Alliance Comments on Clean Energy Standards for the Senate Energy & Natural Resources Committee

Submitter’s Name/Affiliation: Alliance to Save Energy on behalf of the Energy Efficiency Coalition

Executive Summary

While the purpose of a broad Clean Energy Standard (CES) has not been clearly stated, it seems clear that the intent, even more than for previous proposed utility standards, is to shift the whole electric system toward cleaner, sustainable resources and reduce the significant environmental costs of electricity production.  Energy efficiency programs are widely used to meet consumer energy needs just as much as supply resources—they help customers achieve the energy services they desire without requiring more power plants and fuel supplies—and they are clean, secure, domestic, and cheap.  Thus energy efficiency should be fully eligible to meet any CES without limit.  To exclude efficiency from a CES would severely distort the clean energy market, unnecessarily increase costs, and reduce potential benefits.

We focus on three questions in our more detailed responses:

• Energy efficiency should qualify as clean energy, as described above.  While it is harder to measure than electricity supply, there is huge experience in how to do so.  (Question 2)
• Because there are widespread energy efficiency programs, it is important that a federal policy build on the existing state infrastructures and not undermine them. (Question 1)
• Energy efficiency programs only achieve part of the potential cost-effective energy savings, and they build on other efficiency policies, so it is also important to enact additional policies. (Question 6)

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