NRECA provided comments to the Environmental Protection Agency (EPA) regarding the Energy Efficiency goals stipulated under the 111(d) regulations. EnerVision researched and provided documentation in support of NRECA’s position that the 1.5% annual energy efficiency savings goal is too broad and does not account for the widely varying characteristics of electric cooperatives across the nation.
Electric cooperatives provide safe, reliable, and affordable power to their members across the country. Just as they are geographically diverse, electric cooperatives also differ in size, load characteristics and growth, wholesale power supply arrangements, and member demographics. It is typical for electric cooperatives to assess energy efficiency programs in terms of whether they are the most cost-effective alternatives available (i.e., by utilizing the rate impact measure test) and/or whether their member-consumers find the demand-side alternatives desirable. EnerVision’s research highlights how these differences are a core consideration when developing energy efficiency programs and how the EPA’s 1.5% goal does not properly account for them.
EnerVision’s analysis also highlights why states will need to conduct case by case analyses to evaluate both the potential for what energy efficiency savings can be achieved, as well as potential costs associated with developing and implementing such programs, including quantitative and qualitative justifications.
EnerVision’s research is broken into sections/examples in the following report, which was incorporated by NRECA into their comments.
NRECA’s full comments which reference EnerVision’s work:
EnerVision’s input – Attachment H (page 237):