March 3, 2023 — Comments

NCLC has recommended several best practices to DOE in our Jan. 18, 2023 letter with the Center for American Progress and the Alliance for a Clean Energy Economy. In addition, we recommend the following best practices:

a) Ensure states have the flexibility to administer the rebate funds through existing networks and programs to avoid duplication between programs. Program outreach should be combined with existing outreach efforts for other energy programs where possible, promoting efficiencies for consumers and program administrators.

b) Create outreach and navigator programs with trusted community partners (similar to the digital navigator approach to internet access). Allow up to 5% of the state grants to be used for outreach and navigator programs conducted by trusted community-based organizations, non-profit organizations, and local agencies as appropriate. These trusted messengers are key to serving hard to reach populations (to overcome barriers of trust, language, accessibility, and to help braid these rebate opportunities with other assistance programs). It is unreasonable to place the burden on consumers to master the enrollment rules and processes for these different programs. Trained navigators can help eligible consumers package the federal rebates with Weatherization, LIHEAP, utility ratepayer funded energy efficiency and other energy assistance programs, to ensure that members of disadvantaged communities and low-income households are able to enroll in the best combination of assistance available.

c) Establish clear requirements for outreach to owners of multi-family housing and to tenants, whether through state plans or other guidelines to ensure an appropriate percentage of this population is served by the rebate programs. Since nearly 40% of federal WAP households are tenants, this outreach will be important to the success of the program.

d) Provide easily accessible application materials, through paper and telephone application processes in addition to on-line applications.