As part of a public discussion organized by clean energy advisors David Gardiner and Associates, Chris James and John Shenot of RAP explored energy efficiency as a compliance mechanism for meeting proposed EPA emissions standards for existing power plants under Section 111(d) of the Clean Air Act. They highlighted the value of energy efficiency, which has the advantage of addressing multiple air pollutants simultaneously, such as criteria, toxic, and greenhouse gas pollutants, with a single strategy, whereas most pollution control devices are designed to address one pollutant. Drawing on the so-called “mobile source analogy,” which refers to how the EPA assesses emissions from mobile sources based on behavior-based measures taken by the states, such as implementing commuter lanes and inspection standards, Mr. James and Mr. Shenot extended this concept to stationary sources to explore the benefits of behind the meter combined heat and power resources. This form of on-site generation has advantages and characteristics similar to energy efficiency. Around 60 representatives of clean energy companies, energy efficiency advocates, energy service companies, environmental organizations, and other NGOs joined the call.