After nearly six months, the comment period for EPA’s Clean Power Plan has concluded. The Plan aims to limit carbon dioxide (CO₂) emissions from existing power plants while affording states great flexibility to develop compliance approaches that most suit their contexts. 

Energy efficiency is prominently featured in the Plan as a way for states to most cost-effectively meet their emissions targets. Time and again, energy efficiency has been shown to be our least expensive, cleanest, most abundant and most reliable energy resource — our nation’s “first fuel”.

While offering great flexibility, the Clean Power Plan also presents challenges and complexity. Unprecedented levels of communication and collaboration are occurring among state air regulators, utility commissioners and energy officials who will grapple with how their areas of responsibility interact with the Plan.[1] Utilities, regional transmission operators and independent power generators will all be affected. Various private and public sector entities — energy service companies, local efficiency programs, weatherization providers and building code officials, among others — can play important roles to help their states meet emission goals while also pursuing their corporate, organizational or programmatic missions.

The Alliance has submitted a set of comments on the rule after an extensive period of engaging with EPA, Alliance Associate members, state officials and other corporate, non-governmental and public sector stakeholders. The comments help encourage energy efficiency as an emissions reduction strategy while strengthening its recognition and the crediting process.

Our comments center on several important areas where the Plan and its supporting technical documents can be clarified and strengthened. Recommendations include:

• Explanation should be provided by EPA on implications for states of choosing mass over rate-based targets.
• Provide clarification and guidance for states and other entities on including non-utility ratepayer-funded energy efficiency programs, policies and measures in state compliance plans.
• Provide states with clearer guidance on a number of issues related to evaluation, measurement and verification (EM&V) of energy savings.
• Address interactions of EM&V, quantification and enforceability issues for energy efficiency.
• Address inter- and multistate issues concerning crediting of energy efficiency.
• Take early action crediting issues.
• Strengthen the opportunity and benefits of combined heat and power (CHP) and waste heat to power (WHP) in the context of the Clean Power Plan.

EPA will have a big task in digesting the multitude of comments submitted and in writing a final rule, due in June 2015. The Alliance will remain engaged with EPA, state officials and other stakeholders through the rulemaking period and well beyond into the state planning and implementation phases to ensure that energy efficiency is used as our first fuel and best compliance strategy.