennsylvania should explore this issue with EPA early on to understand how broadly we could define eligibility for the CEIP.  This could be a powerful new economic development tool in depressed towns and cities across the state which are struggling with high unemployment, high poverty and a host of other ills.

Carbon Trading, Coordinating With Other States

Given the early analysis performed by PJM, there seem to be very significant advantages to Pennsylvania of working with other states in reducing carbon emissions; particularly since Pennsylvania is such a larger exporter of power.  A coordinated approach through trading with neighboring states seems most appropriate.

Carbon trading offers tremendous advantages if organized well. Pennsylvania should definitely adopt a trade-ready program.

Growing Our Clean Energy Industry

We commend Gov. Wolf’s intent to submit Pennsylvania’s plan on time.  Committing to meet or exceed the Clean Power Plan’s goals and submitting in a timely manner will help signal to the business community that Pennsylvania is serious about growing its clean energy industry.

During the 2008-2012 period, we made significant strides in building our renewable and EE industries.  After ARRA [the 2009 federal economic stimulus program], however, it was as if the wheels fell off and we seem to have lost much of the ground previously gained.

It is critical that this time we do things differently and take the time to plan how to advance our clean energy manufacturing sector, to engage many of our universities as engines of research, development and innovation, and how to build a world-class energy workforce capable of making Pennsylvania a leader in the fastest growing sector of the energy economy.

The opportunities are very real, and we need a comprehensive plan to take advantage of them.

Thank you again for the opportunity to comment on the Clean Power Plan.  Energy efficiency and renewable generation are key to a compliance path for Pennsylvania which will create maximum benefit for the environment as well as for all Pennsylvanians.

A complete copy of Robinson’s comments is available online.

For more information and a schedule of the remaining sessions, visit DEP’s Climate Change webpage.  Comments on the Clean Power Plan can be submitted online.  Click Here to see comments submitted by others so far.

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