RE: Senate Bill(SB) 978 Public Process OPAL, Verde Comments

Transcription

1 July Public Utility Commission of Oregon Attn: Julie Peacock 201 High St SE, Suite 100 Salem, Oregon RE: Senate Bill(SB) 978 Public Process OPAL, Verde Comments Dear Public Utilities Commission (PUC) Commissioners, We appreciate the work that the Oregon Public Utilities Commission has undertaken so far in the SB 978 process. We are submitting final comments on SB 978 s directive for the Public Utility Commission of Oregon to investigate developing industry trends, technologies, and policy drivers; their impact on the current regulatory system; and how this will and could impact the system moving forward. It is important to holistically undertake the engagement of non-traditional stakeholders to be involved in these conversations. We support advancing pathways for environmental justice communities to be meaningfully engaged and empowered in these decision-making processes. Environmental Justice communities (low-income communities and communities of color) have seen and felt the rapid depletion of Mother s Earth non-renewable resources from our extractive economy first and worst. This depletion goes hand-in-hand with increased energy consumption globally and especially in the United States. It is more important now than ever that decision-makers meaningfully engage our communities to achieve a more clean energy-efficient future. No real solution excludes our communities. In addition, EJ communities are interested in not just access to decision-making processes, but also in access to the jobs, education, health, and ownership opportunities that may result from a restructuring of the regulatory system. Energy regulatory policy is complex, making it important for EJ communities to weigh in on larger policy recommendation goals and objectives. Therefore, OPAL Environmental

2 Justice Oregon and Verde write to ensure we are clear regarding our priorities and how we define a successful SB 978 process. We ask that our recommendations be incorporated as part of the final SB 978 report and desire to partner with the PUC in implementing a successful plan to meet these priorities. OPAL stands for Organizing People, Activating Leaders. Organizing brings together people and resources to create systemic change. We believe everyone can be an active community leader. Founded in 2006 by and for people of color and low income communities, OPAL organizes the people decision-makers often overlook. We develop community members leadership skills and motivate them to take action at the intersecting policy areas of transportation, housing, public health, environmental quality, and equitable access to green infrastructure and economic opportunity. Our members lead campaigns, impact public processes, and win victories in policy and procedure to achieve a safer, healthier environment where we live, work, learn,play, and pray. Verde is a Portland-based non-profit focused on ensuring that low-income communities and communities of color participate and benefit from sustainability and environmental investments. Since 2005, Verde has worked at the intersection of sustainability, social justice and equity and has brought environmental infrastructure to low-income neighborhoods, engaged residents to design and implement these projects, and ensured that environmental investments contribute to community well-being. The recommendations underlined below are similar to those articulated throughout the public involvement process. Note these are priorities and recommendations continuing to be co-created with the communities we work with and will be further informed by frontline community participation in the Community Energy Justice Summit taking place July 13th-15th. Institutionalizing and Implementing Equity and Environmental Justice (EJ): An Equity and Environmental Justice analysis must be a core, primary priority not only on the Oregon Public Utilities Commission but also of any program / docket it establishes. This should provide PUC staff and PUC stakeholders tools and resources to ensure equitable outcomes. Oregon s communities have various energy needs, and if we do not manage how already-burdened EJ communities can benefit equitably, those burdens will only worsen. Provide training for staff and the agency around Environmental Justice and Equity Frameworks on a continuous basis. Work with the Environmental Justice Task Force for such processes to be more EJ based.

3 Consider the makeup of a non-traditional rate payer committee in which such communities can be involved in creating the solutions they see fit. Affirmatively and measurably reduce current energy burden and inequities, rather than only mitigating burdens to low income communities and communities of color. Creating a More Inclusive Participatory Process The agency must identify best practices and resources to implement an effective and meaningful community participation. The agency must build transformational relationships with a shared analysis of energy processes which includes: Identifying key elements of the rule-making process and how to incorporate actual community experiences and concerns into the regulatory process. Providing training on how to use existing tools, data and resources to effectively communicate community needs and concerns regarding improving energy efficiency. Providing training about how to make effective public comments that can help shape the final rules, and role play effective public commenting. This includes considering the extension of public comment periods in order for EJ communities to have enough time and resources to participate in such decisions. Considering the resourcing for equity and environmental justice work to be carried forward in this process. Distributed Energy Resources: EJ communities have a high level of interest in exploring how investments in distributed energy resources can support low-income households, decrease our overall energy costs, and increase greater resiliency of the grid and community as whole. We believe that there is momentum for greater decentralized systems, but without Public Utilities Commission oversight, low-income communities and communities of color will most likely be left out of such benefits. Our communities have continuously advocated for solutions that include our vision in 1 mind. As an example Verde released the Living Cully Community Energy Plan The Energy Plan is a neighborhood-scale energy plan which identifies energy generation and energy conservation efforts. Our communities lead three of the identified pilots which include localized energy generation and two which include solar storage. In addition, the Portland Clean Energy Fund (PCEF), the first community of color led environmental initiative in the state of Oregon, just submitted over 60,000 signatures to 1

4 place our energy petition on the November ballot. If passed, PCEF would create a pathway for low-income communities and communities of color to lead energy generation and energy conservation projects. Research and reports continue to demonstrate how energy burdens impact low-income communities and communities of color most. Investing in such communities and removing energy burden will mean families can take better care of their needs, and prevent hard decisions between energy, transportation, housing, food, health and other lifeline common human rights. Distribution of energy resources equitably must avoid substantial burdens (e.g., physical and economic displacement of low-income households due to energy cost, increased exposure on unhealthy inefficient housing, exposure of air pollution, among many more) to the very residents and communities that are intended to benefit from these investments in the first place. Investments must significantly address priority needs of EJ communities, low-income households, and low-income communities. Access to Emerging Energy Technology: A report conducted by OPAL Environmental Justice Oregon and Portland State University Community-based assessment of Smart Transportation needs in the City of 2 Portla nd demonstrates the disparities and barriers low-income communities face in accessing smart transportation technologies. As new energy technologies emerge we must consider the following: Opportunities and Investments must be community-driven - Community leadership and decision-making power must drive the implementation of any new technology. Environmental Justice communities must be the primary decision-makers on how investment in such technology are made, and which projects are funded within their neighborhoods. While providing outreach and technical assistance to increase community awareness of and capacity to access such opportunities is important, it alone is insufficient to ensure that the priority needs of communities are met. Opportunities and benefits from technology drivers must be reported in an accountable and transparent manner- any benefit should be delivered, measured and reported to the environmental justice communities and reported to 3 the Environmental Justice Task Force on a quarterly basis. 2 SU_Forth-Final.pdf 3 The Environmental Justice Task Force holds quarterly meetings.

5 Conclusion During this upcoming weekend (July 14-16), over 60 community members, representing various organizations serving communities of color in Multnomah County will gather for the Community Energy Summit. The convening is hosted by a partnership between City of Portland, Multnomah County, OPAL, and many culturally-specific organizations. The event covers 20 hours worth of energy systems curriculum and introduces an action plan for meeting the City of Portland and Multnomah county s 2% 4 community-based renewable energy goal. EJ organizations and organizations serving EJ communities are taking a greater interest in a democratized energy system and building capacity to advocate for equitable energy benefits. We hope to be able to report at the final SB 978 hearing (on Tuesday July 17) on the outcomes of the Community Energy Summit and how these align with the comments filed today. We want to thank the Commission for the overall SB 978 process and this opportunity to comment on Oregon s regulatory system. Sincerely, Carolina Iraheta Gonzalez Carolina Iraheta Gonzalez Community Energy Advocate Verde María Hernández Segoviano Advocacy Coordinator OPAL Environmental Justice Oregon 4