Roadmap for Incorporating Energy 

Efficiency/Renewable Energy

Policies and Programs into State and Tribal 

Implementation Plans

Appendix F: Control Strategy Pathway
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EPA-456/D-12-001g

July 2012

Roadmap for Incorporating Energy Efficiency/Renewable Energy

Policies and Programs into State and Tribal Implementation Plans

Appendix F: Control Strategy Pathway

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
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ACKNOWLEDGMENTS

We would like to acknowledge substantial contributions from members of an inter-office 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.
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Contents

SECTION F.1: BASICS OF CONTROL STRATEGY PATHWAY .........................................................................................F-4

Pathway Description...............................................................................................................................................F-4

Tradeoffs of Pathway..............................................................................................................................................F-4

Circumstances the Pathway is Best Suited For.......................................................................................................F-6

SECTION F.2: FOUR CRITERIA OF THE CONTROL STRATEGY PATHWAY.....................................................................F-6

SECTION F.3: QUANTIFICATION CRITERION...............................................................................................................F-6

Steps to Quantify Emissions Impacts......................................................................................................................F-6

Provide a Mechanism to Validate and Evaluate the Effectiveness of the Policy ....................................................F-7

SECTION F.4: SURPLUS CRITERION ............................................................................................................................F-7

SECTION F.5: ENFORCEABLE CRITERION....................................................................................................................F-8

SECTION F.6: PERMANENT CRITERION ......................................................................................................................F-9

SECTION F.7: SIP CREDIT IN A MULTI-STATE SCENARIO ............................................................................................F-9

REFERENCES..............................................................................................................................................................F-11
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SECTION F.1: BASICS OF CONTROL STRATEGY PATHWAY

Pathway Description 

A control strategy is a policy, program, or requirement used by a state, tribal or local agency in 

a nonattainment, attainment, or unclassifiable area to reduce ambient air pollution levels. 

States adopt control strategies to satisfy Clean Air Act (CAA) requirements for the purposes of, 

as appropriate, attaining or maintaining the National Ambient Air Quality Standards (NAAQS), 

demonstrating reasonable further progress (RFP) towards attainment, or meeting other 

statutory State Implementation 

Plan (SIP) requirements. 

After jurisdictions adopt control 

strategies, they incorporate them

into a SIP or Tribal 

Implementation Plan (TIP) for a 

particular air pollutant and then 

submit them to EPA for review. 

Collectively, all of the control 

strategies in a SIP/TIP need to

reduce emissions to levels that 

satisfy attainment, maintenance, 

RFP, and other pertinent SIP 

provisions. 

This appendix addresses the 

tradeoffs, level of effort, 

methods, and other key criteria

involved in incorporating energy 

efficiency and renewable energy 

(EE/RE) policies and programs in a SIP/TIP as a control strategy. As with any SIP/TIP pathway, 

EPA recommends that state, tribal and local agencies coordinate with their EPA regional office 

as soon as they decide to move forward.

Tradeoffs of Pathway 

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

jurisdiction’s different EE/RE policies and programs. With respect to the control strategy 

pathway, including EE/RE policies and programs in a SIP/TIP under that pathway can help 

jurisdictions meet their air quality goals by accounting for emission reductions needed to show 

attainment, RFP, or maintenance. The control strategy pathway may be an especially appealing 

option to state, tribal and local agencies that are having difficulty reaching attainment and are 

seeking new and viable emission reductions opportunities. 

State, tribal and local agencies should consider several tradeoffs and issues when deciding 

whether to include EE/RE policies and programs in the control measure pathway consistent 

with the jurisdiction's circumstances and objectives. Reviewing the tradeoffs will enable a 
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state, tribal and local agency to evaluate the merits of following the control measure approach 

in the context of the other three pathways.

Key tradeoffs and considerations when deciding whether to pursue the control strategy

pathway include: 

Transparency: Of the four pathways, this option offers the most transparent and direct 

approach to estimating the air quality impacts of EE/RE policies. State, tribal and local

agencies will gain a better understanding of how much generation from which fossil 

fuel-fired EGUs will be displaced as a result of future EE/RE policies/programs. State, 

tribal and local agencies will have a tons-per-day amount of emissions for each fossil 

fuel-fired EGU they expect to reduce based on a specified EE/RE policy and program. 

State, tribal and local agencies will have emission reductions from a control strategy to 

help them attain.

Documentation: This option needs more documentation than the future baseline and 

WOE approaches because under the CAA a jurisdiction would have to show that the 

EE/RE policy/program was permanent, enforceable, quantifiable, and surplus. As better 

information about the success of EE/RE policies and programs becomes available, EPA 

believes it will be feasible for air agencies to make the necessary demonstration to 

address the requirements in their SIPs/TIPS. 

Federal Enforceability: To gain SIP/TIP approval, the EE/RE policies and programs that 

are included as a control strategy need to be enforceable against a responsible party. 

State, tribal and local agencies should consider their role and responsibility, as well as 

the associated resources needed to enforce EE/RE policies included in a control strategy.

Coordination: Early coordination will help ensure that responsible agencies and entities 

understand their roles and have sufficient time dedicated to incorporating EE/RE 

policies and programs as a SIP/TIP control strategy. Developing strategies and 

determining their efficacy for meeting and maintaining compliance with NAAQS 

necessitates a high level of coordination among multiple government agencies.

Level of Analytical Rigor: Overall, quantification under this pathway can be more 

resource intensive because the state, tribal or local agency would have to perform an 

EGU analysis that shows where emissions are likely to go down in relation to the 

nonattainment area of interest. The specific level of effort necessary for quantifying the 

emission reduction impacts depends on the analytical approach selected. Appendix I 

describes four different approaches of analysis that vary in sophistication. 

Coordination Across Relevant State Agencies: Another factor affecting level of effort is 

the degree to which agencies responsible for SIP implementation coordinate with 

entities responsible for overseeing and evaluating EE/RE policies and programs (e.g., 

typically the state’s public utility commission (PUC) or state energy office). The purpose 

of these discussions is to:

Help air quality planners fully understand the jurisdiction’s EE/RE policies/programs,

including their extent, duration, and anticipated impact.
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Ensure that all parties understand the implications of including EE/RE in the SIP, 

including the obligation to sustain the program consistent with agreements in the 

SIP and federal enforceability of SIP provisions.

Help the respective agencies better understand the other’s roles and 

responsibilities. 

o In many cases, formal agreements can be established between state air agencies 

and PUCs to outline each entity’s obligations for implementing the state's EE/RE 

activities, quantifying their impacts, and including them in the SIP. 

Circumstances the Pathway is Best Suited For

The control strategy pathway is best suited for “on the way” EE/RE policies that state, tribal and 

local agencies want to include in their SIP/TIP control strategy that have not been accounted for 

elsewhere in the SIP and that are not emerging/voluntary programs. (This could include 

policies that were adopted after preparation of the SIP emissions baseline that were, thus, not 

considered “on the books” when the baseline was prepared.) If incorporated in the control 

strategy, such policies would be federally enforceable. 

SECTION F.2: FOUR CRITERIA OF THE CONTROL STRATEGY PATHWAY

To become part of the SIP/TIP as a control strategy, the EE/RE policy or program needs to be:

Quantifiable

Surplus

Permanent

Enforceable 

SECTION F.3: QUANTIFICATION CRITERION

Steps to Quantify Emissions Impacts

Emissions and emission reductions attributed to the measure are quantifiable if someone can 

reliably measure or determine their magnitude in a manner that can be replicated. The 

recommended procedure for determining the amount of SIP/TIP credit generated by an EE/RE 

policy or program follows four basic steps:

Step 1: Estimate the energy savings that an EE measure will produce, or, for a RE

project, the amount of energy generation that will occur.

Step 2: Convert the energy impact in STEP 1 into an estimated emissions reduction. 

Step 3: Determine the impact from the estimated emission reduction on air quality in 

the nonattainment area.

Step 4: Provide a mechanism to validate or evaluate the effectiveness of the project or 

initiative.
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Appendix I provides guidance on the first three of the four steps and describes two 

quantification approaches that EPA suggests for estimating the emission reductions of EE/RE 

control strategies:

Dispatch or Capacity Expansion Model Approach

Historical Hourly Emission Rate Approach

Provide a Mechanism to Validate and Evaluate the Effectiveness of the Policy

The purpose of step four is to determine the type of monitoring, record keeping, and reporting 

that is needed to evaluate whether the expected energy impacts, emission reductions and/or 

air quality improvements were achieved in practice. If an air agency wants to incorporate EE

policies as a control measure, the agency should conduct evaluation, measurement, and 

verification (EM&V) of the EE impacts over time, as savings accrue. In jurisdictions with 

significant levels of EE investment in place, a robust EM&V framework likely already exists and 

is overseen by the PUC. Communications with these officials can reveal the frequency, rigor, 

and scope of the EM&V effort needed, as well as the timing for impacts reporting. 

Air officials can then use these data to document and validate the effectiveness of the EE policy 

for SIP purposes. Public utility commissions can also point to any irregularities with the data, as 

well as any issues with EE reporting that may affect the policy validation process. In 

jurisdictions where the entity overseeing and evaluating the EE policy is not immediately 

apparent, an inquiry with the EE service provider (often a utility or non-profit organization) or a 

local organization can help. While it is not necessary for air officials to become experts in EE

EM&V, it may be useful to understand the sources of EE data, along with reporting schedules, 

overall level of rigor, the roles played by leading organizations, and other basic information 

relevant to the successful linkage of air and energy policy. For more information on EE EM&V, 

see the National Action Plan for Energy Efficiency Guide on this topic.1

For RE policies and programs, jurisdictions should have a system in place to track whether 

energy providers are meeting required percentage targets for procurement of RE. Typically, the 

PUCs or state energy offices monitor utility compliance or performance on a year-to-year basis. 

SECTION F.4: SURPLUS CRITERION

Jurisdictions cannot “double count” emissions reductions. Emission reductions associated with 

EE/RE policies and programs may not be relied upon in any of the other three pathways 

included in a jurisdiction’s SIP/TIP. To demonstrate that this criterion has been met, 

jurisdictions should provide:

A statement that the appropriate agency has reviewed the control strategy and 

confirms that it is not accounted for as part of other pathways in the SIP; and 

 

1

EPA and U.S. Department of Energy (2006).
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A statement describing the potential areas of overlap, if any, and steps to ensure that 

emission reductions are surplus and that there is no double-counting.

Emission reductions associated with the EE/RE policies and programs may be relied upon to 

satisfy the SIP Reasonably Available Control Technology and RFP requirements, as well as CAA 

requirements for emissions standards. 

SECTION F.5: ENFORCEABLE CRITERION

The jurisdiction’s EE/RE policies and programs need to be mandatory, created either by specific 

state legislation, commission order, or regulation. Under the CAA, states are required to have 

enforcement authority for the policy or program. If a state submits a SIP that incorporates 

EE/RE programs, the programs also become federally enforceable. Making state adopted EE/RE 

programs federally enforceable puts them on par with more traditional air pollution control 

programs for which states have sought SIP credit in the past. Once these policies and programs 

become federally enforceable EPA has the authority under the CAA to apply CAA-mandated 

penalties against the party responsible for noncompliance. Depending on the policy, the 

responsible party would not be the agency administering the policy – typically a PUC. Instead,

the party may be the load serving entity responsible for delivering power to customers and 

upon whom the duty to use EE/RE has been placed, for example, through a permit or the rate 

setting process. For example, under a Renewable Portfolio Standard policy, a state could 

require certain entities to purchase an amount of RE. If the state relies upon such requirements 

within the SIP, then such measure could be enforceable against the entities required to 

purchase the renewable electricity, even if those entities are not responsible for the operation 

of the electricity generating units at which the emission reductions are expected to occur.

Additionally, if the reductions are enforceable against another party responsible for the EE or 

RE activity, then they are considered enforceable if:

The activity or measure is independently verifiable;

Violations are defined;

Those liable for violations can be identified;

The activity or measure is practicably enforceable in accordance with EPA guidance on

practicable enforceability;

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and

The state maintains the ability to apply penalties and secure appropriate corrective 

actions where applicable.

From the standpoint of federal SIP enforceability, an agreement among state agencies is not 

necessary for EPA to approve an EE/RE policy into a SIP as a control measure. However, it is 

recommended to ensure adequate coordination and communication at the state level so that 

expectations and responsibilities are clear. The EPA recommends a memorandum of 

understanding between the state department of environmental protection (DEP) and the PUC 

 

2

EPA (1989) and EPA (1992).
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or other state entity to ensure adequate program coordination. From EPA’s standpoint, it does 

not matter what part of state government implements the program – it could be the DEP or the 

PUC – so long as the state agency in question has authority from the legislature to administer 

the program. The governor (or its designee) would need to sign the SIP to give the proper state 

agency authority in this situation where one state agency – typically a PUC – is administering 

the EE/RE policy or program and the state DEP is responsible for developing the SIP. 

SECTION F.6: PERMANENT CRITERION

The impacts of the EE/RE policy and/or program control strategy need to continue through the 

future attainment year unless it is replaced by another control measure or the state 

demonstrates in a SIP revision that the emission reductions from the EE/RE policy or program 

are no longer needed to meet applicable statutory and regulatory requirements. The state, 

tribal or local agency should demonstrate that the EE/RE policy was adopted in a state 

regulation or enacted in statute. 

To demonstrate permanence in the case of EE, the jurisdiction should ensure that the projected 

emissions impacts of the EE policy and program are achieved by the attainment year. If the EE 

policy or program is not fully implemented by the attainment year, then new programs should 

be adopted to deliver the same results. One way to increase the likelihood that EE programs 

will result in emissions reductions is to secure a commitment for continued support and funding 

for the EE programs in the future.

SECTION F.7: SIP CREDIT IN A MULTI-STATE SCENARIO

Electricity continuously flows through the electric grid, as electricity providers produce power 

to meet demand both within and across state boundaries. This dynamic raises the question of 

how to apportion emission reduction SIP credit between states that buy and sell electricity from 

each other. Historically, about half of the states (e.g., California, Virginia) import electricity to 

meet electricity demand within the state, while about half of the states (e.g., New Mexico, New 

Hampshire) export electricity to meet demand elsewhere.3 For a state to obtain “credit” for 

emission reductions associated with these electricity transfers, a state would need to account 

for these transfers as part of the analysis it conducts for estimating future EGU emissions. For 

example, imports and exports of electricity across state lines are accounted for in dispatch and 

capacity expansion models, such as IPM energy modeling that EPA provides to support 

regulatory analysis.

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Estimates of future year EGU emissions made by states using other 

techniques should also account for imports and exports of electricity across state lines.

For a state to obtain credit under the control strategy pathway for emission reductions that are 

associated with these electricity transfers, the state should ensure that its estimate of reduced 

 

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For more information on state-level export/import data, go to: http://www.epa.gov/cleanenergy/energyresources/egrid/index.html. 

4

Note that EPA’s IPM modeling only includes “on the books” EE/RE policies and programs that have been adopted 

in regulation, statute or commission order. 
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future year EGU emissions includes the impact of these policies and programs as outlined 

within the control strategy. Typically, Regional Planning Organizations model the air quality 

impact of state control strategies across multiple states in a “control strategy” modeling run. 

After the baseline modeling is constructed, states put forth the suite of strategies they intend 

to adopt as part of the SIP to be modeled in the “control strategy” modeling run. Those control 

strategies need to meet the provisions outlined per the four SIP control strategy criteria

discussed above. Ultimately, when EPA reviews the SIP it needs to determine whether or not 

the suite of control strategies assumed in the multi-state SIP modeling were actually adopted 

by the states in question, including EE/RE policies and programs.
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REFERENCES

EPA (1989). Guidance on Limiting Potential to Emit in New Source Permitting. June 13, 1989. Available 

online at <http://www.epa.gov/reg3artd/permitting/t5_epa_guidance.htm>

EPA (1992). Use of Long Term Rolling Averages to Limit Potential to Emit. February 24, 1992. Available 

online at <http://www.epa.gov/region7/air/title5/t5memos/rollave.pdf>

EPA and U.S. Department of Energy (2006). National Action Plan for Energy Efficiency. July 2006. 

Available online at <http://www.epa.gov/cleanenergy/documents/suca/napee_report.pdf>
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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-12-001g

July 2012