Today, the Alliance filed comments with the U.S. Environmental Protection Agency (EPA) recommending that CHP projects in low-income communities be eligible for participation in the Clean Energy Incentive Program (CEIP). The CEIP is an “early action program” that will award certain wind and solar investments, along with certain energy efficiency projects in low-income communities that take place in 2020 and 2021 (before the official start of the Clean Power Plan).
In the proposed rule, EPA limits the definition of eligible renewable energy (RE) projects to zero-emitting technologies with short lead times. As written, these criteria only apply to RE projects and we are concerned that this limitation on eligible RE projects could be misconstrued to extend to low-income energy-efficiency projects as well. We recommend that EPA clarify that the definition of energy-efficiency is not limited to zero-emitting technologies, allowing both CHP and WHP projects in low-income communities to be eligible for participation in the CEIP. We also recommend that EPA provide an example of CHP that serves a public purpose and benefits low-income communities for states to consider as they are developing their CEIP plans.
You can read our full comments here.