— Brad Penney, NASCSP General Counsel —

The National Association for State Community Services Programs (NASCSP) applauds the June 2 release of standards proposed by the Environmental Protection Agency to reduce carbon emissions under Section 111(d) of the Clean Air Act. Yesterday’s EPA action demonstrates that the United States is prepared to take strong steps to fight global climate change. NASCSP recognizes that the key to implementation of the EPA standard is flexibility in state compliance planning and the deployment of available clean energy efficiency and conservation measures as compliance options. This flexibility provides the opportunity for low-income Americans to benefit from the proposed EPA rule. No sector of our country faces a greater energy burden than low income citizens, who pay anywhere from 15% to 40% or more of their income to heat and cool their homes (middle income Americans pay only about 3% – 4% of their income for home energy costs.)

One of the proven and effective measures for deploying energy efficiency in low-income households is the Department of Energy’s low income Weatherization Assistance Program (WAP). WAP has provided lasting energy efficiency savings for more than 7.4 million low income households, however estimates are that as many as 30 million additional homes qualify for and need Weatherization. NASCSP urges all state governments to consider the deployment of weatherization assistance as a compliance option in the development of implementation plans under the proposed 111(d) rule announced yesterday by EPA. We also urge the Congress to allocate additional resources to the WAP in order to fund deployment of Weatherization under the state implementation plans, and we further urge private utilities to devote greater resources to WAP partnerships in order to maximize the impact of energy efficiency in low income households. As the United States is transforming the means of developing and delivering energy, taking us away from dependence on fossil fuels and foreign sources of energy, we must consider the disproportionate burden of rising energy costs of low-income citizens. The proposed rule has the potential to bring clean energy and energy efficiency to hundreds of thousands of low-income households if state implementation plans include weatherization assistance in the mix of options for reducing carbon emissions. Low income Americans will also benefit from the new investment and job creation that will result from greater deployment of energy efficiency through programs like WAP. The United States can lower emissions and create new jobs at the same time under the initiative announced by EPA. We urge the states to consider WAP as a primary option for carbon reduction savings using energy efficiency in the implementation of yesterday’s proposed EPA rule.