EPA’s Clean Power Plan: EE’s Role to Help States Comply
At 1,560 pages, the Environmental Protection Agency’s (EPA) Clean Power Plan (CPP) presents a challenge for states to read and assimilate the final rules, and subsequently craft a plan for compliance. At a meeting of the Association of Energy Services Professionals (AESP), Christopher James offered a head start by summarizing what has changed since the proposed rule, providing guidance on best practices for compliance, and delving into the role of energy efficiency (EE) in meeting the emission reduction targets set forth by EPA.While EE was removed from the four “building blocks” for compliance in the final rule, EPA anticipates that many states will implement it to meet some or all of the required greenhouse gas emission reductions. While the quantification of avoided emissions from EE is not simple, EPA’s draft evaluation, measurement, and verification guide provides some direction. In addition, regulators can adapt existing methods such as deemed energy savings, the “AP-42 emission factors” approach, and the MOVES model for assessing vehicle emissions, to quantify avoided emissions due to energy efficiency.Mr. James encourages state regulators to leverage energy efficiency and renewable energy sources to ensure an approvable, least-risk, least-cost compliance plan.