[no-glossary]In late September, the ether was all abuzz with news of EPA’s proposed New Source Performance Standards for regulating carbon dioxide emissions from new power plants. Since then, many attempts have been made to read the tea leaves in hopes of predicting what approach EPA will take to regulate carbon dioxide emissions from existing power plants—the big fish in terms of potential pollution benefits (86% of U.S. greenhouse gas emissions are energy related).[/no-glossary]
EPA has until June 1, 2014 to propose a rule to regulate these existing power plants. The relevant provision of the Clean Air Act, Section 111(d), allows for flexibility in the way the rule is designed. Flexibility can ensure that the lowest-cost emission reductions are achieved and leave the door open for new and better technologies to play a role in achieving future emission reductions. One of the greatest opportunities that flexibility can allow is end-use energy efficiency. This can help the United States to meet ambitious greenhouse gas reduction targets while minimizing the cost of transitioning to a clean energy future. ACEEE’s latest report, Trailblazing Without the Smog: Incorporating Energy Efficiency into Greenhouse Gas Limits for Existing Power Plants , makes a number of recommendations regarding how these regulations should be structured so that the benefits of end-use energy efficiency are realized.
There are a number of unsettled legal questions with regard to how end-use efficiency may be incorporated into a 111(d) rulemaking, but in many cases there are clear and practical implications of one approach over another. Those practical implications create a strong justification for a rule that incentivizes states and power plants to take advantage of end-use energy efficiency resources. ACEEE’s report dives into many of these issues, such as how to measure and verify energy savings and how to determine which energy efficiency policies should get credit under a rule.
When people think of reducing air pollution, many envision installation of control technologies at the end of a smoke stack. End-use energy efficiency avoids the need to generate electricity, eliminating greenhouse gases as well as other pollutants such as mercury and sulfur. Incorporating end-use energy efficiency into a 111(d) rulemaking will reduce the costs of complying with other federal air regulations, helping to ensure that the power sector maintains reliability and that electricity prices remain affordable.