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Energy Efficiency / Renewable Energy in State Implementation Plans

NESCAUM worked with three volunteer Northeast/Mid-Atlantic states to road test the U.S. Environmental Protection Agency’s (EPA’s) Roadmap for Incorporating Energy Efficiency/ Renewable Energy Policies and Programs into State and Tribal Implementation Plans (the Roadmap). This initiative looked at three pathways through which energy efficiency (EE) and renewable energy (RE) may be incorporated into State Implementation Plans (SIPs), including: (1) baseline emissions forecast; (2) control strategy; and (3) weight-of-evidence (WOE).1

The project was funded by EPA and the NESCAUM states. The goals were to highlight opportunities to include EE and RE in air quality planning, to provide EPA and other states with real-world examples of incorporating EE and RE in SIPs, and to consider lessons learned.

  • The Massachusetts Department of Environmental Protection (MassDEP) case study reviews how it might represent its statutory requirement to employ “all cost-effective EE”2 using the baseline emissions forecast pathway. MassDEP’s case study reviews Massachusetts’ recent experience developing load projections to support analysis of changes to the Regional Greenhouse Gas Initiative (RGGI) program and shows what can be achieved through sustained collaboration with multiple state agencies and electric grid operators.
  • The New York State Department of Environmental Conservation (NYSDEC) case study provides a hypothetical SIP submission and supporting documentation using the control strategy pathway. NYSDEC’s case study illustrates how a state might use an energy model to quantify emissions changes associated with energy programs, the number of small- and mid-size energy programs needed to achieve desired emissions reductions, as well as the opportunity for bundling EE and RE measures for inclusion in a SIP.
  • The Maryland Department of the Environment (MDE) case study reinterprets EPA’s WOE pathway, which, as written, does not allow for SIP crediting, and proposes an expanded WOE approach. MDE is conducting a comprehensive multi-pollutant analysis, using energy, economic, air quality, and health assessment models, that will be the basis of its 2015 ozone SIP. The case study is a status report of work completed to date, and describes MDE’s work towards including EE and RE emissions reductions in its SIP.

A final report to EPA included case studies from each of the three volunteer states and a summary of ongoing discussions with EPA on key policy considerations, including:

  • Promoting state and regional consistency in the development and review/approval of SIPs that incorporate EE and RE
  • Addressing the challenge of determining location of emissions reductions from EE and RE programs, including using an approach similar to how mobile and area source programs are assessed credit for SIP purposes
  • Clarifying expectations for how states demonstrate that EE and RE programs benefit the nonattainment area, as discussed in the August 2013 Frequently Asked Questions document3.
  • Promoting consistency in quantification methods, including the assessment of EE evaluation, monitoring and verification (EMV) protocols
  • Briefing the states on the U.S. Department of Energy (DOE) State and Local Energy Efficiency (SEE) Action Network and the DOE Uniform Methods project,4. including timelines, expected outcomes, and applicability of these efforts to quantifying EE and RE in SIPs

Next steps are to continue discussion and dialogue with EPA as these case studies are introduced to other states, and as they and other states prepare SIPs that quantify EE and RE programs.

The NESCAUM final report to EPA is available here.

For a copy of the Roadmap and supporting documents, see:

For a copy of EPA’s Roadmap Frequently Asked Questions document, see:


1A fourth pathway, innovative and emerging measures, was used as the basis for EPA’s previous EE in SIPs guidance, issued in 2004. See:

2For the Massachusetts Green Communities Act of 2008 and Massachusetts’s requirement to implement “all cost effective EE,” see:

3EPA, Roadmap for Incorporating EE/RE Policies and Programs into SIPS/TIPs – Frequently Asked Questions (August 2013). See:

4See: and

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