About ten years ago, the U.S. EPA began publishing guidance regarding how states could take credit for emissions reductions realized through electric sector energy efficiency (EE) and renewable energy (RE) policies and programs. The initial guidance, was published in August 2004 and was followed by guidance related to addressing emerging and voluntary measures in state implementation plans in September 2004, guidance on incorporating “bundled measures” in a state implementation plan (SIP) in August 2005, and modeling guidance for demonstrating attainment with the Ozone and PM2.5 national ambient air quality standards (NAAQS) and Regional Haze in April 2007. These initial EE/RE guidance documents were intended to prompt states to take credit for emission reductions related to EE/RE in their SIPs. However, the initial guidance apparently resulted in very few instances of states incorporating EE/RE policies and programs into SIPS. The reasons cited for the limited use of the initial guidance included a perception that the effort needed was not justified by reward (SIP credit), a lack of guidance from U.S. EPA, overly burdensome documentation requirements, and uncertainty regarding the achievable reductions.
On July 2, 2012, the U.S. EPA issued “new” guidance, referred to as the EE/RE Roadmap Manual (Roadmap); to assist states for incorporating EE/RE policies and programs into their SIPs. The agency identified several reasons for the release of the new Roadmap, the most compelling for states being the increasingly stringent NAAQS levels, the need to find (and document) even greater emissions reductions where the majority of the larger emission point sources have already been controlled, and the realization that non-traditional emission reductions may be the most cost effective reductions available. In addition, the agency cited the increased state adoption of EE/RE policies and programs since 2004 that could result in air quality benefits (and that could be reflected in SIPs) and provided the following examples:
- At least 29 states have adopted renewable portfolio standards (RPS) requiring retail electricity suppliers to provide a fixed amount of retail power from renewable resources.
- States have significantly increased investment in EE programs with over 5 million dollars of ratepayer resources.
The Roadmap is comprised of a summary or “Main Body” document and a series of eleven (11) appendices that defines terms, explains the workings of the U.S. electric system, summarizes previous/existing EE/RE guidance, explains several state EE/RE programs and policies, describes the use and function of four alternative “mix and match” pathways, provides methodology for quantifying EE/RE emission and reductions and energy savings, and identifies examples of EE/RE policies and programs that have been adapted by states. It also includes an extensive disclaimer which clearly states that it is not a regulatory action and does not create new guidance, but was issued primarily to “clarify existing guidance.” The remainder of this article very generically identifies EE/RE strategies, summarizes the pathways identified in the Roadmap, provides a few examples of how several states are currently evaluating the use of the Roadmap, and identifies why this process is important for sources beyond EGUs.