Meeting with the Board of the Business Council for Sustainable Energy

July 9, 2014
Questions from Participants (Q)/Key Points Discussed (KP) **Key Comments**

 Noted BCSE work with Bloomberg Energy Finance to produce annual report on U.S. clean energy usage and penetration. Provides a snapshot of the industry
– may not be covered adequately in other analysis.  Important for BCSE member organizations and companies to hear from senior EPA and Administration policy makers
– gives them confidence to speak in favo r of clean energy and the rule.
 EPA may have undercounted renewable energy’s (RE) contribution
– RE could provide a bigger share of reductions (from AWEA).
**Q: Who (i.e., which audiences) are you trying to explain the rule to?**  **(PIMA)** KP: Suggestion that EP A provide materials for use in communicating with CEOs, corporate sustainability officers, and town council members. Important to reach local level and specific segments such as the NACO engineers who would be involved in facilities management and technic al analysis. **Q: What about the treatment of hydropower?**  **(Scott Sklar, Stella Group)** KP: EPA should be open to allowing for upgrades at existing, older dams that increase their efficiency. **Q: How do you respond to apparent confusion on the timing of cre**  **diting actions –**  **there is potential for delaying actions in order to receive credit later?**  **(Johnson Controls)** KP: JM encouraged good comments so EPA doesn’t create disincentives to action and promote delay. **Q: Could a state wait until one year or a few yea**  **rs before 2030 to start compliance measures? (Follow** **- up)**  KP: Appreciate d JM ’s explanation that while “we would have to look at the math,” it’s unlikely that a state could put off action until that close to the end. **Q: Will EPA put out guidance on EM&V?**  **(Johnson Controls)** KP: More examples of how to do EM&V will be useful to states. One area is building codes, especially down to the local level (also an education and enforcement issue). **Q: If a utility**  **(e.g., in CA) has a**  **P ower Purchase Agreement**  **with an RE generator in**  **another state** **, do the emissions reductions count in C** **A? What about fossil generation? ( Sempra Energy)** KP: Agree d with EPA that the reductions from the RE generator should count for the receiving state

(following the RECs) but need to work with facilities to avoid doublecounting. Makes sense that the fossil generation counts against the state in which it’ s located. **Q: On natural gas issues, in Building Block #2, were the gas infrastructure and marketplace taken into account**  **to develop the percentage for gas capacity**  **? Doesn’t seem clear. (BCSE President and AGA)** KP: Discussion addressed question about EPA’s approach and what was taken into account in both the analysis and design of the proposed rule. **Q: What is meant by “federally enforc eable” for measures included in Building Block #4? (AGA)**  KP: Appreciate d JM’s explanation about the option for states to take a “portfolio approach” and share responsibility (so not enforceable for individual actions but for a set of actions). Welcome d i nvitation to provide assistance with legal and policy dimensions. **Q: Do “problems” (e.g., with being federally enforceable) dissipate with a mass -**  **based approach? (EnerNOC)**  KP: Appreciat ed JM’s response that a mass

- based approach could simplify a state’s approach (e.g., regarding EM&V and enforceability on specific measures) but states still have the responsibility to lay out a compliance path and comply with it.