On June 2, the Environmental Protection Agency (EPA) made history with the release of the agency’s Clean Power Plan. For the first time, the United States has taken steps toward regulating the emission of greenhouse gases from their largest source: existing power plants. Now that the proposed rule has been published in the Federal Register, the policy wonks of the world have fewer than 120 days to hunker down and process this massive document before comments are due on October 16.
No summer blockbuster is complete without its share of drama. Some were critical before the ink was dry. Others lauded the proposal as a triumph at first glance. Whatever the reaction, it is clear this proposal is a big deal, and 120 days will be a short window to sift through the minutia and develop a clear stance on each detail of the proposal.
For those of us who are proponents of energy efficiency, initial impressions have been mostly positive. In setting the level of emissions reductions required under the proposal, EPA has included reductions attributable to demand-side efficiency as one of four “building blocks.” These building blocks constitute the four policies at the core of EPA’s goals for states, and represent policies the agency believes all states can implement in order to achieve their required greenhouse gas reductions.
Unfortunately, EPA chose to leave building codes out. With around 70% of electricity in the US consumed by buildings, codes could provide large energy savings. In a recent report, ACEEE found that over 155 million MWh of energy could be saved in 2030 from updating and adopting commercial and residential codes. This could reduce greenhouse gas emissions by 106 million tons that same year, a significant portion of the Clean Power Plan’s goal.
41 states have already implemented building codes for a reason—they save consumers money and increase building comfort. They also allow for the implementation of energy efficiency technology at the most cost-effective point in the life of a building: during construction. Codes are a proven emission reduction strategy that should be considered when setting the emission reduction goal and should be a compliance option explicitly and clearly laid out for states.
With fewer than 100 days left, the window to let EPA know what you think is rapidly closing. The comment period ends October 16. Click here for more details.