The Environmental Protection Agency (EPA) is about to put the proverbial pen to paper as it begins writing proposed “emissions guidelines” for states to regulate carbon dioxide (CO2) emissions from existing power plants under Section 111(d) of the Clean Air Act. 

As discussed in my previous posts Energy Efficiency, Systems Approach Needed to Achieve CO2 Goals and Energy Efficiency: Role in Prospective Power Plant CO2 Rules?, this potentially is a very big deal for energy efficiency as it could play a significant role in achieving cost-effective emissions reductions. This regulatory process is also a key component of President Obama’s Climate Action Plan, where the president reiterated a goal of doubling U.S. energy productivity by 2030 as had been recommended in Energy 2030. 

Justifiably, the EPA has embarked on an unprecedented stakeholder engagement process, seeking input from states, businesses, non-governmental groups, and individuals well in advance of any formal regulatory proposal. It has held listening sessions and webinars, participated in workshops, and is accepting informal comment.

Earlier today, the Alliance and the American Council for an Energy-Efficient Economy (ACEEE) submitted our joint comments in response.

Our comments to the EPA:

The Alliance and the American Council for an Energy-Efficient Economy (ACEEE) have teamed up to provide joint comments to the EPA in response to a series of stakeholder questions.  

We reinforce that energy efficiency is the Nation’s “first fuel,” having already delivered large economic and environmental benefits, including through a growing number of state electric end-use efficiency programs. Energy efficiency remains our most abundant, reliable, cleanest and cost-effective energy resource.

We strongly support recognition and encouragement of energy efficiency as an emissions reduction strategy and a means to help achieve compliance with air quality regulations.  We believe that the Clean Air Act allows and EPA ought to incorporate in its 111(d) emissions guidelines:

• A system-based approach to setting standards that considers the entire electricity system rather than a source-based approach that only includes measures that can be taken within the fence lines of individual power plants,
• Flexibility for states to apply various compliance strategies, including end-use energy efficiency,
• A way to recognize and build upon diverse state experiences, such as the growing number of state energy efficiency resource standards and the Regional Greenhouse Gas Initiative, and
• Good guidance to states, particularly for states with modest resources and limited energy efficiency experience, to help them implement 111(d) requirements while also allowing states the flexibility to tailor implementation to their circumstances and to be innovative.

Moving Forward on 111(d)

The Alliance will continue to work with the EPA, our Associates, states, non-governmental organizations, and other stakeholders to advance policies and programs that recognize and encourage energy efficiency in helping to meet environmental objectives.

Our full comments can be found here.