Comment letter sent to the USDA Rural Utilities Service co-signed by over 260 organizations and individuals

Last month, the Rural Business-Cooperative Service (RBCS) and the Rural Utilities Service (RUS), agencies of the Rural Development (RD) mission areas of the United State Department of Agriculture (USDA), announced that they would host a single listening session and except public written public comments regarding implementation of the Inflation Reduction Act (IRA) of 2022.

In response, RPC rallied 60+ organizations serving and/or in support of Rural Electric Cooperatives and 200+ individuals and member-owners to provide verbal comments and sign on to joint letters. We also drafted a technical letter to address the series of questions that were posed during the listening session and co-wrote an additional letter with Tri-State Generation and Transmission Association and the Sierra Club.

Now that the public comment period has ended, we’re working to meet with members of the administration directly.

To Administrator Berke:

In 1936 Congress passed the Rural Electrification Act, which transformed rural America. For the first time, America’s farmers, ranchers, rural businesses, and rural communities had access to electricity, opening the door for modern food supply and energy and electricity production as we know it. Rural electric cooperatives are the foundation of this transformation, formed by those same rural people, who came together to take advantage of the 1936 Act. Since their foundation, electric cooperatives have accomplished substantial quality-of-life improvements for rural Americans. 

Thanks to the historic investments in the Inflation Reduction Act - specifically sections 22001 and 22004 - Rural Electric Cooperatives are poised once again to improve the lives of millions of rural Americans through creating rural jobs, reducing costs for rural consumers, and acting on the climate crisis. 

In order to fully deliver on the promise of the Rural Electrification Act and the Inflation Reduction Act, voices in rural communities must be heard. 

Recently the Rural Power Coalition sent a letter to the Administration urging them to assure a transparent public process for the implementation of electric cooperative programs in the Inflation Reduction Act. People in rural communities and electric cooperative member-owners deserve a chance to have their voices heard. Engaging impacted communities takes time and hard work, and cannot be accomplished with a 2 hour listening session with 5 days advanced notice followed by a 3 week written public comment period including Thanksgiving week. We are concerned and disappointed by this timeline.

Such a brief window for community engagement is a missed opportunity for rural communities to learn more about the clean energy transition, build public support, and provide the Rural Utility Service the nuanced feedback it requires to implement these programs effectively.

Further, the communities that have the most to gain from the investments in the Inflation Reduction Act are the most likely to need technical or other assistance in order to submit an application. We assert that the current time frame does not allow for the communities that need it most to participate fully in a public comment process nor prepare a competitive application.  

The USDA is under an Executive Order to apply the Justice 40 principles to this program, reinforced by an Executive Order on the Implementation of the Energy and Infrastructure Provisions of the Inflation Reduction Act calling for an all-of-government approach to advancing a just transition, including effective engagement with stakeholders. The Rural Development Division should adopt protocols that require applicants to demonstrate benefits to communities, especially disadvantaged communities (with particular consideration given to black communities, indigenous communities, and communities of color), and energy transition communities and it should strongly consider them during all phases of decision-making.

Absent the opportunity for the most impacted rural communities to make their voices heard in this process, the Rural Power Coalition and the undersigned organizations recommend the following priorities in the RUS implementation of the Inflation Reduction Act programs pertaining to electric cooperatives.

Ensuring Local Investment and Workforce Development 

The cooperative programs of the Inflation Reduction Act give major opportunities to develop rural economies and create rural jobs. Implementation of these programs should ensure maximum benefits to rural communities and rural workers. The RUS can accomplish this by creating programs that: 

• Are accountable for Justice40 implementation. Historically underserved areas, areas of persistent poverty, and areas with the highest reliance on fossil fuel generation have the most to gain through these programs in both job creation and potential savings per dollar invested. 

• Prioritize holistic energy transition plans that take into account communities and workers should be given priority over projects without a robust Community Benefit Plan. Establish selection criteria and scoring that assures federal support reaches places where planning is robust, transparent, and takes into account community benefits and greenhouse gas emissions reductions.

• Apply strong labor/wage standards such as prevailing wage and “Buy American, Build America.”

• Assure local investment by requiring applications from generation and transmission cooperatives make investments in the service territories and within the members/communities of the member distribution cooperatives that own them and distribute the electricity they deliver. 

Energy Savings & Affordability

New cooperative investments in the clean energy transition should maximize benefits to member-owners, with a focus on site-specific energy upgrades and other projects that lower costs and increase local resiliency. The RUS can accomplish this by creating programs that: 

• Prioritize projects that ensure savings for member-owners and prioritize local investments in renewable energy and energy efficiency. 

• Lower the energy burden for the most impacted member-owners. 

• Give weight to projects that seek to address underlying finances of cooperatives, such as stranded assets, that impact member-owner energy costs.

• Prioritize plans that address affordability by ensuring that customers' bills are lower over time, relative to business as usual conditions, and that energy burden is improved, not worsened.

Reduction of GHG Emissions & Expansion of Clean Energy Investments

Through implementation of 22004, the USDA should prioritize accomplishing greenhouse gas (GHG) emissions reductions through local investment in clean energy and equitable deployment of energy efficiency, electrification, and other site-specific investments that result in community benefits and savings for rural communities. The RUS can accomplish this by creating programs that: 

• Prioritize projects that directly support member-owners’ ability to increase energy efficiency at their home or business, take steps towards beneficial electrification, and increase on-site renewable energy generation and/or storage.

• Recognize energy efficiency at member sites as zero emission systems - and define “zero emission systems” to include everything covered in the Energy Efficiency Conservation and Loan Program. 

• Prioritize proven technologies that achieve the greatest lifecycle reductions in carbon dioxide, methane, and nitrous oxide emissions. Once a plan has been shown to reduce costs, it should be evaluated for its ability to reduce overall/lifecycle GHG emissions.

• Take a whole-of-government approach to implementation of energy transition policies. 

The creation of strong programs is critical to the success of the mission set forth by first the Rural Electrification Act and now the Inflation Reduction Act. We urge you to strongly consider the broad priorities laid out in this letter and reconsider your public input process to allow more communities the opportunity to build support and have their voices heard. 

Sincerely, 
Rural Power Coalition and 60+ organizations serving and/or in support of Rural Electric Cooperatives and 200+ individuals and member-owners 

Organizations

Atlantic Climate Justice Alliance

Center for Common Ground

Clean Energy Action

Cleveland owns

Climate and Community Project

Climate Reality Project Long Island Chapter

Community Farm Alliance

Croatan Institute

CURE

Dakota Resource Council

Dakota Rural Action

DPL Strategies

Earth Ethics, Inc.

Ecolibrium3

Elders Climate Action

Energy Alabama

Family Farm Defenders

Fairbanks Climate Action Coalition 

Georgia Conservation Voters

GreenFaith

GRID Alternatives

Honor the Earth

Institute for Local Self-Reliance

Kentucky Conservation Committee

Kentuckians for the Commonwealth

Kentucky interfaith power and light

Kentucky Resources Council

Livelihoods Knowledge Exchange Network

Minnesota 100% Campaign

Mountain Association

Mt Tabor Benedictines

Native Movement

Native Sun Community Power Development

NDN Collective

NESAWG

New Economy Coalition

Norml National Care Givers

North Dakota Native Vote

Northern Plains Resource Council

Nuclear Information and Resource Service

One Voice

Partners for Dignity & Rights

Pennsylvania Council of Churches

Power Shift Network

Reclaim Philadelphia

Redwood Energy

Renew Missouri

Rise Up WV

Rural Climate Partnership

Rural Democracy Initiative

Salish Sea Cooperative Finance

Shareable

Sierra Club

Solar United Neighbors

Solstice Initiative

The Alaska Center

The Alliance for Appalachia

The Climate Reality Project, Western New York Chapter

The Imani Group

The People's Justice Council

Transform Finance

Unite North Metro Denver

Western Clean Energy Campaign

Western Colorado Alliance

Western Organization of Resource Councils

Willmar Area Climate Action Group

Wisconsin Farmers Union

350.org

350 New Hampshire

To Individuals

Michael Brennan

Gary Zahler

Mary Zahler

Jarrett Cloud

John Dervin

Judith Ford

Michael Langlais

Colleen Lobel

Bill Lindner

Steve Troyanovich

Barbara We

Lisa Krausz

Karen Mallam

Lanelle Lovelace

Michael Overend

Nancy St Germain

Janet Kolodner

Karen Kaser-Odor

Neal Gorenflo

Alberto Saavedra

JL Angell

Deborah Carroll

Lawrence East

Adrienne Ferriss

Don Somsky

Dara Gorelick

Richard Anderson

Sharon Longyear

Zada Rose

Ward Giblin

Joseph Pfister

Andrea Christgau

Arthur Rosenberg

Richard Boyce

Tracey Katsouros

Sandra Ashmore

Kent Borges

Scott Mahood

Jean Wiant

Dennis Nagel

JoAnn McGreevy

Ruth Felix

Kate Crowley

Barbara Harper

Jeannie Finlay-Kochanowski

Rochelle La Frinere

Nancy Walsh

Harriet McCleary

Linda Inness

Barry Cutler

Lana May

Bruce Rosen

Russ Cross

Don Ghidoni

John Robinson

Karl Lohrmann

Robert Reed

Justin Philipps

Carroll Arkema

John Chase

Pamylle Greinke

Maureen Laughlin

Aloysius Wald

Glen Anderson

William Welkowitz

Steve Molenaar

Charles Wieland

Riley Brannian

Judith Sandeen

Robin Lorentzen

Connie Raper

Lorraine Brabham

Susan Siniard

Ingrid Rochester

Raymond Nuesch

Laura Neiman

Nancy  McMahon

Andrea Denault

Dorothy Lynn Brooks

Aaeron Robb

Norda Gromoll

Emily Metz

Susan Heath

Donna Selquist

Beth Darlington

Ann McCabe

Mark Taggart

Steven Vogel

Libby E Berman

Judith Lasko

Dudley Campbell

Candace Campbell

Carl Prellwitz

Elizabeth Watts

Chas Griffin

Donald Harland

Karen McCaw

Lynne Weiske

Diane DiFante

Ro Vanstrien

William Fisk

Susan Olive

Katherine Robertson

Erik Garcia

David Wendt

Phil Klein

Michael Sileno

Stephen Greenberg

David Gustafson

Esther Garvett

Dr. MhaAtma S. Khalsa

Alfred Higgins

Paul Eisenberg

Kathryn Rose

Mary Danhauer

Kathy Bradley

Dorothy Anderson

Vicki Fox

L. Adams

Gail Weininger

Nancy LaPorta

S. Nam

Karen Berger

Rory McIlmoil

Carol Myers

Jaszmene Smith

Frank Belcastro

Maryellen Redish

Donald Hunt

Linda Heath

Beverly Mitchell

Sharon Paltin

Leann Turley

John Papandrea

Justin Truong

Paul Blackburn

Sandy Rhein

Diana Saxon

Derek Benedict

George Ruiz

Lauren Murdock

Doris Ashbrook

Mark Baker

Patricia Pruitt

Sandra Lynn

Chris Washington

Brandon Kozak

Matthew Eager

Dawn Kenyon

Julia Hartman

Phil Klein

Annick Richardson

Rachael Pappano

Phillip Woolery

David Burtis

Evelyn Griffin

Sylvana Arguello

Michael Pan

Maddy Koch

Robert Buchanan

Stephen Dutschke

Bruce Cratty

Linda Howie

Desiree Nagyfy

Barbara Sorgeler

Priscilla Trinh

Mary Bissell

Dean Borgeson

Frances Goff

Nancy Carl

Danielle Stannard

Lori Stefano

Todd Snyder

DeeDee Tostanoski

Gracelyn Mcclure

Elizabeth Seltzer

Tim Wheeler

Gayla Cremin

Robin VanTassell

Karyn Barry

Paul Ghenoiu

Kathleen Felt

Tiffany Rapplean

Brady Watson

Steven Andrychowski

Doris Ashbrook

Bethany Lacktorin

Jack Roberts

Brian Ainsley

Jessie Rathburn

Syd Bauer

Sherrill Futrell

Mitchell Hancock

Angelica Solloa

Harold Watson

Brad Snyder

Josi Riederer

Michael Nelson

Sarah Mooradian

Thomas Llewellyn

Robert Raymond

Alison Huff