12/01/14: Rodney Sobin

Alliance to Save Energy Clean Power Plan Comments

The Alliance’s focus is on energy efficiency, so we offer no comment on what may be appropriate emissions limits and stringency. Rather, when air quality regulatory measures are developed and implemented, we support recognition, crediting and encouragement of EE as an emissions reduction strategy. As the EPA has acknowledged at various times, including in this proposal, more efficient use of energy reduces the amount of fuel required to provide energy services and, thus, the emissions and other negative environmental impacts associated with fuel use. In the context of the CPP, EE measures taken throughout the electrical system — at generating plants (electrical generating units [EGUs]), in transmission and distribution (T&D) and in energy end-use — can provide cost-effective emissions reduction and avoidance.

Our comments center on several important areas where the CPP proposal (including the rule, rule preamble, TSDs and other guidance) can be clarified and strengthened. These topics include:

  • EPA should explain implications for states of choosing mass- over rate-based targets.
  • States and other entities need clarification and guidance on including non-utility ratepayer-funded EE programs, policies and measures in state compliance plans.
  • States need clearer guidance on a number of issues related to evaluation, measurement and verification (EM&V) of energy savings.
  • Interactions of EM&V, quantification and enforceability issues for EE.
  • Inter- and multistate issues concerning crediting of EE.
  • Early action crediting issues.
  • Several ways to strengthen the opportunity and benefits of combined heat and power (CHP) and waste heat to power (WHP) in the context of the CPP.