Rural Power Coalition Urges Voices of Rural Communities to Be Prioritized in Implementation of Inflation Reduction Act

Today, the Rural Power Coalition sent the following letter to White House Cabinet Members and Officials including Tom Vilsack, Secretary of Agriculture, Jennifer Granholm, Secretary of Energy, and John Podesta, Senior Advisor to the President (White House Office on Clean Energy Innovation and Implementation) asking them to ensure the voices of rural communities are heard throughout the implementation process of the Inflation Reduction Act (IRA). It is imperative that underserved communities have the opportunity to offer their input on how the IRA should be implemented.

We also make the case that distributing the funds without a Justice40 protocol similar to the one implemented at the Department of Energy is a hazard to the IRA’s impact and the impact it will have on our communities.

Dear Secretary Vilsack, Secretary Granholm, and Mr. Podesta,

The Rural Power Coalition – a coalition of groups representing the interests of electric cooperative member-owners and rural communities – would like to express its gratitude for the Biden Administration’s leadership and support of the historic investments in rural electrification contained in the Inflation Reduction Act. The Rural Power Coalition sees a future for electric cooperatives that is grounded in justice, democracy, and resilience. For many years, the rural communities represented by the Rural Power Coalition have worked extensively to win investment in the rural energy transition. Our advocacy, in part, played a significant role in passing the following programs in the Inflation Reduction Act:

• USDA Assistance for Rural Electric Cooperatives, Sec. 22004 - The allocation of $9.7 Billion Dollars of USDA Assistance for Electric Cooperatives for a voluntary program for rural electric cooperatives to make investments in renewable energy.

• Additional Funding for Electric Loans for Renewable Energy, Sec. 22001 - The Allocation of $1 Billion Dollars in additional funding to cover the cost of loans related to Renewable Energy.

Thanks to these appropriations, our nation’s rural electric cooperatives have a major opportunity to deliver tangible economic benefits to communities that need it most as we accelerate the retirement of 57,000 MW of fossil-fueled generation by investing in essential energy upgrades and 100% clean power by 2035. In order to maximize both economic and climate impacts, these transformative investments must be implemented with strong attention to environmental justice, which requires a robust process for public input. 

The voices of rural communities deserve to be heard through the implementation process, and a rush to distribute the funds without a Justice40 protocol similar to the one implemented at the Department of Energy is a hazard to the policy’s impact and its impact on our communities. 

With the signing of Executive Order 14008, the Biden Administration vowed that 40% of benefits for certain federal programs will flow to historically marginalized communities. Rural electric cooperatives cover 56% of the nation’s landmass, including 92% of federally recognized persistent poverty counties and many Justice40 identified Disadvantaged Communities. Electric cooperatives are well positioned to not just rapidly transition to clean energy but also deliver on the mission of Justice40 – making investments in communities that need it most and that have been previously left behind.

Rural communities and their representatives advocated for the  reinvestment in rural electric cooperatives with the goal of using these new investments to advance environmental justice. The spirit of the language passed in the Inflation Reduction Act intended to reduce carbon emissions through new clean energy investments, assure local investment, particularly in Justice40 identified Disadvantaged Communities, and reduce rural families’ monthly bills through deployment of energy efficiency technology. 

We firmly believe it is imperative that underserved communities have the opportunity to offer their input in the form of a Request for Information (RFI) process and stakeholder workshop(s), followed by a Notice of Intent (NOI), and finally a Funding Opportunity Announcement (FOA). This process is similar to the process for Justice40 implementation at the Department of Energy. Justice40 already applies to many USDA RUS programs and should apply to these historic investments as well.   

To assure an implementation that follows the spirit of the law USDA-RUS should specifically:

• Forge a Joint Office of Rural Electric Investment between DOE and USDA to provide technical assistance to rural communities and electric cooperatives developing proposals for federal investment.

• Fully apply Justice40 to the aforementioned programs with protocols for public input that are at least as strong as those assured in Department of Energy programs.

• Require local clean energy investments in the communities that program applicants serve.

• Require program applicants to include energy efficiency and electrification as a component of their proposals to the USDA Assistance for Rural Electric Cooperatives Program.

• Provide a pathway to stranded asset relief and fossil fuel plant retirement.

• When considering 22001, prioritize public and member-owned rural utilities that apply for funding for forgivable loans for renewable energy.

• Prioritize proposals that achieve actual greenhouse gas emissions reductions from proven and less expensive technologies rather than projected emissions reductions from unproven and more expensive technologies.

• Evaluate the climate and economic impact of each proposal based on a methodology that accurately evaluates actual greenhouse gas emission reductions and whether the project will provide real utility bill reductions and economic benefits to local communities. 

• Prioritize projects that enforce high road labor standards, including a Davis Bacon wage requirement, and employ a local and/or disproportionately impacted workforce. 

This once-in-a-generation opportunity was hard won by the organizing efforts of the organizations and communities represented in this coalition and others across this country; they deserve an opportunity to provide feedback on how these programs should be administered and how funds are distributed. We urge the USDA – and all Federal agencies – to follow a robust stakeholder input process, consistent with principles of environmental justice and the Justice40 initiative. 

Prioritizing the specific outcomes desired by the communities that will be impacted the most by these investments and allowing these communities the opportunity to express their viewpoints through a robust public input process is critical to achieving the spirit of these historic investments.