Making energy efficiency a part of EPA’s upcoming carbon pollution standards for existing power plants is critical, say energy efficiency advocates
A group of regional energy efficiency advocacy organizations* issued a position paper last month exploring how energy efficiency can be included in upcoming carbon pollution standards for existing power plants. Authored by Howard Geller, Executive Director of the Southwest Energy Efficiency Project, the report examines how the standards can best support and give appropriate credit for efforts that utilities, states and other entities take to increase the efficiency of electricity use and reduce electricity consumption.
This is important because energy efficiency is the lowest-cost “fuel” currently available to us. That is, energy efficiency programs typically cost two to three cents per kWh saved, compared to costs of six cents per kWh or greater for new sources of electricity supply whether fossil fuel-based, nuclear power or renewable energy resources. In addition, energy efficiency has other benefits such as job creation, economic health, increased public health, and enhanced reliability of the electrical grid.
Mass-based emissions reduction approach preferable, report says
The approach taken to measure and reduce CO2 emissions will determine how effectively energy efficiency can be included in carbon pollution reductions. Two approaches might be used in the upcoming regulations: in one, maximum allowed rates of carbon dioxide emissions (pounds or tons per MWh) decline over time. In the other, maximum allowed tons of carbon dioxide emissions decline over time.
The latter is called a mass-based emissions reductions approach. The paper says the mass-based reduction approach is preferable because it would make it possible – and quite straightforward – to give appropriate credit for any and all energy efficiency efforts. Energy efficiency policies that could be part of this approach include utility/ratepayer-funded energy efficiency programs, state or local building energy codes, pricing policies that reduce electricity use, and more.
A mass-based reduction approach would give appropriate credit to these and other energy efficiency efforts because the approach gives credit for actual emissions reductions from all efforts. Thus, anything a state, utility, local authority or other entity does to increase the efficiency of electricity use will reduce electricity consumption and therefore reduce power plant operation. Conversely, if the energy efficiency programs did not work to reduce electricity consumption, power plant operations would not be reduced, and no emission reduction credits would be given for the efficiency program.
This then helps the state to achieve the specified CO2 performance standard for existing power plants without the need for a complicated system to evaluate the effectiveness of each energy efficiency policy in order to determine emission reduction credits.
The paper concludes that energy efficiency improvements could play a large role in helping states and utilities meet the forthcoming carbon pollution standards for existing power plants at least cost. But the degree to which this occurs depends on the nature of the standards or guidelines adopted by the EPA. The report recommends that the EPA
• Encourage a mass-based emissions reduction approach
• Direct states to pursue cost-effective energy efficiency initiatives to the maximum degree feasible in order to reduce costs of compliance
• Allow states to include a wide range of energy efficiency policies in their approach
• Allow inclusion of energy efficiency programs and polices without limitation
• Take into account the potential for substantial, cost-effective CO2 emissions reductions from energy efficiency policies, programs and measures when establishing the levels of emissions reduction called for by the standards.
The full report is available HERE.
*Links to report sponsors and authors:
Southwest Energy Efficiency Project
Northeast Energy Efficiency Partnerships
Midwest Energy Efficiency Alliance
Southeast Energy Efficiency Alliance
The South-central Partnership for Energy Efficiency as a Resource