Vulnerable Communities and the CPP

UPDATED 02.21.2017 Webinar materials are available here.  

The final Clean Power Plan and the proposed Federal Implementation Plan/Model Trading Rules (Proposed Federal Plan) refer often to vulnerable, overburdened, and low-income communities. For example, the CPP requires states to “describe their engagement with their stakeholders, including their most vulnerable communities” as part of their plan submittals. And as part of its early-mover “Clean Energy Incentive Program” (CEIP), the EPA plans to reward early emission allowance and emission rate credits to demand-side energy efficiency investments that are implemented in low-income communities.

These terms are not defined in the regulatory text, so who is EPA including in these phrases? In the CPP, EPA states that

[it] analyzed the communities in closest proximity to power plants and found that they include a higher percentage of communities of color and low-income communities than national averages. . . .We refer to these communities generally as “vulnerable” or “overburdened,” to denote those communities least resilient to the impacts of climate change and central to environmental justice considerations.

In the Proposed Federal Plan, EPA’s description is broader:

There are many rural power plants that are located near small communities with high percentages of low-income populations and lower percentages of communities of color. In urban areas, nearby communities tend to be both low-income communities and communities of color. In light of this difference between rural and urban communities proximate to power plants and in order to adequately capture both the low-income and minority aspects central to [environmental justice] considerations, we use the terms “vulnerable” or “overburdened” when referring to these communities. Our intent is for these terms to be understood in an expansive sense, in order to capture the full scope of communities, including indigenous communities most often located in rural areas.

For those interested in learning more about how to engage communities (vulnerable, overburdened, low-income or otherwise) in the CPP implementation process or if you are a community representative seeking ways to engage your community in the process, EPA offers a Clean Power Plan Community Page with resources related to the CPP and Proposed Federal Plan.

Tomorrow, September 9, from 1:00-2:30 PM ET EPA will be holding a Webinar for “Community Leaders and Non-Traditional Stakeholders.”  Information about logging into the webinar is available here, and EPA states that it will later make the webinar materials available on the Clean Power Plan Community Page.

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