Northeast Energy Efficiency Partnerships Comments On 111(d)

NEEP Applauds the Obama Administration for its work on regulating CO2 as a pollutant having serious public health, economic, and environmental impacts

Lexington, MA, June 2, 2014 – In response to the U.S. Environmental Protection Agency’s (EPA) proposal of a commonsense plan requiring states to reduce their greenhouse gas emissions from existing power plants, Northeast Energy Efficiency Partnerships (NEEP) commends the Obama administration for its recognition of the value of energy efficiency as a first-order resource available to states to address the proposed regulations

Carbon pollution from existing power plants is the nation’s largest source of greenhouse gas emissions, and tackling this issue will significantly improve our nation’s climate, economy, and public health. As a leader in energy efficiency, the Northeast is poised to stand as a successful example of how a mass-based emissions reduction approach can dramatically lower carbon emissions from power plants while also providing jobs and growing economies.

"The Northeast and Mid-Atlantic regions have been showing, through smart energy efficiency programs, policies like energy codes and appliance standards, and the Regional Greenhouse Gas Initiative (RGGI), that states can reduce their greenhouse gas emissions while maintaining strong economic growth,” says Susan Coakley, NEEP Executive Director. “We look forward to working with states and utilities in our regions to find creative ways to use energy efficiency programs to comply with the EPA's carbon pollution rules.”

Additionally, here are some of the key messages that NEEP supports in reaction to the EPA’s proposal, and as we move into the subsequent period of analysis.  

  • As states will ultimately need to develop compliance plans with these new federal emissions standards for greenhouse gasses, NEEP points to the value and demonstrated success of energy efficiency as a least-cost resource to back down the demand for power plant generation and, thereby, avoid air emissions.
  • NEEP supports the idea that all efficiency resources be allowed to count towards reduction goals—including rate payer-funded programs, complementary policies like building energy codes, building rating, appliance efficiency standards, and local energy initiatives.
  • NEEP supports an aggregated or “mass-based” emissions reduction approach consistent with RGGI, successfully in operation since 2009.
  • The Northeast is an example of how a multi-state cap and trade pact has significantly reduced carbon emissions across the region and resulted in substantial economic savings for residents and businesses alike. In its first three years, RGGI delivered $1.3 billion in lifetime energy bill savings for utility customers, helped an estimated 2,400 workers secure training in clean energy job skills, and generated $545 million in auction proceeds that went directly to state efficiency programs. And, most importantly, the Northeast states cut their CO2 emissions by 23 percent in just the first three years of the program.
  • For the Northeast/Mid-Atlantic states who currently or may participate in RGGI, NEEP supports recognition RGGI as the compliance path for those states under 111 (d).
  • There are multiple benefits of efficiency as a compliance strategy. Not only would it be less costly to generators who emight otherwise install costly technology onsite; it actually delivers an economic benefit, as RGGI has shown.
  • RGGI was a non-partisan construct. It was first proposed by Republican Governor George Pataki of New York, and it was the administration of former Governor Mitt Romney in Massachusetts that first modeled that if you double efficiency investments, a state could turn RGGI into a net economic positive.
  • The energy efficiency and other clean energy investments enabled by RGGI proceeds has helped to significantly reduce emissions in the region, thereby mitigating public health threats from carbon and other power plant pollutants. Again, it has done this without economic harm.
  • Lastly, NEEP does not believe that allowances should be given for free to generators but auctioned for public benefit purposes, with  proceeds reverting to states for reinvestment in CE programs or measures, similar to what happens with RGGI.
  • For states that use energy efficiency as a means of meeting CO2 reduction targets, NEEP would strongly encourage those states to adopt a policy of pursuing all cost-effective energy efficiency that is less than the cost of new generation resources.
  • While NEEP understands the need for flexibility in how states meet their emissions reductions, we stress that it is important to keep the bar high for leading states, while encouraging states with less mature efficiency programs to keep moving forward.
  • NEEP is home to the Regional Evaluation, Measurement and Verification Forum. While our region is further ahead than some parts of the country in at least beginning the dialog on consistent protocols and data sharing, we are fully aware that there is much work to be done at the state level and among the states. Still, this is something to strive for and is important in attempting to quantify the benefits of efficiency.
  • Whichever compliance model is chosen by states, NEEP submits that transparency and consistency in evaluation, measurement and verification protocols should be fostered. If states are already conducting sufficient EM&V of their efficiency programs, there need not be additional verification of savings.

To speak with a NEEP expert on the value of energy efficiency and the role it will play in the EPA proposal, please contact Lisa Cascio, NEEP Public Relations Manager, at or 781-860-9177 ext. 137.


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