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AESP Attendees Get Schooled in EPA's 111(d): The Time is Now To Develop Plans to Incorporate Energy Efficiency Into Compliance Plans

Government and Economy Concept

Energy efficiency must play a key role in state plans to implement an EPA rule created to cut carbon pollution, and should be fully integrated into the state’s overall compliance plans, an expert panel told attendees of the Association for Energy Services Professionals annual meeting this week.

In June 2014, the U.S. Environmental Protection Agency proposed its Clean Power Plan to cut carbon pollution from power plants. As proposed, the plan would provide the states with the flexibility to comply with the requirements by using measures that match each state’s mix of sources and opportunities, including energy efficiency. Though the rule is still being finalized, compliance is expected by 2030.

That date is sooner than it seems.

At the 25th national conference of the Association for Energy Services Professionals, a panel led by Gene Rodrigues of ICF International provided an update and tips on compliance with the rule – 111(d) --  and it was clear that energy efficiency should play a clear and prominent role and that states should be undertaking analysis now that will guide the development of their implementation plans and efforts if and when the rule goes into effect.  

“Even though 111(d) is still in the review and comment period, now is the time to start thinking about the profound impact it may have on the way we deliver energy efficiency, the way we measure energy efficiency cost efficiency and results, and the types of programs that will be most useful in optimizing a portfolio to get the best results,” Rodrigues said in an interview following the session.

Rodrigues said that state officials should consider three main principles when incorporating energy efficiency into compliance plans:


·      Analytical underpinnings and mechanisms to measure results
·      Planning and implementation of cost-effective and reliable programs and initiatives to optimize portfolios
·      A holistic view of the entire ecostructure of energy efficiency to include non-utility efforts including codes and standards, efforts of local governments and services companies not affiliated with utilities.

The panel included David Jacot, Los Angeles Department of Water & Power; David Terry, National Association of State Energy Officials (NASEO); Matthew Gibbs, Eversource Energy;Chris MacCracken, ICF International and Luis Martinez, Natural Resources Defense Council.

“The bottom line,” Rodrigues said, “is that energy efficiency is a critical contributor to EPA’s state target calculation. It has the potential to be even more important for compliance. The states will have flexibility in designing their plans, so it is time for state energy leaders and stakeholders to engage in a conversation about what role they want energy efficiency to play .”

Rodrigues also that “in a sector where it takes several years to build new generation and transmission, or develop a new program, the 4 years that states and stakeholders will have from final Clean Power Plan rule to implementation will seem very short.”

And, he said, “If energy efficiency is not included in a state’s program or does not show up, compliance must come from other options – new generation and more unit retirements, so states need to consider all implications – e.g., energy efficiency participation can extend the life of coal units, which means more gradual transition, more flexibility, different economic impacts.”

Terry, with NASEO,  listed several ways that energy efficiency might play a role

  • State-overseen, IOU Ratepayer Programs, about $7 billion annually  
  • Public Facilities Retrofits  
    • NASEO developed multi-state project and accounting  
  • Building Energy Code Compliance
    • DOE-funded pilot code compliance program (e.g., TX)
  • Financing programs linked to efficiency  
  • Development of energy efficiency credit trading

“Since the states will have great latitude in designing the compliance plans, now is the time for all interested stakeholders to undertake the analysis required to fully participate in deliberations about the role of energy efficiency,” Rodrigues said. 

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