Pennsylvania DEPARTMENT OF ENVIRONMENTAL PROTECTION

November 1, 2016

Environmental Protection Agency EPA Docket Center (EPA/DC) Mail Code 2822IT

1200 Pennsylvania Avenue, NW Washington, D.C. 20460

Attention: Docket ID No. EPA-HQ-OAR-2016-0033 To Whom It May Concern:

The Department of Environmental Protection (DEP or Department) appreciates the opportunity to submit comments on the U.S. Environmental Protection Agency's (EPA) Proposed Design Details for the Clean Energy Incentive Program (CEIP). It is important to note that the

comments submitted by DEP represent the Department's official position on the proposed design of the CEIP. Any comments submitted on behalf of an organization of which DEP might be a member represents the comments of that organization and not those of the Department. DEP applauds the establishment of the CEIP as an optional design element of the Clean Power Plan (CPP) to help states meet their carbon dioxide (C02) emission goals in 2020 and/or 2021. DEP is fully supportive of a flexible compliance mechanism that would encourage early investments in zero-emitting renewable energy generation and remove barriers to investment in energy efficiency and solar projects that directly benefit low-income communities. In DEP's comments to the EPA (Docket ID EPA-HQ-OAR-2015-0199) DEP stated that EPA should not limit types and sources that qualify for CEIP but rather include all eligible resources that meet the construction requirements with verified energy savings in 2020 and 2021. On

June 16, 2016, EPA proposed a limited expansion of the type of projects that are eligible for CEIP to also include both demand side energy and solar renewable energy projects for low income community projects, as well as technologies beyond solar and wind to include geothermal and hydropower for renewable energy projects. DEP supports the expansion of the types of projects which are proposed to be eligible for the CEIP and encourages EPA to allow all projects that meet verified lesser emitting generation, such as Biogas or Combined Heat and Power and other energy savings projects which commence commercial operation (prior to when) to be eligible for CEIP.

DEP is supportive of EPA actions to help existing state and local programs that serve lowincome communities by allowing the use of more than one existing definition of low-income communities where the definition was established prior to the publication of the final CPP. DEP further supports the allowance of the use of a definition that has been updated after publication of the final CPP. DEP agrees that allowing a State to be able to consistently apply existing and

Secretary Rachel Carson State Office Building | P.O. Box 2063 | Harrisburg, PA 17105-2063 | 717.787.2814 | www.dep.pa.gov