In a new paper, the Regulatory Assistance Project calls on the efficiency community to include avoided emissions in both potential studies and evaluation, measurement, and verification (EM&V) reports. Calculating Avoided Emissions Should be a Standard Part of EM&V and Potential Studies argues that efficiency professionals possess both the skills and resources to effectively quantify avoided emissions—information increasingly valuable to state and local air pollution regulators.

Thanks in large part to recent guidance and proposed federal regulations by the U.S. Environmental Protection Agency, state and local air pollution regulators have a growing interest in using energy efficiency as a strategy to improve air quality. Air pollution regulators, however, don’t always have the knowledge or resources to quantify the impacts of energy efficiency programs in a way that is suitable for regulatory purposes. That’s where the efficiency community can help.

To measure the air quality impacts of efficiency, 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. Efficiency professionals are better suited to this task of quantifying current or potential future avoided emissions than the air pollution regulators themselves.

“It’s a win-win situation,” says John Shenot, author of the report. “Avoided emissions can form a significant component of the economic benefits of efficiency programs while justifying the programs as air quality improvement mechanisms. Both should lead to more resources for energy efficiency programs and cleaner air.”

RAP envisions a collaborative environment in which efficiency professionals work closely with air quality regulators to refine EM&V protocols to include useful air quality data. This is best done at the program evaluation planning (or potential study scoping) stage, with oversight and support from energy regulators, before EM&V data are collected. In time, these modified EM&V practices may become standardized to the point where air regulators become data “customers” and are no longer involved in program evaluation planning.

The paper, presented at the American Council for an Energy-Efficient Economy’s Summer Study, also highlights Wisconsin, Texas, and several Northeast states that already quantify avoided emissions in their EM&V studies.