SELC to EPA: Level the playing field for energy efficiency, renewables
As model carbon trading rules are finalized for the U.S. Environmental Protection Agency's (EPA) Clean Power Plan (CPP), clean energy supporters are urging the EPA to let energy efficiency and renewable energy compete on a level playing field with traditional utility power plants -- and related studies are supporting this position.
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According to Southern Environmental Law Center (SELC), Southeastern states, in particular, stand to gain from a model framework that includes these incentives.
"EPA has the opportunity to change energy incentives that have left the Southeast behind -- as a region, we rank eighth in the world in carbon pollution, which has created a host of public health and environmental problems for our communities," said SELC Senior Attorney Frank Rambo, leader of the organization's Clean Energy and Air program. "But as currently proposed, the model trading rules do not go far enough to support consumers' freedom to lower their power bills through efficiency upgrades and home-grown solar generation."
The proposed rules do not provide enough incentive for new energy efficiency and renewable energy investments, as they are designed to leverage existing state programs and practices, according to SELC, ignoring the fact that the Southeast has historically underinvested in energy efficiency and continues to lack strong state policies that encourage more investment. For example, 70 percent of Southeastern states rank in the bottom quarter nationally for energy-efficiency efforts.
"Given the higher rates of poverty in the Southeast, it's important that we be able to meet Clean Power Plan goals through energy-efficiency programs as much as possible," said Rambo. "Low-income customers are too often forced to spend large amounts of their limited income on home energy bills, so energy-efficiency programs offer families the greatest savings, while also creating good local jobs."
The proposed rules also contain "unnecessary and burdensome" obstacles to using solar power to meet Clean Power Plan goals, according to SELC, despite an unprecedented opportunity to support the expanding solar market in the Southeast.
"It is critically important that this initiative be carried out in a way that supports cheaper, cleaner energy options historically ignored in the Southeast," said Rambo. "This is not just for the sake of successfully implementing the Clean Power Plan, but for the sake of the Southeastern communities that have the most to gain."
The study supporting energy efficiency and renewable energy investments to meet the CPP focuses on another region of the country, but is useful, nonetheless, demonstrating that implementing the EPA's Clean Power Plan would have minimal impact on electricity costs in Virginia, and could even provide savings for ratepayers under some scenarios, compared with projected energy costs in 2030.
Those are the findings of "Modeling Low Cost Approaches to Clean Power Plan Compliance for Virginia," published by the AEE Institute, which presents the results of two specific scenarios that are representative of multiple runs of the new State Tool for Electricity Emissions Reduction (STEER). The demonstrated scenarios are based on varying considerations, but find that the least expensive way to reach EPA's prescribed emission targets includes a significant amount of energy efficiency and renewables and does not include any additional plant retirements beyond those already announced.
"STEER is an extremely valuable tool for understanding the options available to Virginia for complying with the Clean Power Plan," said Malcolm Woolf, senior vice president for Policy and Government Affairs for Advanced Energy Economy (AEE), a national business association. "It shows that, under a wide variety of scenarios, energy efficiency and renewable energy are the cheapest ways to meet the Clean Power Plan targets with minimal impact on electric rates, and even saving money for ratepayers under some circumstances."
For each scenario of assumptions run through the tool, STEER identifies the combination of generation sources, efficiency improvements, and other measures that represents the lowest cost means of meeting the state's electric power needs in 2030 while complying with Clean Power Plan standards for Virginia. The compliance period established by EPA for the carbon emission regulation begins in 2022, with final standards for carbon emissions from the electric power sector in each state in 2030.
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