The Link Between Energy Efficiency and Clean Air

Report: Efficiency Can Help 32 States Meet EPA Rules

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Posted: Wednesday, June 6, 2018 11:45 am | Updated: 2:25 pm, Thu Jun 7, 2018.

Energy efficiency is a proven, low-cost way to reduce pollutants, and it can significantly help 32 states comply with U.S. air quality regulations, according to a new report by the American Council for an Energy-Efficient Economy.

Despite its value, many states are not taking credit for using energy efficiency to meet federal standards.

The U.S. Environmental Protection Agency’s (EPA’s) National Ambient Air Quality Standards (NAAQS) set limits on six criteria pollutants that are harmful to public health and welfare. States are required to develop state implementation plans (SIPs) to maintain or achieve these standards. EPA designates states with air pollutant concentrations above the NAAQS limits as “nonattainment” areas. These states must meet added stringency requirements through their SIPs to reduce air pollutant emissions in specific geographic regions. States that meet the standards are in “attainment” and must take steps to maintain this status.

Energy efficiency is a least-cost strategy for reducing multiple pollutants simultaneously by reducing the need for power generation from power plants. States can use energy efficiency as a strategy to help reach or maintain attainment with NAAQS or to proactively reduce emissions to avoid initial nonattainment designations. EPA recognizes the multiple benefits of energy efficiency and supports its use as an air quality strategy. Yet, even though energy efficiency policies and utility programs are reducing pollution, many states are missing opportunities to take credit for these reductions. They are not incorporating their energy efficiency programs into SIPs and are instead relying on costlier compliance options.

ACEEE conducted a survey of state air regulators to understand why more states are not taking credit for what they are already doing. Responses suggest that a variety of real and perceived barriers hinder states’ use of energy efficiency as a NAAQS compliance strategy. One such barrier involves the complex nature of the electric grid and the movement of pollutants through the atmosphere. The air quality benefits of reducing pollution extend throughout the country, but the exact location of air quality improvements depends on many complex factors. State regulators cannot assume that energy efficiency executed in a state or city will result in improved air quality in that same state or city, let alone a specific nonattainment area.

Modeling can be used to overcome this uncertainty. The ACEEE analysis uses a publicly available screening model to identify where state-level energy efficiency measures will result in some of the greatest in-state pollution reductions and determine which states can make the best use of energy efficiency to demonstrate compliance with NAAQS.

Using AVERT (AVoided Emissions and geneRation Tool), an emissions quantification tool developed by EPA, we evaluated the avoided power plant pollution that energy efficiency can achieve. We preliminarily identified 32 states where energy efficiency has the potential to reduce certain criteria pollutants required under NAAQS (modeled NAAQS obligations). We determined the potential for each state using results from AVERT that showed pollutant reductions from energy efficiency in geographic areas that coincide with modeled NAAQS obligations. Table ES1 gives an overview. Figure ES1 shows reductions from energy efficiency in every region of the country.

Next, we selected five states with high potential (more than 2,500 tons) and developed a range of estimates for the amounts and locations of the pollutants that could be reduced by energy efficiency. The results indicate that savings from energy efficiency can be a significant contribution to a SIP depending on the state’s obligations. The pollutant reductions from our scenario on a ton-per-day basis are comparable to those from nonenergy efficiency measures states currently rely on to demonstrate compliance.

RESULTS

Illinois

Our energy efficiency scenario resulted in multipollutant reductions in six geographic areas throughout the state. Illinois could incorporate energy efficiency as a compliance strategy to help meet NAAQS for sulfur dioxide (SO2), particulate matter (PM2.5), and ozone, including the 2015 Ozone NAAQS.

Missouri

Our energy efficiency scenario resulted in multipollutant reductions in five geographic areas throughout the state, including two overlapping areas with Illinois. Missouri could incorporate energy efficiency as a compliance strategy to help meet NAAQS for SO2, PM2.5, and ozone, including the 2015 Ozone NAAQS.

Ohio

Our energy efficiency scenario resulted in multipollutant reductions in three key geographic areas throughout the state. Ohio could incorporate energy efficiency as a compliance strategy to help meet NAAQS for SO2, PM2.5, and ozone, including the 2015 Ozone NAAQS.

Pennsylvania

Our energy efficiency scenario resulted in multipollutant reductions in 11 geographic areas throughout the state. Pennsylvania could incorporate energy efficiency as a compliance strategy to help meet NAAQS for SO2, PM2.5, and ozone, including the 2015 Ozone NAAQS.

Texas

Our energy efficiency scenario resulted in multipollutant reductions in 14 major geographic areas throughout the state. Texas could incorporate energy efficiency as a compliance strategy to help meet NAAQS for SO2, PM2.5, and ozone, including the 2015 Ozone NAAQS. Energy efficiency can also help with obligations under the Ozone and PM Advance Program.

RECOMMENDATIONS

Based on our survey of states and the opportunities for pollution reduction identified in our analysis, we recommend the following steps.

Develop tools that states can use to evaluate the impact energy efficiency measures will have on SIP compliance obligations. States have access to a number of valuable tools and guidance documents, but determining the impact of any single program or policy on overall attainment requires detailed and expensive power sector and atmospheric air quality modeling. This rigor of modeling is an integral part of the SIP process but is resource intensive for states. This means that to evaluate the impact a measure will have on the concentrations of a pollutant, a state must invest substantial resources. A tool or decision-making framework for making this assessment before investing the resources for atmospheric modeling could be useful.

Develop a streamlined, EPA-acceptable approach for measuring and documenting outcomes of efficiency programs to be included in a SIP. In 2012, EPA produced a Roadmap detailing pathways a state could take to include energy efficiency programs and policies in a SIP (EPA 2012b; Appendix B). This document provides valuable guidance on many aspects of incorporating energy efficiency into a SIP and has 11 supporting appendices outlining additional details. ACEEE and the National Association of State Energy Officials (NASEO) have also produced templates for guiding states through this process (ACEEE 2014; NASEO 2017). What seems to remain elusive is a simple, straightforward way to account for, document, and model the results of an energy efficiency program or policy for inclusion as part of a SIP plan. This may be partially because many efficiency programs are designed for the non–air quality benefits they provide. For example, utility-run energy efficiency programs are generally regulated by public service commissions, where cost and reliability are top goals. These programs are typically subject to rigorous evaluation, measurement, and verification-reporting requirements, but those results may not be presented in the format that air quality regulators might need. Ideally, programs would report one set of results that could be used by utility commissions and air regulators alike. One way to simplify this process is to treat pollution reductions from energy efficiency similarly to how area and mobile sources are treated in SIPs. Like energy efficiency measures, compliance strategies for area and mobile sources include many small and dispersed measures that states do not individually track but can reasonably model to demonstrate compliance (Colburn, James, and Shenot 2015; Seidman 2017). Building on these existing resources, states could benefit from additional guidance and a streamlined process for measuring and documenting energy efficiency outcomes in a SIP.

Provide states with ongoing, in-depth technical support. Many groups, including ACEEE, provide technical support to states looking to assess the potential role for energy efficiency in attaining air quality goals. However that assistance will be limited by budgets, time constraints, and other realities. Ideally, states would have a long-term support partner with the capacity to offer the rigor and in-depth analytics to answer their most complex questions. A permanently staffed institute or support organization dedicated to meeting these needs could be one way to supplement states’ staffing and budget constraints. For example, Northeast States for Coordinated Air Use Management (NESCAUM) performs modeling for the Northeast states. Multijurisdictional organizations that already perform state and regional air quality modeling (e.g., Mid-Atlantic Regional Air Management Association [MARAMA] and Lake Michigan Air Directors Consortium [LADCO]) could incorporate both energy efficiency and other emission reduction strategies to help relieve individual states of this analysis burden.

CONCLUSION

Energy efficiency is a valuable resource that can achieve low-cost, multipollutant reductions in states across the country. Air regulators can rely on energy efficiency to meet specific pollutant reductions required under NAAQS, but states are missing out on this opportunity. One reason for this is the complexity of determining the exact location where pollutant reductions from energy efficiency will show up.

Our analysis demonstrates that savings from energy efficiency can result in avoided pollution from power plants in the locations needed for modeled NAAQS obligations in 32 states. Looking further at Illinois, Missouri, Ohio, Pennsylvania, and Texas, potential reductions from energy efficiency savings occurred in areas that are currently or anticipated to be in nonattainment for SO2, ozone, and PM2.5. States can use energy efficiency as a low-cost strategy to help reach or maintain attainment with NAAQS or to avoid initial nonattainment designations.

While all states have energy efficiency programs and policies, experience with incorporating energy efficiency in SIPs has been limited. Ignoring the multipollutant reduction benefits from energy efficiency means states must invest in potentially unnecessary control measures for reducing pollution. Our survey of state air regulators indicates that a variety of real and perceived barriers hinder states’ use of energy efficiency as a NAAQS compliance strategy.

Based on our survey of states and assessment of opportunities identified in our analysis, we recommend several actions to further the role of energy efficiency as an air quality strategy for states. To help states evaluate the impact energy efficiency measures can have on SIP compliance, we suggest developing a tool or decision-making framework for making this assessment prior to investing the resources required for atmospheric modeling. In addition, states could benefit from a streamlined, EPA-acceptable approach for measuring and documenting outcomes of efficiency programs for inclusion in a SIP. We also suggest providing ongoing and in-depth technical support. Although the value of energy efficiency as an air quality planning strategy is clear, further work is needed to incorporate energy efficiency into SIPs for NAAQS.

Download the entire report at:

https://aceee.org/research-report/h1803

About the Authors

Cassandra Kubes conducts research, analysis, and outreach on opportunities for energy efficiency to reduce air pollution and improve public health. She provides technical analysis and educates decision makers on strategies to advance energy efficiency policies and programs through federal, state, and local governments. Cassandra is a master of public policy candidate at George Washington University and holds a bachelor of arts degree in people-environment geography from the University of Wisconsin–Madison.

Sara Hayes leads ACEEE’s work related to health and the environment. She oversees a research team focused on the use of energy efficiency to reduce pollution in buildings, increase air quality, and improve human health. Sara serves on the US Environmental Protection Agency’s Clean Air Act Advisory Committee and has over 15 years of experience related to the implementation of the Clean Air Act in federal rulemakings and in states. She has a bachelor of arts degree in environmental studies from Lewis & Clark College and a JD from Fordham Law School.

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