by Brianna Crandall — November 12, 2014—Advanced Energy Economy (AEE), a national association of businesses making energy secure, clean, and affordable, has submitted comments in support of the U.S. Environmental Protection Agency’s (EPA) draft rule for reduction of carbon emissions under Section 111(d) of the Clean Air Act — EPA’s “Clean Power Plan” — but saying that advanced energy technology targets should be strengthened because EPA has underestimated their potential.
Methodologies utilized by EPA in setting state-by-state targets based on expected use of energy efficiency and renewable energy to reduce emission rates are flawed, according to AEE. EPA has ignored billions of dollars in annual energy efficiency investments that can be relied upon to achieve even greater emission reductions in the years ahead, and its targets for zero-emission renewable energy do not take into account the available resources that states will be able to capture as the costs of wind, solar, and other technologies continue to fall between now and 2030.
“AEE strongly supports the Clean Power Plan as a vital step toward modernizing the U.S. electric power system for greater efficiency, reliability, and economic opportunity,” said Malcolm Woolf, Senior Vice President for Policy and Government Affairs. “With a wide range of solutions including natural gas power generation, energy efficiency, and renewable energy, reducing greenhouse gas emissions will not be difficult, and it will drive investment in an electric power system that sorely needs it. We are urging EPA to build upon the solid foundation of the Clean Power Plan by making changes that fully realize the benefits of advanced energy technologies for emission reduction and economic growth.”
In its comments, AEE also 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;
- Take several actions to facilitate the use of advanced energy technologies for state compliance. In order to avoid uncertainty on the part of states about eligible technologies and how to incorporate them into compliance plans, AEE asked EPA to clarify the crediting of emission reductions from renewable energy and energy efficiency actions;
- Expand the range of compliance options to explicitly include the 40 technologies described in AEE’s Advanced Energy Technologies for Greenhouse Gas Reduction; and
- Avoid disruption in advanced energy markets that are already growing, which could occur if new policies and programs were delayed until the start of the formal compliance period, by giving credit for new actions taken by states prior to 2020.
An Executive Summary of AEE’s comments to EPA and the full 62-page submission are available from the AEE Web site with a brief registration.
