0

Roadmap for Incorporating Energy 

Efficiency/Renewable Energy

Policies and Programs into State and Tribal 

Implementation Plans
1

EPA-456/D-12-001a

July 2012

Roadmap for Incorporating Energy Efficiency/Renewable Energy

Policies and Programs into State and Tribal Implementation Plans

By:

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Outreach and Information Division

Research Triangle Park, North Carolina

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Outreach and Information Division

Research Triangle Park, North Carolina
2

ACKNOWLEDGMENTS

We would like to acknowledge substantial contributions from members of an interoffice EPA team that included the Office of Atmospheric Programs, the Office of Policy 

Analysis and Review, the Office of General Counsel and Regions 1 and 6. This document 

also reflects comments received from a number of stakeholders, including state and 

local air quality agencies.
3

TABLE OF CONTENTS

APPENDICES.................................................................................................................................................... 4

FIGURES .......................................................................................................................................................... 5

TABLES ............................................................................................................................................................ 6

ACRONYMS..................................................................................................................................................... 7

EXECUTIVE SUMMARY.................................................................................................................................... 9

Purpose of the Roadmap............................................................................................................................ 9

The Four Pathways..................................................................................................................................... 9

SECTION 1.0: PURPOSE AND ROADMAP ORGANIZATION ........................................................................... 11

Energy Efficiency/Renewable Energy Policies and Programs as Cost- Effective Strategies ..................... 12

Four Reasons to Take Advantage of Energy Efficiency/Renewable Energy Policies and Programs in Air 

Plans ......................................................................................................................................................... 12

Four Pathways Available........................................................................................................................... 14

Challenges of Incorporating Energy Efficiency/Renewable Energy Policies and Programs in State and 

Tribal Implementation Plans .................................................................................................................... 15

This Roadmap Clarifies Existing Guidance and is Not a Regulation.......................................................... 16

Scope of Roadmap.................................................................................................................................... 16

SECTION 2.0: ACTIVITIES FOR GETTING STARTED........................................................................................ 19

Functioning of the Electric System ........................................................................................................... 19

Roles and Responsibilities of Key State Electric Energy Organizations .................................................... 19

State, Tribal and Local Energy Efficiency/Renewable Energy Policies and Programs in Jurisdictions...... 20

Estimating Potential Emission Reductions ............................................................................................... 21

Understanding Existing EPA Energy Efficiency/Renewable Energy SIP Guidance .................................... 21

Common “Getting Started” Questions and Answers ............................................................................... 21

SECTION 3.0: DECISION-MAKING FOR NAVIGATING THE FOUR PATHWAYS............................................... 27

Decision-Making Flowchart...................................................................................................................... 27

Pathways for Jurisdictions That Have Emerging and/or Voluntary Measures ......................................... 28

Pathways for Jurisdictions That Do Not Have Emerging and/or Voluntary Measures............................. 28

Additional Resources................................................................................................................................ 29

SECTION 4.0: BASELINE EMISSIONS PROJECTION PATHWAY ...................................................................... 33

Qualifying Criteria..................................................................................................................................... 34

Mandatory Policies That Are Not Federally Enforceable.......................................................................... 34

SECTION 5.0: CONTROL STRATEGY PATHWAY............................................................................................. 35

Control Strategy Pathway Must Meet Four Criteria................................................................................. 35

SECTION 6.0: EMERGING/VOLUNTARY MEASURES PATHWAY ................................................................... 37

SECTION 7.0: WEIGHT OF EVIDENCE PATHWAY.......................................................................................... 39

REFERENCES ................................................................................................................................................. 41
4

APPENDICES

Appendix A: Glossary................................................................................................................................... A-1

Appendix B: Overview of the U.S. Electric System ..................................................................................... B-1

Appendix C: Existing EPA Energy Efficiency/Renewable Energy Guidance ................................................ C-1

Appendix D: Understanding State Energy Efficiency and 

 Renewable Energy Policies and Programs.................................................................................................D-1

Appendix E: Baseline Emissions Projection Pathway ...................................................................................E-1

Appendix F: Control Strategy Pathway.........................................................................................................F-1

Appendix G: Emerging/Voluntary Measures Pathway ................................................................................G-1

Appendix H: Weight of Evidence Pathway ..................................................................................................H-1

Appendix I: Methods for Quantifying Energy Efficiency and Renewable Energy Emission Reductions ...... I-1

Appendix J: Draft Methodology for EPA’s Analysis of Existing State Energy Efficiency/Renewable Energy 

Policies ......................................................................................................................................................... J-1

Appendix K: State, Tribal and Local Examples and Opportunities ............................................................. K-1
5

FIGURES

Figure 1: Organization of the Roadmap ....................................................................................................... 11

Figure 2: Electric Energy Efficiency Program Budgets.................................................................................. 13

Figure 3: Growth in State Policies for Renewable Portfolio Standards........................................................ 14

Figure 4: How the Appendices Support the Four Pathways........................................................................ 18

Figure 5: Energy Efficiency/Renewable Energy Pathway Flowchart for State and Tribal Implementation 

Plans ............................................................................................................................................................. 22

Figure 6: Energy Organizations’ Roles and Responsibilities ......................................................................... 23

Figure 7: Characteristics of Policies and Programs Suitable for Each Pathway ............................................ 30

Figure 8: Four Criteria the Control Strategy Pathway Must Meet............................................................... 36
6

TABLES

Table 1: Common “Getting Started” Questions and Answers..................................................................... 24

Table 2: Examples of Energy Efficiency/Renewable Energy Policies and Programs for the Four State and 

Tribal Air Planning Pathways........................................................................................................................ 31

Table 3: Information on State and Tribal Implementation Plan Credit and Quantification Approaches .... 32
7

ACRONYMS

AAGR: Annual Average Growth Rate

AEO: Annual Energy Outlook

ARRA: American Recovery and Reinvestment Act 

CAA: Clean Air Act

CFEC: Capacity Factor Emission Calculator

CHP: Combined Heat and Power

CO: Carbon Monoxide

CO2: Carbon Dioxide 

DEP: Department of Environmental Protection 

EE: Energy Efficiency

EERS: Energy Efficiency Resource Standard

eGRID: Emissions & Generation Resource Integrated Database

EGU: Electric Generating Unit

EIA: Energy Information Administration

EIP: Economic Incentive Program

EM&V: Evaluation, Measurement and Verification

EMM: Electricity Market Module

GWhs: Gigawatt Hours

HEDO: High Electric Demand Days

Hg: Mercury

IPM: Integrated Planning Model

ISO: Independent System Operator

KWh: Kilowatt-Hour

MW: Megawatt

MWh: Megawatt-Hour 

NAAQS: National Ambient Air Quality Standard

NEEDS: National Electric Energy Data System

NEMS: National Energy Modeling System

NERC: North American Electric Reliability Corporation

Pb: Lead

PM: Particulate Matter

PUC: Public Utility Commission

RE: Renewable Energy

RFP: Reasonable Further Progress

RGGI: Regional Greenhouse Gas Initiative

RPS: Renewable Portfolio Standard

RTO: Regional Transmission Organization

SEO: State Energy Office

SIP: State Implementation Plan

SO2: Sulfur Dioxide

TIP: Tribal Implementation Plan

WOE: Weight of Evidence

ACEEE: American Council for an Energy-Efficient Economy
8

LCSE: Levelized Costs of Saved Energy
9

EXECUTIVE SUMMARY

The U.S. Environmental Protection Agency’s (EPA’s) Office of Air and Radiation 

encourages state, tribal and local agencies to consider incorporating energy efficiency 

(EE) and renewable energy (RE) policies and programs in their State and Tribal 

Implementation Plans (SIPs/TIPs). State and local governments have increased their 

adoption of EE/RE policies and programs since EPA last issued guidance on the topic in 

2004. This increase in activity has the potential to provide appreciable emission benefits 

for air quality that state, tribal and local air planners could capture in SIPs/TIPs. As EPA 

continues to review and, as appropriate, revise National Ambient Air Quality Standards 

(NAAQS) to protect public health, emission reductions from EE/RE policies and programs 

may become increasingly important for jurisdictions designated as nonattainment. The 

goal of this document is to facilitate the use of EE/RE emissions reduction strategies in 

air quality plans. This is made possible by the abundance of information available on

the energy impacts of EE/RE policies and programs and by the availability of the SIP/TIP 

pathway decision-making framework provided here in this roadmap. 

Purpose of the Roadmap

The EPA is issuing this roadmap to reduce the barriers for state, tribal and local agencies 

to incorporate EE/RE policies and programs in SIPs/TIPs by clarifying existing EPA 

guidance and providing new and detailed information. The roadmap provides a section 

on “getting started” that includes charts and tables for decision-makers to consider in 

weighing which pathway or pathways to pursue for incorporating EE/RE policies and 

programs in SIPs/TIPs. The charts and tables also describe the advantages and 

disadvantages of each pathway. Attached to the roadmap are detailed appendices that 

include new information. A range of topics is covered from basic information on 

understanding the electric system and EE/RE policies and programs to details on four 

different approaches for quantifying EE/RE benefits. The appendices also provide basic 

information on each pathway, including SIP/TIP documentation.

The Four Pathways

The roadmap describes the four SIP/TIP pathways that are available to state, tribal and 

local agencies as they consider which approach to adopt for incorporating policies and 

programs in SIPs/TIPs. The four pathways described in the roadmap are:

1. Baseline emissions projection pathway; 

2. Control strategy pathway; 

3. Emerging/voluntary measures pathway; and

4. Weight of evidence (WOE) determination pathway.

State, tribal and local agencies can, of course, select more than one pathway for their 

jurisdiction’s different EE/RE policies and programs. Each option is appropriate for a 

specific set of circumstances and has its own documentation and analytical provisions. 

For example, the baseline emissions projection pathway is an option for agencies that 

have already adopted EE/RE policies and programs that they wish to incorporate in their 
10

emissions forecast. Alternatively, if the jurisdiction is contemplating adopting new 

EE/RE policies before it submits its SIP/TIP to EPA, then the control strategy pathway is 

an option. In cases where jurisdictions have adopted emerging and/or voluntary 

measures (i.e., those that are difficult to enforce and/or quantify), the 

emerging/voluntary measures pathway may be the preferred route. The WOE pathway 

is a supplemental analysis to an attainment demonstration in cases where a jurisdiction 

is not predicted to attain an air quality standard based on air quality modeling; it is a 

recommended option for accounting for EE/RE policies and programs where a state, 

tribal or local agency wants to claim emissions benefit that will potentially affect air 

quality in the attainment year, but where modeling the impacts of the policy or program 

is either too resource intensive or not feasible for other reasons and/or the jurisdiction 

is not interested in SIP/TIP credit.
11

SECTION 1.0: PURPOSE AND ROADMAP ORGANIZATION

This document provides a roadmap to assist state, tribal and local agencies with 

accounting for and incorporating 

energy efficiency and renewable 

energy (EE/RE) policies and 

programs in State 

Implementation Plans (SIPs) and 

Tribal Implementation Plans1

(TIPs). The roadmap 

accomplishes this task by 

clarifying guidance2the U.S. 

Environmental Protection 

Agency (EPA) issued in 2004 on 

incorporating EE/RE policies and 

programs into SIPs, as well as 

related guidance3EPA issued in 

that year and in 2005. 

States are required, under the 

Clean Air Act (CAA), to submit 

SIPs when an area is designated 

as nonattainment for a National 

Ambient Air Quality Standard 

(NAAQS). The EPA is then 

required to either approve or disapprove the SIP/TIP, based on whether the plan meets 

the requirements of the CAA. EE/RE policies and programs are increasingly being 

explored by state, tribal and local agencies for use in meeting air quality goals and 

SIP/TIP requirements (i.e., emission reductions needed to demonstrate attainment 

and/or satisfy other CAA requirements).4 

To help state, tribal and local air quality planners start, the main body of this roadmap 

provides several resources, is designed to be user friendly and is intentionally brief. The 

detailed appendices describe the electric system mechanics, emission quantification 

 

1

The Clean Air Act provides authority for tribes to implement CAA programs and instructed EPA to adopt 

regulations so that eligible Tribes may manage their own EPA-approved air pollution control programs 

under the CAA. The 1998 Tribal Authority Rule (TAR) implements the provisions of section 301(d) of the 

CAA to authorize eligible Tribes to develop their own tribal programs. Under the TAR, a Tribe may be 

approved by EPA to be eligible to be treated in the same manner as a state for one or more CAA 

programs. Such a program may include, but is not limited to, a TIP. Tribal governments are not required 

to submit a TIP, nor are they subject to deadlines mandated under the CAA. However, EPA must meet its 

obligations with respect to tribal lands under the CAA.

2

EPA (2004a).

3

EPA (2004b) and EPA (2005). 

4

The other requirements include: Reasonable Further Progress and Reasonably Available Control 

Technology/Reasonably Available Control Measures.

Figure 1: Organization of the Roadmap
12

approaches and detailed provisions for incorporating EE/RE policies and programs in the 

four SIP pathways. References to outside sources are also provided.5 Figure 1 provides 

the overall organization of the roadmap. Figure 4 describes each appendix and its 

applicability to each of the four pathways.

Energy Efficiency/Renewable Energy Policies and Programs as CostEffective Strategies

EE/RE policies and programs (as described in Section 2.0) offer the potential to achieve 

emission reductions at a cost that can be lower than traditional control measures. The 

EPA is gaining experience with these potentially cost-effective strategies in rulemakings 

affecting the utility and other sectors.

6

 The EPA is working to define how and when 

EE/RE policies can lower the overall cost of achieving compliance with the requirements 

of emissions standards. 

EE/RE policies and programs may be a cost-effective strategy that state, tribal and local 

agencies can use as part of multi-pollutant emissions reduction approaches to help 

attain and maintain compliance with NAAQS, as well as achieve other regulatory or nonregulatory objectives such as improving visibility, reducing regional haze, reducing air 

toxics, and limiting greenhouse gases. 

Four Reasons to Take Advantage of Energy Efficiency/Renewable 

Energy Policies and Programs in Air Plans

EE/RE policies and programs represent a real opportunity for improving air quality. The 

EPA encourages state, tribal and local air quality planners to quantify and take 

advantage of the emission benefits of EE/RE policies and programs. Over the past 10 

years, states have made substantial investments in EE/RE initiatives and are seeing 

significant increases in EE savings and renewable generation as a result. These 

commitments have the potential to provide appreciable emission benefits for air quality 

that state, tribal and local air planners could capture in SIPs/TIPs. 

Four reasons for state, tribal and local agencies to consider EE/RE policies and programs 

in SIPs and TIPs are: 

1) From 2006 to 2011, states have increased their budget investments in electric EE 

programs significantly, committing over $5 billion of ratepayer resources in 2011 

to electric EE programs. (See Figure 2 for growth in state EE expenditures from 

 

5

For links to sources external to EPA, note that EPA cannot attest to the accuracy of non-EPA information 

provided by these third-party sites or any other linked site. The EPA provides these links as a reference. 

In doing so, EPA does not endorse any non-government websites, companies or applications. 

6

For example, a recent EPA modeling scenario for EPA’s Mercury and Air Toxics Standard rule predicts 

that moderate levels of energy-demand reduction – equivalent to the continuation of current policies –

could lower total compliance costs, reduce ratepayer bills over the long term, and in some cases, delay or 

avoid the need for equipment upgrades or new construction of generating facilities and emissions 

controls. This energy-demand reduction is also likely to reduce emissions of air pollutants on high 

electricity demand days when air quality can be especially harmful (Federal Register 2011a).
13

2006-2011.) 7 Additionally, nearly all states (48) have EE programs reporting 

efficiency program budgets.8

2) As of 2011, twenty-nine states (and Washington, DC) had adopted renewable 

portfolio standards (RPS) which require retail electricity providers to supply a 

minimum percentage or amount of retail demand with renewable resources, 

more than double the number of states in 2000 (see Figure 3).9

3) As EPA periodically reviews NAAQS to strengthen public health protection, the 

need for state, tribal and local agencies to find greater emission reductions may 

well continue. EE/RE policies and programs can provide a resource to help meet 

that need. 

4) Information about the energy impacts of EE/RE policies and programs and their 

resulting emission benefits is now more widely available. State, tribal and local 

agencies do not have to start analyses from scratch, but can access existing, 

quality data. (Refer to Appendix D for a list of resources.)

 

7

For more information, go to: http://www.cee1.org/ee-pe/2011AIR.php3.

8

ACEEE (2012), Appendix A.

9

For more information, go to: http://www.cleanenergystates.org/assets/Uploads/2011-RPS-SummitCombined-Presentations-File.pdf

Source: http://www.cee1.org/ee-pe/2011AIR.php3

Figure 2: Electric Energy Efficiency Program Budgets
14

CO 

(2007)

HI

(2005)

IL

(2008)

MA 

(2003)

CT

(2000)

M D

(2006)

DC

(2007)

NH

(2008)

M I

(2012)

ME 

(2000)

PA 

(2001)

NJ

(2001)

NY 

(2006)

DE

(2007)

NC

(2010)

M O

(2011)

IA M N

(2002)

AZ

(1999)

NV

(2001)

WI 

(2000)

T X

(2002)

NM

(2002)

CA

(2003)

RI 

(2007)

M T

(2008)

WA

(2012)

OR

(2011)

OH 

(2009)

KS

(2011)

1983 1991 1994 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011

IA MN AZ MN NM CT NJ CT AZ CA DC HI CO CA

WI NV MN NM CO CA CO DE IL DE CT

NV PA NV CT CT HI ME IL DC

TX HI DE MA MN MA DE

NJ MD MD NV MD MD

WI ME NJ O R NJ NC

MN RI NY WI

NJ

NM

PA

TX

Enactment (above timeline)

( ) Year of First Requirement 

Enactment (above timeline)

Major Revisions (below timeline)

Year of First Requirement

Four Pathways Available

The EPA recognizes that state, tribal and local agencies interested in incorporating these 

policies and programs in SIPs/TIPs may need more detailed information on how to 

achieve this goal. To that end, this manual provides a roadmap for understanding the 

parameters and other aspects of the four pathways available for incorporating EE/RE 

policies and programs in SIPs/TIPs. State, tribal and local agencies can, of course, select 

more than one pathway for their jurisdiction’s different EE/RE policies and programs. 

The pathways are:

1. Baseline emissions projection pathway: This is an option for agencies that have 

already adopted EE/RE policies and programs and they wish to incorporate the 

impact of those policies and programs in their SIP/TIP forecast of emissions for 

the electric generating units (EGUs).

2. Control strategy pathway: If a jurisdiction is contemplating adopting new EE/RE 

policies before it submits its SIP/TIP to EPA, then the control strategy pathway is 

an option. EE/RE policies incorporated in a SIP/TIP as a control strategy must be 

quantifiable, surplus, enforceable and permanent.

3. Emerging/voluntary measures pathway: In cases where jurisdictions have 

adopted emerging and/or voluntary EE/RE measures (i.e., those that are difficult 

to enforce and/or quantify), the emerging/voluntary measures pathway is the 

preferred route. 

4. Weight of evidence (WOE) determination pathway: The WOE pathway is a 

supplemental analysis to an attainment demonstration in cases where a 

jurisdiction is not predicted to attain an air quality standard based on air quality 

Source: http://www.cleanenergystates.org/assets/Uploads/2011-RPS-Summit-Combined-Presentations-File.pdf

Figure 3: Growth in State Policies for Renewable Portfolio Standards
15

modeling; it is a recommended option for accounting for EE/RE policies and 

programs where a state, tribal or local agency wants to claim emissions benefit 

that will potentially affect air quality in the attainment year, but where modeling 

the impacts of the policy or program is either too resource intensive or not 

feasible for other reasons and/or the jurisdiction is not interested in SIP/TIP 

credit.

Each pathway is appropriate for a specific set of circumstances and has its own 

documentation and analytical provisions. 

Challenges of Incorporating Energy Efficiency/Renewable Energy 

Policies and Programs in State and Tribal Implementation Plans

In addition to the advantages, the EPA also recognizes the challenges associated with 

incorporating EE/RE policies and programs in SIPs, including:

 

Establishing partnerships between air and energy regulators in jurisdictions

Quantifying the emissions and air quality benefits of EE/RE policies and programs

One challenge is establishing strong, productive partnerships among energy and 

environmental agencies within state, tribal or local governments. In many jurisdictions, 

environmental agencies have not traditionally partnered with public utility commissions 

(PUCs) and state energy offices (SEOs). Collaborating with PUCs and SEOs can help all 

parties understand the details of relevant EE/RE policies and how the associated 

emission benefits can help an area attain one or more NAAQS. Greater collaboration 

may help with the transfer of energy information that is needed for SIP/TIP 

documentation from energy to air agencies. Partnerships among state air and energy 

offices can facilitate successful monitoring of compliance with adopted EE/RE policies

and evaluation of their impacts; this will ensure that projected energy and emission 

benefits are achieved.

The EPA also recognizes that quantifying the emission impacts of EE/RE policies and 

programs in a manner acceptable for SIPs/TIPs can be challenging, especially in cases 

where air agencies need to determine whether and to what extent the EE/RE initiative is 

affecting a particular nonattainment area. Appendix I of the roadmap describes 

emission quantification approaches state, tribal and local agencies can apply to 

understand the magnitude and location of EE/RE policy and program emission impacts. 

Depending upon the emission quantification approach used, emission reductions can be 

attributed to specific EGUs within (or upwind of) a nonattainment area. 

One of the key issues is to identify where and when the emission reductions need to 

occur to reduce harmful air quality levels for a particular NAAQS in a particular area. For 

criteria pollutants like sulfur dioxide (SO2) and primary particulate matter (PM), 

reductions in electricity demand from a fossil fuel-fired EGU can produce air quality 

improvements in the area around the EGU in a shorter time frame. For other criteria 
16

pollutants, like ozone or secondary PM, the air quality improvements from EE/RE 

policies and programs would occur at a larger regional scale and over a longer period

since these pollutants form in the atmosphere over a greater period of time and at a 

greater distance from the pollution source. 

Air agencies should evaluate the effectiveness of an EE/RE policy or program on 

achieving benefits to air quality within a nonattainment area. This can depend upon the 

form of the NAAQS – that is, short-term versus long-term concern – and on local 

impacts versus long distance concerns. To address these challenges, in Appendix I, EPA 

describes four emission quantification approaches for EE/RE policies and programs. 

These approaches encompass a range of techniques that can be used to support the 

four SIP pathways. In addition, the appendix addresses pertinent analytical questions, 

as well as a description of the advantages and disadvantages of each approach.

This Roadmap Clarifies Existing Guidance and is Not a Regulation 

This roadmap is being issued to clarify existing guidance and does not create new 

guidance. In addition, the CAA and implementing regulations at the Code of Federal 

Register, Title 40, Part 51: Requirements for Preparation, Adoption, and Submittal of 

Implementation Plans (40 CFR Part 51) contain legally binding requirements. This 

roadmap does not substitute for those provisions or regulations, nor is it a regulation 

itself. Thus, it does not impose binding, enforceable requirements on any party, and 

may not be applicable in all situations. 

The EPA and state, tribal and local agency decision makers retain the discretion to adopt 

approaches for approval of SIPs/TIPs that differ from this guidance where appropriate 

and consistent with applicable law. Any final decisions made by EPA on a submitted 

revision for a particular SIP will be made based on the statute and regulations within the 

context of EPA notice and comment rulemaking. Therefore, interested parties may raise 

questions and objections about the substance of this roadmap and appropriateness of 

its application to a particular situation. The EPA will, and state, tribal and local agencies 

should similarly, consider whether the recommendations in the roadmap are 

appropriate in a particular situation. 

This roadmap is a living document and may be revised periodically without public 

notice. However, the EPA welcomes public comments on this document at any time and 

will consider those comments in any future revision of this document. Finally, this 

document does not prejudice any future final EPA decision regarding approval of any 

SIP, which will only be completed through notice and comment rulemaking.

Scope of Roadmap

The roadmap described in this document pertains only to the impact of EE/RE policies 

and programs on air emissions from the electric utility sector, which is a major 

stationary source of emissions contributing to ozone, SO2 and PM2.5 air quality levels. 
17

Other source sectors, especially mobile sources,10 can also contribute to ambient levels 

of these pollutants. In addressing nonattainment air quality problems, state, tribal and 

local agencies will need to consider emission reductions from more than the utility 

sector. 

 

10 EPA (1997).
18

Figure 4: How the Appendices Support the Four Pathways
19

SECTION 2.0: ACTIVITIES FOR GETTING STARTED

The purpose of this section is to help state, tribal and local agencies understand what 

activities EPA recommends agencies consider when deciding whether to incorporate 

EE/RE policies and programs in a SIP/TIP. The EE/RE SIP Pathway Flowchart (Figure 5) 

recommends initially that agencies become familiar with:

Basic functioning of the electric system

Roles and responsibilities of key state energy-related organizations

State, tribal and local EE/RE policies and programs in the jurisdiction

Estimating potential emission reductions 

Understanding existing EPA EE/RE SIP guidance

Common “getting started” questions and answers

More information on each one of these topics can be found in the appendices. 

Functioning of the Electric System

Many air agencies are already familiar with the electric system, and the roles and 

responsibilities of energy agencies in their state. For those who want more information 

on the topic, it is provided here. It is important to understand the workings of the 

electric system and to address key issues that arise in energy and air quality planning, 

most notably quantifying the emission impacts and accounting for the EE/RE policies 

and programs in SIPs/TIPs (see Appendix I). The operation of regional power systems is 

complex and dynamic, so predicting how these systems will react to new resources –

including EE and RE – is likewise a complex undertaking. 

The decision of which EGU to dispatch and in what order is based in principle on 

economics, with the lowest cost resources dispatched first and the highest cost 

resources last. The last resources to be called upon are referred to as the marginal 

units, which are typically the most expensive units to run. In some cases in certain parts 

of the country, these plants can also be among the highest emitting and least efficient 

EGUs of the power plant fleet.

EE/RE can affect dispatch in different ways, though both cause marginal units to run less 

frequently and can result in fewer air emissions. In the case of EE, energy savings occur 

at the point of consumption, resulting in a reduction in demand on the electric system 

and a corresponding reduction in emissions from the power plant fleet. In the case of 

RE, energy savings occur at the point of generation, resulting in a reduction of 

generation by fossil fuel-fired EGUs and a corresponding reduction in emissions from 

the power plant fuel. (Refer to Appendix B for more information on the electric 

system.)

Roles and Responsibilities of Key State Electric Energy Organizations

Reaching out to your energy counterparts and explaining the emissions and air quality 

benefits of EE/RE policies and programs within your jurisdiction is one way to start 
20

identifying partnership opportunities, common objectives and policy goals. In most 

cases, the SEOs and PUCs will have information on the state’s adopted or planned EE/RE 

policies and programs. The regional planning organizations and sustainability 

coordinators, within the city or county operations, will most likely have information on 

adopted or planned local EE/RE policies and programs. Tribal jurisdictions may also 

have a designated representative that is knowledgeable on EE/RE policy and program 

issues. 

Building partnerships with energy agencies and organizations within your jurisdiction, 

prior to and during the SIP planning stages, can help facilitate information exchange on 

areas such as: energy impacts of EE/RE policies and programs for required SIP/TIP 

emission quantification and documentation. To get started, EPA recommends reviewing 

the roles and responsibilities of the following energy-related organizations: SEOs, PUCs 

and Regional Transmission Organizations/Independent System Operators. To assist, 

Figure 6 lays out what they do, the types of policies and programs they oversee and the 

types of information they can provide. The EPA encourages state, tribal and local

agencies to collaborate with these energy experts to obtain information on their 

jurisdiction’s EE/RE policies and programs. (Appendix B provides more information on 

the different types of agencies and how they interact.)

State, Tribal and Local Energy Efficiency/Renewable Energy Policies and 

Programs in Jurisdictions

The following questions can help lead state, tribal and local agencies in the appropriate 

direction: 

Which EE/RE policies and programs has the jurisdiction adopted?

What are the details of those policies and programs in terms of implementation 

dates, stringency, financial commitments, historic investments in EE/RE and 

important enforcement features?

Is there any information on the energy impacts (projected and/or historical) of 

those EE/RE policies in terms of energy saved, quantities of RE procured and air 

emission impacts?

Which organization or agency monitors and evaluates the energy impacts of 

those EE/RE policies?

Certain terms are important to understand as state, tribal and local agencies review this 

roadmap: 

EE/RE policies are regulations, statutes, or state public utility commission orders 

that require parties to acquire EE and/or RE or to commit to funding levels for 

programs aimed at acquiring EE/RE. Policies can include Renewable Portfolio 

Standards (RPS) and Energy Efficiency Resource Standards (EERS).

EE programs are designed to increase adoption of energy efficient technologies

and practices in particular end-use sectors through education and outreach, 
21

financial incentives, financing mechanisms, and/or technical or deployment 

assistance. Such programs are frequently implemented in support of mandatory 

state-level policy goals (e.g., an EERS). 

RE programs are designed to increase the production and use of RE sources 

through resource procurement and development, education and outreach, 

financial incentives, and/or technical assistance. Such programs may be 

implemented in support of mandatory state-level policy goals (e.g., an RPS), or 

may be for other purposes (e.g., voluntary purchases of RE).

Estimating Potential Emission Reductions

After a jurisdiction determines what state, tribal and local EE/RE policies and programs 

are in place and gathers information on their energy impacts, EPA recommends air 

quality professionals conduct an initial calculation of potential emission benefits. 

Estimating the potential emission reductions allows a jurisdiction to determine whether 

further investigation is warranted. 

Appendix I describes four different emissions quantification approaches for EE/RE 

policies and programs. Three of these quantification approaches could help with 

performing back-of-the-envelope calculations of potential emission reductions of EE/RE 

policies and programs. Having a sense of the emissions impact of a policy or program 

will help a jurisdiction decide whether and how to move forward with incorporating an 

EE/RE policy or program in a SIP/TIP.

Understanding Existing EPA Energy Efficiency/Renewable Energy SIP 

Guidance

The EPA has issued five guidance documents related to incorporating EE/RE programs in 

SIPs. Appendix C provides highlights of the parts of those documents relevant to EE/RE 

and SIPs. State, tribal and local agencies should gain a basic understanding of EPA’s 

existing guidance (and this roadmap’s clarifications) before deciding on which pathway 

or pathways to pursue for its policies and programs.

Common “Getting Started” Questions and Answers

The EPA has also identified important EE/RE policy and program frequently asked 

questions state, tribal and local agencies could ask when determining whether to 

incorporate the emission impacts of EE/RE policies and programs in a SIP/TIP. Table 1

includes several “getting started” questions and answers to help state, tribal and local 

agencies address some basic issues.
22

Figure 5: Energy Efficiency/Renewable Energy Pathway Flowchart for State and Tribal Implementation Plans
23

Figure 6: Energy Organizations’ Roles and Responsibilities
24

Table 1: Common “Getting Started” Questions and Answers

Question Answer

With all the other regulatory activities I'm 

responsible for, why should I take time to 

consider EE/RE measures?

In many cases, state, tribal and local governments have 

already adopted EE/RE policies and programs for reasons 

other than air quality improvement. It may be a matter of 

simply accounting for the emission impacts of these 

existing initiatives. The EE/RE policies and programs may 

be able to provide emission reductions, which could 

include criteria pollutants, toxic air pollutants, and 

greenhouse gases. Air quality planners will benefit from 

understanding the full benefits of these strategies

I represent a city government in a 

nonattainment area that wants to take 

credit for locally-initiated EE measures. 

The plan for the nonattainment area is a 

SIP, managed by the state government, 

not a local plan. What should I first do?

One of the first actions EPA recommends is to talk with 

your state environment department to understand its 

position. The SIP is a State Implementation Plan, so an 

important first step is to engage the state agency 

primarily responsible for that plan. Analyses will need to

be performed of the expected emission benefits of the 

measures and any impact on air quality in the 

nonattainment area. Agreements between local and state 

government agencies can clearly delineate responsibility 

for making up any discrepancies that might arise if 

emission reductions do not occur as expected. 

Some states may be apprehensive about 

depending on EE/RE policies or programs 

for emission reductions in the SIP because, 

if the reductions fail to materialize, then 

the state will have to make up the 

reductions elsewhere. Is this an issue?

Some states have expressed this apprehension. If this is a 

concern, states can evaluate which SIP pathway can 

accommodate a jurisdiction’s unique needs. The WOE 

pathway is also available to reach attainment goals even if 

reductions fail to materialize. In addition, for the baseline 

pathway and voluntary measures, if the state finds the 

EE/RE policy or program is not needed to attain the 

NAAQS, then action would not be needed to make up the 

shortfall.

Are daily emission reductions from electric 

sector EE/RE SIP initiatives typically small?

The jurisdictions that have requested SIP credit in a 

nonattainment area have typically claimed less than 1 

ton/day of nitrogen oxides (NOx) credit for an ozone SIP. 

However, EPA is aware of some state proposals that 

would seek multiple tons/day of NOx credit. The 

magnitude of emission reductions depends on the 

aggressiveness of the EE/RE policy or program and its 

effects on EGU emissions. The EPA encourages state and 

local governments initially to review more aggressive 

EE/RE policies and programs so that jurisdictions can 

capture the largest benefits first.
25

Question Answer

How much effort does it take to complete 

the technical documentation to account 

for emission impacts of EE/RE policies and 

programs in SIPs/TIPs? 

It varies depending upon a number of factors, including 

which EE/RE policies and/or programs state, tribal or local 

agencies have adopted; the energy data availability; 

whether the air agency has an established relationship 

with energy regulators; and the chosen SIP pathway. For 

example, relatively less effort is needed to fold existing 

EE/RE policies into a baseline emission projection analysis. 

For the emerging/voluntary measures and WOE 

pathways, documentation is based on a jurisdiction’s 

desired level of rigor and energy information availability. 

By contrast, for the control strategy approach, a higher 

level of documentation and communication with energy 

regulators is needed and the particular EE/RE provisions 

need to be enforceable. 

We have been designated as a 

nonattainment area for ozone and are 

subject to an emissions budget program 

for NOx. Can we get SIP credit for EE/RE 

policies or programs? 

Yes, SIP credit is available under these circumstances.11 

One acceptable way is by achieving additional emission 

reductions from EE/RE policies or programs in the 

presence of this type of program through the retirement 

of allowances commensurate to the emissions expected 

to be reduced by the EE/RE policy or program. Another 

way is to clearly demonstrate that emissions will decrease 

in the nonattainment area and/or time of interest despite 

the presence of the emissions cap.12

Where do you go to find the major steps 

to proceed from having a state or local 

EE/RE policy or program to realizing SIP 

credit for such a measure in a SIP revision?

The EPA has designed this roadmap to cover the major 

principles common for each SIP pathway, Figure 5 of this 

roadmap is provided as a starting point. Depending upon 

which SIP pathway is pursued, further information on the 

major steps for each pathway can be found in the 

roadmap appendices that illustrate the major steps a 

state, tribal or local agency would take to quantify 

emission reductions, documentation and other applicable 

requirements. 

How do I know which state, tribal or local 

EE/RE policies or programs may already be 

accounted for in a future emissions 

inventory, which is incorporated in a SIP 

baseline emissions projection?

Appendix E of this roadmap outlines the steps state, tribal 

and local governments can take to understand what EE/RE 

policies and programs are already reflected in the SIP 

emission baseline projections. First, a state, tribal or local 

agency needs to know the information source of energy 

forecast and evaluate which EE/RE policies are affecting 

the demand and supply assumptions in the energy 

forecast. 

 

11 EPA (2004a), pp. 9-10.

12 The Agency plans to provide an example of such a demonstration and to further clarify this answer.
26

Question Answer

What specific tools are available to enable 

me to estimate the kilowatt-hours (kwh) 

impacts from various, common EE and RE 

programs (e.g., green building codes, 

renewable energy credit purchases, water 

conservation and water pumping 

improvements, retrofits of public 

buildings)?

The energy regulators within your state or energy-related 

local government offices are normally the people who 

manage these common EE/RE programs. The EPA 

encourages you to reach out to your colleagues to 

understand the tools and methods that are employed to 

estimate the energy impacts of specific programs. You 

can also refer to the following website for general 

information on this topic. 

http://www.epa.gov/statelocalclimate/state/activities/me

asuring-savings.html. 

How can I specifically estimate the 

magnitude of kwh reduced (and emissions 

reductions) from each EGU that supplies 

the geographic area where the EE/RE 

policies and programs are being 

implemented?

Examples supplied in Appendix K of this roadmap discuss 

this methodology. An energy model such as a dispatch 

modeling has the capability of performing this type of 

analysis. Performing a regional analysis is the best 

approach for this situation because the electricity 

suppliers generally cross state boundaries to meet the 

demand or reduce demand when EE/RE programs are 

brought onto the electric grid in a particular area. 
27

SECTION 3.0: DECISION-MAKING FOR NAVIGATING THE FOUR 

PATHWAYS

After completing the initial tasks identified at the top of the EE/RE Pathway Flowchart 

(Figure 5), the next activity EPA recommends is exploring which of the four pathways 

described above represents the most appropriate mechanism for incorporating a 

jurisdiction’s EE/RE policies and programs in their SIP/TIP. The purpose of this section is 

to help state, tribal and local agencies with this task by navigating through the decisionmaking flowchart. 

To use the flowchart, jurisdictions need to understand certain definitions contained in 

the EPA’s 2004 guidance13 and for federal enforceability:

An emerging program does not have the same high level of certainty as 

traditional measures for quantification purposes. (Traditional measures are 

generally thought of as control measures applied to stationary industrial sources 

that can take the form of emissions limitations.) 

A voluntary program is not enforceable against an individual source or 

implementing party.

Federal enforceability refers to the fact that in the SIP planning process when 

EPA approves a SIP control strategy submitted to it for review, the SIP becomes 

federally enforceable, which provides EPA with authority to ensure the SIP is 

implemented. Once EE/RE policies and programs become federally enforceable,

EPA has the authority under the CAA to apply CAA-authorized penalties against 

the noncompliant party. 

Decision-Making Flowchart

The EPA has identified certain key EE/RE policy/program characteristics agencies should 

address when determining which pathway they can pursue to account for the emission 

impacts of EE/RE policies and programs in a SIP or TIP. State, tribal and local agencies 

can apply these characteristics to their unique situations and needs. As additional aids, 

for each pathway Figure 7 provides characteristics of policies and programs that would 

suit each approach and Table 2 contains examples of EE/RE policies and programs for 

the four pathways.

Five key questions will aid jurisdictions in determining what SIP pathway(s) to pursue for 

each EE/RE policy or program, or group of EE/RE policies or programs:

1) Does the jurisdiction have emerging or voluntary programs?

2) If the answer is “yes,” then does the jurisdiction want SIP/TIP credit under EPA’s 

emerging/voluntary measures policy?

 

13 EPA (2004a, 2004b).
28

The term “SIP/TIP credit” means emission reductions achieved by using 

technologies or strategies, used by a state or tribe for the purpose of 

meeting emission reduction requirements in its reasonable further 

progress (RFP14), attainment or maintenance strategy.

3) If the answer is “no,” then does the jurisdiction want a federally enforceable 

control strategy?

4) Are the EE/RE policies and programs “on the books” (i.e., already adopted by a 

legislative or regulatory body)? 

If the policies and programs are not “on the books,” then the logical 

assumption is whether the jurisdiction has EE/RE policies and programs 

that are “on the way” to being adopted prior to SIP submittal to EPA.

5) Does the jurisdiction have access to emissions projection modeling or can it 

perform baseline emissions projections itself? 

State, tribal and local agencies can do a combination of any, or all, of the four pathways. 

They should proceed through the steps in the flowchart in Figure 5 for each separate 

policy and program in their jurisdiction so that they evaluate each policy and program 

separately. 

Whether a jurisdiction has emerging and voluntary measures serves as the entry point 

question into the decision-making flowchart. The next two sections describe the 

possible scenarios that can result from whether the answer to this question for a 

specific policy or program is “yes” or “no.” 

Pathways for Jurisdictions That Have Emerging and/or Voluntary 

Measures

If a jurisdiction has EE/RE policies and programs that meet the emerging and/or 

voluntary measures definition and wants SIP/TIP credit for the emission reductions, 

then it should consider the emerging/voluntary measures pathway. If it does not 

choose that pathway, but nevertheless wants to reflect the emissions reduction benefit 

of its EE/RE policies and programs in its SIP/TIP, then the WOE pathway would be the 

appropriate option.

Pathways for Jurisdictions That Do Not Have Emerging and/or 

Voluntary Measures

If a jurisdiction does not have EE/RE emerging and/or voluntary programs, then it can 

consider at least two or three of the other pathways. The first important question is 

whether or not the jurisdiction wants the EE/RE policy or program to be a federally 

 

14 Under the Clean Air Act, the term "reasonable further progress" means such annual incremental 

reductions in emissions of the relevant air pollutant as are required by the CAA or may reasonably be 

required by the Administrator for the purpose of ensuring attainment of the applicable NAAQS by the 

applicable date. In previous guidance, when referring to SIP requirements EPA also referred to rate of 

progress or ROP, which was intended to cover a portion of emissions needed to satisfy reasonable further 

progress. In this guidance, EPA has dropped the ROP term and is now referring to the reasonable further 

progress requirement only as RFP. 
29

enforceable control strategy. If the answer is “yes,” then the control strategy pathway

would be the recommended option. If the answer is “no,” then the next decision point 

hinges on whether the jurisdiction has access to emissions projection modeling or can 

perform the baseline emissions projections itself. If the answer is “yes,” EPA 

recommends that “on the books” policies and programs be accounted for in the 

baseline emissions projection pathway. If the answer is “no”, then EPA recommends the 

WOE pathway.

Additional Resources

Table 3 contains summary information on SIP credit for each pathway, including 

appropriate percentage of SIP “credit,” suggested quantification methods and relevant 

EPA guidance. It also includes suggested emission quantification approaches state, 

tribal and local agencies can use as guidelines when accounting for emission impacts of 

EE/RE policies and programs within a certain SIP/TIP pathway. These approaches are 

suggestions only, so a jurisdiction can choose to use an alternative approach, not listed 

here, that has comparable rigor and emission results. Before getting too deeply into any 

EE/RE emissions analysis, contact the air program in an EPA regional office15 to discuss 

options for emission quantification approaches that are appropriate for the EE/RE 

policies and programs at hand. 

 

15 For more information, go to: http://www.epa.gov/aboutepa/where.html.
30

Figure 7: Characteristics of Policies and Programs Suitable for Each Pathway
31

Table 2: Examples of Energy Efficiency/Renewable Energy Policies and Programs for the Four 

State and Tribal Air Planning Pathways16

Policies Programs

Baseline Emissions Projection Pathway

Existing policies such as:

Renewable portfolio standards

Energy efficiency resource standards

Public benefit funds

Not applicable

Control Strategy Pathway

New policies (or proposed increases in 

stringency for existing policies) with respect 

to:

Renewable portfolio standards

Energy efficiency resource standards

Public benefit funds

Not applicable

Emerging/Voluntary Measures Pathway

New or existing policies such as:

Mandatory commercial whole-building 

energy use disclosure at time of sale or 

lease

On-bill financing for EE retrofits

New or existing programs such as:

Development and implementation of municipal 

energy conservation plan

Municipal building retrofit programs

Statewide EE awareness program

Customer feedback on energy usage

Weight of Evidence Pathway

New or existing policies such as:

Renewable portfolio standards

Energy efficiency resource standards

Public benefit funds

Mandatory commercial whole-building 

energy use disclosure at time of sale or 

lease

New or existing programs such as:

Development and implementation of municipal 

energy conservation plan

Municipal building retrofit programs

Statewide EE awareness program

Customer feedback on energy usage 

 

16 Example policies are provided here for all four pathways. Generally, because of their larger scope, 

EE/RE policies have the potential to provide greater emission reductions than programs. By contrast, 

EE/RE programs are frequently implemented in support of mandatory state-level policy goals and 

individually have the potential to achieve smaller emission impacts. Example programs are provided for 

only two of the four pathways – the emerging/voluntary measures and WOE pathways. Example 

programs are not provided for the baseline emissions projection and control strategy pathways because 

they are not anticipated to provide enough potential emission reductions to warrant the time and 

resources necessary to satisfy the SIP documentation needs of each of those pathways. However, 

jurisdictions can decide if this is true in their unique circumstances. Reviewing the resources needed can 

help provide the context for EE/RE policies and programs as jurisdictions consider which SIP/TIP pathway 

is appropriate for each of its EE/RE policies and programs.
32

Table 3: Information on State and Tribal Implementation Plan Credit and Quantification 

Approaches

Percentage of SIP “Credit” 

Allowed

Suggested Quantification 

Methods

Relevant EPA Guidance

Baseline Emissions Projection Pathway

No SIP credit limit

Allows for jurisdictions to 

account for established EE/RE 

policies in the SIP

Energy model approach

Historical hourly emission 

rate approach

Alternative emissions 

projection tools or analysis

More information on IPM is 

available at 

http://www.epa.gov/airmarkt/epa

-ipm/

“EIIP, Emissions Projections 

Volume X”, EPA, 

http://www.epa.gov/ttnchie1/eiip

/techreport/volume10/x01.pdf, 

1999

Control Strategy Pathway

No SIP credit limit 

Need to present case for 

credit

Energy model approach

Historical hourly emission 

rate approach

Capacity factor approach

“Guidance on SIP Credits from 

Emission Reductions from ElectricSector Energy Efficiency and 

Renewable Energy Measures,” 

EPA, 

http://www.epa.gov/ttncaaa1/t1/

memoranda/ereseerem_gd.pdf, 

August 2004

Emerging/Voluntary Measures Pathway

Presumptive limit is 6 percent 

of the total amount of 

emission reductions required 

for SIP purposes

Limit applies to the total 

number of emission 

reductions that can be 

claimed from any 

combination of emerging 

and/or voluntary measures

Can be greater than six 

percent where a clear and 

convincing justification is 

made

Capacity factor approach “Incorporating Emerging and 

Voluntary Measures in a State 

Implementation Plan (SIP),” EPA, 

http://www.epa.gov/ttncaaa1/t1/

memoranda/evm_ievm_g.pdf, 

September 2004

“Guidance on Incorporating 

Bundled Measures in a State 

Implementation Plan,” EPA, 

http://www.epa.gov/ttn/caaa/t1/

memoranda/10885guideibminsip.

pdf, August 2005 

Weight of Evidence Pathway

No SIP credit limit

Only an option if the 

predicted air quality value in 

the attainment 

demonstration (using 

modeling) is within a 

prescribed margin of 

attaining the NAAQS

Energy model approach

Historical hourly emission 

rate approach

Capacity factor approach

eGRID sub region non-base 

load emission rates

“Guidance on the Use of Models 

and Other Analyses for 

Demonstrating Attainment of Air 

Quality Goals for Ozone, PM2.5, 

and Regional Haze,” EPA, 

http://www.epa.gov/ttn/scram/gu

idance/guide/final-03-pm-rhguidance.pdf, April 2007 
33

Baseline Emissions 

Projection Pathway

For an understanding of existing baseline 

pathway guidance

See Appendix C.2

For information on the baseline pathway

See Appendix E

SECTION 4.0: BASELINE EMISSIONS PROJECTION PATHWAY

When developing a SIP/TIP, jurisdictions must have an inventory of current emissions 

and a baseline projection of future emissions. The baseline emissions projection shows 

the level of emissions in the future 

target year that will result if no 

additional control strategies, policies 

or programs are implemented. The 

baseline emissions projection 

includes effects of existing federal, 

state, tribal or local policies or 

programs that will come into effect 

by the future attainment year, but

does not include any additional (“on 

the way”) strategies not yet in 

statute or codified by a regulatory 

body. These strategies can include 

cases where a local community 

wants to capture local EE/RE SIP measures that are not part of federal or state 

regulations or statutes. The EPA will consider the concept of a state entering into a 

binding commitment with a community in order to capture such reductions within the 

baseline emissions projection pathway. 

Jurisdictions can take steps to understand the impacts of their existing EE/RE policies 

and programs, and to represent these impacts in baseline emission projections. State, 

tribal and local agencies interested in accounting for “on the books” EE/RE policies in 

the baseline emissions projections pathway can conduct their own analysis or use EPA’s 

emissions projections of the EGU sector. 

Appendix E provides 

details on incorporating 

“on the books” EE/RE 

policies in the SIP/TIP 

baseline pathway and on 

implementing this 

pathway. Agencies 

interested in EPA’s energy 

modeling capability (using 

the IPM model) to account 

for EE/RE policies in their 

baseline emission 

projections can start by 

reviewing Appendix E.2. 

State, tribal and local 
34

Baseline Emissions Projection Pathway: 

Qualifying Criteria

•State, tribal and local agencies can include a specific 

EE/RE policy in the future SIP/TIP attainment year 

emissions baseline if:

•It has already been adopted by a governing body in 

a jurisdiction AND

•The effects of the policy have not already been 

accounted for in the SIP/TIP (no double counting). 

agencies considering developing their own method can also review Appendix J which 

describes the methodology EPA used to develop energy savings estimates for state 

EE/RE policies, provides an overview of the information EPA is making available and 

outlines potential uses for the information. 

Qualifying Criteria

Certain qualifying criteria have to be met in order to include a policy in the future

baseline attainment year. First, EE/RE policies in the baseline need to be mandatory 

policies adopted by a governing body in a jurisdiction. For example, EERS that have 

been adopted in law can be included in the baseline emissions forecast. However, if a 

state, tribal or local agency is currently discussing whether to adopt such a policy, or has 

proposed but not yet adopted one, then it is not appropriate to include. Voluntary 

EE/RE policies – where there is no regulatory obligation – are likewise ineligible. 

Second, EPA wants to ensure that the emission reductions from EE/RE policies are not 

counted twice. Prior to 

adjusting the baseline 

emission projections, state, 

tribal and local agencies must 

clearly understand which 

EE/RE policies and programs

are already assumed in the 

baseline. Likewise, any EE/RE 

policies accounted for in the 

baseline cannot be 

incorporated in any other SIP pathway.

Mandatory Policies That Are Not Federally Enforceable

EE/RE policies incorporated into the baseline emission projections are not federally 

enforceable and the EPA may not bring an enforcement action if a state fails to 

implement such an initiative. However, if the state, tribal or local air agency is relying 

on the EE/RE policy in the baseline to help the area attain a NAAQS and the EE/RE policy 

is not implemented as assumed and air quality does not improve so as to meet the 

NAAQS as anticipated in the SIP/TIP, then the jurisdiction may be required to implement 

backup policies to make up for the emissions shortfall. The air agency might also agree 

voluntarily to revise their SIP. Alternatively, EPA may initiate a SIP call under section 110 

of the CAA in which EPA can require that the state revise the SIP to make up the 

emissions relied upon to meet the applicable NAAQS. In addition, state public utility 

commissions typically have mechanisms to require compliance with state EE/RE policy 

requirements, including financial incentives for exceeding state policy requirements and 

penalties for non-compliance. These enforcement mechanisms can provide more 

certainty that EE/RE policy requirements will be achieved. 
35

Control Strategy Pathway

For an understanding of existing control 

measure pathway guidance

See Appendix C.3

For information on the control strategy 

pathway

See Appendix F

SECTION 5.0: CONTROL STRATEGY PATHWAY

SIPs and TIPs include strategies containing 

control measures to provide emission 

reductions to enable nonattainment 

areas to attain and meet SIP 

requirements. The control strategy 

pathway would provide state, tribal and 

local agencies the opportunity to include 

EE/RE policies as part of a control 

strategy. It is best suited for a state, 

tribal or local agency that is 

contemplating adopting EE/RE policies 

before submitting its SIP to EPA (“on the 

way” policies) and whose emission 

benefits will be realized coincident with 

the planning timeframe of its SIP. The 

control strategy pathway offers the most visible and direct benefit in the SIP context, is 

federally enforceable and represents the pathway taken when an agency adopts a 

traditional control measure into a SIP/TIP (e.g., a control measure for a stationary 

source).

This pathway involves significant 

documentation and quantification 

efforts. State, tribal and local 

agencies that undertake the 

control strategy option have to 

provide a demonstration that the 

emission reductions resulting 

from their mandatory EE/RE 

policies are permanent, 

enforceable, quantifiable and 

surplus. This roadmap clarifies 

how those requirements can be 

satisfied. As better information 

about the success of these policies 

and programs becomes available, EPA believes that it will be feasible for air agencies to 

make the necessary demonstration to address the requirements in their SIPs/TIPS.

Control Strategy Pathway Must Meet Four Criteria

Because the control strategy pathway is federally enforceable, coordination issues could 

be significant. The state, tribal or local air quality office will most likely need to reach 

out to the state public utility commission and others to explain the implications of 

making the state, tribal or local agency’s mandatory EE/RE policies federally 

enforceable. 
36

Additional details about this pathway are included in Appendix F. Appendix F contains 

information on four criteria that have to be met and how a state, tribal or local agency 

can satisfy them (see Figure 8). The strategy must be permanent throughout the term 

for which the credit is granted unless it is replaced by another measure or the state

demonstrates in a SIP revision that the emission reductions from the measure are no 

longer needed to meet applicable requirements. The strategy must be federally 

enforceable and its emission reductions must be quantifiable and include procedures to 

evaluate and verify over time the level of emission reductions actually achieved. The 

emission reductions must be surplus and not double counted.

With respect to quantifying the benefits of mandatory EE/RE policies, the approaches

outlined in Appendix I reflect that some state, tribal and local agencies (or groups of 

state, tribal and local agencies) will possess the resources and capability to perform 

sophisticated modeling analyses of the energy and air benefits of mandatory EE/RE 

policies, while others will not. Appendix I contains four quantification approaches that 

range in sophistication and describes how to handle uncertainty, including which 

approaches would be appropriate for the control strategy pathway. 

Permanent

•Evidence that 

regulation or 

legislation is 

mandated 

throughout 

attainment 

planning period

Enforceable

•EPA has ability to 

enforce EE/RE 

policies and 

programs brought 

into SIPs as control 

strategies 

•Federal 

enforceability is key 

for expanded SIP 

credit

Quantifiable

•Use a reliable and 

replicable emissions 

quantification 

approach that 

illustrates which 

EGUs will reduce 

emissions based on 

EE/RE policies and 

programs 

Surplus

•Document no 

double counting of 

emissions 

reductions

•Demonstrate 

emission reductions 

are not used for 

other CAA 

requirements (e.g., 

under a cap and 

trade program)

Figure 8: Four Criteria the Control Strategy Pathway Must Meet
37

Emerging/Voluntary Measures 

Pathway

For an understanding of existing 

voluntary/emerging measures pathway guidance

See Appendix C.4

For information on the voluntary/emerging 

measures pathway

See Appendix G

SECTION 6.0: EMERGING/VOLUNTARY MEASURES PATHWAY 

In the 2004 guidance,17 EPA recognized that many jurisdictions of the country had 

implemented most available, traditional emission control strategies and wanted to try 

new types of pollutant reduction strategies to attain NAAQS, including emerging and 

voluntary EE/RE programs. The EPA 

supports and encourages the testing of 

emerging and voluntary pollutant reduction 

strategies. An emerging measure is a 

measure or strategy that does not have the 

same high level of certainty as traditional 

measures for quantification purposes. A 

voluntary measure is a measure or strategy that 

is not enforceable against an individual 

emissions source or a party responsible for 

implementing the EE/RE activity. A measure can be 

both emerging and voluntary. These measures can be state initiatives, but are generally 

locally-based initiatives, that are designed to encourage or require citizens, businesses 

or local government to reduce emissions.

In addition, the individual emerging 

and/or voluntary measure can be 

"bundled" in a single SIP submission. The 

emission reductions for each measure in 

the bundle would be quantified and the 

total reductions would be summed 

together in the SIP submission. After SIP 

approval, each individual measure would 

be implemented according to its schedule 

in the SIP. It is the performance of the 

entire bundle (the sum of the emission 

reductions from all the measures in the 

bundle) that is considered for SIP 

evaluation purposes, not the effectiveness 

of any individual measure.18

This pathway is similar to the control 

strategy pathway in that an EE/RE 

program can receive emission reduction 

SIP credit. For emerging/voluntary stationary measures, the presumptive SIP credit limit 

is 6 percent of the total amount of emission reductions required for RFP, attainment or 

 

17 EPA (2004b).

18 These measures can be bundled with non-EE/RE measures.
38

maintenance demonstration purposes.19 These measures must satisfy the four criteria 

for SIP measures:

Permanent

Enforceable 

Quantifiable

Surplus

The 2004 guidance provides flexibility for emerging measures on the quantifiable 

criterion and for voluntary measures it provides flexibility on the enforceable criterion. 

The pathway is well suited for jurisdictions that have emerging and/or voluntary EE/RE 

policies and programs that are not easy to enforce and/or quantify but for which the 

jurisdiction would like SIP credit. The pathway establishes conditions that limit the 

credit that emerging/voluntary measures can receive. (See Table 3 for details on how 

much SIP credit is allowed under this pathway compared to other pathways.) The 

emerging/voluntary measures pathway provides a mechanism that allows state, tribal

or local agencies to receive provisional emission reduction credit in their SIP for new 

emission control and pollutant reduction strategies that have the potential to generate 

additional emission reductions or air quality benefits. Provisional emission reductions 

or pollutant reduction strategies can become permanent when post-implementation 

evaluations validate the amount of emission reductions achieved. 

 

19 EPA (2004b).
39

Weight of Evidence Pathway

For an understanding of existing WOE 

pathway guidance

See Appendix C.5

For information on the WOE measures 

pathway

See Appendix H

SECTION 7.0: WEIGHT OF EVIDENCE PATHWAY

When state, tribal and local agencies prepare SIP/TIP demonstrations of attainment, 

sometimes air quality modeling results can be inconclusive and predict that jurisdictions 

may not attain a NAAQS based solely on air quality modeling. In those cases, EPA 

guidance allows state, tribal or local agencies to submit WOE demonstrations to show 

that, despite inconclusive modeling results, the nonattainment area will still attain 

based on other evidence. The WOE 

pathway can reflect mandatory and 

voluntary EE/RE policies and programs 

that demonstrate, through objective 

analysis, which emission reductions will occur 

within the same planning timeframe as that 

used for attainment. 

The WOE pathway is applicable where a state, 

tribal or local agency has prepared an attainment 

demonstration that includes modeling that results 

in projected future air quality that is close to the NAAQS, but does not meet the level of 

the NAAQS. In this case, an agency may choose to submit a WOE analysis, which may 

include, among other things, alternative modeling results, emissions controls that were 

not modeled, and ambient data trends and analyses. As part of the WOE showing, the 

agency may wish to take advantage of EE/RE policies or programs adopted in its 

jurisdiction for purposes other than the SIP/TIP. They may want to reflect the emission 

benefits of the policies or programs in the determination because they believe that the 

positive benefits will potentially affect air quality in the attainment year, but modeling 

the impact of the policy or program is 

either too resource intensive or not 

feasible for other reasons or the 

jurisdiction is not interested in SIP/TIP 

credit.

Agencies need to perform objective 

analyses of the benefits expected from 

the EE/RE programs and policies reflected

in the WOE demonstration that are 

intended to help improve air quality in 

the nonattainment area in question. The 

more robust the analysis supporting the 

WOE demonstration, then the stronger 

the argument that the area will attain despite inconclusive air quality modeling results. 

The WOE demonstration can be strengthened in several ways, including obtaining 

commitments from SEO or PUCs that the EE/RE policy or program requirements are 

approved or will be in place for the duration of the attainment plan. Process issues 
40

associated with this pathway can be more or less significant, depending on the extent of 

the supporting analysis. 

WOE demonstrations are generally a set of analyses of air quality, emissions, 

meteorological data, and modeling data that state, tribal and local agencies can use to 

show that attainment of a NAAQS is likely, despite initial modeled results that may not 

show attainment or may be close to the level of the NAAQS. The greater the difference 

between the modeled design value and the level of the standard, the more compelling 

the additional evidence produced by analyses must be in order to conclude (based on 

the WOE results) that attainment is likely despite the inconclusive modeled attainment 

test. WOE demonstrations are described in guidance EPA has issued on their use in SIP 

attainment demonstrations.20 The EPA guidance includes guidelines for assessing when 

corroborating analyses and/or WOE determinations may be appropriate. 

Emission reductions from mandatory EE/RE policies and voluntary programs proposed 

for use in the WOE demonstration cannot be used elsewhere in the SIP. In other words, 

no double counting is permitted. In addition, the measures must be in place for the 

duration of the SIP planning period. Appendix H describes the WOE approach in more 

depth and provides information on WOE analyses and Appendix K provides two 

examples of states that incorporated EE/RE policies and programs in their SIP WOE 

demonstrations.

 

20 EPA (2007).
41

REFERENCES

American Council for an Energy-Efficient Economy (2011). The 2011 State Energy Efficiency 

Scorecard. October 2011. Available online at <http://www.aceee.org/researchreport/e115>

EPA (1997). Guidance on Incorporating Voluntary Mobile Source Emission Reduction Programs in 

State Implementation Plans (SIPs). October 1997. Available online at 

<http://www.epa.gov/otaq/stateresources/policy/general/vmep-gud.pdf>

EPA (2004a). Guidance on SIP Credits from Emission Reductions from Electric-Sector Energy 

Efficiency and Renewable Energy Measures. August 2004. Available online at 

<http://www.epa.gov/ttncaaa1/t1/memoranda/ereseerem_gd.pdf>

EPA (2004b). Incorporating Emerging and Voluntary Measures in a State Implementation Plan 

(SIP). September 2004. Available online at 

<http://www.epa.gov/ttncaaa1/t1/memoranda/evm_ievm_g.pdf>

EPA (2005). Guidance on Incorporating Bundled Measures in a State Implementation Plan. 

August 2005. Available online at 

<http://www.epa.gov/ttn/caaa/t1/memoranda/10885guideibminsip.pdf>

EPA (2007). Guidance on the Use of Models and Other Analyses for Demonstrating Attainment of 

Air Quality Goals for Ozone, PM2.5, and Regional Haze. April 2007. Available online at 

<http://www.epa.gov/ttn/scram/guidance/guide/final-03-pm-rh-guidance.pdf>

Federal Register (2011a). Vol. 76. No. 85. pp. 24976- 25147. Proposed Rule: National Emission 

Standards for Hazardous Air Pollutants From Coal and Oil-Fired Electric Utility Steam 

Generating Units and Standards of Performance for Fossil-Fuel-Fired Electric Utility, 

Industrial-Commercial-Institutional, and Small Industrial-Commercial-Institutional Steam 

Generating Units. May 3, 2011. Available online at <http://www.gpo.gov/fdsys/pkg/FR2011-05-03/pdf/2011-7237.pdf> 
42

United States

Environmental Protection

Agency

Office of Air Quality Planning and Standards

Outreach and Information Division

Research Triangle Park, NC

Publication No. EPA-456/D-12-001a

July 2012