On Nov. 5, we submitted to the Environmental Protection Agency AEE’s comments on the Clean Power Plan. As we testified in the Agency’s hearing in July, AEE supports the Clean Power Plan, because we see it as a vital step toward modernizing the U.S. electric power system for greater efficiency, reliability, and economic opportunity. Compliance with the Clean Power Plan may be complicated, but with all the technologies available and all the flexibility allowed for individual states to develop plans that make sense for them, EPA’s state targets for reduced greenhouse gas emissions will be easy to achieve. In our comments, what we told EPA is this: Advanced energy can contribute much more to emission reduction than the draft of the Clean Power Plan contemplates, and provide economic benefits at the same time.
Methodologies utilized by EPA in setting state-by-state targets based on expected use of energy efficiency and renewable energy to reduce emission rates significantly underestimate their potential, both today and in the future. EPA has ignored billions of dollars in annual energy efficiency investments – including those made largely outside utility programs by energy services companies (ESCOs) – that can be relied upon to achieve even greater emission reductions in the years ahead. Its targets for zero-emission renewable energy do not take into account distributed energy installations – notably rooftop solar, the fastest growing renewable energy technology – nor all the renewable resources that states will have available to them as the costs of wind, solar, and other technologies continue to fall between now and 2030.
In our comments, we urged EPA to strengthen the target based on renewable energy to better reflect what is actually achievable and cost-effective given available resources in states and the demonstrated trend toward lower costs. Similarly, the targets set based on end-use efficiency should be strengthened to reflect the full extent of achievable efficiency as demonstrated in the market.
An Executive Summary of AEE’s comments and the full 62-page filing can be found here.
Part of the problem is simply the difficulty of predicting the technological progress that will take place by 2030 and beyond. For this reason, we called on EPA to regularly review and revise its emission targets given the steady improvement of advanced energy technologies, which will enable greater emission reductions over time.
Besides ways to strengthen the targets associated with advanced energy, we also urged EPA to take several actions to encourage the use of advanced energy technologies by states.
One way to do this is to explicitly approve more emission-reducing technologies for compliance. We called on EPA to expand the range of options to include the 40 technologies described in AEE’s Advanced Energy Technologies for Greenhouse Gas Reduction. The full report is available here.
In order to avoid uncertainty on the part of states about eligible technologies and how to incorporate them into compliance plans, EPA needs to clarify the crediting of emission reductions from renewable energy and energy efficiency actions in a variety of ways. Specifically, we urged EPA to develop a non-exclusive list of protocols for evaluation, measurement, and verification (EM&V), so that states could employ energy efficiency in their compliance plans with confidence.
We also asked that EPA provide clarity as to the crediting of renewable energy across state lines, in order to encourage the continued expansion of interstate markets. EPA should also improve the crediting of energy efficiency investments in states that are energy exporters, as well as clarify the crediting of emission reductions that occur in one state as a result of efficiency investments made in another state.
Finally, AEE urged EPA to accelerate advanced energy markets, and their associated emission reductions, by crediting emission reductions achieved prior to 2020 by new projects stemming from state compliance plans.
In sum, we are urging EPA to build upon the solid foundation of the Clean Power Plan by making changes in the final rule to fully realize the benefits of advanced energy technologies for emission reduction and economic growth. With the formal comment period open until December 1, we hope other supporters of a better energy future will do the same. Click below to download the full version of AEE's comments.