Why Energy Efficiency Deserves a Key Role in EPA Carbon Limits
The U.S. Environmental Protection Agency (EPA) has embarked on a vital effort—accompanied by extensive outreach to states, power companies, environmental organizations and other stakeholders, including you—to establish the nation’s first limits on carbon pollution from fossil fuel-fired power plants.
The EPA was directed to take this critical step for public health and the environment in the president’s Climate Action Plan that was released last summer. Protective and well-designed Carbon Pollution Standards will provide important benefits for all Americans.
Fossil fuel-fired power plants emit 40 percent of the nation’s carbon pollution, as well as significant amounts of mercury, acid gases, and pollutants that contribute to smog and particulates.
That’s why it is critical to get these rules right, and to mobilize common sense solutions proven in red and blue states alike in reducing carbon pollution from the power sector.
Of all the available ways to reduce carbon pollution, one of the most cost-effective and time-tested approaches is to reduce demand for fossil fuel electricity through end-use energy efficiency (EE).
EE measures encompass countless improvements, large and small, in the ways we use electricity in our offices, factories, and homes. All of those improvements can add up to big savings, not only in our monthly energy bills but in the total amount of fossil generation needed to power our society.
Dozens of states and power companies are already investing heavily in EE, and have built up decades of experience in measuring and verifying the many benefits it can yield for consumers and for the environment.
Incredible Potential to Cut Emissions and Save Money by Reducing Wasted Electricity
States and power companies around the country have been implementing EE programs for decades, and have increased their efforts in recent years as experience with the benefits of EE has grown.
Twenty-six states in diverse regions of the country, from Arizona and Colorado in the Southwest, to industrial Midwest states like Ohio and Illinois, now have “energy efficiency resource standards” or similar policies that require utilities to achieve a certain amount of energy savings each year.
State spending on EE programs increased by 28 percent between 2010 and 2012.
As EE policies and investments have grown, so have energy savings.
In 2011, state EE programs saved a total of 22.9 million megawatt-hours—roughly equivalent to the entire annual output of seven 500 megawatt coal-fired power plants.
These savings increased 22 percent since 2010 and, importantly, count only those savings achieved in the first year these EE measures are in place.
Because most EE measures continue to yield energy savings years or even decades after they are installed, the cumulative savings from these state EE programs are much larger.
A recent study by the American Council for an Energy Efficient Economy found that EE programs and policies are a key reason why residential and commercial electricity demand has remained stable since 2007.
As impressive as these developments are, they only scratch the surface of what could be achieved if we were to fully unlock the potential for EE to save energy and reduce emissions.
An exhaustive 2009 analysis by McKinsey & Company, for example, found that rigorous investment in cost-effective EE could reduce the country’s total energy consumption by 23 percent in 2020.
Energy savings on this scale would yield massive emission reductions—about 700 million metric tons of carbon dioxidein 2020 alone (more than 30 percent of power sector emissions today) – and at a cost per kilowatt-hour saved that is about 85 percent less than the average retail price of electricity.
The report also estimated that realizing these energy savings would create about 600,000 to 900,000 jobs through 2020.
In 2012, for example, the Southwest Energy Efficiency Project (SWEEP) issued a report focusing on the potential benefits of scaling-up EE programs in six Southwestern states (Arizona, Colorado, Nevada, New Mexico, Utah, and Wyoming).
Based on the track record of “best practice” EE programs around the country, SWEEP found that these six states could reduce their electricity demand in 2020 by more than 20 percent while achieving net benefits of about $20 billion—amounting to $2,650 for every household in the region (largely in the form of lower energy bills).
Investments in EE at this scale would also create about 30,000 additional jobs in the region by 2020, and increase wages and salaries by more than $1 billion.
At the same time, these EE measures would reduce carbon pollution by more than 30 million metric tons in 2020, (a 16 percent reduction relative to expected emissions in 2020), while also reducing thousands of tons of pollutants that contribute to smog, acid rain, and harmful particulate pollution.
EE and the Carbon Pollution Standards
If you’ve read my colleague Megan Ceronsky’s earlier blog, you’ve already heard about section 111(d) of the Clean Air Act.
That section provides bedrock authority for EPA to issue Carbon Pollution Standards for existing power plants. It also provides a broad, flexible framework for states and companies to deploy EE and other flexible approaches to reducing carbon pollution from the power sector.
Under section 111(d), EPA and the states will work together to reduce emissions from existing power plants. EPA will issue “emission guidelines” that identify the “best system of emission reduction” for carbon pollution from existing power plants and the emission reductions achievable using that system. The states then have the responsibility to develop plans that implement standards consistent with those guidelines.
Just a few weeks ago, Kate Konschnik, Policy Director of the Environmental Law Program at Harvard Law School, released a report that makes a strong legal case for considering EE as part of the “best system of emission reduction” that underpins EPA’s emission guidelines.
As Konschnik argues, the Clean Air Act grants EPA broad authority to consider flexible measures such as EE as a part of the best system of emission reduction for carbon pollution, "because it is adequately demonstrated and cost-effective, imposes minimal environmental costs, and reduces overall energy requirements."
Moreover, as Konschnik points out, methods for quantifying and verifying EE-related energy savings and emission reductions are well-developed.
Over the last two decades, at least 35 states and two regional transmission organizations have adopted protocols for measuring and verifying energy savings from EE projects. These savings are now widely used as the basis for critical regulatory proceedings and market functions, including establishing utility rates, compensating EE in regional capacity markets, and carrying out long-term regional resource planning.
In addition, EPA has already allowed several states to credit emission reductions resulting from EE and renewable energy towards compliance with national air quality standards. EPA has also issued detailed guidance to the states on analytical approaches and tools that could be used for future programs.
Ensuring Smooth Implementation of EE in the Carbon Pollution Standards
Under traditional emissions trading programs such as the Regional Greenhouse Gas Initiative (RGGI) or California’s cap-and-trade system, the emission reduction benefits of EE are readily observed as emissions from power plants drop.
Under these programs, no separate system for tracking emission reductions from EE is necessary. As a recent report by RGGI confirms, these programs are also funding significant investments in EE programs that have already helped 815,000 families.
However, some states may choose to directly incentivize EE through policies that credit individual projects and programs for their impacts on energy savings and emissions.
For this reason, EDF has worked with experts in the field to study how measurement and verification for such EE crediting systems could work in a way that is environmentally rigorous and administratively streamlined, and that builds on extensive state and regional experience with existing EE programs.
We recently submitted a report to EPA, developed by the Analysis Group, that lays out one possible framework for ensuring both desirable outcomes:
- Rigorous measurement and verification of EE projects, and
- Consistent methods for determining emission reductions that are attributable to EE projects
This framework recognizes the diverse approaches to measurement and verification of EE that are in use around the country. But in developing this framework, we were also struck by the significant progress that a number of organizations have made in developing best practices and consensus protocols for evaluating EE projects.
One example is the Department of Energy’s Uniform Methods Project (UMP), which has organized a multi-stakeholder process to develop rigorous yet streamlined measurement and verification protocols for different types of EE projects.
To date, UMP has released protocols addressing seven major EE project types and five “cross-cutting” evaluation issues. Eight more protocols are expected to be finalized in the coming months.
Other notable efforts to develop and encourage best practices in the field include:
- The International Performance Measurement and Verification Protocol, which lays out four broadly accepted approaches to measurement and verification of EE projects and has been adopted or recognized by various states and regional transmission organizations
- Regional technical initiatives such as the Northeast Energy Efficiency Partnership and Pacific Northwest Regional Technical Forum, which work to develop regional databases on the performance of EE programs
- The evaluation guides and studies produced by the State and Local Energy Efficiency Action Network, which brings together diverse stakeholders to promote timely, cost-effective, and accurate measurement and verification practices
EE: Ready for Prime Time
EE represents a historic opportunity to achieve extensive reductions in emissions of carbon pollution and other power sector pollutants that directly harm public health and the environment.
In many cases, EE measures will actually save families and businesses money over time and help strengthen the economy.
Decades of state and utility experience in designing and implementing EE programs have demonstrated that the benefits of EE are real, and that the policies and tools needed to incentivize EE and measure its effects are available.
EPA should fully mobilize the potential of EE by exercising its authority to consider EE in the design of the Carbon Pollution Standards, and by providing guidance to the states to facilitate the inclusion of EE in state plans implementing those standards.
By Katy Neusteter
The Biden-Harris transition team identified COVID-19, economic recovery, racial equity and climate change as its top priorities. Rivers are the through-line linking all of them. The fact is, healthy rivers can no longer be separated into the "nice-to-have" column of environmental progress. Rivers and streams provide more than 60 percent of our drinking water — and a clear path toward public health, a strong economy, a more just society and greater resilience to the impacts of the climate crisis.
Public Health<img lazy-loadable="true" data-runner-src="https://assets.rebelmouse.io/eyJhbGciOiJIUzI1NiIsInR5cCI6IkpXVCJ9.eyJpbWFnZSI6Imh0dHBzOi8vYXNzZXRzLnJibC5tcy8yNTUyNDY3MC9vcmlnaW4uanBnIiwiZXhwaXJlc19hdCI6MTY2MDkxMTkwNn0.pyP14Bg1WvcUvF_xUGgYVu8PS7Lu49Huzc3PXGvATi4/img.jpg?width=980" id="8e577" class="rm-shortcode" data-rm-shortcode-id="1efb3445f5c445e47d5937a72343c012" data-rm-shortcode-name="rebelmouse-image" data-width="3000" data-height="2302" />
Wild and Scenic Merced River, California. Bob Wick / BLM<p>Let's begin with COVID-19. More than <a href="https://www.nytimes.com/interactive/2020/us/coronavirus-us-cases.html?name=styln-coronavirus&region=TOP_BANNER&block=storyline_menu_recirc&action=click&pgtype=LegacyCollection&impression_id=2f508610-2a87-11eb-8622-4f6c038cbd1d&variant=1_Show" target="_blank">16 million Americans</a> have contracted the coronavirus and, tragically,<a href="https://www.nytimes.com/interactive/2020/us/coronavirus-us-cases.html?name=styln-coronavirus&region=TOP_BANNER&block=storyline_menu_recirc&action=click&pgtype=LegacyCollection&impression_id=2f508610-2a87-11eb-8622-4f6c038cbd1d&variant=1_Show" target="_blank"> more than</a> <a href="https://www.nytimes.com/interactive/2020/us/coronavirus-us-cases.html?name=styln-coronavirus&region=TOP_BANNER&block=storyline_menu_recirc&action=click&pgtype=LegacyCollection&impression_id=2f508610-2a87-11eb-8622-4f6c038cbd1d&variant=1_Show" target="_blank">300,000 have died</a> due to the pandemic. While health officials encourage hand-washing to contain the pandemic, at least <a href="https://closethewatergap.org/" target="_blank">2 million Americans</a> are currently living without running water, indoor plumbing or wastewater treatment. Meanwhile, <a href="https://www.theguardian.com/us-news/2020/jun/23/millions-of-americans-cant-afford-water-bills-rise" target="_blank">aging water infrastructure is growing increasingly costly for utilities to maintain</a>. That cost is passed along to consumers. The upshot? <a href="https://research.msu.edu/affordable-water-in-us-reaching-a-crisis/" target="_blank">More than 13 million</a> U.S. households regularly face unaffordable water bills — and, thus, the threat of water shutoffs. Without basic access to clean water, families and entire communities are at a higher risk of <a href="https://www.americanprogress.org/issues/green/news/2020/08/05/488705/bridging-water-access-gap-covid-19-relief/" target="_blank">contracting</a> and spreading COVID-19.</p><p>We have a moral duty to ensure that everyone has access to clean water to help prevent the spread of the coronavirus. Last spring, <a href="https://nymag.com/intelligencer/2020/03/coronavirus-stimulus-bill-explained-bailouts-unemployment-benefits.html" target="_blank">Congress appropriated more than $4 trillion</a> to jumpstart the economy and bring millions of unemployed Americans back to work. Additional federal assistance — desperately needed — will present a historic opportunity to improve our crumbling infrastructure, which has been <a href="https://www.theguardian.com/us-news/2020/jun/23/millions-of-americans-cant-afford-water-bills-rise" target="_blank" rel="noopener noreferrer">grossly underfunded for decades</a>.</p><p>A report by my organization, American Rivers, suggests that <a href="https://s3.amazonaws.com/american-rivers-website/wp-content/uploads/2020/07/09223525/ECONOMIC-ENGINES-Report-2020.pdf" target="_blank" rel="noopener noreferrer">Congress must invest at least $50 billion</a> "to address the urgent water infrastructure needs associated with COVID-19," including the rising cost of water. This initial boost would allow for the replacement and maintenance of sewers, stormwater infrastructure and water supply facilities.</p>
Economic Recovery<p>Investing in water infrastructure and healthy rivers also creates jobs. Consider, for example, that <a href="https://tinyurl.com/y9p6sgnk" target="_blank">every $1 million spent on water infrastructure in the United States generates more than 15 jobs</a> throughout the economy, according to a report by the Value of Water Campaign. Similarly, <a href="https://tinyurl.com/yyvd2ksp" target="_blank">every "$1 million invested in forest and watershed restoration contracting will generate between 15.7 and 23.8 jobs,</a> depending on the work type," states a working paper released by the Ecosystem Workforce Program, University of Oregon. Healthy rivers also spur tourism and recreation, which many communities rely on for their livelihoods. According to the findings by the Outdoor Industry Association, which have been shared in our report, "Americans participating in watersports and fishing spend over <a href="https://s3.amazonaws.com/american-rivers-website/wp-content/uploads/2020/06/30222425/Exec-summary-ECONOMIC-ENGINES-Report-June-30-2020.pdf" target="_blank">$174 billion</a> on gear and trip related expenses. And, the outdoor watersports and fishing economy supports over <a href="https://s3.amazonaws.com/american-rivers-website/wp-content/uploads/2020/06/30222425/Exec-summary-ECONOMIC-ENGINES-Report-June-30-2020.pdf" target="_blank">1.5 million jobs nationwide</a>."</p><p>After the 2008 financial crisis, Congress invested in infrastructure to put Americans back to work. The American Recovery and Reinvestment Act <a href="https://thehill.com/blogs/congress-blog/economy-a-budget/25941-clean-water-green-infrastructure-get-major-boost" target="_blank">of 2009 (ARRA) allocated $6 billion</a> for clean water and drinking water infrastructure to decrease unemployment and boost the economy. More specifically, <a href="https://www.conservationnw.org/news-updates/us-reps-push-for-millions-of-restoration-and-resilience-jobs/" target="_blank" rel="noopener noreferrer">an analysis of ARRA</a> "showed conservation investments generated 15 to 33 jobs per million dollars," and more than doubled the rate of return, according to a letter written in May 2020 by 79 members of Congress, seeking greater funding for restoration and resilience jobs.</p><p>Today, when considering how to create work for the <a href="https://www.bls.gov/news.release/pdf/empsit.pdf" target="_blank" rel="noopener noreferrer">10.7 million</a> people who are currently unemployed, Congress should review previous stimulus investments and build on their successes by embracing major investments in water infrastructure and watershed restoration.</p>
Racial Justice<p>American Rivers also recommends that Congress dedicate <a href="https://s3.amazonaws.com/american-rivers-website/wp-content/uploads/2020/07/09223525/ECONOMIC-ENGINES-Report-2020.pdf" target="_blank" rel="noopener noreferrer">$500 billion for rivers and clean water over the next 10 years</a> — not just for the benefit of our environment and economy, but also to begin to address the United States' history of deeply entrenched racial injustice.</p><p>The <a href="https://www.epa.gov/npdes/sanitary-sewer-overflows-ssos" target="_blank" rel="noopener noreferrer">23,000-75,000 sewer overflows</a> that occur each year release up to <a href="https://www.americanrivers.org/2020/05/fighting-for-rivers-means-fighting-for-justice/#:~:text=There%20are%20also%2023%2C000%20to%2075%2C000%20sanitary%20sewer,to%20do%20with%20the%20mission%20of%20American%20Rivers." target="_blank" rel="noopener noreferrer">10 billion gallons of toxic sewage</a> <em>every day</em> into rivers and streams. This disproportionately impacts communities of color, because, for generations, Black, Indigenous, Latinx and other people of color have been <a href="https://www.scientificamerican.com/article/flooding-disproportionately-harms-black-neighborhoods/" target="_blank" rel="noopener noreferrer">relegated</a> to live in flood-prone areas and in neighborhoods that have been intentionally burdened with a lack of development that degrades people's health and quality of life. In some communities of color, incessant flooding due to stormwater surges or <a href="https://www.ajc.com/opinion/opinion-partnering-to-better-manage-our-water/7WQ6SEAQP5E4LGQCEYY5DO334Y/" target="_blank" rel="noopener noreferrer">combined sewer overflows</a> has gone unmitigated for decades.</p><p>We have historically treated people as separate from rivers and water. We can't do that anymore. Every voice — particularly those of people most directly impacted — must have a loudspeaker and be included in decision-making at the highest levels.</p><p>Accordingly, the new administration must diligently invest in projects at the community level that will improve lives in our country's most marginalized communities. We also must go further to ensure that local leaders have a seat at the decision-making table. To this end, the Biden-Harris administration should restore <a href="https://www.epa.gov/cwa-401#:~:text=Section%20401%20Certification%20The%20Clean%20Water%20Act%20%28CWA%29,the%20United%20States.%20Learn%20more%20about%20401%20certification." target="_blank">Section 401 of the Clean Water Act</a>, which was undermined by the <a href="https://earthjustice.org/news/press/2020/tribes-and-environmental-groups-sue-trump-administration-to-preserve-clean-water-protections#:~:text=Under%20Section%20401%20of%20the%20Clean%20Water%20Act%2C,seeks%20to%20undermine%20that%20authority%20in%20several%20ways%3A" target="_blank">Trump administration's 2020 regulatory changes</a>. This provision gives states and tribes the authority to decide whether major development projects, such as hydropower and oil and gas projects, move forward.</p>
Climate Resilience<p>Of course, the menacing shadow looming over it all? Climate change. <a href="https://media.ifrc.org/ifrc/wp-content/uploads/2020/11/IFRC_wdr2020/IFRC_WDR_ExecutiveSummary_EN_Web.pdf" target="_blank">More than 100 climate-related catastrophes</a> have pummeled the Earth since the pandemic was declared last spring, including the blitzkrieg of megafires, superstorms and heat waves witnessed during the summer of 2020, directly impacting the lives of more than <a href="https://media.ifrc.org/ifrc/wp-content/uploads/2020/11/IFRC_wdr2020/IFRC_WDR_ExecutiveSummary_EN_Web.pdf" target="_blank">50 million people globally</a>.</p><p>Water and climate scientist Brad Udall often says, "<a href="https://www.youtube.com/watch?v=xQhpj5G0dME" target="_blank">Climate change is water change</a>." In other words, the most obvious and dire impacts of climate change are evidenced in profound changes to our rivers and water resources. You've likely seen it where you live: Floods are more damaging and frequent. Droughts are deeper and longer. Uncertainty is destabilizing industry and lives.</p><p>By galvanizing action for healthy rivers and managing our water resources more effectively, we can insure future generations against the consequences of climate change. First, we must safeguard rivers that are still healthy and free-flowing. Second, we must protect land and property against the ravages of flooding. And finally, we must promote policies and practical solutions that take the science of climate disruption into account when planning for increased flooding, water shortage and habitat disruption.</p><p>Imagine all that rivers do for us. Most of our towns and cities have a river running through them or flowing nearby. Rivers provide clean drinking water, irrigate crops that provide our food, power our homes and businesses, provide wildlife habitat, and are the lifeblood of the places where we enjoy and explore nature, and where we play and nourish our spirits. Healthy watersheds help <a href="https://news.un.org/en/story/2020/03/1059952" target="_blank" rel="noopener noreferrer">mitigate</a> climate change, absorbing and reducing the amount of carbon in the atmosphere. Healthy rivers and floodplains help communities adapt and build resilience in the face of climate change by improving flood protection and providing water supply and quality benefits. Rivers are the cornerstones of healthy, strong communities.</p><p>The more than <a href="https://archive.epa.gov/water/archive/web/html/index-17.html" target="_blank" rel="noopener noreferrer">3 million miles</a> of rivers and streams running across our country are a source of great strength and opportunity. When we invest in healthy rivers and clean water, we can improve our lives. When we invest in rivers, we create jobs and strengthen our economy. When we invest in rivers, we invest in our shared future.</p>
EcoWatch Daily Newsletter
Fifteen states are in for an unusually noisy spring.
- Millions of Cicadas Set to Emerge After 17 Years Underground ... ›
- Cicadas Show Up 4 Years Early - EcoWatch ›
Deep in the woods, a hairy, ape-like man is said to be living a quiet and secluded life. While some deny the creature's existence, others spend their lives trying to prove it.
- Why Hunting Isn't Conservation, and Why It Matters - Rewilding ›
- Decline In Hunters Threatens How U.S. Pays For Conservation : NPR ›
- Is Hunting Conservation? Let's examine it closely ›
- Oklahoma Department of Wildlife Conservation | Oklahoma ... ›
- Oklahoma Bill Calls for Bigfoot Hunting Season | Is Bigfoot Real? ›
By Jon Queally
Noted author and 350.org co-founder Bill McKibben was among the first to celebrate word that the president of the European Investment Bank on Wednesday openly declared, "To put it mildly, gas is over" — an admission that squares with what climate experts and economists have been saying for years if not decades.
- Fossil Fuel Industry Is Now 'in the Death Knell Phase': CNBC's Jim ... ›
- Mayors of 12 Major Global Cities Pledge Fossil Fuel Divestment ... ›
- World's Largest Public Bank Ditches Oil and Coal in Victory for the ... ›
Nine feet tall is gigantic by human standards, but when researcher and conservationist Michael Brown spotted a giraffe in Uganda's Murchison Falls National Park that measured nine feet, four inches, he was shocked.
<span style="display:block;position:relative;padding-top:56.25%;" class="rm-shortcode" data-rm-shortcode-id="54af350ee3a2950e0e5e69d926a55d83"><iframe lazy-loadable="true" src="https://www.youtube.com/embed/yf4NRKzzTFk?rel=0" width="100%" height="auto" frameborder="0" scrolling="no" style="position:absolute;top:0;left:0;width:100%;height:100%;"></iframe></span>
- Giraffe Parts Sold Across U.S. Despite Plummeting Wild Populations ... ›
- Green Groups Sue to Get Giraffes on Endangered Species List ... ›
- Conservationists Sound Alarm on Plummeting Giraffe Numbers ... ›