Overview: These comments provide recommendations to the Department of Energy on how to structure the Home Energy Rebate program in a manner that makes it accessible for disadvantaged communities. The letter was the product of collaboration by 60 equity, environmental justice, community-based, and grassroots organizations and their allies around the US.

Home Energy Rebate Program Recommendations

To ensure that the rebates are administered as justly and equitably as possible, our partners and The Greenlining Institute urged the Department of Energy to adapt the following recommendations:

  • 100% of rebates for low-income households and disadvantaged communities – Low income and disadvantaged communities (LI/DACs) should receive all of these rebates. Within that prioritization, DOE should require states to set aside at least 40% of the funds for LI/DACs and at least 20% of the funds for multifamily affordable housing. The remainder of the funding should be used for low-income and disadvantaged communities. DOE should also consider establishing an income cap for the Home Efficiency rebates.
  • Maximize pollution reduction and cost savings – DOE should require plans to maximize the cost savings for LI/DACs by targeting households with high energy burdens. DOE should not allow rebates to be used for anything using fossil fuels.
  • Streamline income verification – DOE should require states to streamline income verification by allowing self-certification and eligibility based on participation in other income-based federal, state, or local benefit programs.
  • Clearly identify disadvantaged communities – DOE should use either its energy justice mapping tool or the Climate and Environmental Justice Screening Tool as well as categorically including Tribal lands and U.S. territories to define disadvantaged communities. DOE should also allow states to use their own tools to define disadvantaged communities, if the state tools are on par with or more robust than the federal tools.
  • Coordination with other programs – DOE should assist states with developing mechanisms that coordinate with complementary efficiency, weatherization, and similar programs to improve program efficiency and provide more targeted and holistic retrofits;
  • Best practices for multifamily affordable housing – DOE should require that rebates are provided before project completion, assist states with providing rebates in the form of loans, and clarify the application of the program to multifamily affordable housing;
  • Robust tenant and consumer protections – DOE should require states to develop tenant protections for owners retrofitting low-income households, including rent protections, relocation assistance and right of return, eviction and sales protection, enforcement of tenant protections, and provisions to ensure that income-eligible households benefit from the retrofits;
  • Program evaluation and equity measurement – DOE should require reporting and program evaluation to ensure its program’s design best meets the needs of LI/DACs;
  • Transparent and accessible information – Require states to ensure that online information that is understandable, transparent, and accessible to meet the needs of all community members;
  • Require community engagement – DOE should require states to include community engagement plans, community benefits plans, and community workforce agreements to ensure that LI/DACs realize the benefits of the program. This should include targeted outreach to Minority, Women, and Disadvantaged Business Enterprises and partnerships with community-based organizations to design programs to most successfully reach LI/DACs;
  • Advance a diverse workforce – DOE should encourage states to provide opportunities for workforce development and conduct robust outreach to encourage the participation of small and minority-owned enterprises in the program, especially from LI/DACs. DOE should also prioritize contractors that are Minority, Women, and Disadvantaged Business Enterprises and use high road practices.

We further urge DOE to continue to proactively and meaningfully engage with environmental justice communities; prioritize clean, community-centered development; and to ensure that its actions do not perpetuate, exacerbate, or create pollution burdens in communities that have disproportionately suffered the negative effects of fossil fuel development and use.

Download Comment Letter Here