models from Texas, California and RAP,
the state has yet to include a credit for
CHP. So as states begin to embrace policies that recognize and encourage more
energy-efficient technologies, there is
still work to be done to ensure that all
usable energy products are fairly credited. Even though CHP systems can be
upwards of 80 percent efficient, this
efficiency can continue not to be fully
recognized in regulation.
Resources for Decision
Resources to aid regulators and other
decision makers on output-based emissions policies are starting to grow. In
addition to the model rules and reports
mentioned above, this article is based on
a larger report, Output-Based Emission
Standards: Advancing Innovative Energy
Technologies, published by the
Northeast-Midwest Institute in 2003
( www.ne mw.org/output_emissions.pdf).
The report addresses the role of output-based regulations in a changing federal
policy framework and within state air-quality policies. In addition, it identifies
alternative emissions models developed
by regional and environmental groups
and highlights initiatives abroad.
In August 2004, the EPA released a
handbook for state regulators on output-based regulations to assist air regulators
in developing emissions regulations that
recognize the pollution-prevention benefits of efficient energy generation. The
handbook, Output-based Regulations: A
Handbook for Air Regulators, provides
practical information to help regulators
decide if they want to use output-based
regulations and explains how to develop
an output-based emissions standard. (See
The agency has since worked with the
Northeast States for Coordinated Air Use
Management on an educational effort to
demonstrate to the region’s air regulators
the benefits of this energy-efficiency and
The movement toward output-based
emission policies will continue as decision
makers learn more about how electricity
generation affects the environment and
the opportunities available to incorporate
energy efficiency into air regulation.
Tracking emissions per kilowatt-hour is
a logical next step in monitoring air
quality. Since the use of output-based
standards is still relatively new, states
need to learn from each other how best
to integrate those measures into future
emissions-permitting and cap-and-trade
programs. Federal direction also will be
needed. Regulations must reflect the
environmental benefits of more energy-efficient, cleaner technologies. The marketplace is ready for this change.
Susan Freedman is the senior
policy analyst for the San Diego
Regional Energy Office, an independent, public-benefit, nonprofit
501(c)( 3) organization that provides
objective information, research,
analysis and long-term planning on energy
issues for the San Diego region. She engages in
legislative and regulatory affairs at the local,
state and federal levels. Freedman was formerly
the energy policy analyst for the Northeast-Midwest Institute, a Washington, D.C.-based,
nonpartisan regional policy center where she
authored the report, Output-Based Emission
Standards: Advancing Innovative Energy
Technologies, and worked with congressional
staff on implementation of output-based
approaches. She holds a master’s degree in energy and environmental policy from the College of
Urban Affairs and Public Policy at the University
of Delaware and has a bachelor’s degree in political science and human and natural ecology from
Emory University. Freedman is the Webmaster
for the U.S. Combined Heat and Power
Association. She may be reached at susan.
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