Kate Zerrenner, Environmental Defense Fund
Right now, there are no limits on carbon pollution from power plants, even though these facilities were responsible for roughly 40 percent of all U.S. carbon dioxide (CO2) emissions in 2012.
That’s why the Environmental Protection Agency (EPA) is crafting greenhouse gas (GHG) regulations for new fossil fuel-fired power plants by setting a limit on how much CO2 the plants can emit. Later this year, EPA will issue proposed CO2 “emission guidelines” for existing fossil fuel-fired power plants using various Clean Air Act tools to protect human health and to clean up our air.
To achieve significant and cost-effective emission reductions from existing power plants, EPA should look to leading states that are already implementing successful measures to reduce emissions. These measures include investing in renewable energy, harvesting energy efficiency, and utilizing more efficient and lower-emitting fossil fuel-fired units.
Energy efficiency, in particular, is a cost-effective way to cut emissions by reducing the sheer amount of electricity produced and used, which saves money for consumers in the process. However, it is vital that energy savings and emission reductions from customer-facing, demand-side energy efficiency – that is energy efficiency installed in homes and businesses – be accounted for in the process.
What is section 111(d) of the Clean Air Act?
The best near-term opportunity to curb climate change is to place national limits on carbon pollution from power plants, and section 111 of the Clean Air Act gives EPA the responsibility to put the right rules in place.
As called for in the President’s Climate Action Plan, EPA has issued a proposed rule under section 111(b) that would set the first federal limits on carbon pollution from new fossil fuel-fired power plants. But it is section 111(d) that will enable EPA to regulate the vast quantity of carbon pollution from existing power plants.
Section 111(d) calls for a dynamic federal-state partnership that is expected to set overarching performance benchmarks in the “emission guidelines”, while still allowing states to write their own plans on how to meet those goals. Specifically, state plans must meet or exceed the benchmark defined in the guideline. This process creates an opportunity for EPA to proactively engage with states to ensure GHG reductions are achieved in the most efficient and effective manner possible.
Does energy efficiency have a role in 111(d)?
Section 111(d) gives EPA flexibility in the design of its emission guidelines, and thus opens the door for demand-side energy efficiency. Energy efficiency provides numerous benefits to states: savings to consumers, job creation, and reductions in several power plant emissions, including carbon emissions, sulfur dioxide, and ozone-forming pollutants.
Many states favor including demand-side energy efficiency in state plans and the concerns for implementation, such as how to quantify emission reductions from energy efficiency and how to measure the energy savings, are solvable.
Energy efficiency should be an all-in measure.
In the face of a changing climate, where power plants are responsible for 34% of carbon pollution in Texas, strong standards need to be put in place.
Energy efficiency is already the most cost-effective way to reduce energy use and carbon pollution from power plants. It also creates other benefits to the power grid, like improving grid reliability and lowering costs for infrastructure maintenance. Plus, saving energy saves water, which is critical in a state like Texas under the pressure of a multi-year drought.
The good news is that about half of the states in the United States already have mandatory energy efficiency targets, so there is a wealth of knowledge and experience across the country. In fact, Texas was the first state to set an energy efficiency resource standard and, although its target has since lagged in terms of aggressiveness, it has the knowledge base to make energy efficiency thrive. Many Texas cities are leaders in energy efficiency as well, undertaking significant efforts to upgrade public buildings and more.
There is no doubt that the benefits of energy efficiency go beyond the power plant’s fence line. Figuring out how to include this valuable resource as a flexible compliance mechanism is an important step in ensuring the health and vitality of Texas and states across the U.S.
Kate Zerrenner is a project manager at the Environmental Defense Fund.
