Creating Meaningful Community Engagement with IRA Rebates

When designing long-running energy efficiency programs, state energy offices have an opportunity to meaningfully engage communities and labor groups early in the process. Meaningful engagement is beneficial for all stakeholders: programs will increase their reach towards all population segments, more households and businesses will benefit from upgraded buildings, and the work will be executed more efficiently and effectively if the workforce is adequately trained. Now, with increased federal funding from the Inflation Reduction Act (IRA) in the form of the Home Electric Appliance Rebates (HEAR) and Home Efficiency Rebates (HERs) through the Department of Energy, states have a unique opportunity to design programs equitably and effectively.

To complement the mandates in Justice40, the IRA is intended to help state energy offices begin this process of engagement; all funding requires some form of community benefits, community engagement, labor engagement, and workforce development plans. In fact, U.S. DOE has just released guidance that lists required elements of a community benefits plan (CBP) for IRA rebates, putting “supporting meaningful community and labor engagement” as its first objective. The plan must explain how the state will hold at least one public input session, use feedback to guide program iteration, solicit further feedback during the program, and conduct community engagement and outreach. This is an important part of the process, which enables community stakeholders to become meaningful parties in planning and decision-making. Below, NEEP has identified some key steps for states to kick off community engagement.

Why Programs Need Early and Meaningful Engagement
A history of environmental racism and inequitable energy decision-making have led to historically marginalized communities bearing the largest burdens of the fossil fuel economy but not receiving many of the benefits. Discriminatory practices have meant that historically marginalized and/or underserved communities now live in older buildings in need of repair, experience higher energy burden, and lack input into the programs meant to serve them. Policymakers and program implementers can make changes in program design and objectives to better center equity so that the benefits of these programs can be accessible to everyone. 

While energy efficiency programs have policies to ensure access and prioritize historically marginalized and/or underserved communities, these policies generally focus on equal access to programs, and not equity in access to benefits. Equal access can be achieved through segmented programs for low- and moderate-income, market rate, and commercial customers, or by setting program spending equal to each sector’s contribution in energy bills. This standard ensures equality, allowing everyone access to the same resources or opportunities, but not equity. To improve equity, we must recognize disparities that already exist – such as housing and income inequalities – and create programs and policies that proactively address those disparities. Creating meaningful engagement on the design of these programs can start to address these barriers through solutions that have been generated by the community members themselves.

What is Meaningful Engagement?
Meaningful engagement means inviting community partners early in the design process, incorporating their feedback, and implementing a plan that reflects their input. For example, one way that states can show their commitment to empowering these groups is through collective bargaining and project labor agreements. The U.S. Department of Labor has good resources on project labor agreements (PLAs) (including this resource guide and the report PLAs for Equity). Project labor agreements can incorporate many of a project's unique terms and goals from the outset. These can include a requirement to hire local community members (which directly benefits the community), to target recruitment toward underserved communities and populations, and to establish monitoring procedures.

State energy offices recognize the need to talk to representatives from a diverse set of demographics within the state, taking into consideration disparities in race, socioeconomic status, housing type, owner vs. renter, and urban vs. rural. Below is a list of actors within the energy efficiency industry that states should be sure to include:

• Uplift historically marginalized members of the industry such as minority and women business owners.
• Ensure resident voices are heard by reaching out to community-based organizations and local community representatives, perhaps county commissioners or city councilors.
• Listen to partners already embedded in foundations of justice and equity such as environmental justice non-profits.
• Work with labor groups such as trade associations and unions to recruit, reskill, upskill, and transition as needed as the energy economy continues to change. 
• Partner with utilities, who often offer energy efficiency programs, so that state and utility offerings are designed to be complementary. 
• Ensure the building retrofit program is serving the four primary audiences identified in this report from Elevate: property owners, renters, contractors, and community members. Understanding specific needs of these stakeholders allows program design to be flexible enough to accommodate nuances and reduce complexity.

So how can state energy offices identify and reach these stakeholders? Luckily, stakeholders want to be included and have perhaps even reached out. Below are some ways to start to identify them:

• Check a list of organizations that have submitted public comments on housing and related topics.
• Release a notice on the state website and through a press release, asking for volunteers or applicants for an advisory group.
• Leverage local non-profits who are aware of other organizations focusing on the same topic areas and can reach out through their networks.

Recommendations for Community Outreach with IRA Rebates
States are required to hold public input sessions and use feedback to guide program design and iteration.
Access to the decision-making processes is a big part of stakeholder engagement. Processes should look for ways to accommodate all types of schedules and remove barriers where possible to enable procedural justice (where we look to center the most vulnerable and historically marginalized or excluded voices), yet it can be hard to design a stakeholder process that accommodates various needs. Some possibilities to increase accessibility include scheduling recurring meetings at various times each month to account for different schedules, ensuring hybrid access (in-person and virtual options) and building accessibility, releasing documentation in all the most commonly spoken languages in the region, and providing high-quality masks at meetings during the ongoing pandemic.

• New York, one of the earliest states to submit funding applications for the IRA rebates, held its public input session as a webinar.

States are required to solicit and respond to further feedback during the program.
Once relevant stakeholders have been identified, conversations with them should have meaningful input into the decision-making process. This means that they should be repeated regularly, establishing accountability and community trust. It is important that states clearly communicate meeting goals, input asks, and what results they will inform.

• California, another of the earliest states to submit funding applications for the IRA rebates, will be holding workshops to seek input on program development in 2024, and is also accepting written comments.
• In Massachusetts, the Metropolitan Area Planning Council, which is working on the Greater Boston Climate Action Plan, sought community-based organizations and non-profits as participants for its Justice40 Advisory Group to help shape the regional climate plan. Members will be participating in several meetings through mid-2025 and are eligible for stipends as compensation.

States are required to conduct community engagement and outreach.
As explained in the Community Engagement to Ownership Spectrum, engagement from the most vulnerable community members provides greater knowledge, new solutions, and better procedures – all of which benefit not only the most vulnerable, but also everybody else. 

The Spectrum of Community Engagement to Ownership, Facilitating Power

• Hawai’i, another of the earliest states to submit funding applications for the IRA rebates, held a webinar on its HEAR program, and is taking feedback through a survey.

Conclusion 
Each of these options makes it a little more possible for everyone in a specific community to participate fully. Building a meaningful stakeholder engagement process must be done thoughtfully for the most effective and equitable outcomes. The new influx of funding is a unique and powerful opportunity for policies and programs to engage communities in ways that deliver not only equity, but justice. NEEP is available to help states as they navigate this process and hopes to be a resource to help identify ways to engage stakeholders and embed their feedback into program design.