Jay Griffin

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To Serve Everyone, IRA’s Climate Grants Need Inclusive Participation

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As expansive and even overwhelming as the Inflation Reduction Act (IRA) seems to be, it is important to remember that the IRA authorizes a number of different programs that will benefit states — programs, for example, that may come out of the Department of Energy to state energy offices, or from the Environmental Protection Agency (EPA) to state environmental agencies.

The EPA’s Climate Pollution Reduction Grants program (CPRG) is likely to be some of the first IRA funding that states will see. The CPRG will provide states with a significant springboard to reduce their carbon emissions. Before suggesting how states can make the most of this, let’s take a moment and outline the program.

What Is Clear: An Opportunity for States

The CPRG is a two-part program. Part 1 ($250 million) provides formula grants to every state. This will support states to develop a carbon reduction plan. Part 1 is on its way; the announcement and guidance will be coming out on March 1, and a Notice of Intent to Participate from states will be due March 31.

Part 2 ($4.6 billion) sets out a program of additional grants, funding for states to carry out elements of their plans and will probably roll out in early 2024. While Part 1 provides every state money for planning, Part 2 will require states to compete for funding to support the implementation of their carbon reduction programs.

For states that have yet to develop climate plans, this is an opportunity to use federal funding to explore ways to modernize your state’s economy. More specifically, this is a chance to look at the ways that your citizens, for example, manufacture products, grow crops, transport themselves, and heat and cool their homes — all sectors of your economy that produce significant carbon emissions.

In case a state doesn’t think that GHG planning is important, the CPRG provides for political subdivisions within a state, such as municipalities or local air agencies, to participate. Even where states have already developed climate action plans, these federal dollars could be very useful in updating and improving existing plans.

What Is Not Clear: Support for All Communities

While the CPRG will support states in developing carbon reduction plans, it is not clear the degree to which the program will support improving the outreach and public engagement necessary to ensure that a plan is equitable and that it will serve all communities.

This is a challenge for even successfully developed state plans. For example, in 2021, the Vermont Climate Council, spent over 10 months developing the Vermont Climate Action Plan. This was a significant undertaking by state agencies and citizens and the plan is an admirable start. However, the plan’s authors acknowledge in its preface that robust marginalized community representation was missing from the stakeholder participation:

This initial Climate Action Plan represents one of the first public processes in the State of Vermont to acknowledge and try purposefully to incorporate equity and the principles of a just transition in both its development and outcome — but we know we fell short. During our meetings and outreach, too few Vermonters had their voices lifted up to join the voices of those who have also participated in similar endeavors in the past. In our development of pathways, strategies, and actions, we faced challenges creating programs and policies organically in partnership with marginalized communities and individuals in Vermont and to envision new ways to ensure a just transition for all of us. As we continue forward, we have a strong desire to engage more Vermonters deeply and equitably in this transition, recognizing the historical and present harms and systemic injustices that are at work here in Vermont and elsewhere.

In developing its 2021 Climate Action Plan, Vermont saw first-hand that these working Vermonters did not have the time or capacity to participate and engage. This was not because they weren’t notified or encouraged to participate. People are busy earning a living. And their representatives are also challenged to participate because they work on many other pressing equity-related topics besides climate mitigation, including housing, transportation, policing, food, racism, and education. Frontline advocates generally recognize the importance of this work, but simply don’t have the bandwidth or the means to meaningfully participate.

Hearing from and consulting with marginalized communities isn’t just a matter of equitable inclusion — it’s essential to achieve the goals of climate policies, period. We need programs that are able to deliver GHG savings in all communities and to all income levels. Greater inclusion in planning will yield better, more comprehensive initiatives, in addition to more equitable program designs and benefits.

Will the EPA’s CPRG planning grants be helpful in this respect? It is not clear. The CPRG seeks to transition America to a clean energy economy that benefits all Americans, a goal that logically would incorporate the views of historically marginalized communities.

So, hopefully the EPA will recognize this need and enable states to provide direct support for community participation in CPRG-funded state planning efforts. The agency will have to make that determination.

If the EPA determines that the IRA does not allow for this, then hopefully the agency will still recognize the need and identify any other resources that it might have to help states to support this critical piece of carbon planning. The EPA may have available other funding for communities that are disproportionately impacted by air pollution and climate change. For example, there is air monitoring funding, along with environmental and climate justice block grant opportunities, that may support this work and can be stacked with CPRG funding. Finessing support for intermediaries like civic organizations or faith-based groups might also be helpful in incorporating the voices of frontline communities.

Apart from the question of the federal funding for state carbon planning, states agencies could still ask whether or not their public engagement is as thorough as it might be or whether it needs to be more welcoming to the public to be truly representative. RAP’s Public Access and Participation Plans: A Starter Kit for State Agencies is a document that outlines simple steps that state agencies can take to improve their outreach, and public participation.

Damali Rhett Harding Named Acting U.S. Program Director

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MONTPELIER, Vt. – The Regulatory Assistance Project (RAP) announces that Damali Rhett Harding has been named acting director of its U.S. program, effective March 17.

Harding, a highly regarded expert in renewable energy and electric utilities, joined RAP last year as the U.S. program’s managing principal. As acting director, she will succeed Mandy Mahoney, who is stepping down to pursue further opportunities in energy and environmental work.

”For 30 years, RAP has been the leader in creating data-driven policy and analysis in support of the clean energy transition for regulators, and I am honored to lead this transition,” Harding said.

She previously worked for Oracle as an account strategy and relationship director, advising utilities such as Duke Energy and National Grid on behavioral load shaping, customer engagement strategies, and demand response management.

Harding also served as executive director of the Energy Co-op, a Philadelphia-based nonprofit that provides renewable energy to thousands of homes and businesses in Pennsylvania. She currently holds seats on the board of directors for the Co-op and the American Association of Blacks in Energy.

“Damali’s organizational expertise and deep understanding of the energy transition landscape have been assets to the U.S. program,” RAP President and CEO Richard Sedano said. “I am pleased to have her step into this role and lead the team as we continue to provide innovative thought leadership and crucial support for regulators and policymakers.”

Harding holds an MBA from the Tuck School of Business, is a proud member of Delta Sigma Theta Sorority, Inc., and in her spare time works passionately to eradicate energy poverty.

NOx Standards for Water Heaters: Model Rule Technical Support Document

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RAP developed a model rule for use by U.S. state and local air quality regulators to reduce nitrogen oxide (NOx) emissions from water heaters. This technical support document was published to assist regulators and staff in understanding and making use of the model rule. It describes why water heaters are a significant source of air pollution, why NOx emissions standards are an excellent tool for reducing the environmental impact of water heaters and how those standards can promote electrification and market transformation. It also explains in detail the design and structure of the model rule.

Raphael Breit

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Model Rule: NOx Standards for Water Heaters

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Fossil-fueled water heaters represent a significant uncontrolled source of nitrogen oxide (NOx) emissions, which have a variety of harmful environmental effects. RAP developed a model rule for use by U.S. state and local air quality regulators to reduce NOx emissions from water heaters over time. A related technical support document explains the background and context of this work and describes in detail how the model rule was designed.

Public Access and Participation Plans: A Starter Kit for State Agencies

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State government agencies are becoming aware that there is more that they can do to reach communities that may be underserved by agency programs — communities of color, indigenous communities, and low-and moderate-income communities. This policy brief describes steps that agencies can take to engage these communities more meaningfully as partners and stakeholders in government decision-making.

This “starter kit” looks at the typical aspects of government agency contact with the public and provides suggestions for how agencies can take simple steps to improve their engagement. Specifically, it discusses ways to improve public meetings, how to make agency websites more accessible, elements of staff training, and the importance of ongoing improvement. Two appendices look at mission statements and equity statements. In each section, a summary and notes on the topic are followed by model language an agency’s public access and participation plan might include, along with useful resources.

Tapping the Mother Lode: Employing Price-Responsive Demand to Reduce the Investment Challenge

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The rapid and parallel growth in both variable electricity production from wind and solar, and in large inherently flexible loads (such as electric vehicles and heat pumps) presents an opportunity to ensure that each transition is both reliable and affordable. In a future that will be increasingly capital-intensive, demand flexibility can significantly reduce the amount of infrastructure that must be financed. But much remains to be done to access that potential, most of which is beyond the reach of traditional approaches to demand response.

The primary focus must shift from strategies that require flexible demand to mimic centrally dispatched generation, to strategies that empower consumers to save money by linking their consumption more dynamically to daily fluctuations in variable supply. At a retail level, this includes adopting a series of innovations that widen consumers’ access to the untapped potential for flexible loads to reduce costs and lower electricity bills. At the wholesale level, it means attacking institutional practices that discriminate against flexible demand reliant on energy market pricing, and that artificially depress energy prices by pre-emptively committing consumers to pay for uneconomic investments through forward capacity mechanisms. Overall, it means progressively assessing and integrating responsive demand into forward resource planning and procurement processes.

This paper is one of a series of eight produced by ESIG’s Aligning Retail Pricing with Grid Needs Task Force, led by RAP’s Carl Linvill. The task force examined ways that retail pricing may be used more widely and more efficiently to allow flexible demand to respond to grid needs.

Power Outage Rapid Response Toolkit

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Interruptions in electricity supply – ‘the lights going out’ – make for arresting headlines and capture public attention. Yet it is strikingly rare for any kind of electricity generation shortfall to trigger blackouts: major reliability events are nearly always the result of grid failure incidents such as wires frying or being damaged by trees.

Furthermore, none of the recent events that have occurred in markets with high shares of renewables have been caused by over-reliance on renewables to provide sufficient electricity supplies. In spite of this, the fossil energy industry has a track record of seizing on any opportunity to promote the narrative that more fossil generation is needed and that the growing shift to renewables is undermining and driving up the cost of secure supplies.

To dispel many of the myths surrounding the causes of recent significant power outages, the toolkit looks at four case studies: Texas 2021, California 2020, Great Britain 2019 and South Australia 2016.

These case studies prove it is important that advocates for a clean energy transition can set the record straight quickly, credibly and substantively. This package equips advocates with information and tools to respond quickly to the misinformation that spreads rapidly in the wake of power grid reliability events, and in particular:

  • introduces the advocate to reliability events, and their causes and consequences; 
  • provides a checklist for advocates to understand and analyse emerging reliability events (a separate, interactive checklist can be downloaded here: Power Grid Rapid Response Checklist);
  • provides holding lines for advocates during the information vacuum that normally proceeds a reliability event;
  • explains why large-scale reliability events are almost always caused by network failures and not renewable electricity generation.