Official comments from the Puerto Rican Green Energy Association (APEV), in the matter of WAP:

FOR IMMEDIATE RELEASE
(Free-Press-Release.com) November 23, 2011 -- My name is Allan Rivera, a resident of Toa Baja, Puerto Rico. Owner of a residential property, father and husband. Active in our Puerto Rican community in community causes such as the educational and technical assistance for more than 5000 MS patients in the country, science clubs in schools and community schools as well as retired cultural promoter.

Since 2006, chairman of the Puerto Rican Green Energy Association, a non-profit corporation for education to residential and business subscribers, in the legal, technical and scientific aspects of energy production in Puerto Rico: establishment of research and development of pilot energy projects, water and waste management as sustainable agriculture.

APEV is the only institution in Puerto Rico trained by Point Carbon, with education, metrics and management structure for carbon credits based on world markets schemes and sustainability projects backed by the United Nations through the Kyoto treaty for reducing greenhouse gases.

As a member of the Governing Board of the Savings and Credit Cooperative (APEVCOOP), we are promoting savings and loan products, efficiency audits and green loans.

Comments:

Our comments are on the Weatherization plan proposed for the territory of Puerto Rico. The WAP is useful and beneficial for the low income residential owner/renter, some are associates to APEV. We bring our vision of an efficient weatherization program in Puerto Rico and strongly support the need to implement best practices to the climate of the Caribbean to reduce electricity consumption generated from fossil fuels.

We present the following comments and observations on the proposed Puerto Rico's WEP draft:

1. It is necessary that the program management be monitor regularly and audit the management of these funds, with the participation of cooperatives and nonprofit corporations. APEV is available to represent the partner /owner of our nonprofit corporation and cooperative. More than 200 members of APEV prospects are expecting to use the program to their advantage and will undergo education on: "best practices" that APEV recommend before hiring an energy auditor and the legal framework to the consumer.

The federal weatherization program (WAP) since 1976 is directed to the residential subscriber with limited income. It is based on non-profit corporations and community-based education providers and services and maximizes the financial incentives between cooperative partners/owners.

2. We understand that the funds are for the implementation of the WAP in residential structures. They are not to train, educate or hire any consultant or buy equipment that uses a contractor.

We submit a petition for do an underlined in these matters and put in bold black letters according to the standard allowed by law (U.S. Department of Justice/Americans with Disabilities Act (ADA)), all terms to contractors and subservices. It is our desire to help auditing the funds so that most benefits go to the homes of people with disabilities such as Multiple Sclerosis, Asthma and lodging that are subsidized by the Puerto Rico Energy Public Authority (PREPA).

In Puerto Rico there is sufficient educational forums for professional groups such as: Bar of Engineers of Puerto Rico, Bar of Electrical Surveyors of Puerto Rico, U.S. Green Building Council-Chapter of PR, ACONER-PR, College of Arts and Mechanics- Mayaguez and Higher education institutions and vocational skills Institutes.

3. We consider necessary to include in this draft, which certifications will be required to meet qualifications for energy audit professionals, installation and implementation of products in Puerto Rico. The WEP management must express this in a policy of openness and cooperation with APEV, non-profit corporations and cooperatives and let us participate auditing the results in inhibited carbon tonnage among other data generated by the program. PREPA, in 2007 reported about $78 million that consumers saved with an efficiency lighting program, solar thermal heating and Energy Star program.

The government of Puerto Rico will receive other ARRA grants as part of the State Energy Program (DOE) totaling approximately $37 million, of which the education necessary to lead this and other programs including proposed by APEV can be developed. APEV requires additional explanations about the WEP's administrative costs on this draft.

4. The proposed plan does not offer specifically how it will form the public policy committee and does not commit the participation of non-profit corporations or cooperatives of workers in the various stages of the WAP. We suggest a role of the Department of Consumer Affairs of Puerto Rico in the audit of the proposed weatherization program.

We offer our comments with the intention that they are accepted in its entirety as part of the DOE finally approval to the territory of Puerto Rico. Copies of this document are being provided to DOE and EPA respectively.

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