AGA Comments on EPA Clean Energy Incentive Program (CEIP)

Policy December 16, 2015

On December 15, AGA, the National Association of State Energy Officials (NASEO), the Business Council for Sustainable Energy (BCSE) and the Alliance for Industrial Efficiency filed comments on EPA’s CEIP questions. The goal of the CEIP is to offer free tradeable emission credits (“allowances” for mass based plans, and “emission reduction credits”) to (1) renewable energy projects, and (2) energy efficiency projects benefiting low income communities – provided the projects take place during the period before the CPP reduction goals commence.

AGA asked EPA to do the following:

  1. Define “low income community” on a flexible geographic basis (rather than just by households) so that combined heat and power (CHP) and direct use in businesses and institutions (like schools and community centers) can qualify for the CEIP economic incentives, and not just home energy efficiency. We also ask EPA to include low income households in areas that are otherwise not low income.
  2. Define “eligible energy efficiency” to include natural gas direct use, CHP and waste heat and power (WHP).
  3. Allow states with mass based plans to skip having to create a special new protocol for Evaluation, Measurement and Verification (EM&V) just for the two years of the CEIP – 2020 and 2021. (Having to create a new EMV protocol just for two years would create a serious disincentive for these states to participate in CEIP and offer incentive credits for energy efficiency projects such as natural gas direct use and CHP. (States with rate-based plans are already required by CPP to have special EM&V protocols, so we just asked EPA to allow them to use the same protocols for CEIP as for CPP.)

A copy of the comments filed by AGA, NASEO, BCSE and Alliance are attached.

If you have any questions regarding this item, please feel free to contact Pam Lacey, placey@aga.org.

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AGA CEIP Criteria Comments 12_15_2015421.65 KB
Alliance CEIP Comments AIE 12_15_2015624.14 KB
NASEO Comments CEIP 12_15_201594.51 KB
BCSE Comments on CEIP 12_15_15373.49 KB