On November 5, 2014, the HLS Environmental Policy Initiative submitted comments on EPA’s Clean Power Plan, which proposes to regulate greenhouse gas emissions from existing stationary sources for the first time in U.S. history. The comments are in the form of an Energy Efficiency Evaluation Tool, which states and stakeholders can use to determine whether energy efficiency (EE) programs can be included in their emission reduction plans. The Evaluation Tool contains a series of questions that guide the evaluation of EE programs, organized around four attributes of Clean Air Act compliant emission reduction credits: quantifiable, enforceable, permanent, and non-duplicative. The Tool also integrates past EPA guidance and summarizes EE programs that have received past EPA approval to provide additional clarity to stakeholders. Finally, the Tool provides concrete suggestions for EPA to consider prior to finalizing the Clean Power Plan.
In its cover letter, the Environmental Policy Initiative expresses support for EPA’s plan, and in particular praises the flexibility offered to individual states in allowing them to achieve compliance through end-use energy efficiency programs.