NCLC has responded to NASEO’s RFI regarding an essential component of state’s IRA home energy rebates programs — consumer protections. The Department of Energy’s one-time nearly $9 billion home energy efficiency and electrification rebates provide an opportunity to package critical energy efficiency investments to the most vulnerable households, but it could open the door to unfair or predatory practices. We draw from the lessons of PACE financing and provide consumer protections to protect low-income consumer energy affordability and protections from unaffordable costs or predatory practices.
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