HRC Comments to DOE on Defining “Inadequate Electric Service”

The Hydropower Reform Coalition (HRC) submitted these comments in response to the Department of Energy (DOE) request for information (RFI) on the definition of the term “inadequate electric service,” which appeared in the 2020 update to Sec. 242 of the Energy Policy Act of 2005

“Section 242 of the Energy Policy Act of 2005 (Pub. L. No. 109-58) established an incentive payment program to benefit owners of qualified hydroelectric facilities who add electrical generation equipment to existing dams. Section 3005 of the Energy Act of 2020 (Pub. L. 116-260) then amended Section 242 by expanding the definition of a qualified hydroelectric facility to include certain facilities “constructed in an area in which there is inadequate electric service,” which requires the Secretary to take into consideration (a) access to the electric grid; (b) the frequency of electric outages; or (c) the affordability of electricity.” (DOE RFI)

These comments are framed as responses to specific questions outlined in the RFI.

In December 2021, DOE released guidance on the definition of “inadequate electric service,” which takes into account some of the HRC recommendations.