EPA ACE Rule Is Far From Affordable for Low-Income Families

The Environmental Protection Agency has proposed repealing the Clean Power Plan, the nation's first limits on the nearly two billion tons of climate-changing carbon pollution coming from power plants each year, and replacing it with a thinly-veiled bailout for the coal industry that would actually be worse than doing nothing. If finalized, this proposed rule (the affordable clean energy rule or ACE rule) would increase dangerous air pollution from coal-fired power plants, harming public health and stymieing efforts at the state and local levels to move toward clean energy and combat climate change. Worst of all, low-income families will bear the biggest burden of this rule.

Last week, I joined a deep bench of colleagues and partners on October 1 in Chicago to testify against this proposal, at the only public hearing EPA scheduled in the entire country. Scores of scientists, consumer and environmental advocates, public health experts, elected officials (including US Senator Tammy Duckworth, and Washington Governor Jay Inslee in person!), and concerned citizens, including a girl scout troop, demanded that US EPA do better and strengthen our climate and health protections—not weaken them.

My testimony:
 

My name is Laura Goldberg, and I work at the Natural Resources Defense Council, based here in Chicago. I am NRDC’s Midwest Regional Director of a project called Energy Efficiency for All, which is focused on increasing energy efficiency in affordable multifamily housing. I work every day with coalitions of local Midwest partners to ensure that tenants and owners of multifamily housing can have equitable access to safe, healthy, efficient, and affordable homes.

I am deeply concerned that the proposed affordable clean energy rule will be far from affordable, especially for those living in low-income communities. The proposed rule will increase costs for vulnerable families who will be required to pay for upgrades to aging power plants rather than cost-reducing, energy efficiency options in their homes. I strongly advise the EPA to reject and withdraw the proposed Affordable Clean Energy Rule, as it will have harmful climate, health, and economic effects locally here in the Midwest, but also nationally and globally. 

States should be encouraged to continue investing in the environmental and economic benefits of a clean energy future—and to minimize potential bill impacts for vulnerable communities—by prioritizing energy efficiency and renewable energy. More clean energy in the Midwest’s low-income single family and multifamily housing would allow low-income families to direct a greater share of their budget toward other needs, such as food, healthcare, and additional essentials.

Energy efficiency measures are far less likely to be installed in multifamily rentals than in any other type of housing. Also, low-income households (both single and multifamily) have an energy burden that is three times higher than that of non-low-income households. Which is why we need a rule that prioritizes energy efficiency investments in low-income communities. 

I am worried that this new proposed rule will adversely harm, rather than help, low-income and minority communities by extending the length of time that fossil-fuel powered electric generating units could emit pollution. EPA’s own estimates state that up to 1,400 premature deaths would occur in 2030 if the proposed ACE Rule is put into place. This is in stark contrast to the 2,700 to 6,600 premature deaths and 140,000 to 150,000 asthma attacks in children the Clean Power Plan was projected to prevent. Furthermore, contrary to the EPA’s analysis, there is a wealth of evidence that air pollution disproportionately affects low-income communities, people of color, and other vulnerable populations. 

Any proposed action by EPA should proactively ensure clear and equitable benefits to low-income, minority, and indigenous communities. In the CPP, the Clean Energy Incentive Program (CEIP) was created to do just that. The CEIP would’ve helped to ensure that the benefits of a federal clean energy rule could be “shared broadly across society and that potential adverse impacts on low-income ratepayers are avoided.” 

The CPP also presented an opportunity to make smart decisions about our nation’s energy future, to benefit consumers, our public health, the environment, and workers. The Midwest is currently home to over 700,000 clean energy jobs, over 500,000 of which are in energy efficiency. This new proposed rule will hamper the growth of this clean, sustainable, rapidly growing local jobs sector. A sector that is ripe to help employ those living in vulnerable communties so they can reap both the health and economic benefits of a clean energy future.

In conclusion, any future action must have the country’s most vulnerable communities, including single-family and multifamily households, in mind and should ensure that energy burden and environmental injustices are reduced rather than exacerbated. This rule reduces our opportunity to receive the benefits of clean energy and exposes Americans to at least $5-10 billion in climate harms. A smart investment in energy efficiency creates local jobs, eliminates the need for expensive new power plants, and reduces pollution and energy costs. I strongly urge the EPA to reject and withdraw the Affordable Clean Energy Rule, so we can get back to working towards a clean energy future that everyone has equitable access to.

Thank you.