Utah Clean Energy is grateful for the opportunity to offer comment on the Governor’s Utah Energy and Innovation Plan. We have been working on energy in Utah for 20 years and the technological advances, economic opportunities, and ability to provide Utahns with affordable, reliable clean energy while addressing air quality and the costly risks of climate change, are at our fingertips. We look forward to working with you to lead Utah through this important transition in the manner Utah has on other tough issues: with compassion, ingenuity, and pragmatism. Giving thorough attention to social and racial equity in Utah’s energy planning efforts is of paramount importance. Planning with the science of climate change, and the desire to protect future generations should be cornerstones of Utah’s Energy and Innovation Plan.
This document includes near-term recommendations in key areas affecting our economy and our energy resources. Thank you for considering these comments and please know that our staff of 13 is focused entirely on clean energy solutions, and is a resource for you and your team.
- Make Energy Efficiency a Priority Resource. The cheapest and cleanest form of energy is the energy that we don’t use. Energy efficiency also supports over 30,000 Utah jobs. The Utah Energy and Innovation Plan should include goals to improve the energy efficiency of Utah’s new and existing homes and buildings, which lowers costs for Utahns while supporting clean air and local jobs.
- Adopt updated energy conservation codes as they are published for both residential and commercial buildings and continue Utah’s energy code training program to support the implementation of energy codes in Utah. (Utah should apply for federal funds from the Federal Infrastructure Investment and Jobs Act (IIJA Title V, Subtitle B, Section 40511) to support this.)
- Develop a home energy upgrade revolving loan program with a goal to retrofit 10,000 homes by 2030 with an initial focus on home energy upgrades across rural Utah. (Utah can leverage federal funds from the Federal Infrastructure Investment and Jobs Act (IIJA Title V, Subtitle A, Section 40502) to develop and launch a program in Utah.)
- Launch a Utah home energy labeling pilot program to give much-needed information to homeowners and prospective home buyers about the energy use, energy costs, and emissions footprints of homes. This program would directly complement the previous recommendation for a home energy upgrade revolving loan program. (A pilot program should be based on OED’s Home Energy Label report submitted to the Utah Legislature in Nov 2021.)
- Adopt updated energy conservation codes as they are published for both residential and commercial buildings and continue Utah’s energy code training program to support the implementation of energy codes in Utah. (Utah should apply for federal funds from the Federal Infrastructure Investment and Jobs Act (IIJA Title V, Subtitle B, Section 40511) to support this.)
- Support Building Electrification. By 2024, area sources, including our homes and businesses, will be the greatest contributor to air pollution in Utah—approximately 40% of all emissions. Electrification supports cleaner air by accelerating the adoption of combustion-free appliances, and heating and cooling equipment in our homes and buildings.
- Evaluate the opportunities to retrofit Utah’s current housing stock, and programmatic workforce needs necessary to scale-up energy efficiency and electrification in buildings.
- Incorporate building electrification and demand response into energy efficiency planning and other energy planning efforts.
- Work with the Legislature to develop an “Energy and Innovation Solutions Fund” or other innovative financing mechanisms to provide affordable financing to scale-up energy efficiency, resiliency, and emissions-reducing technologies in Utah. These should be targeted at low-income, rural, and communities of color that may face higher energy burdens and not have resources to pay for energy saving projects upfront.
- Evaluate the opportunities to retrofit Utah’s current housing stock, and programmatic workforce needs necessary to scale-up energy efficiency and electrification in buildings.
- Accelerate Adoption of Zero-Emission Vehicles. The Cox-Henderson administration has prioritized accelerating the adoption of zero-emission vehicles in order to reduce emissions, as shown in the One Utah Roadmap 2.0. Recently the Federal Government announced a historic investment in zero-emissions vehicles, and Utah should ensure its plans are responsive to new requirements to have a competitive advantage during grant selection.
- Expand UDOT’s Statewide EV Charging Plan to include all areas of transportation electrification, including public transit and other e-mobility opportunities.
- Support the new Statewide Electric Vehicle Charging Steering Committee and provide robust opportunities for participation and input by the public.
- Identify and utilize new federal resources from the Infrastructure Investment and Jobs Act to rapidly deploy new electric vehicle charging infrastructure and purchase new zero-emissions vehicles, including school buses and heavy-duty vehicles.
- Expand UDOT’s Statewide EV Charging Plan to include all areas of transportation electrification, including public transit and other e-mobility opportunities.
- Expand Renewable Energy Development. Utah benefits from abundant renewable energy potential, including wind, solar, and geothermal, which create jobs and long-term tax revenue especially in rural communities. Utah’s energy policy should encourage the development of our low-cost renewable energy resources and signal to investors and developers that Utah is open for business.
- Support regional energy markets. Moving towards an integrated electricity market in the West will diversify our energy and transmission resources, saving money for customers and creating a more resilient and reliable grid. Several states in the West are aggressively pursuing the creation of a west-wide energy market to gain access to these benefits for their residents. Utah needs to be a part of this discussion.
- Revisit Utah’s Renewable Portfolio Standard and set a new target that reflects the potential for clean energy and storage resources to serve a substantial portion of Utah’s future energy needs.
- Support investments in battery storage and demand response to improve the reliability and flexibility of Utah’s grid. Battery storage and demand response are extremely flexible resources that can be dispatched on-demand to meet changing energy needs.
- Support regional energy markets. Moving towards an integrated electricity market in the West will diversify our energy and transmission resources, saving money for customers and creating a more resilient and reliable grid. Several states in the West are aggressively pursuing the creation of a west-wide energy market to gain access to these benefits for their residents. Utah needs to be a part of this discussion.
- Invest in Grid Modernization to Make Utah’s Electricity System More Resilient. Utah is gifted with an incredible solar resource. Portfolios of distributed energy resources such as solar, energy storage, and smart appliances, can deliver both energy savings and improved resiliency to Utah families. Fully leveraging the potential of new technologies will require modernizing our electricity infrastructure. The plan should prioritize innovative distributed energy resource projects that demonstrate the benefits of diversifying our energy mix and protecting families from power outages. Utah can leverage new financial resources from the Federal Infrastructure Investment and Jobs Act to fund Grid Modernization and other clean energy investments.
