Calculating Avoided Emissions Should be a Standard Part of EM&V and Potential Studies
Thanks in large part to some recent guidance and proposed federal regulations by the U.S. Environmental Protection Agency (EPA), state and local air pollution regulators have a growing interest in using energy efficiency (EE) as a strategy to improve air quality. The largest challenge for air pollution regulators is to quantify the impacts of EE in a way that is suitable for regulatory purposes. To measure the air quality impacts of EE, one has to begin with an assessment of energy savings. However, assessing the timing and location of energy savings is also critically important for estimating avoided emissions. EE professionals are better suited to this task of quantifying current or potential future avoided emissions than the air pollution regulators themselves. This paper explains the enormous hurdles that air pollution regulators face in this area, and why the methods are more suitable for use by EE professionals. This paper also suggests how EE professionals might collaborate with air pollution regulators to better understand the data needed for regulatory purposes, and modify their standard practices accordingly. Further, it explains how EE professionals and the other audiences they serve (utilities, public utility commissions, and consumer advocates) will all benefit from a greater emphasis on the air quality benefits of EE. Finally, encouraging examples where these ideas are already being put into practice are discussed briefly.