NEEP, with ACEEE, drafted and facilitated joint EE stakeholder comments regarding EM&V provisions in EPA’s proposed Clean Power Plan Federal Plan and Model Trading Rules (MTR), and its draft EM&V guidance for demand side energy efficiency (January 2016). Note that because the Joint EE Stakeholders comments address both EM&V provisions in EPA’s proposed Fed Plan/MTR and the EM&V guidance, the links below are to the same comments, but different cover page.
Jan 2016 Joint EE Stakeholder Comments to US EPA Regarding EM&V in proposed Model Trading Rules (Docket ID No. EPA-HQ-OAR-2015-0199)
Jan 2016 Joint EE Stakeholder Comments to US EPA Regarding draft EM&V Guidance
2014 Joint EE Stakeholder Comments on EM&V Elements of Proposed Clean Power Plan