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APGA Comments on the IRA’s Home Efficiency Rebates Program

By Lindsay Selfridge posted 03-23-2023 10:11 AM

  

Earlier in March, APGA responded to a Request for Information (RFI) from the Department of Energy’s (DOE) Office of State and Community Energy Programs (SCEP) on Home Efficiency Rebate Programs. The programs, funded through the Inflation Reduction Act (IRA), allocate $8.8 billion towards residential energy efficiency improvements.


APGA supports the goal to improve energy efficiency in homes, which reduces energy costs for U.S. consumers and reduces emissions. However, there is a major concern that these rebates will be used only for appliance fuel switching from gas to electric. DOE should acknowledge gas appliances are three times as efficient when used directly inside the home as when it is used to generate electricity because so much energy is lost when converting and transmitting electricity. This rebate program should be executed in a way that truly benefits Americans, with a focus on improving the actual energy efficiency of homes, not just changing out appliances.


Specifically, APGA urged SCEP to consider the below input. 

  1. Accessible and Equitable Program Design: APGA advised SCEP to remain fuel neutral in its efforts to improve residential energy efficiency and ensure that the Home Efficiency Rebates program is accessible and equitable by including gas technologies in its design.
  2. Designing Programs for Maximum Impact: To ensure maximum impact, the rebate program should allow for natural gas and other, lower carbon fuels, such as renewable natural gas, which can be carried through the existing pipeline system.
  3. Estimating and Measuring Energy Savings: As SCEP works to implement its rebate program, it should ensure that it is estimating and measuring energy savings on a full-fuel-cycle basis. Again, directly using natural gas in appliances is three times more efficient than electric appliances.
  4. Eligible Technologies for Rebates: SCEP should ensure that it promotes the use of gas-fueled appliances in its Home Efficiency Rebates program. In addition, APGA asked that SCEP exercise caution in relying upon certain ENERGY STAR programs such as the “Most Efficient List,” which may encourage fuel switching.


To see APGA’s comments, click here


For questions on this article, please contact Lindsay Selfridge of APGA staff by phone at 202-464-0834 or by email at lselfridge@apga.org.  

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