TESTIMONY

OF

MALCOLM D. WOOLF

Director, Maryland Energy Administration

On behalf of the

NATIONAL ASSOCIATION OF STATE ENERGY OFFICIALS

Before the

COMMITTEE ON ENERGY AND NATURAL RESOURCES

UNITED STATES SENATE

December 10, 2008

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Mr. Chairman and members of the Committee, my name is Malcolm Woolf and
I am Director of the Maryland Energy Administration. I am appearing
today on behalf of the National Association of State Energy Officials
(NASEO). NASEO represents all of the state energy offices in Washington,
D.C., and helps coordinate the work of the energy offices throughout the
United States. We are pleased to have this opportunity to discuss
immediate steps the federal government can take to accelerate energy
solutions that will promote affordable, reliable and clean energy, and
also help address our immediate fiscal challenges. Prior to joining the
Maryland Energy Administration, I served as Staff Director of the
Natural Resources Committee of the National Governors Association,
counsel on the U.S. Senate Environment and Public Works Committee and in
private legal practice.

**SUMMARY**

It is hard to overestimate the promise of clean energy to stimulate the
economy, create green collar jobs, advance energy security and address
our climate and environmental challenges. To be successful, however, we
need to re-establish a true partnership between the states and the
federal government on energy matters. We need to leverage the federal
government's resources with the ability of states to experiment with
innovative new strategies and implement programs on the ground. By
building a more meaningful partnership, we can achieve our ambitious
energy goals.

Major new investments in clean energy should be a critical part of the
emerging economic recovery package. Like roads and bridges, such
investments immediately create new green collar jobs, ranging from attic
insulators to solar installers. Such jobs can't be outsourced overseas.
And these investments will continue to pay dividends in the years to
come by reducing our monthly energy bills, increasing generation of
clean, renewable power, and accelerating our nation's transition to a
more sustainable energy future.

For many years we have discussed the need to achieve significant
increases in energy efficiency in order to strengthen our economy and
reduce dependence on foreign imports. We are now facing an historic
opportunity where Congress and the Administration are committed to this
effort.

States are uniquely positioned to immediately implement major new energy
investments. Currently, state energy offices and research institutions
manage approximately \$3 billion in program funding annually. As such,
energy offices can provide a ready-made, 50-state delivery mechanism.

These proposals would strengthen the Federal, state and local
partnerships and create the opportunity for significant success. Many
states and local governments are already setting ambitious goals and the
funds that we are requesting would help establish a real partnership,
not just one based on platitudes.

For example, under Governor O'Malley, Maryland enacted earlier this year
one of the nation's most ambitious energy efficiency goals to reduce
consumption 15% by 2015. We already have a list of pre-approved energy
performance contractors ready to overhaul state buildings, as well as
programs for energy efficiency grants and low interest loans to local
governments, non-profits, and private businesses, and workforce training
to create qualified contractors that can improve home performance. While
every state has a slightly different set of tools, there is no other
existing vehicle that can coordinate local implementation in all 50
states.

For the proposed stimulus package, we recommend the following immediate
actions, which utilize existing delivery mechanisms:

1\) Provide \$10 billion for an energy efficiency buildings retrofit
program, utilizing existing delivery mechanisms (Draft Legislation and
Appropriations Language attached as Appendix A);

2\) Provide \$6 billion for the Energy Efficiency and Conservation Block
Grant (Authorized in the Energy Independence and Security Act of 2007
\["EISA"\]);

3\) Expand funding for proven programs, including:

\(a\) \$125 million for the State Energy Program (Reauthorized in EISA);

\(b\) \$1 billion for the Low-Income Weatherization Assistance Program
(Reauthorized in EISA);

\(c\) \$100 million for Energy Efficiency Building Codes (consistent
with the authorization contained in the Energy Policy Act of 2005
\["EPACT 2005"\]);

\(d\) \$100 million for the EPA ENERGY STAR program (consistent with the
authorization contained in EISA);

> \(e\) \$250 million for Green Jobs (Authorization contained in EISA);

\(f\) \$250 million for the REAP program at USDA, authorized in the 2002
Farm Bill, and reauthorized in the 2008 Farm Bill, to provide energy
efficiency and renewable energy funds for farmers, ranchers and rural
small businesses; and

\(g\) \$2.5 billion for the Low-Income Home Energy Assistance Program
("LIHEAP"), in addition to the \$5.1 billion in FY'09 appropriation.

4\) Provide 8 year extensions for the energy efficiency and renewable
energy tax provisions (including e.g., Production Tax Credit \["PTC"\],
Investment Tax Credit \["ITC"\], CREBS, energy efficiency commercial
buildings deduction, etc.) to ensure long-term job creation, and expand
the energy efficiency tax credits to create immediate incentives for
home energy efficient makeovers.

**DISCUSSION**

**A) STIMULUS PACKAGE**

**1) Launch Energy Efficient Buildings Retrofit Program ("Direct
Install")**

With seventy percent of electricity consumed in buildings, minimizing
the amount of energy that literally goes out the window -- or through a
leaking air duct - is a great investment. In addition, numerous studies
have documented the significant number of jobs created by energy
efficiency programs. For example, for every \$1 million in energy
performance contracting, twenty green collar jobs are created. A massive
new investment in energy efficiency building retrofits should therefore
be a central part of an economic recovery package, as long as is
implemented quickly.

Let me suggest four fundamental principles essential to success. First,
we need aggressive standards in all types of buildings -- residential,
industrial, commercial, institutional, state and local government. This
is important because, once a building is in place, it lasts decades.
Second, we should focus on upgrading infrastructure as this will
generate energy cost savings, help households as well as businesses, and
produce sustainable high quality jobs. Third, rapid deployment of energy
efficiency measures is important to reduce the costs of climate change
mitigation measures to all consumers. Energy efficiency reduces
regulated air pollutants and greenhouse gas emissions, and will be a
critical step in any climate bill that is developed. Finally, and
perhaps most importantly, speed requires a deployment mechanism
utilizing existing deployment routes, i.e., states.

The recommended approach for this new program is quite simple, and we
have attached the draft legislative language and associated
appropriations language (Appendix A). This proposed \$10 billion plan
would have \$5 billion disbursed to the states within 30 days of the
date of enactment, utilizing the existing State Energy Program formula.
The existing authorization for SEP is quite broad and the only
modification necessary would probably be to increase the authorization
level. The states would disburse the funds utilizing all deployment
routes, including energy service companies, utilities, contractors,
community action agencies, etc. The savings would have to be monitored
and verified. Within three months of the date of enactment, DOE would be
required to publish guidance on metrics for the remaining portion of the
funds. Within ten months of the release of funds, the states would
provide a report on implementation of the energy efficiency buildings
retrofit measures, and within twelve months of the release of the
initial funds, the remaining \$5 billion would be disbursed in
accordance with performance. This is a highly aggressive schedule. It
will require speed from DOE, which has not generally been a hallmark of
their efforts. Leadership from Congress and the new Administration will
help.

A number of complimentary proposals have been suggested, including
efforts in schools and creating a residential energy efficient buildings
retrofit program. These suggestions from groups such as the Center for
American Progress, the Energy Future Coalition, ACEEE and NRDC should be
quickly and closely examined. We have worked with these other groups on
these proposals A melding of these ideas is possible as well. From our
perspective, the key element is speed, which can only be achieved
utilizing a deployment mechanism which exists in all the states,
territories and the District of Columbia.

**2) Appropriate Funds for Energy Efficiency and Conservation Block
Grants**

Sections 541-548 of EISA established a new Energy Efficiency and
Conservation Block Grant ("EECBG"). This is a strong priority of the
U.S. Conference of Mayors, other local governments and the state
governments. If implemented quickly, it could provide critical near-term
investments in clean energy technologies.

We support the efforts of the U.S. Conference of Mayors and others to
streamline this process, so that the funds can be disbursed to local
governments quickly. If the EECBG funds wait for DOE to go through a
normal rulemaking process, followed by a competition among the local
governments, the funds could take years to distribute. That is
absolutely contrary to the intent of the incoming President and, I
expect, this Congress.

We recommend that the state portion of these funds be released within
thirty days in accordance with the existing formula for the State Energy
Program. NASEO recently wrote to Energy Secretary Bodman to implement
these measures urging DOE to take certain administrative steps
immediately to avoid delay in the distribution of funds early in the
Obama Administration. There is sufficient statutory and legal authority
to act in this manner. In short, the state energy offices are committed
to sharing best practices with the local governments and ensuring
regional coordination so that we actually can increase the leverage and
the success of these programs.

**3) Expand Proven Energy Programs**

**a) State Energy Program**

The State Energy Program ("SEP") provides funds to the state energy
offices through the Department of Energy to fund energy efficiency and
renewable energy programs impacting every sector of the economy. A study
conducted a few years ago by Oak Ridge National Laboratory concluded
that for every federal dollar invested, over \$7 in direct energy
savings is achieved and almost \$11 in non-federal funds are directly
contributed to energy programs and projects. As noted, this study was
conducted several years ago when energy prices were substantially lower,
thus the projected savings today are even higher.

If Congress and the new Administration are serious about addressing
energy efficiency and renewable energy, the state energy network will be
crucial to achieving any of these goals quickly, if at all. This network
is robust and the energy offices generally serve as the program
implementers as well as energy policy advisors to the Governors. A
comprehensive energy effort must be coordinated, both at the federal and
state levels. There is no other existing vehicle that can do the
coordination. This funding allows the states to improve the energy
efficiency of homes, schools, hospitals, small businesses, local
governments, and the agricultural sector and to help the poor, elderly
and disabled. Funds are utilized to promote ENERGY STAR products and
work with energy service companies, utilities, local governments and
others on all types of energy projects. Aggressive implementation of
alternative fuels programs, as well as hybrid and plug-in hybrid vehicle
initiatives, is also part of this effort. States promote the use of
energy service performance contracts and implement these projects, which
reduces energy costs for all types of public and private facilities,
while keeping capital costs lower. States utilize these funds to support
new and innovative "Green Jobs", including training programs, workshops,
etc. States utilize these funds to implement more aggressive building
energy codes and conduct training for code officials, builders, local
building inspectors, architects and contractors. States facilitate all
types of energy financing programs for projects. States also utilize
these funds to conduct energy emergency preparedness and to respond to
energy emergencies.

The FY'07 Energy and Water Development Appropriations Bill provided \$50
million for this program. The FY'08 Appropriations were \$44 million,
including \$10 million for competitive programs (\$4 million of these
funds were siphoned off to other uses determined by the Department of
Energy). The FY'09 Appropriations Bills would have provided \$50
million, though the House bill would have provided one-half of these
funds for a "competitive" program between the states and the Senate
version would have provided \$50 million for base funding \-- an
approach we supported.

We recommend \$125 million for the stimulus package for SEP and an
additional \$125 million for the FY'09 Energy and Water Development
Appropriations Bill. If the energy portion of the stimulus package is
going to succeed, Congress and the Administration will require a
coordinating function at the state level as well as the federal level.
Making this program "competitive" between the states fails to support
the laboratories of innovation and the collaborative model of best
practices. After all, many of the nation's most successful energy
programs, including the precursor to the Federal Energy Management
Program, the Renewable Portfolio Standard, the Renewable Fuel Standards,
and performance contracting programs, were created through state
innovations and would never have occurred in response to a DOE-issued
"Request for Proposals."

**b) Weatherization Assistance Program**

The President-elect stated that he wanted to weatherize one million
homes per year for ten years. The FY'09 Continuing Resolution ("CR")
provided for \$477 million for the DOE Weatherization Program, up from
\$227 million in FY'08. The stimulus package should provide at least \$1
billion for Weatherization, in addition to the FY'09 CR. The FY'10
appropriations should be \$1.4 billion, and the ramp-up should continue
beyond that. While the ramp-up will be a challenge, especially in the
training area, it can be achieved. To ensure success, we strongly urge
that tens of millions of dollars from these funds be allocated to worker
training to get the community action agencies, local contractors and
local agencies qualified to perform high quality energy efficiency
retrofits.

**c) Energy Efficient Building Code Program**

EPACT 2005 authorized an expanded program to promote energy efficient
building codes, training and technical assistance. The states are
working to upgrade energy efficient building codes, but more is needed.
A massive new effort at training local building inspectors, code
officials, contractors, builders, utility personnel and architects is
needed to get these upgrades accomplished. We have worked with
congressional staff to create a national model standard with minimum
energy efficiency levels. We were greatly disappointed that the
International Code Council ("ICC") process led to energy efficiency
gains of less than twenty percent at the ICC meeting in September, when
the higher codes were examined. This is insufficient and far too slow.
Those who have opposed increased building energy efficiency codes have
generally argued that it is never a good time to increase codes. This is
a mistake. Congress should take two steps: a) increase funds from the
pitiful \$3.9 million presently provided for energy efficient building
codes to \$100 million for this effort; and b) move forward on
legislation to upgrade the energy efficient building codes on a national
level. This will require a commitment, not only this year, but for a
number of years.

**d) EPA ENERGY STAR Program**

The EPA ENERGY STAR Program, within the Climate Protection Division of
the Office of Air and Radiation, is an exemplary program. The FY'08
funding contained in the Interior and Environment Appropriations Bill
should be doubled to \$100 million in the stimulus package, and should
increase in base FY'09 funding and thereafter. The program works with
states, utilities and others to promote energy efficiency, saving
billions and reducing both electricity demand and natural gas demand.
This effort is absolutely a joint activity with the states and it needs
to expand.

A specific set of ENERGY STAR program expansion measures (totaling \$50
million) should be instituted as part of the stimulus package:

> 1\) **Energy efficient existing homes** (+\$12.5 million), including
> Home Performance with ENERGY STAR (which is a joint activity between
> the states, EPA and DOE). This promotes whole-home retrofits. We are
> working with contractors, utilities and others to bring the
> transaction costs down. We have instituted a pilot program in the
> Mid-Atlantic States. Additional training should be started promoting
> quality installation of heating and cooling equipment. For example,
> air conditioning units are frequently oversized and improperly
> installed, leading to more peak demand and inefficiencies.
>
> 2\) **Expanded energy performance ratings** systems for the nation's
> buildings (+\$7.5 million), should be instituted. Ten percent of U.S.
> building space has already utilized the EPA metrics (energy use/square
> foot). This performance rating could apply to 60 percent of U.S.
> commercial building space. Additional funding would allow the program
> to be expanded to the vast majority of the nation's buildings and
> would allow EPA to partner with states, local governments, builders
> and others.
>
> 3\) **Expanded small business programs** would allow greater technical
> assistance to this sector (+\$10 million), including small and
> medium-sized manufacturers and others. Again, the focus would be the
> proper installation of high efficiency services and products.
>
> 4\) **Expanded outreach** (+\$10 million) to states, utilities, local
> governments, elementary and secondary schools and other energy
> efficiency program sponsors in the implementation of energy efficiency
> programs. The ENERGY STAR "platform" can assist these emerging program
> sponsors in developing programs quickly, based on existing best
> practices for overall greater effectiveness.
>
> 5\) **Expanded outreach to state and local governments** (+\$10
> million) could help these entities serve as a "force multiplier" in
> achieving stated goals and monitoring and verifying energy savings.
> This includes technical assistance, sharing of best practices and
> programs, alternative financing approaches and matching funds for
> innovative state programs. This could also serve as a vehicle for
> identifying efficiency measures in water and wastewater treatment
> facilities, though the direct funding for the infrastructure
> improvements could be provided through other elements of the stimulus
> package.
>
> 6\) **Exploring new technologies and practices** (+\$5 million) could
> help EPA and DOE work together in their efforts to partner with the
> states, and local governments and would also help establish the
> "feedback loop" with the federal agencies to ensure that federal
> laboratory and other spending is sufficiently connected to the real
> world and programs that might be used by the population.

**e) Green Jobs**

In addition to the additional training requirements noted in the
Weatherization section and the building codes section, of this testimony
EISA authorized a new "Green Jobs" program. While it is authorized at
\$125 million, the funding should be \$250 million in the stimulus
package, and it should be increased over time.

To successfully address the nation's energy challenges, a wide range of
new workers will be needed, including insulation installers, air
sealers, HVAC professionals, plumbers, renewable energy installers,
energy auditors, etc. The unions have established extensive
apprenticeship training efforts, which should be supported. Training is
also needed for local code officials, contractors, building inspectors,
and architects. In the industrial area, an expansion of the Industrial
Assessment Centers should be an important priority, along with expanded
coordination with the state energy and economic development officials.
Community colleges, technical colleges, manufacturing extension
services, cooperative extension activities (through USDA and state
agricultural agencies), are also key elements of a training regime. This
will require not only stimulus funds, but also persistent funding over a
period of years. Recent initiatives in Arizona, Maryland, Massachusetts
and New York could be excellent models for other state and federal
initiatives.

In addition, we recommend a new assistant secretary for "Green Jobs" or
workforce development be established. This could be at DOE or DOL, or
both. The key will be coordination.

**f) "REAP" Program**

While technically not jurisdictional to this Committee, we strongly urge
Congress and the Administration to expand the renewable energy and
energy efficiency program for farmers, ranchers and rural small
businesses, which was authorized in the Energy Title of the 2002 Farm
Bill, and reauthorized and expanded in the Energy Title of the 2008 Farm
Bill. This program has been successful thus far, but could be a more
important lynch pin of federal energy and agricultural policy. This
program should be funded at a level of \$250 million in the stimulus
package and an additional \$250 million in FY'09. There is an existing
competitive program operated by USDA, with cooperation from the state
agricultural agencies, the state energy agencies and the agricultural
extension agents. Recent proposed changes by the present Administration
is pushing more funds towards loans and less to grants. This is a
mistake; especially in a faltering economy. The focus should be on
grants, with reduced match requirements, as well as technical assistance
programs. In addition to the stimulus package, we would recommend base
program funding in FY'09 of \$250 million, with increasing amounts in
the future.

**g) Low-Income Home Energy Assistance Program (LIHEAP)**

In the FY'09 CR, Congress doubled the LIHEAP program to \$5.1 billion.
The funding is still inadequate to the task. Energy prices have
dramatically increased in the past five years and low-income, elderly
and disabled consumers are paying up to 20-30% of their net income for
energy costs. This includes not only natural gas and electricity, but
also heating oil and propane, which have experienced extreme price
volatility. The state level energy organizations support a funding level
of \$7.6 billion, which would serve between one-third and one-half of
the eligible population. As you know, even at these higher funding
levels, LIHEAP funds provide only a share of energy costs. Recent
surveys by the National Energy Assistance Directors Association
("NEADA") have shown that shut-offs of utility service have increased
substantially in 2008. Recent oil price decreases have not saved poor
consumers from these price increases. Again, a consistently higher
funding level for LIHEAP is critical to serving the poor. The energy
efficiency building retrofit program discussed elsewhere in this
testimony would not duplicate either LIHEAP or Weatherization.

**4) Boost the Energy Tax Incentives**

One of the simplest steps Congress could take to promote long term job
creation and new energy investments is to increase the energy tax
incentives. Recent congressional action to extend a number of the energy
efficiency and renewable energy tax provisions for a period ranging from
one year to eight years was a positive step. We recommend that these
provisions uniformly be extended to the eight years established for the
solar investment tax credit to provide stability to this industry. This
includes the PTC, ITC, CREBS, energy efficiency tax credit for new and
existing homes, and the commercial buildings energy efficiency deduction
(which should be expanded from \$1.80/square foot to \$3/square foot, in
accordance with the proposal from the American Institute of Architects)

Several additional tax changes could also make a significant impact.
First, in light of the credit crunch and the desire to deploy these
technologies, a refundable tax credit should be instituted. These
credits also should be transferable. In addition, state tax benefits
should not be offset against the federal tax benefits for energy
efficiency and renewable energy.

Second, to boost job creation in homeowner building retrofits, the
energy efficiency tax credits should be increased from 10% of materials
(up to \$500 per home) to 50% for materials *and* labor (up to \$2500
per home). Contractors would promote such an incentive directly,
ensuring a real world impact without government implementation or delay.

Finally, the new tax credit for plug-in hybrid and electric vehicles
should also be extended.

**B) ADMINISTRATIVE CHANGES**

**1) White House Energy Council**

We support creation of a White House National Energy Council.
Coordination of DOE, EPA, USDA, DOI and other agencies should be a high
priority of this new position. In the 1990s, through 2001, the state
energy agencies, the state utility commissions, the state air program
administrators and the state environmental commissioners (with support
from the federal government) met to coordinate policies, programs and
initiatives. The state agencies have begun meeting again to reinvigorate
this effort. The support of the new White House National Energy Council
and the Council on Environmental Quality would be critical to this
effort.

**2) Energy Efficiency and Renewable Energy Office**

Sadly, over the past few years, the Department of Energy has become
largely irrelevant to the real energy challenges facing the nation.
First, the procurement process for the Department of Energy's Energy
Efficiency and Renewable Energy Office is not working. It has gotten
slower and has become more distant from the states, local governments
and other governmental and private initiatives.

Second, with the elimination of DOE's regional offices a few years ago,
the substantive connection between the federal government and the states
has been washed away. The state energy offices pledge support to new
regional efforts and we have numerous suggestions on DOE reorganization.

Third, the "stovepipes" remain at DOE, where the technologies are not
meshing. A bright spot has been the industrial energy efficiency
program, with increased levels of cooperation between the federal
government and the states. We are hopeful that with the recent new
management in the state and local program office, and a new commitment
from the incoming Administration, successful joint programs could be
instituted.

We also recommend the creation of Senior Deployment Coordinators in each
of the end-use offices at the Energy Efficiency and Renewable Energy
Division. These individuals would help work with states, local
governments, and the private sector to help get the work of the national
laboratories and these offices into the marketplace. There is a
fundamental lack of understanding at DOE about the connection between
R&D and deployment. The deployment function is not seen as important and
there is no institutionalized feedback mechanism between the states and
DOE on what works and what does not work. R&D cannot be done in a
vacuum. New efforts at commercialization have been a useful start.

We would also recommend expansion of the Technical Assistance Program
("TAP") coordinated by the National Renewable Energy Laboratory
("NREL"), which utilizes federal laboratory expertise and other DOE
contractor resources to assist the states in implementing innovative
policies, based upon best practices.

The Federal Energy Management Program ("FEMP") now has strong
leadership. However, there is approximately \$1.3 billion in Energy
Service Performance contracting projects in the pipeline. Leadership
from the White House is needed to order agencies, including DOD, to
expedite these projects. A separate proposal being considered by the
President-elect and Congress to add significant funding to FEMP projects
would also expedite federal energy efficiency measures.

**3) Office of Electricity and Energy Reliability**

This office does an excellent job with very limited resources \-- but
they need more resources. First, NASEO supports expanded efforts to make
the transmission and distribution grid more robust and reliable and
creating a "Smart Grid". Second, DOE must do more to help prepare the
country for energy emergencies. Many in Washington, D.C. do not
appreciate that DOE has significant responsibilities for energy
emergency preparedness and response, and that these efforts are often
done in conjunction with state governments. Funding has been cut for
energy emergency preparedness and it has significantly impaired our
nation's ability to respond to energy emergencies. For example, the
National Infrastructure Protection Plan ("NIPP") needs to be upgraded
and more regional energy emergency exercises need to be conducted.
Finally, increased funding for the basic OE function should be provided,
as should increased funding for the energy emergency function. Enhanced
coordination with FERC, the state energy agencies, and the state utility
commissions should be encouraged. Recent efforts to create Clean
Renewable Energy Zones should be expanded.

**4) Energy Information Administration**

The Energy Information Administration ("EIA") needs more resources to do
its job more effectively. While not necessarily part of a stimulus
package, there are a number of items that are falling behind. Section
805 of EISA required EIA to develop a plan and identify additional
measures. Just as the state programs have been cut, so has EIA. This
agency has not had enough funds to make investments required to ensure
its surveys accurately track rapidly changing markets. EIA data is
relied upon and, of course, inaccurate data can distort energy-related
decisions. For example, EIA's natural gas storage report, released in
November 2005, erroneously showed a substantially larger than expected
withdrawal. As a result, December futures on the NYMEX immediately
jumped sixty cents, costing consumers an additional (and unnecessary)
\$100 million - \$1 billion. FERC's Office of Market Oversight concluded
that this incident illustrates the need to make more supply and demand
information available to the public. EIA's \$97.8 million budget in
FY'08 will not allow the agency to update needed data sets, provide
critical data on carbon emissions to help the country address climate
change, provide more state-level data information (and in a more timely
manner), provide more data on ethanol and biodiesel use and penetration,
update data on demand response, expand the heating oil, propane and
natural gas program operated in coordination with the states and provide
more accurate data on state-level programs (especially using comparable
data from different states), etc.

**5) Office of Policy**

**\
**DOE's Office of Policy had previously been involved in more
discussions among offices at DOE and with the states and other
interested parties. This function has been substantially diminished in
the past few years. We strongly urge DOE to aggressively enhance the
involvement of this office in developing energy policy, working with the
states and with the proposed White House National Energy Council.

**C) ENERGY LEGISLATION**

Beyond some of the stimulus measures and administrative changes
discussed above, Congress and the new Administration will be considering
important new policies including, but not limited to, a Renewable
Portfolio Standard and an Energy Efficiency Resource Standard, expansion
of authority to set multiple performance standards for appliances,
building labeling models, energy efficient mortgages, expanded grants
and programs for multi-family and manufactured housing, etc. One program
that has not been widely discussed, but should be, is a national effort
to provide rebates to the owners of the 2 million pre-1976 manufactured
housing units in the country. These are terrible energy wasters for
people who are generally very poor. This rebate program could be modeled
after examples in Maine and New Hampshire and would encourage people to
upgrade to ENERGY STAR homes.

**CONCLUSION**

Clean energy investments, such as incentives for attic insulation or
solar panels, offer the ability to stimulate the economy and create
green collar jobs, while at the same time reducing household energy
bills, advancing the nation's energy security, and addressing our
climate and environmental challenges. The states are uniquely positioned
to jump start real world energy projects in weeks, not seasons. We urge
Congress to leverage the federal government's resources with state's
ability to innovate and quickly implement energy projects on the ground.
We also hope to have the opportunity to work with DOE, EPA, USDA, DOI
and the possible White House Energy Council, in addressing a set of
coordinated policy measures.