EPA Underestimated Energy Efficiency in the Clean Power Plan?

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energy efficiencyThe Clean Power Plan, the Obama administration’s program to cut carbon dioxide emissions from existing power plants, is likely to bring dramatic change to the energy industry.

How will it impact energy efficiency? The better question might be how can energy efficiency impact the plan.

The Natural Resources Defense Council says that by ramping up energy efficiency and renewables the US can achieve deeper cuts in carbon dioxide emissions than proposed by the Obama administration. NRDC was among those that filed comments with the Environmental Protection Agency on the December 1 deadline, part of the process toward finalizing the rule in June 2015.

The proposed rule calls for reducing carbon dioxide emissions 30 percent by 2030. NRDC says 40 percent by 2030 is conceivable with the right mix of resources.

The EPA over-estimated the cost and under-estimated the future growth of energy efficiency and renewables, says the organization.

For example, the EPA was too conservative when it forecast that energy efficiency could supplant 1.5 percent of retail electric sales. The EPA didn’t include potential energy efficiency gains through such measures as building codes, transmission and distribution and voltage optimization. Incorporating those factors, raises energy efficiency potential to 2 percent of retail sales each year, according to NRDC.

“Clearly, with more efficiency and more renewable power, there’s room for the EPA to readily cut power plant carbon pollution by more than 40 percent in 2030, compared to 2005 levels,” said David Doniger, director of NRDC’s Climate and Clean Air Program.  “We should commit to at least that much of a cut in this dangerous carbon pollution, and demonstrate with actions, not words, that we’re serious about protecting future generations from the dangers of climate change.”

An executive summary of NRDC’s comments to EPA on the Clean Power Plan is available here.

Separately, the CHP Association, which represents the combined heat and power industry. urged the EPA to credit CHP plants as a voluntary compliance solution and give states clear guidance on how they can do so. CHP is highly energy efficient because it uses the waste heat from power production to heat and cool buildings and water and to create steam. In comparison, conventional power plants allow the heat to dissipate unused. (See details about how CHP contributes to microgrids in our new report, The Energy Efficient  Microgrid.)

The association also told the EPA that existing CHP plants should not be regulated under the rule because:

  1. The focus of the rule is on utility-scale electricity generation units
  2. CHP facilities are providing substantial climate and other benefit

More details on the CHP Association comments are here.

Keep on top of the Clean Power Plan and what it means to energy efficiency. Follow us on twitter @EfficiencyMkts.


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Elisa Wood About Elisa Wood

Elisa Wood is the chief editor of MicrogridKnowledge.com. She has been writing about energy for more than two decades for top industry publications. Her work also has been picked up by CNN, the New York Times, Reuters, the Wall Street Journal Online and the Washington Post.


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