Energy Efficiency and the Proposed EPA Clean Power Plan

In June 2013, based on the authority provided in Section 111(d) of the federal Clean Air Act, President Obama directed the U.S. EPA to “issue carbon pollution standards, regulations, or guidelines, as appropriate, for modified, reconstructed and existing power plants”. He asked the EPA to issue proposed standards or guidelines by June 1, 2014 and final standards or guidelines a year later requiring States to submit plans by June 2016 to implement the carbon emissions standards.  

On June 2, 2014, the EPA issued its proposed Clean Power Plan (CPP) to cut carbon pollution from power plants – the largest source of carbon pollution in the U.S. – by 30 percent from 2005 levels. The proposed draft rule includes State-specific goals for CO2 reductions with guidelines for the development, submission and implementation of State plans. In applying a “best system of emission reduction” standard, the EPA established three “building blocks” through which States can develop and implement their compliance plans. These include:

1.    Heat rate improvements of energy generating units.

2.    Reducing emissions at the most carbon-intensive units by substituting less carbon-intensive resources.

3.    Expanding low- or zero-carbon generation

On October 23, 2015, the US EPA published their Final Rules for the Clean Power Plan, as well as Draft EM&V Guidance for Demand Side Energy Efficiency.


NEEP Actions Supporting the US EPA’s Clean Power Plan

As the Northeast and Mid-Atlantic region has some of the most mature, cost-effective and successful energy efficiency policies seen anywhere in the U.S., NEEP zeroed in on this building block as the key to state compliance with the proposed Clean Power Plan. Over the last year, we have worked with a variety of stakeholders – our fellow Regional Energy Efficiency Organizations, or REEOs; state air and energy offices and regulators; efficiency program administrators; and other energy efficiency advocates – to help foster greater understanding of the role of energy efficiency in meeting the CPP requirements, and to prepare comments to the US EPA supportive of the comprehensive inclusion of energy efficiency as a key strategy to reduce power plant carbon pollution.  This effort addressed a variety of topics, including the complex issue of evaluation, measurement and verification (EM&V) of energy efficiency programs.     

NEEP strongly supports the EPA and its plans to create a more sustainable, reliable and affordable energy future for the U.S. that complements successful state policies to aggressively reduce carbon pollution through increased energy efficiency. In November 2013 NEEP staff joined other REEOs in providing to the US EPA a paper on this topic.  In November 2014 NEEP staff filed with US EPA joint comments with 14 other stakeholders on the topic of EM&V, and on December 1, provided supplemental NEEP staff comments on other topics supporting energy efficiency as a key strategy to reduce power plan carbon pollution. In January 2016, NEEP Staff facilitated a diverse group of stakeholders for joint comments on the EM&V within the Clean Power Plan's Model Trading Rule, as well as draft EM&V Guidance for the Clean Power Plan itself.

See NEEP's comments to the EPA on the proposed Clean Power Plan, and updates and informational resources on this topic, below:

Joint Stakeholder Comments to EPA on Draft EM&V Guidance in the Clean Power Plan (1.21.16)

Joint Stakeholder Comments to EPA on EM&V in the Model Trading Rule (1.21.16)

NEEP’s Comments to EPA on Proposed Clean Power Plan (111d) (12.1.14)

Supplemental RGGI Comments to EPA (12.1.14)

Joint Stakeholder Comments on EM&V Elements of Proposed Clean Power Plan (11.26.14)

Initial RGGI Comments to EPA (11.5.14)

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