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Andrew Barbeau

Technical Expert Testimony

Andrew Barbeau

Technical expert Andrew Barbeau, President of the energy consultancy The Analysis Group, testified that ComEd must change the way its performance is measured to meet the requirements of the Climate and Equitable Jobs Act (CEJA).

ComEd’s proposed metrics do not require it to differentiate between locations within its system, even though research shows that service varied greatly depending on where customers lived: frontline communities in Chicago had outages 83% more frequently and for 140% longer than other Chicago communities.

Barbeau proposed that the Illinois Commerce Commission require ComEd to use equity-focused metrics that reflect CEJA goals and that would improve the level and reliability of services provided to frontline communities. An example is the Reliability and Resiliency in Vulnerable Communities Metric. Including “resiliency” in the metric reflects the need to account for impacts of outages on customers, given that wealthier communities can withstand and recover from electricity outages better than more vulnerable communities. He also described the need for metrics that encourage development of distributed energy resources.

Barbeau described in detail how he arrived at four metrics that would help measure and hold ComEd accountable for providing equitable electric services in frontline communities.

The Commission agreed in September 2022, requiring the utility to increase the beneficial impact of reliability upgrades within frontline communities in order to receive a performance incentive. The Commission noted that it shared EDF’s concerns that frontline communities are burdened by longer and more frequent outages than other communities.

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As state energy regulators navigate the clean energy transition and equity issues, they must also consider language access, which. ensures that everyone can receive information on how to access rate support programs. State energy regulators should consider implementing current EPA guidance on best practices for language access, which includes translating information into every language spoken by at least five percent of people in the relevant area. State energy regulators should err on the side of over-inclusivity in translation to non-English languages. Environmental justice must be considered in every aspect of the energy transition. From access to translated information to access to heat in the middle of winter, no one should be left behind. EDF is working to ensure that equity concerns are at the forefront of policy conversations at public utility commissions. Haley Maher is a third year law student at the University of Colorado. This blog is based on her research as an intern at Environmental Defense Fund in summer 2024.   Memmott, T., Carley, S., Graff, M. et al. Sociodemographic disparities in energy insecurity among low-income households before and during the COVID-19 pandemic. Nat Energy 6, 186–193 (2021). https://doi.org/10.1038/s41560-020-00763-9 DPU Issues Notice of Investigation on Energy Affordability for Massachusetts Ratepayers, Department of Public Utilities, https://www.mass.gov/news/dpu-issues-notice-of-investigation-on-energy-affordability-for-massachusetts-ratepayers Affordability and Energy Bills, Colorado Department of Regulatory Agencies, https://puc.colorado.gov/affordability#:~:text=The%20Commission's%20Affordability%20Initiative%20demonstrates,a%20letter%20from%20Governor%20Polis. Massachusetts Low Income Home Energy Assistance Program (LIHEAP), Benefits.gov, last accessed Aug 6, 2024, https://www.benefits.gov/benefit/1576 Low Income Home Energy Assistance Program (LIHEAP), Benefits.gov, https://www.benefits.gov/benefit/623 About Us, Mass Save, Last accessed Aug. 6 2024, https://www.masssave.com/en/about-us Paying for Power a Struggle for Some, Consumer Watchdog, https://consumerwatchdog.org/uncategorized/paying-power-struggle-some/ Guidance to Environmental Protection Agency Financial Assistance Recipients Regarding Title VI Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons, 69 F.R. 35602, https://www.govinfo.gov/content/pkg/FR-2004-06-25/pdf/04- 14464.pdf