The Alliance applauds three major state government associations for adopting “Principles for Including Energy Efficiency in 111(d) of the Clean Air Act.” The document encourages EPA to recognize energy efficiency as a valuable tool for complying with upcoming greenhouse gas standards for existing power plants.

The document was developed by the National Association of Clean Air Agencies (NACAA), the National Association of Regulatory Utility Commissioners (NARUC) and the National Association of State Energy Officials (NASEO), which are the principal organizations of state and territorial air quality regulators, public utility commissioners and energy offices, respectively.

The agencies and commissions represented by the “3Ns” all have major stakes in upcoming EPA regulations for existing power plants under Section 111(d) of the Clean Air Act.  They have responsibilities for balancing environmental requirements with energy reliability and affordability needs. That they all find that “energy efficiency should be an integral, creditable part” of state and tribal 111(d) plans is heartening.

The Alliance endorses the 3N principles, which urge EPA to allow state flexibility and to recognize the diversity of state experience with effective energy efficiency programs and policies. They call on EPA to offer states guidance and recommendations on how energy efficiency can be included in state plans, and on such matters as recognizing privately contracted energy efficiency projects, measurement and verification of energy savings, quantification of emissions impacts, encouraging multi-state and regional programs and accountability for energy efficiency in state plans.

As the document notes: “By recognizing the significant emissions reductions that are achievable through energy efficiency, EPA will enable states and tribes to design the most cost-effective 111(d) compliance plans.”

The principles are largely consistent with comments that the Alliance jointly submitted with the American Council for an Energy-Efficient Economy to EPA.  The Alliance will continue to work with EPA, our Associates, states, non-governmental organizations and other stakeholders to recognize and encourage energy efficiency as a cost-effective and beneficial way to help meet environmental objectives.