Advanced Energy Economy (AEE) has come up with a number of recommendations for the Clean Power Plan. The AEE sees these new federal regulations as a great benefit to the electric power system and an added opportunity to the energy industry. Here is a brief summary of AEE’s recommendations for the Clean Power Plan:
Part of the problem is simply the difficulty of predicting the technological progress that will take place by 2030 and beyond. For this reason, we called on EPA to regularly review and revise its emission targets given the steady improvement of advanced energy technologies, which will enable greater emission reductions over time.
Besides ways to strengthen the targets associated with advanced energy, we also urged EPA to take several actions to encourage the use of advanced energy technologies by states.
One way to do this is to explicitly approve more emission-reducing technologies for compliance. We called on EPA to expand the range of options to include the 40 technologies described in AEE’s Advanced Energy Technologies for Greenhouse Gas Reduction. The full report is available here.
In order to avoid uncertainty on the part of states about eligible technologies and how to incorporate them into compliance plans, EPA needs to clarify the crediting of emission reductions from renewable energy and energy efficiency actions in a variety of ways. Specifically, we urged EPA to develop a non-exclusive list of protocols for evaluation, measurement, and verification (EM&V), so that states could employ energy efficiency in their compliance plans with confidence.
We also asked that EPA provide clarity as to the crediting of renewable energy across state lines, in order to encourage the continued expansion of interstate markets. EPA should also improve the crediting of energy efficiency investments in states that are energy exporters, as well as clarify the crediting of emission reductions that occur in one state as a result of efficiency investments made in another state.
Finally, AEE urged EPA to accelerate advanced energy markets, and their associated emission reductions, by crediting emission reductions achieved prior to 2020 by new projects stemming from state compliance plans.
In sum, we are urging EPA to build upon the solid foundation of the Clean Power Plan by making changes in the final rule to fully realize the benefits of advanced energy technologies for emission reduction and economic growth. With the formal comment period open until December 1, we hope other supporters of a better energy future will do the same.
How do you feel about the Clean Power Plan and about AEE’s recommendations?