Category: Policy (National)

Leading By Example Through Building Performance

The VAEEC recently hosted a webinar on building performance primarily for local governments across the Commonwealth. Leading By Example Through Building Performance followed three different building performance policies and programs to not only encourage the audience to implement their own strong green building policy but to also provide best practices and lessons learned from the design phase all through the day-to-day management of a program.

Speakers included:

  • Dawn Oleksy, Climate Action Programs & Operations Supervisor, City of Richmond
  • Bill Eger, Energy Manager, City of Alexandria
  • Holly Savoia, Director of Sustainability Enforcement, NYC Department of Buildings, and
  • Elizabeth Beardsley, Senior Policy Counsel, U.S. Green Building Council.

With Virginia being a Dillon Rule state, localities are limited as to what they can and cannot mandate. However, jurisdictions are finding ways to make progress happen in their communities.

The webinar began with an overview of green buildings and the benefits of a strong green building policy – such as energy savings, emission reductions, and improved air quality – from Liz. Next, Dawn covered the City of Richmond’s climate action policy, RVAgreen 2050, which the City is currently in the middle of developing. RVAgreen 2050 centers around three key points: equity, climate action, and climate resilience. Buildings & Energy is one of five pathways the City is using to meet its goal of achieving net-zero emissions by 2050 and becoming more climate-resilient. This includes requiring an equitable building performance policy for existing commercial buildings, retro-commissioning for existing commercial buildings to improve efficiency, and benchmarking existing commercial buildings.

RVAgreen 2050 is equitable climate action for a healthy and resilient Richmond.


Dawn specified the need for stakeholder engagement throughout the entire process in order to better understand the community’s priorities. She also shared RVAgreen 2050’s measuring process to track the plan’s outcomes and the shared accountability framework to encourage transparency, a culture of improvement, trusting relationships, institutionalizing sustainability in city government, and regular evaluation.

Richmond just began the next phase of community-wide engagement to gather feedback on the plan. RVAgreen 2050 is scheduled to be finalized this summer and adopted by fall.

Next, Bill provided an overview of the City of Alexandria’s Green Building Policy. The City initially enacted this policy in 2009. Alexandria created the Environmental Action Plan 2040 to support the City’s goals, which include climate action and energy reduction.

The Green Building Policy establishes minimum green building practices for new public and private development and major renovations.


To work around Virginia’s “constrained policy environment”, authority for this policy is rooted in the City’s zoning code. Certain building performance conditions are required for the Development Site Plan and Development Special Use Permit review processes. New development must achieve the LEED Silver level of certification at a minimum. Using a third-party rating system provides an expert verification of meeting compliance requirements without having to have experts on staff. The policy also includes a minimum threshold requirement for a number of community priorities, such as energy efficiency, renewable energy, and advanced energy metering.

The Green Building Policy was updated in 2019 to include newer concepts such as decarbonization. In the ten-year span between 2009 and 2019, over 95% of the development square footage constructed or currently under construction in Alexandria is compliant with the 2009 policy. This equates to nearly 10 million square feet of green building development.

Holly provided an overview of New York City’s Energy Grades Program, including the local sustainability laws that led to this program. PlaNYC set out to reduce the City’s emissions by 30% by 2030. The Greener, Greater Buildings Plan paved the way for benchmarking, energy audits and retro-commissioning, and lighting upgrades and sub-metering. Then, after Hurricane Sandy hit, the One City Built to Last Policy increased the emissions reduction goal to 40% by 2030 and 80% by 2050.

Commercial benchmarking served as the precursor to the City’s Energy Grades Program.

Since it provides transparency of a property’s annual energy and water usage, benchmarking is seen as the first step for building owners or tenants to make a building more efficient – you can’t change what you can’t measure.

The City’s commercial benchmarking mandate originally applied to buildings over 50,000 SF, but was later amended to apply to any building over 25,000 SF. Building owners must report their building’s energy and water consumption annually through the U.S. EPA’s Energy Star Portfolio Manager. Portfolio Manager is a readily accessible, free tool, so the municipality did not have to purchase it or develop their own benchmarking software. Additionally, building owners do not have to pay to use it or hire someone else to input the data, which helps lead to higher compliance rates. New York City has also created a way for building owners to automatically upload their data from their utility bills. Initially, violation fees were issued once a year. Now that they are issued on a quarterly basis, the City has a 96% compliance rate.

New York City’s Building Energy Grades Program applies to most buildings over 25,000 SF. The Department of Buildings uses a building’s benchmarking data to assign qualified buildings a letter grade distribution based on their Energy Star score. Owners are required to post their building’s Energy Efficiency Rating Label in a conspicuous location of their building’s entrance. The program provides transparency of a property’s energy efficiency to the public.

One of the key takeaways from all the speakers is the importance of getting the private sector involved early in the policy-making process. Getting them involved from the beginning not only increases buy-in but also allows localities to understand challenges that they may not have foreseen and to brainstorm solutions.

It was inspiring to see all of the thought and effort that goes into developing, implementing, and managing green building policies.

A recording of the webinar can be viewed here. Contact for more information.

DOE plans wasteful rollback of Residential Lighting Program standards

The Department of Energy plan to roll back federal energy efficiency light bulb standards will have wide-reaching consequences in Virginia and nationwide. ACEEE released this statement yesterday, positing that the decrease in regulatory standards would lead to an additional 80 billion kWh of energy usage per year, “about the combined usage of all households in Pennsylvania and New Jersey,” as well as pollution increases equal to, “the annual CO2 emissions of more than seven million cars.”

An estimated 115,000 jobs were predicted to come from Phase 2 of the Residential Lighting Program, with the average household saving roughly $100 dollars per year in energy costs.

Moreover, study after study has shown that low-income populations are consistently hit hardest by both energy costs and health effects. 8.5% of all Virginia residents suffer from asthma, with low income communities and young children affected at the highest rates. The environmental ramifications of deregulation will reverse the decreasing trend of asthma-related hospitalizations in the state.

Not only does this have negative consequences moving forward, but the standard that is now being rescinded was the basis of several SCC decisions to reduce energy efficiency program budgets in 2018. Appalachian Power was driven to withdraw one of the five proposed residential energy efficiency programs based on the SCC staff interpretation of the federal lighting standards. The SCC also reduced Dominion Energy’s low-income program from five to three years on the same basis. If implemented, these programs would have expanded LED installations, and other measures, across the state, saving money and conserving energy for the consumer.

As ACEEE stated, the draft rule “will almost assuredly draw legal challenges,” since the current roll back is most likely illegal, based on a federal law prohibiting the DOE from weakening energy efficiency programs on products like light bulbs.

Progress report on Virginia’s Clean Power Plan stakeholder group

Governor McAuliffe’s stakeholder group on the Clean Power Plan (CPP) met for the third time on Friday, February 12, and began getting into the details of the choices before us. The McAuliffe Administration and Virginia Dept. of Environmental Quality (DEQ) are moving forward with a Virginia implementation plan despite the recent Supreme Court stay on the EPA regulation targeting greenhouse gases.

Energy efficiency should have a strong role in the Virginia CPP implementation plan. The state has high per-capita electricity use, due to decades of low prices and limited programs for efficiency. The Commonwealth has enormous potential for cost-effective energy efficiency savings. How well the state captures this potential for economic gain will depend in large part on the implementation plan Virginia designs.

Stay tuned for more.


John Morrill headshotJohn Morrill is the energy manager for Arlington County. He is on the Governance Board of VAEEC, and he was appointed to the CPP Stakeholder Group on behalf of the Virginia Association of Counties (VACO). John welcomes input from readers:

Blog: New White Paper – Clean Power Plan can have minimal impact on Virignia ratepayers, and energy efficiency is key

January 20, 2016

“Implementing the U.S. Environmental Protection Agency’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 among the findings of a white paper released today by the Advanced Energy Economy Institute.Screen Shot 2016-01-20 at 2.01.03 PM

The basis of the paper is an open-access analytic tool called the State Tool for Electricity Emissions Reduction (STEER) that allows state officials and other stakeholders to consider CPP compliance options and their economic impacts.The paper presents the results of two specific scenarios that are representative of multiple runs through STEER.

Echoing previous regional and national studies, this report emphasizes the important role energy efficiency can play in meeting CPP carbon reduction targets:

“Over several runs of the STEER model, energy efficiency and renewable energy are consistently the lowest cost mitigation options for the state. With significant energy efficiency potential, the state has an untapped resource in utility energy efficiency and network efficiency improvements.”

Screen Shot 2016-01-19 at 1.41.18 PMMost likely to turn heads is the report’s finding that with energy efficiency and renewables, these targets can be with minimal impact on electricity costs in Virginia compared with business as usual:

“In Scenario A there is a minor rate increase seen, less than a half of a penny per kilowatt hour, compared with a business-as-usual projection. In Scenario B, the scenario using the SCC’s efficiency potential study, we see a decrease in electric rates compared with business-as-usual. In neither scenario do we see significant costs imposed on Virginia ratepayers as a result of Clean Power Plan compliance. The result is likely due to the substantial contribution to compliance made by low-cost resources such as energy efficiency and renewable energy. The scenarios shown here demonstrate that Virginia can achieve its required carbon reduction targets without imposing significant costs on ratepayers compared with business as usual.”

As the Commonwealth moves forward with CPP compliance plans, reports of this nature provide state leaders with another layer of evidence that the targets are achievable when we harness energy efficiency and renewables.

Side note: The American Council for an Energy Efficient Economy (ACEEE) just released the State Utility Pollution Reduction Calculator Version 2 (SUPR2), a tool that allows anyone to explore the cost and pollution reduction potential of different strategies.

Find out more and get access to ACEEE’s SUPR2 here

Read the full Advanced Energy Economy Institute white paper here. The press release is also available here. 

STEER for VIRGINIA is available for download as an Excel spreadsheet, with user manual, at

Guest Post: PACE update and recommendations

Abby JohnsonGuest Blogger: Abby Johnson, Abacus Property Solutions (VAEEC Member – Individual)

January 19, 2016

This year, Virginia Community Capital received a grant from the Oak Hill Fund to explore implementation of PACE financing in Virginia. As part of this grant, VCC held an initial stakeholder meeting on July 14, 2015 where attendees heard about the new PACE law that went into effect on July 1, 2015 as well as from guest speakers from other states. On December 8th, Virginia Community Capital (“VCC”) held the final Virginia PACE Financing stakeholder meeting at the Trane facility in Ashland. At this meeting, the Department of Mines, Minerals and Energy (DMME) gave an overview of the new PACE financial underwriting guidelines that went to effect December 1, 2015 and Rich Dooley, of Arlington County gave an update on Arlington’s plans to issue an RFP for a program administrator. Then I joined Neal Barber of Community Futures to present the findings from our grant research. Afterwards, attendees broke out into groups to discuss these recommendations and offer their insights.

As a seasoned executive within state and local governments for 40 years, Neal was selected to interview local elected officials and staff from across Virginia. During the fall, Neal met or spoke with 35 jurisdictions to gauge the level of knowledge and interest in participating in a PACE financing program. For the most part, his research revealed that few jurisdictions were currently aware of PACE with the exception of those with dedicated sustainability officials. Although there was definitely interest in the concept of PACE as an economic development tool, top conclusions from these interviews revealed that there is a:

  • Need for significant education to different parts of a locality’s staff to explain how PACE would impact them
  • Benefit to engaging a local champion to push PACE as a priority item within a locality
  • Interest in a centralized “plug and play” program
  • Preference for seeing how PACE is adopted in other jurisdictions before taking the proverbial plunge.

Given my deep knowledge of PACE programs around the country and extensive work in Virginia, I was asked to analyze national best practices and develop an initial set of recommendations for our state. Some highlights include:

  • A minimum annual project volume of $10-20 million is needed to sustain a PACE program, assuming upfront ongoing administration fees are the primary source of funding for the administrator.
  • Most successful programs have or had internal funding or financing structures such as the Green Bank in Connecticut.
  • Successful programs tend to be located in areas with high utility rates, robust incentive structures, and/or higher energy usage such as California and Connecticut.
  • The cost to develop (set-up and implementation) a PACE program is estimated to be $500K to $1 million for a full service program administrator.
  • Although smaller projects (under $300k) represent a major source of deal flow, the costs to both the program administrator and the building owner are often prohibitively high and must be streamlined to be a viable product line.
  • Education is key and must be a major budget item both to convince localities of the program’s value and to train key channel partners.

Although much more research is required to develop a detailed implementation plan, some initial recommendations include:

  • Develop a P3 platform through alignment with a new or existing statewide entity with a standardized set of documents and procedures such as: model ordinance, underwriting criteria, and vetted contractors and capital providers. This state-level entity would partner with regional and local institutions to leverage existing relationships and marketing infrastructure.
  • Prioritize two or three localities with the maximum potential for the first year.
  • Identify creative ways (such as job creation/training grants) to provide the program administrator with funding that generates a healthy pipeline quickly.

Arlington County is forging ahead with developing a PACE program. This past week, Arlington held the first of several planned discussions on the benefits of PACE to local stakeholders – this one geared toward commercial real estate lenders. I, along with Arlington’s Rich Dooley, fielded many thoughtful questions during this lively discussion, demonstrating first hand the absolute importance of education when introducing a new product to the market.


Related Post: PACE is finally here in Virginia (June 2015)

EPA Accepting Comment on Clean Energy Incentive Program through December 15

When the EPA Clean Power Plan rule was finalized this summer, they announced the Clean Energy Incentive Program (CEIP) which allows states to receive double credit for energy efficiency and renewable projects in low-income communities. The EPA is currently accepting comments on the CEIP through December 15, and the VAEEC encourages its members and stakeholders to submit comments.

To comment: 

EPA invites you to provide written responses to the attached questions to the non-regulatory docket established for this purpose. EPA will accept input, identified by Docket ID Number EPA-HQ-OAR-2015-0734 through December 15, 2015. You may use one of the following methods:
· Go to and follow the on-line instructions for submitting comments.

· Send comments by e-mail to

· Fax your comments to: (202) 566-9744.

· Mail your comments to:

EPA Docket Center,

Environmental Protection Agency, Mail Code: 28221T

1200 Pennsylvania Ave., NW

Washington, DC 20460



Under the leadership of President Obama, EPA issued the Clean Power Plan, a historic step to fight climate change. The Clean Power Plan will reduce carbon pollution from power plants, the nation’s largest source, while maintaining energy reliability and affordability. EPA also issued final Carbon Pollution Standards for new, modified, and reconstructed power plants, and proposed a Federal Plan and model rules to assist states in implementing the Clean Power Plan.

We look forward to your participation and please extend this invite to your organization’s leadership. Information about the Clean Power Plan can be found here. Get more information about the Clean Energy Incentive Program here. 


Questions to consider: 

What should EPA consider when defining criteria, terms and requirements under the CEIP?
· What definition(s) of ‘low-income community’ should be required for eligible energy-efficiency (EE) projects?

· What criteria should be used to define eligible wind and solar projects, as well as eligible EE projects implemented in low-income communities? (e.g., by sector (residential, commercial, etc.) or by geography (where a project takes place and who benefits from it))

· What should be the evaluation, measurement and & verification (EM&V) requirements for eligible projects; the requirements for M&V reports of quantified megawatt-hour (MWh); and the requirements for verification reports from an independent verifier?

· How could EPA set criteria for states, tribes and territories for whom goals have not yet been established in the final Clean Power Plan’s Emission Guidelines (EGs) to participate in the CEIP?
The following three questions have been posed by stakeholders:
· What commencement date is appropriate for a project to qualify as eligible for the CEIP?

· How should ‘commence construction’ of an eligible wind or solar project and ‘commence operations’ of an eligible low-income EE project be defined?

· Should CEIP allowances or emission reduction credits (ERCs) be available for projects in jurisdictions without affected entities (e.g. tribal lands and states without EGUs). If so how should the CEIP mechanism be designed to address these areas?

What should EPA consider regarding the timing and distribution of allowances under the CEIP?
· How should the 300 million short ton CO2 emissions-equivalent matching pool be allocated among states participating in the CEIP?

· How should the 300 million short ton matching pool be split between the two reserves: one for wind/solar, one for low-income EE?

· When should EPA allocate matching allowances or emission reduction credits (ERCs) to a state, and when should awards from these allocations be made to eligible project providers?

· How should matching allowances or ERCs that are allocated to a state but not awarded to eligible projects be redistributed among other states with unmet demand for matching allowances or ERCs, and when should this redistribution take place?

What should EPA consider when designing the mechanics of the CEIP?
· What are the appropriate mechanisms a state (in the case of a state plan) or EPA (in the case of a federal plan) should use to review project submittals and issue early action allowances or ERCs?

· How should the 300 million short ton CO2 emissions-equivalent matching pool be converted into ERCs, which are based on MWh?

· What mechanisms should EPA consider for maintaining the stringency of rate-based emission standards during the compliance periods to account for the issuance of early action ERCs for MWh generated or avoided in 2020 and/or 2021?

VAEEC remarks at DEQ Clean Power Plan listening sessions

The Virginia Department of Environmental Quality (DEQ) is in the middle of a series of informal listening sessions on the U.S. Environmental Protection Agency (EPA) Clean Power Plan to cut carbon emissions (greenhouse gases) from existing power plants that generate electricity from fossil fuels. 

The following remarks will be delivered at the Fairfax session tonight by the Chair of VAEEC’s Governance Board; similar remarks have been and will be delivered by Governance Board members at other session. There are three remaining sessions (September 30, 2015, Henrico, VA; October 1, 2015, Big Stone Gap, VA; October 6, 2015, Portsmouth, VA). 


“I’m Cynthia Adams, and I am Chair of the Virginia Energy Efficiency Council. I’ve also been appointed by Governor McAuliffe to the Virginia Energy Council and to the Governor’s Executive Committee on Energy Efficiency. In my professional life I’m the co-founder of a business which focuses the residential energy efficiency market. So from all of these perspectives, I am here tonight to advocate for energy efficiency having a central role in Virginia’s Clean Power Plan Compliance.

The Clean Power Plan affords Virginia an opportunity to make sensible energy decisions now that will benefit the Commonwealth for generations to come.

Energy efficiency is one of the primary tools available to help states meet their targets, and when approached from a performance-based perspective can be counted on to lower carbon emissions.

Energy efficiency is the least expensive resource option to meet our energy supply needs. Plus it saves consumers money with lower energy bills.

Energy efficiency is the cleanest option as it represents energy that doesn’t have to be created or consumed, and its implementation reduces multiple pollutants created by other fossil fuel sources.

Energy efficiency is the safest, most reliable option because through demand reduction it improves our energy security by reducing risk and increasing reliability.

Energy efficiency promotes local economic development and job creation. A recent industry census by the Virginia Energy Efficiency Council documented a $2.2 billion energy efficiency industry in Virginia. This industry supports at least 13,000 jobs at more than 500 firms.

The American Council for an Energy Efficient Economy has found that for every $1M spent in building efficiency improvements, 20 jobs are supported. And for every $1M in avoided consumer energy costs, another 17 jobs are supported.

The Virginia Energy Efficiency Council strongly encourages Virginia to include a robust role for energy efficiency in its compliance plan as a way to meet federal guidelines while generating significant economic and environmental benefits for our fellow citizens.

We strongly advocate for a role for the private market to play in helping the state meet its goal, and we stand at the ready to be a resource to the DEQ should the agency have a need.”

VAEEC Statement on Federal Clean Power Plan

Monday, August 3, 2015

This afternoon, the U.S. Environmental Protection Agency released its long-anticipated final rule on the Clean Power Plan (CPP), a federal initiative for curbing greenhouse gas emissions from power plants. The CPP calls for a significant reduction in carbon emission from the nation’s power sector – a 32 percent reduction below 2005 levels by 2030. The CPP sets state-by-state targets for emission reductions and allows states to develop their own compliance plans. Details can be found here. 

Statement by Ken Rosenfeld, executive director of the Virginia Energy Efficiency Council:

“After much anticipation, the Clean Power Plan is here and the Virginia Energy Efficiency Council (VAEEC) recognizes this as an opportunity to plan for the future and make sensible energy decisions.

While the Clean Power Plan has generated plenty of debate, it’s time now for Virginia to prepare a comprehensive strategy to address the plan’s goals. To that end, the VAEEC strongly encourages Virginia to include a robust role for energy efficiency in its compliance plan. Energy efficiency can help meet the federal guidelines while concurrently generating significant economic and environmental benefits for Virginians.

There are a few specific items in the final rule that deserve particular mention:

  • Energy efficiency is no longer specified as a “building block” – a category used by the EPA to calculate the emissions reduction targets. This is a technical change that was reportedly made to address legal concerns, but it’s important to note that it does not affect the significance of energy efficiency as one of the primary compliance tools available to states to meet their targets.
  • It specifically creates a Clean Energy Incentive Program, which offers credits to states that implement energy efficiency programs in low-income communities.
  • It allows states to request extensions for submitting their implementation plans, and extends the deadline to begin the compliance period from 2020 to 2022; this development provides the time needed to develop thoughtful and comprehensive plans, and allows for careful consideration of how energy efficiency will be incorporated.

We know that an increased emphasis on energy efficiency needs to be part of any comprehensive approach. Energy efficiency is a rare “win-win” in energy policy, a common sense, nonpartisan, and cost-effective solution:

  • It’s the lowest-cost resource option to meet Virginia’s energy supply needs,
  • It’s the cleanest option as it represents energy that’s not consumed,
  • Through demand reduction it improves our energy system by reducing risk and increasing reliability, and
  • It promotes local economic development and job creation – an industry census performed by the VAEEC reveals a $2.2 billion energy efficiency industry in Virginia supporting at least 13,000 jobs at more than 500 firms.

The VAEEC represents a wide range of perspectives, and we look forward to working with the McAuliffe Administration, state agencies, policymakers and our many partners as Virginia devises the best path forward to meeting the Clean Power Plan goals.”

The Virginia Energy Efficiency Council (VAEEC) is a broad coalition working to assess and support innovative programs, policies and best practices that encourage energy efficiency in the Commonwealth and to provide a forum for stakeholder interaction. The VAEEC is a 501(c)(3) nonprofit organization whose membership includes businesses of all sizes, utilities, nonprofit and advocacy organizations, local governments and state agencies. For more information, visit

VAEEC Chair testifies in DC on EPA's proposed carbon regulations, role of home performance

Cynthia Adams, Chair of VAEEC’s Governance Board, testified today at a public hearing on Capitol Hill regarding the Environmental Protection Agency’s new clean power plant rules. Adams represented Efficiency First in her capacity as a Board member. Her full testimony is included below.

Testimony on Carbon Pollution Emission Guidelines for Existing Stationary Sources

Cynthia Adams, Efficiency First

July 30, 2014

Thank you for the opportunity to testify today on the EPA proposed rule on Carbon Pollution Emission Guidelines for Existing Stationary Sources.  My name is Cynthia Adams, and I am Chair of the Virginia Energy Efficiency Council, appointed member of Governor McAuliffe’s Virginia Energy Council, and a board member of Efficiency First whom I am here today to represent.

Efficiency First is the national business association for the home performance industry, whose members are home performance contractors and companies across the U.S. With state and local chapters across the country, we work with companies to retrofit America’s homes and bring them—and our economy—into the future. Together, we advocate for policies that accelerate the growth of the industry, creating huge opportunities for companies and delivering meaningful value to homeowners.

First, we want to applaud the Administration for this important effort to regulate carbon emissions and for the recognition in the rule that energy efficiency should be a part of the answer to carbon reductions.  We believe home performance meets the “Best System of Emission Reduction” (BSER) test and is a crucial part of Building Block #4 (Energy Efficiency) in the proposed rule.  In fact, with more than 113 million residences consuming 22% of all U.S. energy, this sector is a critical part of any program that targets emission reductions. We are here today to offer suggestions for improvement to the draft regulations and we will provide further details in our October 16th Comments.

We urge EPA to consider allowing states to account for natural gas savings in energy efficiency programs.  We urge EPA to recognize the unintended consequences that could be associated with fuel switching and the carbon that would not be captured and measured, as well as the inefficiencies in delivery of energy efficiency services that may come by excluding efficiency gains from gas and other heating fuels under the rule.

For example in the residential sector, current home energy performance programs that aim to reduce the overall energy use of a home, may instead be encouraged by the rule to switch from electric heating to natural gas heating, without ensuring that this effort is coupled with air sealing and insulation.  Unless the home is well insulated, the opportunity to achieve potential savings through the upgrade will be lost. Further, the carbon emitted from the natural gas heater will not be measured.  We recommend that EPA offer states best practices for ensuring that energy savings is maximized in residential programs.

Please know that not all energy efficiency programs are created equal.

Today, rate-payer funded programs are usually required to pass a cost-effectiveness test.  These tests are based on five tests originally developed in the 1970s California Standards Practice Manual.  Despite more recent updates, these tests are often implemented in ways that are biased against deeper energy efficiency investments because they account for all the costs, but frequently ignore many of the benefits.  A new screening effort that Efficiency First has participated in, called the Resource Value Framework (RVF) provides a powerful tool for public utility commissions to ensure that their cost effectiveness tests are balanced, transparent, and account for public policy goals.  We urge EPA to recommend the use of the RVF to states that wish to test their 111D compliance programs for cost-effectiveness in order to encourage deeper energy savings opportunities.

Home performance programs have many different designs, as noted in the proposed rule.  For example, with each method for calculating savings (deemed, modeled, measured, etc), there are best practices that we urge EPA to include in its guidance to states developing their implementation plans.  We will provide further input in our comments, but as a preliminary statement we urge the EPA today to consider that there are new technologies — smart meters to measure energy efficiency as a resource, home energy management devices and others —  emerging every day in the marketplace that can assist with program design and carbon measurement.  These technologies are providing crucial communications between utilities and homeowners.  Standards, protocols, and platforms are just being developed.  We strongly recommend that EPA recognize this nascent revolution and ensure that their regulation not close the door to new technologies and program designs that encourage innovation.

As EPA develops its rules for evaluation, measurement, and verification (EMV), we urge the consideration of energy consumption data as provided by utilities. This data, in the form of both traditional utilities bills and more advanced technologies such as “smart devices” and home energy management systems, can provide valuable information about energy use and contribute to accurate quantification of savings.  This information should be recognized and considered for use in EMV protocols.  However, protocols and policies that allow for both data access and analysis may take time to develop. We encourage EPA to include the use of this data specifically in its EMV rules.

Finally and importantly, we ask EPA to consider the non-ratepayer funded solutions to energy savings in the private sector and encourage aggregation and the development of a registry to register and retire emissions that private contractors and companies can provide from electricity reduction outside the utility programs.

Thank you on behalf of the Efficiency First for the opportunity to testify.  While there are great gains to be made overall, please ensure that continued attention is paid to the only element of the rule that directly both includes small business and average Americans – the energy reductions in the residential sector.

Thank you.

Tom Coburn amendment to federal workers: Flip that switch

It’s the kind of thing most people heard from their parents over and over again when they were kids: Turn off the lights when you leave a room. Now Sen. Tom Coburn hopes to make it legally binding The Oklahoma Republican filed an amendment to energy efficiency legislation being debated by the Senate that would “encourage Federal employees to help reduce energy use and costs by turning off the lights at the end of the day.” But it would go beyond just offering encouragement.

Read the full story. (Politico)

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