Statement Establishing an energy efficiency registry as a tool for state compliance under U.S. EPA's Clean Power Plan September 22, 2014
Energy efficiency has enormous potential to lower energy costs and reduce greenhouse gas (GHG) emissions, therefore mitigating the impacts of climate change. U.S. EPA’s Clean Power Plan (CPP) enshrines energy efficiency as one of the building blocks that states can utilize to achieve their GHG reduction targets. Many states are already implementing innovative energy efficiency strategies and programs. However, energy savings resulting from these measures are projected, estimated, reported, and audited using a range of approaches. This lack of consistency is exacerbated by a lack of transparency when energy savings data are reported and aggregated. A flexible energy efficiency registry is needed to enable and expand energy efficiency programs across the U.S., to pave the way for more financing of energy efficiency projects, and to underpin compliance under the CPP. There are many ways of approaching and implementing energy efficiency; an energy efficiency registry would consolidate these varied efforts and demonstrate compliance and real reductions. Specifically, an energy efficiency registry would: aggregate data from demand-side energy efficiency programs that could be consistently reported to EPA; provide a transparent platform for documenting and communicating the benefits of energy efficiency, as well as the methods for measuring and reporting it; consolidate evaluation, measurement and verification (EM&V) documentation of energy efficiency measures; provide clear and transparent attribution and ownership of energy savings;
serve as the foundation for a trading platform for energy efficiency credits for interested states and regions;
demonstrate, verify, and track energy and carbon savings – that may then be recorded as credits - generated in partnership with energy service companies (ESCO’s) or as the result of municipal and state policies (i.e. building codes);
serve as a platform to share knowledge and build capacity across states and regions. The Climate Registry (TCR), an NGO governed by states and provinces with extensive expertise in measuring and tracking GHGs, with support from the Climate Action Reserve (CAR), has developed a white paper on the energy efficiency registry and how it might be implemented. The paper is available on TCR’s website http://www.theclimateregistry.org/downloads/2014/09/TCR_An-EE-Registry.pdf. We encourage U.S. EPA to recognize an energy efficiency registry as a tool for state compliance under the CPP. We encourage states, utilities and other organizations to support the implementation of an energy efficiency registry, and to reference TCR’s white paper in their comments to EPA on the CPP Rule, which must be received by December 1, 2014.
Endorsed by The Climate Registry Executive Committee (U.S. members):
Doug Scott, TCR Board Chairman and Chairman, Illinois Commerce Commission Mary Nichols, Chairman, California Air Resources Board David Littell, Commissioner, Maine Public Utilities Commission David Thornton, Assistant Commissioner, Minnesota Pollution Control Agency
An Energy Efficiency Registry
A Flexible and Transparent way to Track and Report Energy Efficiency under the Clean Power Plan
September 1, 2014 Authored by: The Climate Registry with support from:
Acknowledgments This white paper was developed by The Climate Registry (TCR) with support from the Climate Action Reserve and substantial input from Kyle Aarons, C2ES; Bill Becker, National Association of Clean Air Agencies; Patrick Cummins, Center for the New Energy Economy at Colorado University; Amy Fredregill, Midwest Renewable Energy Tracking System, Inc.; Dian Grueneich, Stanford University; Lisa Jacobson, Business Council for Sustainable Energy; Christopher James, Regulatory Assistance Project; David Littell, Maine Public Utilities Commission; Katie Mandes, C2ES; Julie Michals, Northeast Energy Efficiency Partnership; Mary Nichols, California Air Resources Board; Janet Peace, C2ES; Steve Schiller, Lawrence Berkeley National Laboratory; Doug Scott, Illinois Commerce Commission; Pat Stanton, Conservation Services Group; and David Thornton, Minnesota Pollution Control Agency.
TCR also wishes to acknowledge the support of its Board of Directors, which is comprised of more than fifty North American sub-national jurisdictions, including forty U.S. states, as well as the specific contribution of the Clean Power Plan Task Force, made up of TCR Board Members and representatives from 13 U.S. states, which provided direction and feedback on the value of an energy efficiency registry.
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Executive Summary Energy efficiency has enormous potential to lower energy costs and reduce greenhouse gas (GHG) emissions, therefore mitigating the impacts of climate change. U.S. EPA’s Clean Power Plan (CPP) has publicly recognized the value of and potential for energy efficiency as a climate change mitigation strategy by including demand-side energy efficiency as one of the building blocks that states can use to achieve their GHG reduction targets.
While many states are already implementing innovative energy efficiency strategies and programs, energy savings resulting from these measures are projected, estimated, reported, and audited using a wide range of approaches. EPA has indicated that it will accept multiple calculation methods based on current best practices. However, EPA has also acknowledged that the current lack of transparency when energy savings data are reported and aggregated will not be acceptable for energy efficiency measures used for compliance with the CPP.
A flexible nation-wide energy efficiency registry would enable and expand energy efficiency measures that could be used for compliance with the CPP by increasing transparency and using a consistent framework to track and report projected and realized energy savings. This tool, coupled with the driver of the CPP itself, would help expand the implementation of energy efficiency measures by enabling broad analysis of the impacts of existing energy efficiency programs, identifying new opportunities for energy savings, reducing risks that limit available energy efficiency project financing, and potentially serving as the foundation for an energy efficiency crediting and trading platform.
In this paper we expand on the benefits outlined above and recommend a consensus-based stakeholder approach to develop an energy efficiency registry. Key issues that the registry would need to address are explored and a phased implementation plan is outlined that would incorporate broad stakeholder imput, help states meet compliance deadlines, and evolve with the implementation of the regulation itself.
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savings results” (EPA, 2014c). The document Background went on to specify that two important On June 2, 2014, the U.S. Environmental characteristics of EM&V documentation should Protection Agency (EPA) proposed its Clean be that it: Power Plan (CPP), which will require states to (1) enables recalculation of total program cut carbon pollution from the power sector in energy savings, and their jurisdictions. One of EPA’s proposed (2) is provided in a consistent manner options for states to demonstrate compliance across states. with the forthcoming regulation is the implementation of demand-side energy Increased Transparency through an efficiency measures. By including this option, Energy Efficiency Registry EPA has publicly recognized the value of and Given the diversity of energy savings potential for existing state and utility energy quantification approaches and EPA’s efficiency programs–as well as untapped commitment to flexibility in state opportunities–to reduce carbon emissions and implementation plans,1 regulated entities will mitigate climate change. most likely continue to use different methods to Today, energy savings resulting from energy quantify the impacts of energy efficiency. efficiency measures are projected, estimated, However, credible and verifiable accounting reported, and audited using a range of suitable for regulatory compliance will require approaches. This lack of consistency is greater transparency than currently exists. exacerbated by a lack of transparency when An online energy efficiency registry would help energy savings data are aggregated and states efficiently and transparently project, reported. While it is conceivable that different track, audit, and report energy savings and calculation methods can reasonably be used to relevant supplemental information associated quantify the impacts of similar energy efficiency with energy efficiency measures. It would also measures, the lack of transparency around have the potential to encourage standardization what these methods are and how assessments across states, and facilitate communication and compare, ultimately undermines the credibility knowledge transfer between agencies. of projected and reported energy savings. Some states have well-developed analytic EPA recognized the need for greater methods, assumptions, and data sources to transparency in the evaluation, measurement determine the energy savings related to and verification (EM&V) of energy efficiency demand-side energy efficiency measures. In measures in its technical support document on
State Plan Considerations by asserting that 1 In the preamble to the CPP, EPA asserts that the “EM&V documentation will be an important following competing objectives must be balanced; a component of state plans that incorporate need for accurate and consistent emission reductions calculations and a need for states to have energy efficiency programs and measures, flexibility in establishing and implementing the because transparency and reproducibility standards of performance that reflect those increase overall confidence in reported energy emission reductions (EPA, 2014a).
The Climate Registry An Energy Efficiency Registry Page 3 September 2014 others, energy efficiency initiatives are nascent 4. The foundation for a trading platform and would benefit from the expertise of states for energy efficiency credits. that are further along. Even in the absence of the CPP, energy efficiency measures are Consistent terminology and expected to grow dramatically over the next 10 additional information to 15 years in the South and Midwest, requirements: particularly as southern states begin to increase EPA has recognized concerns that the energy implementation of energy efficiency measures efficiency data it relied on to establish and Midwestern states ramp up to meet reduction targets may not consistently apply statutory energy efficiency resource standard definitions and data categories across utilities, targets (Barbose, Goldman, Hoffmann, & states, and years (EPA, 2014b). These Billingsley, 2013). These states will have to discrepancies can significantly impact the develop new methods or adopt existing accuracy of reported energy savings. For methods and approaches to accurately project example, one energy efficiency program may and evaluate energy savings. Through an energy report lifetime savings while another is efficiency registry, best practices for design, reporting annual savings. Analysis conducted on implementation, administration, and evaluation the combined total savings from these of energy efficiency measures can be programs would be inherently flawed. Today, transferred between states with varying levels inadequacies and inconsistencies in energy of expertise. savings performance reporting not only limit robust analysis but also prohibit the The CPP requires the cooperation of state establishment of financing opportunities, such energy commissions, which oversee ratepayer- as dedicated bond measures, that could funded energy efficiency programs, and state otherwise help to fund increased energy environmental agencies, which will develop the efficiency measures. state implementation plans required by the rule. In many states these agencies operate An energy efficiency registry designed using a separately, and sharing data can be a consensus-based stakeholder process could burdensome process. However, an energy standardize data definitions and integrate efficiency registry could be an effective way to educational resources to enable analysis of share information across agencies. reported information to reach verifiable conclusions about the impacts of demand-side The online registry system itself would offer a energy efficiency as well as provide the range of benefits including the establishment consistency necessary to enable innovative of: financing of energy efficiency measures. 1. Consistent terminology and additional An energy efficiency registry could also information requirements, standardize disclosure requirements for 2. Transparent disclosure of acceptable additional information that are needed to EM&V approaches, accurately quantify the corresponding avoided 3. A multi-user infrastructure optimized CO2 emissions, such as information on the for all stakeholders, and
The Climate Registry An Energy Efficiency Registry Page 4 September 2014 location and the hourly, daily, or seasonal basis manage a consistent and coordinated database. of energy savings. Standardized disclosure of The need to develop such an EM&V document this additional information will help to provide database to support best practices was assurance that reported energy savings and identified by the State and Local Energy avoided CO2 emissions are quantifiable, non- Efficiency Action Network even prior to the duplicative, permanent, verifiable, and release of the draft CPP (Jayaweera, et al., enforceable2 as well as enable more robust 2011). Such a system would be more efficient analysis to increase energy savings over time. than the current patchwork of data management that exists between program Transparent disclosure of implementers, public utility commissions, the acceptable EM&V approaches: public, states, and the federal government. The energy efficiency data EPA relied on to establish reduction targets were also calculated Figure 1: Multi-user Infrastructure using different methodologies. Many states with energy efficiency programs use different input values and assumptions in applying EM&V practices. This can result in significant differences in claimed energy savings values for similar energy efficiency measures between states, even when the same measure type is installed under otherwise identical circumstances. In order to address this, EPA has indicated that it intends to develop guidance for In addition to collecting data, an energy the EM&V of demand-side energy efficiency efficiency registry can be used to streamline programs and measures incorporated in state energy savings audits and verification activities plans. conducted by third parties, enable public communication and feedback3 and generate An energy efficiency registry, while not standard or customized reports that could be designed to impose quantification submitted as part of a compliance report. requirements, could transparently disclose the Having a coordinated system will reduce EPA-accepted EM&V methods used to calculate existing paperwork and help to avoid projected and realized energy savings. potentially burdensome new reporting requirements that may otherwise result from Multi-user infrastructure optimized implementation of the CPP. for all stakeholders: A unique benefit of a registry is the ability it affords multiple users to input, access and
2 These characteristics are explicitly identified as 3 States with high-quality EM&V practices often necessary in the preamble of the CPP here: 79 FR include opportunities for public comment (EPA, 34913 (EPA, 2014a). 2014c).
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The foundation for a trading efficiency credits based on common accounting 5 platform for energy efficiency and verification standards. Such a registry credits: could enable states to implement this approach to meet their targets. The draft CPP allows for trading of energy efficiency “credits” either among specific energy generation units (EGUs) or between Energy Efficiency Registry states implementing multi-state plans. Trading Fundamentals such credits would allow for maximum flexibility At its core, a registry is a centralized database in meeting EPA’s emission targets under either designed to transparently record information a mass based or rate based approach.4 and make data available to others. However, a An energy efficiency registry would also support great deal of functionality can be built into a the inclusion of privately-delivered energy registry tool that is of value to users, including efficiency (e.g., through energy service calculation and greenhouse gas conversion companies or other third party providers) in tools, facilitation of energy efficiency credit state plans by providing a mechanism to track issuance and tracking, automated quality the ownership and transfer of such energy assurance checks, comprehensive auditing savings among parties. See Figure 2 below for infrastructure, online help and tutorials, an example of how this might work. standardized and customized reports, and data analysis tools. Figure 2: Potential Credit Chain of Custody Functionality Development Process Originator Registry creates To ensure that the energy efficiency registry submits savings project account claim meets the needs of its users, a consensus-based stakeholder process should be used to develop the principles, standards, and design Credits Verifier reviews requirements that will form the registry’s transfered to and certifies compliance foundation. This stakeholder group should savings claim entity's account include representatives from state and federal agencies who use energy efficiency data, Credits Registry private and public sector energy efficiency transfered to generates measure implementers, utilities, building code retirement compliance experts, regional and national associations of account reports energy and energy efficiency professionals, energy intensive industries, academic Currently, however, there is no central registry for issuing, serializing, and tracking energy 5 Existing infrastructure such as the Western Renewable Energy Generation Information System 4 States have the option of using the rate-based and Renewable Energy Certificate tracking systems target set by EPA or converting it to a mass-based could be expanded to track trading of energy target (EPA, 2014c). efficiency credits.
The Climate Registry An Energy Efficiency Registry Page 6 September 2014 institutions, civil society, and relevant functionality. For example, while the environmental nonprofits. The development stakeholder group may decide that information process should be iterative and should also in the database should be disclosed by unit of include significant opportunities for public electricity (e.g. MWh), the design requirements comment. may stipulate that information about an energy efficiency measure’s location and the Step 1: Principles customer’s utility provider’s electricity emission Defining clear principles at the beginning of the rate will need to be input in order to be able to development process helps to ensure that the convert energy savings to CO2 emissions standards and design requirements work reductions. together seamlessly. Relevant principles for an energy efficiency registry may include Some of the issues that will need to be consistency, transparency, accuracy and the addressed during the design requirements avoidance of double counting. phase are:
Step 2: Standards the level of detail at which data is Standards determine what data are reported to entered into the system, a registry and how they should be reported, if and how data will be aggregated, aggregated, and disclosed. For an energy how additional data will be handled, efficiency registry, it would be in these how energy savings will be converted to documents that the stakeholder group would CO2 emissions reductions, standardize data definitions and parameters for how energy savings projections data additional information. The standards would will relate to ex post reported energy also identify the classes of EM&V methods that savings, should be used to determine energy savings, so how the system can be designed to that in the registry, consistent labels could be streamline audits, applied to energy efficiency data calculated if and how the system will allow for using each method. Some or all of these state-specific modules, parameters should be based on established how the system will function for states best practice as vetted by the stakeholder using different state plan approaches, group and relevant publications. In some how the system will support states with instances, the standards should rely heavily on joint implementation plans, external guidance, such as EPA’s forthcoming how the system will interact with guidance on acceptable EM&V methods and relevant existing regional efforts, state-established technical reference manuals. how a trading system could be Step 3: Design Requirements integrated, Design requirements address how the registry what standardized reports will look like, tool will work. The standards are the starting and point for registry design while the design what options will users have to requirements may add additional reporting generate customized reports. requirements in order to achieve desired
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Key Considerations CO2 emissions may come from other sources Some of issues relevant to the development of (EPA, 2014c). States may choose an approach both the standards and design requirements based on this difference, or they may prioritize are explored in greater detail below. whichever approach most closely resembles their existing energy efficiency and climate Level of Detail efforts. One of the key considerations that will need to be addressed both by the stakeholder group When developing the standards and design and in the design requirements is the level of requirements for an energy efficiency registry, it detail that will be transparently tracked and will be important to consider if and how made available to the public. Some options for different users can track data in different units, this level of detail are energy efficiency or if there should be a single consistent unit programs, energy efficiency measures throughout the database (e.g. MWh) with aggregated by contracts, and individual energy options to display alternate totals in different efficiency measures. Requiring detail at the units (e.g. CO2). Other options may also be measure level increases transparency in the identified as the CPP is finalized. registry, but it may also lead to burdensome Additional Information data entry requirements. At the other end of In the context of an energy efficiency registry, the spectrum, aggregating measures to the additional information is data that supports or program level may obscure information that provides context for the data the registry has could either be analyzed to improve energy been designed to track and share. Several efficiency measures over time or may be categories of additional information could be necessary to accurately audit projected and collected by an energy efficiency registry. First reported energy savings. In the end, it could and foremost, information necessary to make the most sense to require different levels demonstrate that reported energy savings and of detail for different types of energy efficiency avoided CO emissions are quantifiable, non- measures. For example, residential rebate- 2 duplicative, permanent, verifiable, and based energy efficiency programs could likely enforceable would need to be defined and be reported at the program level, while large- incorporated into the system. At a minimum, scale equipment upgrades would be easier to energy savings documentation should be track by each individual measure. provided at a level of detail that allows for Units recalculation of program energy savings totals In the draft CPP, states implementing rate- (EPA, 2014c). Other types of additional based plans can either adjust the CO2 emissions information may not be necessary to meet rate based on avoided MWh or avoided CO2 compliance obligations under the CPP, but emissions. The MWh approach assumes that would be valuable when using the database to the avoided CO2 emissions come directly from analyze the effectiveness of energy efficiency the particular affected energy generating units measures. This information could potentially to which the credits are applied, whereas the address projected returns on investment, air
CO2 approach acknowledges that the avoided quality and public health benefits, energy
The Climate Registry An Energy Efficiency Registry Page 8 September 2014 system reliability impacts, and community year to previously reported savings, or savings economic and social development effects. predicted by a deemed savings database for that measure type. This check could send an From a design requirements perspective, it alert if reported data was significantly different would be important to determine how than the selected reference case. additional information will be linked to reported energy or emissions savings. In addition, in Support of Different State Plan order to enable automated data analysis at Approaches least some additional data points would have to Two key options states have when designing be standardized and disclosed in a quantitative their state implementation plans are whether manner as opposed to being submitted as a to directly apply emission limits to EGUs or use general qualitative description of impacts. a portfolio approach and whether to use the rate-based target set by EPA or convert it to a Audit and Oversight Functionality mass-based target. The role of an energy Several existing registry tools have integrated efficiency registry will vary based on the functionality to support streamlined auditing decisions states make when selecting their and verification. A large portion of this approaches. functionality is based on the definition of different classes of users with different kinds of Emission Limit Approaches access to data. For example, an energy Under a rate-based emission limit approach, efficiency program implementer would need end-use energy that avoids EGU CO2 emissions write-access to all of its data in order to enter would be an enforceable component of a state that information and execute any internal plan.6 This means that the registry’s ability to quality checks. Once data has been entered, it document energy savings projections, ex-post would need to be locked and then an auditing savings, quantification methods, assumptions, body, such as a state agency or third-party and auditing practices would all help a state to provider, would need read-only access to that comply with the CPP. data. However, the auditing body would likely States using a mass-based emission limit can need write-access to other elements of the use demand-side energy efficiency to cost- system, for example to indicate that they effectively reduce CO emissions, but energy endorse the reported information. 2 efficiency would not be included as an Another opportunity to streamline the auditing enforceable measure in state plans. For these process would be to build automatic quality states, an energy efficiency registry’s value as assurance checks into the system. At a related to the CPP would primarily be as a minimum, the system could check to ensure 6 that all required data and additional Energy efficiency actions included in state plans would need to be able to provide assurance that a information has been input for an energy sufficient number of adjustment credits would be efficiency program or measure prior to entering available to allow EGUs to comply with the the audit or reporting phase. More complex emissions rate limit and that the energy efficiency quality assurance checks might include measures generating those credits are properly quantified, monitored and verified (EPA, 2014c). comparing reported savings from the current
The Climate Registry An Energy Efficiency Registry Page 9 September 2014 planning resource and focus on the high quality Energy Efficiency Credit Trading System documentation of energy efficiency savings As indicated above, states may be able to use projections and the ability to compare energy efficiency credit-trading systems as part projections and methods to energy efficiency of an overall package of measures designed to measures planned in other states. States using achieve their emission rate targets, or to this approach could still elect to utilize all of the achieve a mass-based target. To be effective, a features of an energy efficiency registry to credit trading system would require the support other policy objectives. establishment of a registry that:
Portfolio Approaches (1) Ensures that all credits are issued for a Portfolio approaches include emission limits for standard unit of energy savings affected EGUs and other enforceable end-use calculated using acceptable methods, energy efficiency and renewable energy standards, and assumptions, measures that avoid EGU CO2 emissions. Under (2) Ensures that energy saving measures these approaches, achievement of the full level are verified according to common of required emission performance for affected standards, and EGUs is not ensured through the application of (3) Serializes and tracks credits in a direct emissions limits alone; rather emissions transparent and accessible online impacts of energy efficiency measures would be system. included as an enforceable action in the state plan separate from the emissions rate. Such a registry could be tailored to the Therefore, even if a state using a portfolio requirements of individual states, or used as a common platform across multiple states approach is selecting a mass-based emission limit, its compliance with CPP can benefit from choosing to implement energy efficiency credit all of the features an energy efficiency registry trading. would provide for states using rate-based emission targets. Energy Efficiency Registry Interaction with Existing Regional Efforts Development Several relevant regional initiatives that address Based on the schedule proposed by EPA, it energy efficiency data and/or track renewable would be ideal if an energy efficiency registry energy are already in place. An energy could launch prior to the 2016 deadline for efficiency registry could be designed to support states working alone to submit their state these efforts by providing a common platform implementation plans to EPA. This would allow or by developing data sharing practices that these states to use the energy efficiency would enhance the analysis capabilities of data registry as part of their planning process and collected for other initiatives. By focusing on EM&V approach. integrating with regional efforts, the energy efficiency registry will ultimately keep reporter Given the breadth of the project and the burden low while expanding the breadth of importance of soliciting sufficient stakeholder available information. input, work on an energy efficiency registry should begin as soon as possible. Typical
The Climate Registry An Energy Efficiency Registry Page 10 September 2014 timelines for similar measures with strong aggregation of reported energy savings, chain of financial support and stakeholder participation custody tracking, and potentials for a crediting include one-and-a-half to two years to develop and trading system. the principles, standards, and design Ultimately this would result in a multi-year requirements; and an additional nine months to a year to build the web-based tool—although development process that could incorporate building on an existing tool could help shorten broad stakeholder input, help states meet compliance deadlines, and evolve with the this timeline. implementation of the regulation itself. Figure 3 below outlines the steps that should be a part of the energy efficiency registry development process. Conclusion As states and other energy efficiency Figure 3: Energy Efficiency Registry Implementation Plan implementers evaluate the opportunities presented by EPA’s CPP, they will need to • Collect best practices develop acceptable EM&V plans and • Establish stakeholder groups 1 documentation. By participating in the development of and utilizing an energy • Develop principles & standards efficiency registry, states and other energy 2 • Public consultation efficiency implementers would be better able to • Develop design requirements ensure that their energy efficiency EM&V • Identify data partners disclosure practices meet EPA’s requirements of 3 • Develop registry tool enabling savings recalculation and reporting data in a consistent manner across states.
While it would be most efficient to address all Not only will an energy efficiency registry key issues and finalize all standards prior to enable greater implementation of energy initiating the design requirements phase, given efficiency measures for compliance purposes, the aggressive timeline mandated by the CPP, but it will also enable broad analysis of the this process will likely need to include some impacts of existing energy efficiency programs, overlap with priority going to resolving key identifying new opportunities for energy issues that will be part of initial phases of savings, reducing risks that limit available compliance with the rule. For example, in the energy efficiency project financing, and first phase it would be important to reach potentially serving as the foundation for an consensus on units, level of detail and EM&V energy efficiency crediting and trading documentation related to the disclosure of platform. projected energy savings. Once these issues are resolved, design requirements and tool development could begin to move forward while the stakeholder group developing standards turns its attention to issues like the
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Works Cited Barbose, G. L., Goldman, C. A., Hoffmann, I. M., & Billingsley, M. (2013). The Future of Utility Customer- Funded Energy Efficiency Programs in the United States: Projected Spending and Savings to 2025. Lawrence Berkeley National Laboratory.
EPA. (2014a, June 18). Proposed Rule: Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units.
EPA. (2014b). Technical Support Document: Clean Power Plan Proposed Rule: GHG Abatement Measures.
EPA. (2014c). Technical Support Document: Clean Power Plan Proposed Rule: State Plan Considerations.
Jayaweera, T., Haeri, H., Lee, A., Bergen, S., Kan, C., Velonis, A., et al. (2011). Scoping Study to Evaluate Feasibility of National Databases for EM&V Documents and Measure Savings. State & Local Energy Efficiency Action Network.
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