Quantifying Energy Savings and Emission Reductions under the Section 111(d) Carbon Pollution Standard

On June 2, 2014, the Environmental Protection Agency (EPA) released proposed rules to reduce emissions of CO2 from existing electric generating units through Section 111(d) of the Clean Air Act. The proposed rules will require substantial cuts in CO2 emissions from existing generators, yet provide states with a number of flexible options for the design and administration of state implementation plans to achieve compliance, including through the use of energy efficiency. On behalf of the Environmental Defense Fund, Analysis Group Principal Paul Hibbard and Managing Principal Andrea Okie recently proposed a framework that could be used as guidance from the EPA to the states on how to rigorously and efficiently account for the climate benefits of energy efficiency in state plans for implementing and enforcing the new carbon pollution standard.

This guidance reflects the advanced state of energy efficiency measurement and verification approaches that have been implemented in states and organized electricity markets around the country, as well as the diversity of programs and approaches that exist today. The authors' guidance does not mandate a single approach; instead, they describe multiple pathways by which states can validate energy efficiency savings in an environmentally rigorous way, and highlight key decision points for states.

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