From: Szabo, Aaron <Aaron_L_Szabo@omb.eop.gov> 

Sent: Wednesday, July 29, 2015 10:37 PM 

To: Culligan, Kevin; Vasu, Amy; Harvey, Reid 

Cc: Frey, Nathan J.; Grossman, Andrea 

Subject: Summary of Interagency Comments Under EO 12866 and 1356 - Demand-side EE 

TSD 

Attached please find a summary of interagency comments under EO 12866 and 13563 on the 

Demand-side EE TSD. 

 

Thank you and please let know if you have any questions. 

Aaron L. Szabo 

Policy Analyst 

Office of Management and Budget 

202-395-3621 

Aaron_L_Szabo@omb.eop.gov 

<< SummaryOfInteragencyCommentsUnder_EO12866_EO13563_DemandEETSD.docx >> 
Demand-Side Energy Efficiency Technical Support Document Commented [A1]: General Comments:

1) Cite authors in LBNL articles.

2) Recommend not using ACEEE and other non‐peer reviewed

results for cost‐effectiveness as there have been significant peer‐

reviewed studies that could be used.  
ii

Contents 

Page 

List of Figures .............................................................................................................................. v

List of Tables ............................................................................................................................... v

1. Introduction .......................................................................................................................... 1

2. Background .......................................................................................................................... 1

2.1 EE Technologies and Practices .............................................................................. 2

2.2 Barriers to EE Investment ...................................................................................... 3

2.3 EE Policies ............................................................................................................ 5

2.3.1 Objectives and Role in Reducing CO2 Emissions from the Power 

Sector ......................................................................................................... 5

2.3.2 Policy Types .............................................................................................. 7

3. History of EE Policies in the United States ........................................................................ 9

4. EE Programs ...................................................................................................................... 15

4.1 EE Programs ........................................................................................................ 15

4.1.1 Administrators ......................................................................................... 16

4.1.2 Policy Drivers .......................................................................................... 16

4.1.3 Funding Sources ...................................................................................... 17

4.2 The Demand-Side EE Opportunity ...................................................................... 17

4.2.1 Rapid Growth in Demand-Side EE .......................................................... 17

4.2.2 EE Program Impacts ................................................................................ 18

4.2.2.1 Impacts to-date ..................................................................................... 18

4.2.2.2 Projected Impacts ................................................................................. 22

4.2.3 EE Potential ............................................................................................. 23

4.2.3.1 Evaluations of EE Potential ................................................................. 23

4.2.3.2 Overview of Results ............................................................................. 25

4.3 Costs and Cost-Effectiveness of State EE Policies .............................................. 26

4.3.1 EE Cost-Effectiveness ............................................................................. 26

4.3.2 Costs of Saved Energy ............................................................................. 28

5. Other EE Strategies ........................................................................................................... 30

5.1 Building Energy Codes ........................................................................................ 30

5.1.1 Overview ................................................................................................. 30

5.1.2 Authority / Obligated Parties ................................................................... 31

5.1.3 Building Code Regulations Over Time .................................................... 31

5.1.4 Remaining Market Potential .................................................................... 33

5.2 State Appliance Standards ................................................................................... 34
Contents (Continued) 

Page 

iii 

5.2.1 Overview ................................................................................................. 34

5.2.2 Authority / Obligated Parties ................................................................... 34

5.2.3 Appliance Standards over Time ............................................................... 35

5.2.4 Remaining Market Potential .................................................................... 35

5.3 Energy Service Performance Contracting ............................................................ 37

5.3.1 Overview ................................................................................................. 37

5.3.2 History of ESPC Programs and the ESCO Business Model ..................... 38

5.3.3 Remaining Market Potential .................................................................... 38

5.4 Volt/VAR Optimization ...................................................................................... 40

5.4.1 Overview ................................................................................................. 40

5.4.2 History of VVO Programs ....................................................................... 41

5.4.3 VVO Market Potential ............................................................................. 42

6. Utility Regulatory Models for Supporting Demand-Side EE .......................................... 42

7. Energy Efficiency Certificates ........................................................................................... 45

8. Demand-Side EE Plan Scenario: Magnitude and Timing of Savings ............................. 48

8.1 Approach ............................................................................................................. 48

8.2 Inputs ................................................................................................................... 49

8.2.1 Step 1: Determine Current Level of Demand-Side EE Performance ........ 49

8.2.2 Step 2: Determine EE Plan Scenario Level of Performance ..................... 50

8.2.3 Step 3: Determine Start Year for EE Plan Scenario ................................. 53

8.2.4 Step 4: Determine Start Year Level of Performance ................................ 53

8.2.5 Step 5: Determine Pace of Improvement from Start Year to EE Plan 

Scenario Level of Performance ................................................................ 53

8.2.6 Step 6: Determine Average Portfolio Measure Life and Distribution 

of Measure Lives ..................................................................................... 54

8.2.7 Step 7: Determine Sustainability of EE Plan Scenario Level of 

Performance ............................................................................................. 56

8.2.8 Summary of the Demand-Side EE Plan Scenario Construction ............... 57

8.3 Calculations ......................................................................................................... 58

8.3.1 Step 1: Determine Annual Business as Usual (BAU) Sales ..................... 58

8.3.2 Step 2: Determine Annual Incremental EE Savings as a Percentage of 

Sales ........................................................................................................ 59

8.3.3 Step 3: Determine Annual Incremental EE Savings (GWh) ..................... 59

8.3.4 Step 4: Determine Annual Expiring EE Savings (GWh) .......................... 60

8.3.5 Step 5: Determine Net Cumulative EE Savings (GWh) ........................... 60

8.3.6 Step 6: Determine Sales after Net EE (GWh) .......................................... 60
Contents (Continued) 

Page 

iv 

8.3.7 Step 7: Determine Net Cumulative EE Savings as a Percentage of 

BAU Sales ............................................................................................... 61

8.3.8 Summary of Calculation Formulas and Results by Step for South 

Carolina ................................................................................................... 61

8.4 Results ................................................................................................................. 62

8.4.1 Summary of Results ................................................................................. 62

8.4.2 Results in Context .................................................................................... 64

9. Demand-Side EE Plan Scenario: Assessment of Costs .................................................... 65

9.1 Approach ............................................................................................................. 65

9.2 Inputs ................................................................................................................... 66

9.2.1 Step 1: Determine Incremental Electricity Savings .................................. 66

9.2.2 Step 2: Determine First-Year Program Costs and Cost Factors................ 66

9.2.3 Step 3: Determine the Ratio of Program to Participant Costs .................. 68

9.2.4 Summary of Inputs for Demand-Side EE Cost Analysis .......................... 69

9.3 Calculations ......................................................................................................... 70

9.3.1 Step 1: Calculate Annual First-Year Costs ............................................... 70

9.3.2 Step 2: Calculate Levelized Cost of Saved Energy .................................. 71

9.3.3 Step 3: Calculate Annualized Costs ......................................................... 72

9.3.4 Summary of General Formulas and Results by Step for South 

Carolina ................................................................................................... 72

9.4 Results ................................................................................................................. 73

9.4.1 Summary of National Results .................................................................. 73

9.4.2 Results in Context .................................................................................... 74

9.4.3 Costs per Tonne CO2 Reduced ................................................................. 74

10. Analysis Considerations .................................................................................................... 75

10.1 State EE Policies in the Baseline Electricity Demand .......................................... 75

10.2 Energy Information Administration Form EIA-861 as Data Source .................... 76

References .................................................................................................................................. 84

Appendices 

Appendix 1: Summary of Recent Energy Efficiency Potential Studies (2009-2014) ................................. 79

Appendix 2: Incremental Electricity Savings Pace of Improvement Analysis ............................................ 80

Appendix 3: Demand-Side Energy Efficiency Plan Scenario: Data, Calculations and Results .................. 83
v

List of Figures 

Page 

Figure 1. EE Program Portfolio ..................................................................................................................... 16

Figure 2. Residential Energy Building Code Adoption (2005 to 2014) ...................................................... 33

Figure 3. Remaining Market Potential for ESCOs ....................................................................................... 39

Figure 4. Hypothetical Voltage Profiles with and without VVO Technologies .......................................... 41

Figure 5. The Four-Tier Distribution of Demand-Side EE Program Measure Lifetime ............................. 55

List of Tables 

Page 

Table 1. Relative Opportunities Provided by Key EE Programs and Building Codes .................................. 9

Table 2. U.S. Electric Utility EE Program Funding (2006-2013) ................................................................ 18

Table 3. U.S. State Adoption of EE Resource Standards ............................................................................. 18

Table 4. Aggregate Electricity Savings by State, Tribal Area and Territory ............................................... 20

Table 5. Summary of Impacts: Scenarios of Future Utility Customer-Funded Electric EE Programs ...... 23

Table 6. Summary of EE Potential Studies (2009 to 2014) ......................................................................... 26

Table 7. Estimated Energy Savings Potential of State Appliance Standards ............................................... 36

Table 8. Summary of State Regulatory Frameworks: December 2014........................................................ 43

Table 9. International Examples of Trading Energy Savings ....................................................................... 47

Table 10. 2013 State Levels of Incremental Annual Savings ...................................................................... 51

Table 11. 2013 Incremental Annual Savings – Investor-Owned Utilities ................................................... 51

Table 12. 2013 Incremental Annual Savings – Cooperative-Owned Utilities ............................................. 51

Table 13. 2013 Incremental Annual Savings – Municipal-Owned Utilities ................................................ 52

Table 14. Levels of Incremental Savings Required by State EERS ............................................................. 52

Table 15. NPCC Achievable EE Potential and Achieved Incremental Savings (1998-2010) .................... 57

Table 16. Summary of Demand-Side EE Plan Scenario Inputs ................................................................... 57

Table 17. BAU Sales for South Carolina ...................................................................................................... 59

Table 18. Annual Incremental EE Savings as a Percentage of Sales for South Carolina ............................ 59

Table 19. Annual Incremental EE Savings (GWh) for South Carolina ....................................................... 59

Table 20. Expiring EE Savings for South Carolina ...................................................................................... 60

Table 21. Net Cumulative EE Savings for South Carolina .......................................................................... 60

Table 22. Sales after Net EE Savings for South Carolina ............................................................................ 61

Table 23. Net Cumulative EE Savings as a Percentage of BAU Sales for South Carolina ........................ 61

Table 24. Summary of Results by Step for South Carolina ......................................................................... 61

Table 25. Demand-Side EE Plan Scenario: Magnitude and Timing of Net Cumulative Savings .............. 62
List of Tables (Continued) 

Page 

vi

Table 26. Average Annual Savings Rates of Demand-Side EE Plan Scenario ........................................... 64

Table 27. Summary of EE Cost Analysis Inputs .......................................................................................... 69

Table 28. Calculation of Annual First-Year Costs for South Carolina ........................................................ 70

Table 29. Levelized Cost of Saved Energy for South Carolina (at 3% discount rate) ................................ 71

Table 30. Annualized Costs for South Carolina ........................................................................................... 72

Table 31. Summary of Results by Step for South Carolina. ........................................................................ 72

Table 32. First-Year Demand-Side EE Costs (billions 2011$) (Continental U.S.) ..................................... 73

Table 33. Annualized Demand-Side EE Costs (3% discount rate, billions 2011$) (Continental U.S.) ...... 73

Table 34. Levelized Cost of Saved Energy (3% discount rate, 2011$/MWh) (Continental U.S.) .............. 73

Table 35. Annual Growth Rates of Demand-Side EE Program Spending – Historic and DemandSide EE Plan Scenario ................................................................................................................................... 74
1 

1. Introduction 

This chapter provides information on demand-side energy efficiency (EE) as a measure 

for reducing carbon dioxide (CO2) emissions from fossil fuel-fired electric generating units 

(EGUs). Specifically, this chapter supports the discussion of demand-side EE as a non-BSER 

compliance measure in section V, “The Best System of Emission Reduction (BSER) and 

Associated Building Blocks,” and section VIII, “State Plans,” of the preamble. In addition, 

support is provided for the magnitude, timing, and cost of demand-side EE measures included in 

the illustrative demand-side EE plan scenario developed as a basis for the Regulatory Impact 

Analysis (RIA) and related discussion in section X, “Impacts of this Action,” of the preamble. 

The chapter is organized as follows: 

2. Background 

3. History of EE Policies in the United States 

4. EE Programs 

5. Other EE Strategies 

6. Utility Business Models 

7. Experience with EE Certificates 

8. Demand-Side EE Plan Scenario: Magnitude and Timing of Savings 

9. Demand-Side EE Plan Scenario: Assessment of Costs 

10. Analysis Considerations 

Sections 2 through 7 provide support for both the preamble sections cited above as well 

as background for the illustrative demand-side EE plan scenario presented in sections 8 and 9. 

Sections 8 and 9 provide details on the approach, inputs, calculations, and results for the 

magnitude and timing of savings and the assessment of associated costs for the demand-side EE 

plan scenario. Lastly, section 10 discusses considerations relevant to sections 8 and 9. 

2. Background 

Demand-side EE policies and programmatic efforts have existed for decades and are now 

used in all 50 states. These strategies are intended to help states achieve energy savings goals, 
2 

reduce the environmental impacts (including CO2 emissions) of meeting energy service needs, 

save energy and money for consumers, and provide a significant resource for meeting power 

system capacity requirements (EPA 2015). EE policies currently in place are generally 

considered by states to be cost-effective strategies for contributing to these policy objectives.1

Moreover, states – through their utilities, primarily – have been rapidly increasing their funding 

of EE programs in recent years, more than tripling budgets in the five years from 2006 to 2011, 

from $1.6 billion to $5.9 billion (ACEEE 2014c). In 2012, the utility-reported cumulative 

impacts of these programs represented a 3.7% reduction in national electricity demand (EIA 

2012a). And, EE spending is projected to continue to grow at a substantial rate. A recent study 

by Lawrence Berkeley National Laboratory (LBNL) projects EE program spending to reach $8.1 

billion to $12.2 billion (“Medium Case” and “High Case,” respectively) in 2025 (LBNL 2013c). 

2.1 EE Technologies and Practices 

EE is using less energy to provide the same or greater level of service. Demand-side EE 

refers to an extensive array of technologies, practices and measures that are applied throughout 

all sectors of the economy to reduce energy demand while ideally providing the same or better 

level and quality of service. Utilities employ an array of strategies in implementing EE programs, 

these include financial incentives such as rebates and loans, technical services such as audits and 

retrofits, and educational campaigns about the benefits of EE improvements. The purpose of 

these EE programs is to induce EE investments and practices that would not otherwise occur due 

to market failures and behavioral impediments. In the residential sector, examples of EE 

activities include the purchase of more efficient products and equipment (e.g., ENERGY STAR 

labeled), the upgrading of insulation in attics and walls, sealing of air leaks, and undertaking 

home energy audits leading to customized whole home retrofits. Opportunities for cost-effective 

EE in commercial buildings can include optimization of heating, ventilation, and air conditioning 

(HVAC) systems, upgrades of windows, and use of more efficient office equipment at 

replacement. In the industrial sector key EE strategies include motor upgrades and maintenance 

programs, recovery of waste heat streams, and optimization of processes through modern 

instrumentation and controls systems. 

                                                            

1 See below for discussion of cost-effectiveness and related cost tests used by states to evaluate EE programs. 

Commented [A2]: This should be cited as Barbose et al. (2013),

not LBNL. And really, we should be using the numbers from the

peer‐reviewed version of the paper, rather than the working paper:

Barbose, G.L., Goldman, C.A., Hoffman, I.M., Billingsley, M.A. 

(2013) The Future of Utility Customer-Funded Energy 

Efficiency Programs in the United States: Projected Spending 

and Savings to 2025. Energy Efficiency DOI 10.1007/s12053-

012-9187-1 

http://www.springerlink.com/openurl.asp?genre=article&id=doi

:10.1007/s12053-012-9187-1

Deleted: , and sometimes

Deleted: ,

Deleted: in the presence

Deleted: of
3 

The opportunity presented for economic investment in EE is dynamic, growing over time 

as technologies and practices advance, as populations grow, and as investment occurs in the 

construction of new homes, buildings, and industrial facilities. After decades of experience 

implementing policies to accelerate investment in cost-effective EE, states are finding renewed 

opportunities as they develop more sophisticated and effective strategies, evolving from a focus 

on individual end-uses and products to whole-building and systems-based strategies that account 

for the interactions between the many energy end-uses in buildings and industry (ACEEE 2013). 

As will be discussed, the experience in the U.S. has been that, on balance, a persistent and large 

potential for achievable and cost-effective EE is expected to remain even as the impact of past 

and ongoing efforts have accumulated. 

2.2 Barriers to EE Investment 

Despite the persistent and large potential for electricity savings through investment in EE 

technologies and practices, market failures, as well as non-market barriers and behavioral 

impediments, limit the realization of the many benefits of these investments. Several market 

failures that lead to inefficiencies in the investment in energy efficiency are widely recognized 

by analysts and practitioners, and are discussed extensively in the literature (Levine et al. 1995; 

Gillingham et al. 2009; Helfand and Wolverton 2011). In the presence of market failures, users 

of electricity, or those making EE investments, face prices or incentives that prevent them from 

weighing the full social benefits and costs of their investments and thus under-invest in 

approaches to reduce electricity consumption. The behavioral impediments provide another 

explanation for why individuals do not always make EE investments that are seemingly in their 

own best interest. Some of the most common examples of these market failures include: 

 Pollution externalities. Fossil energy consumption is associated with negative 

externalities, such as emissions of CO2, SO2, and NOx that cause human health and 

environmental damages. Energy prices that do not correctly reflect the externalities 

associated with energy use would lead to investments in EE below the socially 

optimal levels. 

 Imperfect information. Energy users often lack accurate information about energy 

savings and other attributes of energy efficient products or practices to understand the 

costs and benefits of EE investments. 

Deleted: As new policies are enacted, leading to the acceleration 

of investment in EE, an additional portion of the expanding 

opportunity is realized. 

Deleted: has 

Deleted: ed

Deleted: use 

Commented [A3]: Recommend removing as this paper is about

fuel economy standards.  Reviewer recommends removing

reference.

Commented [A4]: This clarification is important because some

market failures, such as information market failures, may also lead

individuals to not make EE investments that are seemingly in their

best interest.

Deleted: explain
4 

 Split incentives (or the “principal-agent problem”). Incentives of individuals who 

make EE investment decisions are not always aligned with incentives of those who 

use and pay for energy. Examples include misalignment between landlords and 

tenants, between builders and homeowners, and within organizations and institutions 

(DeCanio 1998; McKinsey 2007). 

 Credit constraints. Limited access to credit may prevent some consumers, especially 

low-income consumers, from making cost-effective EE improvement with higher 

upfront cost. 

 Under-provision of research and development (R&D). Because of the public good 

nature of knowledge, firms involved in technology development may be less willing 

to invest in R&D, leading to sub-optimal levels of EE investments from a social 

perspective (Jaffe et al. 2003). 

 Supply market imperfections. Markets for energy efficient products are often

incomplete and fragmented, leading to underinvestment in innovation and limited EE 

supplied by the manufacturers. In addition, supply chain fragmentation may also add 

complexity to the purchase and installation of otherwise economically rational 

investments, thereby slowing the adoption of EE technologies (Fischer 2005). 

 Behavioral impediments. Behavioral economics and psychology have identified 

potential behavioral phenomena that lead to consumers to deviate from the standard 

theory of welfare maximizing in consumption and other decisions, including EE 

investments (Gillingham and Palmer 2014). 

Other factors, such as hidden costs, risk and uncertainty experienced by both consumers 

and suppliers of energy efficient products, and heterogeneity among consumers, may also 

influence EE investment decisions.2 Examples of such barriers include: 

 Risk and uncertainty. Adopting an unfamiliar, typically more expensive EE 

technology can be an uncertain undertaking given the lack of credible information on 

                                                            

2 It has been recognized that there is a difference between cost-effective energy efficiency investment levels, based on costminimizing consideration, and observed levels of energy efficiency. This phenomenon, also termed ‘energy paradox,’ or ‘energy 

efficiency gap,’ has been discussed extensively in the academic literature, although a full explanation of the gap remains elusive, 

likely because it differs by setting and energy efficiency investment. See, for example, Jaffe and Stavins 1994, DeCanio 1998, 

Sanstad and Howarth 1994, DeCanio and Watkins 2008, and Allcott and Greenstone 2012. 

Deleted: is

Commented [A5]: It might be worth adding Gerarden et al.

(2015) to the list of references in footnote #2:

https://www.aeaweb.org/articles.php?doi=10.1257/aer.p20151012

Deleted: studied
5 

product performance and future energy prices, and the irreversibility of the 

investment. Imperfect or asymmetric information can exacerbate the perceived risk of 

EE investments and help explain why consumers and firms do not always invest in 

EE measures. Suppliers also face risk and uncertainty, without perfect information of 

consumer preferences for EE. In the presence of risk and uncertainties, consumers 

and suppliers alike will invest less in EE. 

 Transaction costs. Consumers face transaction costs in searching, assessing and 

acquiring energy efficient technologies and services. It can be time-consuming and 

difficult for consumers to estimate lifetime operating costs of a product. The 

complexity of the search process may put more efficient products at a disadvantage 

relative to better-known less-efficient products. 

 Capital market barriers. Consumers sometimes face higher interest rates to finance 

EE investments compared to other investments. Lenders can be reluctant to invest in 

EE loan portfolios in part because EE loans may lack standardization and financial 

markets have difficulty ascertaining the likely payoff from such investments. 

EE policies and programs can play an important role in correcting market failures and 

addressing the barriers to the investment and adoption of socially beneficial EE opportunities. 

Examples of effective EE policies and programs include public funding of R&D, information 

programs (such as energy labeling, the ENERGY STAR program, and consumer education), 

rebates for high-efficiency products, product energy performance standards, financing and loan 

programs, and technical assistance. 

2.3 EE Policies 

2.3.1 Objectives and Role in Reducing CO2 Emissions from the Power Sector 

EE policies are implemented by states to meet a number of closely related policy goals, 

including: 

 Reducing costs to electricity customers, 

 Providing a significant resource for meeting power system capacity needs, 

 Meeting energy savings goals, 

Deleted: under

Commented [A6]: Irreverisbilities in the investment would be a

reason that consumers are acting rationally and are NOT

underinvesting (e.g., see Metcalf and Hassett 1993 and several

follow‐on papers).

http://works.bepress.com/gilbert_metcalf/28/

Deleted: s

Deleted: many 

Deleted: with lower upfront costs

Commented [A7]: Is it because they have lower upfront costs

or because they are new products that consumers don’t know as

well?

Commented [A8]: This is tightly related to credit constraints.

One could consider folding this into credit constraints above.
6 

 Stimulating local economic development and new jobs, and 

 Reducing the environmental impacts of meeting electricity service needs (EPA and 

DOE 2006; EPA 2015).

 Improving the health of lower-income households by reducing drafts and better 

retaining heat in the winter and cool air in the summer.

EE policies currently in place are considered by states to be cost-effective strategies for 

contributing to each of these policy objectives (EPA and DOE 2006). While each of these 

objectives, and others, contribute to the motivation of policymakers and utilities to pursue EE 

policies and programs, reducing energy costs to consumers over the long term is a primary 

purpose in pursuing these policies. In addition, EE policies are central to meeting state objectives 

for reducing CO2 emissions from the power sector. EE policies are a leading tool for achieving 

CO2 reductions from power plants, accounting for 35% to 70% of reductions of sector emissions 

in ten states with statutory requirements for greenhouse gas reductions (EPA 2015).3 Many 

evaluations of the economic potential for carbon dioxide reductions from the United States’ 

power sector identify demand-side EE as the lowest cost strategy (typically, as noted above, with 

positive net present value) as well as the strategy having the greatest reduction potential. For 

example, McKinsey found that EE accounted for more than 60% of their mid-range potential for 

greenhouse gas reductions from the U.S. power sector and that it was available at positive net 

present value if “persistent barriers to market efficiency” could be addressed (McKinsey 2007). 

Similarly, economy-wide studies of climate mitigation scenarios confirm that EE plays a 

critical role in reducing the costs and enhancing the flexibility of meeting long-term climate 

stabilization targets (Clarke et al. 2014; Kriegler et al. 2014). An analysis by the International 

Energy Agency (IEA) suggested that in order to stabilize the carbon concentration in the 

atmosphere at 450 ppm, as much as 44% of the estimated global abatement potential in 2035 

derives from greater EE in the world economy (IEA 2012b). Several recent Energy Modeling 

Forum (EMF) studies have investigated the role of technology in achieving climate policy 

                                                            

3

 States with GHG reduction laws include: California, Connecticut, Hawaii, Maine, Maryland, Massachusetts, Minnesota, New 

Jersey, Oregon, and Washington. 

Commented [A9]: Many programs, like WAP, have health

benefits as an explicit policy goal.

Commented [A10]: Recommend removing “consistently” as

there are studies that raise questions about this, including the

earlier cited Allcott and Greenstone (2012) paper.

Deleted: Consistently, evaluations

Deleted: Analysis 
7 

objectives in the U.S. (“EMF 24” and “EMF 25” studies) and globally (“EMF 27” study).4 These 

studies concluded that compared to business-as-usual EE, improvements in EE in various 

economic sectors would slow the increases of GHG emissions in the short run, substantially 

reduce the costs of GHG mitigation (on average, by about 50%), and ease the technology 

transformation pathways to achieve long-term carbon reduction goals (Kriegler et al. 2014; Kyle 

et al. 2011). 

Several economic studies (including EMF25 studies) examined the role of EE policies 

(such as EE standards and subsidies) in relation to other climate policy instruments (such as 

carbon taxes). These studies found that when EE policies address market failures, they are 

welfare improving and can complement climate policy (Comstock and Boedecker 2011; Fischer 

2005; RFF 2010). In addition, EE policies are recognized to be an appropriate response to 

demonstrated market failures and behavioral impediments, particularly in contexts where these 

failures have broader societal implications such as environmental externalities (Gillingham et al. 

2009). 

In addition to providing cost-effective opportunities for reducing GHG emissions, EE is 

recognized to provide other co-benefits, including air quality and public health benefits, waste 

reduction from energy generation, energy security, energy system reliability, community 

economic and social development, and consumer amenities (RAP 2012). EE investments and 

policies that apply to industry have been found to spur productivity growth, technology learning 

and innovation (Boyd and Pang 2000; Worrell et al. 2003). Recently, more attention has been 

paid to developing methods for recognizing these co-benefits and integrating them into the costbenefit analysis framework used by state utility commissions and administrators of EE programs. 

Since these methodologies are not yet fully developed, these co-benefits have not been fully 

accounted for in the EPA analysis. 

2.3.2 Policy Types 

EE policies come in many forms. The most prominent and impactful EE policies in most 

states include those that drive development and funding of EE programs, and building energy 

                                                            

4 Energy Modeling Forum (EMF) is a consortium of energy economists and energy economic modeling teams that was 

established in 1976. Through ad hoc working groups, the EMF has focused on a series of energy and environmental topics that 

are of interest to policy decisions. In recent years, the EMF is recognized for its contribution to the advancement of economics of 

climate change and the reports of the Intergovernmental Panel on Climate Change (IPCC). 

Commented [A11]: Fischer 2010

Deleted: are also

Commented [A12]: Recommend revising this reference as both

of these papers are solely focused on industrial EE and not on EE as

a whole.

Deleted: These 
8 

codes. Other policies include state appliance and equipment standards, “lead by example” 

strategies targeting energy use in state operations through energy services performance 

contracting, and “volt-VAR optimization.” See section 5 for further description of these policies, 

their history, and potential for achieving significant electricity savings. Comparing the relative 

impact (potential or achieved) of the different policy types is challenging, particularly to do so 

comprehensively, across all states, and at the national level. Utility EE programs are the only 

state EE approach that has comprehensive and detailed reporting of impacts, costs, and other 

characteristics from all 50 states.5 This information is generally based upon measurement and 

verification studies submitted annually, most commonly to state utility commissions, and 

reported to the Energy Information Administration (EIA) for all program administrator types 

(including all utility types, third-parties, and government agencies). EE program data reported to 

EIA includes: incremental savings (also referred to as “first-year” savings), cumulative savings, 

peak demand savings, program costs broken down by component, and composition by end-use 

sector (residential, commercial, industrial). As of 2013 EIA ended their collection of cumulative 

savings data. In 2013, utilities and other program administrators in all 50 states and the District 

of Columbia states reported savings from EE programs to EIA through form EIA-861. At a 

national level, the EPA is not aware of a comprehensive dataset reported by states of the 

achieved impacts of strategies other than those that lead to investment in utility EE programs. 

However, state and regional-level information does exist. For example, the Northwest Power and 

Conservation Council (NPCC) has been compiling the impacts of EE policies (including utility 

and third-party EE programs, state building energy codes, and federal appliance standards) 

across their member states (ID, MT, OR, WA) for more than three decades. For the past decade, 

utility EE programs have accounted for more than 75% of the cumulative energy savings from 

state EE policies for NPCC, with building energy codes accounting for the remaining savings 

(NPCC 2010). 

Another representation of the relative opportunity provided by different state EE 

strategies is presented by evaluations of EE achievable potential or projections of the impacts of 

                                                            

5 In 2011, EIA began collecting data from third-party administrators of programs. Prior to 2011, this was a significant 

shortcoming in the breadth of the data collected. The breadth and quality of information collected through Form EIA-861 has 

improved over time, however, outside entities (e.g., ACEEE and CEE) have found that the data can be improved through expert 

review and supplementation with other data sources. While now fairly comprehensive, the EIA data can be improved further with 

regards to data quality and consistency. See section 10 for further discussion. 

Deleted: that are leading to significant

Commented [A14]: Recommend removing unless there are

references as it does not appear justified as they are niche policies

and may not be leading to significant impacts.

Deleted: impacts 

Commented [A15]: Note EIA‐861 only applies to utility EE

programs.
9 

EE policies. The results from two recent evaluations at a national level are presented in Table 1. 

Utility EE programs account for 77% and 82% of achievable savings in studies by ACEEE and 

Georgia Tech, respectively (ACEEE 2014a; Wang and Brown 2013). These studies indicate that 

the substantial majority of potential savings from state EE efforts are available through utility EE 

programs, and that state and local building energy codes can make a significant additional 

contribution. Massachusetts provides a state example of the impacts of EE programs relative to 

other state EE policies. The Massachusetts Global Warming Solutions Act of 2008 established 

statewide limits on greenhouse gas (GHG) emissions of 25 percent below 1990 levels by 2020. 

To achieve this target, Massachusetts is relying upon an integrated portfolio of clean energy 

policies. State EE policies are expected to provide the largest contribution to meeting the 25 

percent target with utility-sponsored EE programs and state building energy codes accounting for 

76% and 17%, respectively, of those policies (Massachusetts EOEEA 2010). In their 2013 

progress report, Massachusetts indicates that they are generally on track for meeting or 

exceeding these projections (Massachusetts EOEEA 2013). 

Table 1. Relative Opportunities Provided by Key EE Programs and Building Codes 

Study Year EE Programs Building Codes Other 

ACEEE 2030 77% 13% 10% 

Georgia Tech 2035 82% 18% 0% 

Source: ACEEE 2014a, and Wang and Brown 2013 

The next section reviews the lengthy history of EE policies in the U.S. In the following 

section, the focus returns to the EE programs highlighted here for an in-depth review of this 

important strategy. 

3. History of EE Policies in the United States 

Demand-side EE has been repeatedly supported through federal policies and market 

innovations over the past four decades, in recognition of its multiple benefits, including 

increased energy security, reduced emissions from the power sector, lower customer energy bills, 

enhanced economic development and job creation, and improved reliability and resiliency of the 

electricity system. Following the 1973 Organization of Petroleum Exporting Countries (OPEC) 

oil embargo, the Nixon administrated established the Federal Energy Administration, imposed 

Commented [A16]: Any estimates from these studies of the

numbers? Not sure that the breakdown between utility programs

and building codes is all that useful.

Deleted: 
10 

oil price regulations, and created Project Independence to put the U.S. back on the path toward 

improved energy security. 

The 94th Congress took the first major U.S. legislative action on energy through the 1975 

Energy Policy and Conservation Act (EPCA). Among other provisions, EPCA authorized the 

creation of vehicle fuel economy standards, and labeling requirements and efficiency standards 

for major household appliances (Congress 1975). Also in 1975, the American Society of 

Heating, Refrigerating, and Air-conditioning Engineers (ASHRAE) developed the first national 

model building energy code, 90-75 “Energy Conservation in New Building Design,” for 

residential and commercial buildings (BCAP n.d.). 

Continuing this trend of energy policy initiatives, Congress passed the Energy 

Conservation and Production Act in 1976, which authorized the creation of mandatory national 

building energy performance standards (BEPS) which were repealed in the 1980s, provided loan 

guarantees for saving energy in public and commercial buildings, authorized grants to states for 

low-income weatherization and state energy conservation programs, and encouraged the 

development of electric utility rate structures designed to save energy. 

Federal energy efficiency policy action continued during the Carter administration. 

President Carter’s 1977 National Energy Plan included energy efficiency as “the quickest, 

cheapest, and most practical source of energy In the same year President Carter also issued the 

first executive order on energy efficiency, Energy Policy and Conservation E.O. 12003 requiring 

federal agencies to develop energy conservation plans (Woolley and Peters n.d.). Other policy 

actions in 1977 included the creation of the U.S. Department of Energy, thereby consolidating 

multiple federal agencies and programs, including many that support energy efficiency, into one 

cabinet-level department. 

In 1978, partly in response to the Administration’s new energy plan, Congress enacted 

the National Energy Act, including the National Energy Conservation Policy Act (NECPA), 

which made EPCA’s provisions for federal efficiency standards mandatory and pre-emptive of 

state law; established the Residential Conservation Service (RCS), which required utilities to 

provide home energy audits; and authorized the Institutional Conservation Program (ICP), a 

grant program for schools and hospitals. NECPA also provides the core authority for the federal 

government’s energy management goals and requirements, which have been updated and 

Commented [A17]: Run‐on sentence
11 

amended since 1978 (Congress 1978a). Congress also passed the Public Utility Regulatory 

Policies Act (PURPA) in 1978 which, among other provisions, introduced competition into 

generation markets, and required state utility commissions to consider ratemaking practices that 

encourage energy efficiency (Congress 1978b). As state commissions pursued PURPA-related 

requirements as well as their own related policy interests, integrated resource planning became 

more widely used, and the concept of demand-side management (DSM) emerged, in which 

utilities implement programs to influence customer loads through energy efficiency and other 

demand-side initiatives (RAP 2011). 

The energy service company (ESCO) business model also emerged during the 1970s and 

1980s. Leaders in the Federal Energy Administration, such as Roger Sant, defined the term 

“energy services” in the 1970s as the services people want from energy, such as lighting and 

comfort, and distinct from energy commodities such as fuels and electricity. This concept gave 

rise to the energy services business, in which ESCOs could reduce energy service costs through 

energy efficiency. The ESCO industry’s growth was supported by utilities paying ESCOs for 

services such as utility-supported energy audits, and by helping federal agencies implementing 

federal energy management goals (NAESCO 2011). ESCOs also succeeded in contracting with 

state and local and institutional customers, whose limited ability to finance energy improvements 

matched up well with ESCOs’ ability to bring private capital to energy improvement projects. 

Federal policy support for energy efficiency declined dramatically in the 1980s under the 

Reagan Administration as energy supplies improved, prices stabilized, and a less favorable 

climate for federal regulation emerged. The BEPS and RCS programs were repealed, and a “nostandard” standard was issued under NECPA appliance standards authority. Some states acted to 

fill these policy vacuums, enacting their own building codes, appliance standards, and utility 

programs. Appliance manufacturers, concerned about the proliferation of multiple, different 

state standards, supported a compromised effort that resulted in the 1987 National Appliance 

Energy Conservation Act (NAECA). NAECA, which was further amended in 1988, established 

the first national home appliance efficiency standards by amending NECPA (NAECA 1987). 

During the 1980s, state and local residential and commercial building energy codes were also 

adopted to achieve greater energy savings in new construction (BCAP n.d.). 
12 

As integrated resource planning and DSM practices continued to spread in the 1980s, and 

electric utilities began to offer customers DSM programs under formal regulatory processes, 

including programs to incentivize more efficient technologies and practices. These DSM 

programs sometimes resembled utility conservation programs launched in the 1970s, but 

signified a larger shift to integrate energy efficiency into broader utility planning and operations 

(ACEEE 2012b). The rapid growth of DSM in the 1980s was the result of the 1970s’ increased 

energy prices, energy security concerns, and the environmental consequences of electricity 

generation. Rising power plant capital and fuel costs resulted in rate increases, rising customer 

dissatisfaction, and new requirements for utilities to pursue IRP to manage electricity demand, 

supply and risk (LBNL 1996). By the end of the decade, 41 states had made some progress 

towards implementing a rule to require integrated resource planning by electric utilities (Synapse 

2011). Utilities also played a key role in supporting ESCO projects into the 1990s by providing 

incentives that offset energy efficiency project costs, as integrated resource plans found that 

investments in energy efficiency were lower-cost alternative to new power plants. 

The 1990s began with the Clean Air Act Amendments and the Pollution Prevention Act 

of 1990, each of which in their own ways recognized the role energy efficiency can play in 

protecting human health and the environment. The Clean Air Act amendments provided the 

authority to use demand-side energy efficiency as a compliance option that gives utilities 

flexibility to obtain needed sulfur dioxide emission reductions through programs that encourage 

customers to conserve energy. In 1992, EPA introduced the ENERGY STAR label for office 

products which manufacturers voluntarily design to perform at superior levels of energy savings. 

President Clinton signed Executive Order 12845 in 1993 requiring federal agencies to purchase 

ENERGY STAR qualified products. The Pollution Prevention Act gave EPA new authority to 

reduce emissions via voluntary and other approaches that reduce pollution sources. 

The Energy Policy Act of 1992 (EPAct 1992) also advanced energy efficiency through a 

broad suite of policies, including federal appliance and equipment efficiency standards, 

requirements for states and the Department of Energy on model building codes, new 

requirements for federal energy management, new provisions on least-cost planning for federal 

electric utilities, and new research and development authorizations. EPAct 1992 also included 

provisions to encourage states to adopt policies to support energy savings through electric utility 

regulatory reforms (EPAct 1992). In 1996, DOE and EPA signed a joint Memorandum of 
13 

Understanding to cooperate in delivering the growing suite of ENERGY STAR programs, 

increasing the number of products and markets covered and leveraging expertise and resources 

across the federal government. 

During the early 1990s, electric utility DSM programs grew rapidly, with energy savings 

exceeding 50 billion kilowatt-hours (kWh) and utility spending at $2.7 billion in 1994 (ACEEE 

2000). About 95 percent of the reported energy savings, though only slightly over half of the 

spending, was attributed to programs reported as targeting energy efficiency (ACEEE 2000). 

These utility programs accelerated the commercialization of advanced energy efficiency 

technologies, often by partnering with federal energy efficiency programs like ENERGY STAR 

(ENERGY STAR 2012a, 2012b). By the late 1990s, funding for utility-sponsored energy 

efficiency programs fell to less than one-third of its 1994 peak, as about half of the states from a 

wave of electricity restructuring policies, accompanied by increased political and regulatory 

pressures to hold down electricity prices (EPA and DOE 2006). Some restructured electric 

utilities shifted their focus away from regulated DSM programs to unregulated power marketing 

and ESCO businesses to deliver energy sales and services directly to customers. However, the 

business model for these market-based ESCOs limited their ability to reach all but the largest 

industrial, commercial and institutional customers. Recognizing the limits of private-market 

delivery of EE, and seeking to preserve the benefits of EE programs, as the more states 

restructured their electricity markets in the 1990s, some 20 states adopted public benefit funds 

(PBFs) to ensure continuation of ratepayer-funded programs. Several states and local 

governments also expanded the authorized use of ESCO services in public facilities via lead-byexample policies. 

Congress displayed a strong commitment to energy efficiency in the Energy Policy Act 

of 2005 (EPAct 2005), which included sweeping energy efficiency provisions: it authorized $250 

million over five years to provide energy efficiency appliance rebates, $1.8 billion over three 

years for weatherization services, included direct enactment of federal efficiency standards, and 

authorized a national consumer education campaign on energy efficiency (EPAct 2005). At the 

same time, however, the ESCO market declined due to an authorization lapse for the federal 

Energy Savings Performance Contracting (ESPC) program and loss of market confidence for 

industrial financing mechanisms (NAESCO 2011). This trend was soon reversed as ESCOs 

increased focus on state and local public buildings and innovated in order to provide customers 

Deleted: Following the year 2000, energy efficiency policies and 

programs gained increased attention and, supported by decades of 

implementation experience, began to be widely recognized as a 

legitimate, measureable, and low-cost option to serve the nation’s 

energy and environmental goals. 

Commented [A18]: Recommend deleting and providing other

information as many people view EE as legitimate, measurable, and

low‐cost, but many people view them very differently – as a cheap

way for utilities to make their regulators happy and earn some

extra profit from the guaranteed rate of return on the DSM

spending.
14 

new technologies and financial models. Eventual resolution of the ESPC authorization program, 

and executive orders by both President Bush and President Obama have also required more 

aggressive energy savings in federal facilities (White House 2007, 2009, 2015). 

By the mid-2000s, the electric utility and regional electricity markets also solidified the 

validity of rate-payer funded energy efficiency programs as system resources. In 2006, the 

National Action Plan for Energy Efficiency Leadership Group of more than 60 leading gas and 

electric utilities, state agencies, energy consumers, energy service providers, environmental 

groups, and energy efficiency organizations released five policy recommendations recognizing 

energy efficiency as a high-priority energy resource. States, utilities, and key stakeholders across 

49 states joined in making aggressive commitments to energy efficiency and endorsing the 

Action Plan recommendations (EPA and DOE 2006). 

In the years following the Action Plan’s efforts, about half the states enacted Energy 

Efficiency Resource Standards (EERS), which are long-term, quantified energy savings targets 

designed to drive ratepayer-funded program plans. These policy drivers lead to the evaluation, 

planning, and adoption of EE programs and associated budgets, which are supported through 

different funding mechanisms. Funding for utility electricity energy efficiency programs has in 

turn increased rapidly, from $1.6 billion in 2006 to $6.3 billion in 2013 (ACEEE 2014c). 

At the regional level, the wholesale electricity market operator in New England began to 

allow energy efficiency to participate in regional capacity markets as part of a 2006 settlement 

agreement with their regulator, the Federal Energy Regulatory Commission (FERC). Since 2009, 

utilities undertaking energy efficiency have been compensated for its measureable contribution 

to meeting New England’s regional capacity needs, helping to ensure sufficient electricity will be 

available in the future to reliably meet demand across the region. PJM, the wholesale electricity 

market operator across 13 states around the Mid-Atlantic region, also integrated energy 

efficiency into this capacity market rules in 2009 (Booz Allen 2012). 

In 2007, the Energy Independence and Security Act (EISA) passed due to growing 

concerns over both energy prices and climate change. EISA included several new, and 

strengthened existing, appliance and equipment standards including a major incandescent lamp 

efficiency standard, authorized industrial energy efficiency programs, and included a provision 

for states to consider adopting policies to support greater energy efficiency. EISA also enacted 

Deleted: s
15 

the federal agency savings goals of President Bush’s 2007 Executive Order 13423, Strengthening 

Federal Environmental, Energy and Transportation Management, which required even more 

aggressive building energy savings than previous Executive Orders. 

The American Recovery and Reinvestment Act of 2009 (ARRA 2009) recognized energy 

efficiency for its economic benefits, including job creation, bill savings and economic 

development. ARRA 2009 allocated DOE around $16 billion for energy efficiency programs, 

including appliance rebates, grants to local governments, state energy programs, weatherization 

assistance, and smart grid grants (DOE 2012c). These investments brought results: for example, 

ARRA’s weatherization program helped more than 650,000 low-income families nationwide, 

exceeding the original target of 600,000 homes. 

4. EE Programs 

4.1 EE Programs 

Portfolios of EE programs are comprised of numerous measures and measure types that 

are applied across all sectors of electricity end-users. Figure 1 illustrates the multi-level 

composition and breadth of EE program portfolios (LBNL 2013b). The diversity represented by 

a typical portfolio of EE programs implemented by a utility (or other program administrator) is 

an important characteristic relevant to analysis of EE policies. Every detailed program type (as 

illustrated in the lower half of the figure) represents a unique set of characteristics including 

costs of energy saved, ratio of program to participant costs, investment life, scale, M&V 

approach, etc.6

                                                            

6 See following sections for discussion of these factors. 

Commented [A19]: Given the recent work by Fowlie,

Greenstone, and Wolfram (2015), it is becoming more common

knowledge that low‐income weatherization programs, like WAP,

overestimate the energy savings. The $437 is likely to be

significantly overestimated. Recommend removing sentence.

https://econresearch.uchicago.edu/sites/econresearch.uchicago.ed

u/files/paper_draft_06_15_clean.pdf

Deleted: These retrofits improved the energy efficiency of the 

homes, saving families an average of $437 a year on their energy 

bills (DOE 2012c).

Commented [A20]: cite the individual authors
16 

Figure 1. EE Program Portfolio7

Source: LBNL 2013b 

4.1.1 Administrators 

EE programs are administered by a variety of entities (“program administrators”) 

including utilities of all ownership types (investor-owned, municipals, and cooperatives), nonprofit and for-profit third-parties (e.g., Vermont Energy Investment Corporation), and state and 

local government agencies (e.g., NYSERDA). Most EE programs (including all investor-owned 

utilities which account for more than 75% of reported savings8

) are overseen by state utility 

commissions, which review and approve program plans, projected impacts, and associated 

budgets; and establish annual reporting and M&V requirements (EIA 2013). 

4.1.2 Policy Drivers 

EE programs result from a number of different policy approaches or “drivers.” These 

include EE resource standards (EERS) (26 states), system benefit charges (14 states), integrated 

                                                            

7 The “EM&V” box is not comparable to the other program types and is not relevant to this discussion. It was included in the 

referenced source to indicate that EM&V is a key activity within a program portfolio. 

8 EPA calculation using EIA-861 2013 data. 
17 

resource planning (IRP) requirements (34 states), demand-side management plan or multi-year 

EE budget (28 states), and statutory requirement to acquire “all-cost-effective EE” (6 states) 

(ACEEE 2014c; LBNL 2013c).9

 EERS is a more recently developed strategy and has quickly 

become the leading driver of the rapid growth in EE programs due to their clear goals and proven 

success as a policy tool (ACEEE 2011). These policy drivers lead to the evaluation, planning, 

and adoption of EE programs and associated budgets, which are supported through different 

funding mechanisms. 

4.1.3 Funding Sources 

Funding sources for EE programs are varied but for most states are dominated by 

revenues collected from ratepayers through electricity surcharges, typically ranging from $1 to 

$4 per megawatt-hour (ACEEE 2014c). More recently adopted funding sources include proceeds 

from the auction of allowances in the Regional Greenhouse Gas Initiative (RGGI) states and 

from EE resources bid into the forward capacity market operated by the New England 

Independent System Operator (NE-ISO). Ratepayer-funding accounts for more than 90% of total 

EE program support nationally. 

4.2 The Demand-Side EE Opportunity 

Utility EE programs are unique among state EE strategies in the comprehensiveness and 

transparency of their reported impacts, funding, and other characteristics. In this section we 

address the rapid growth in EE programs, estimated impacts of EE programs to-date and 

projections of the impacts of existing EE programs and trends, and the electricity savings 

potential achievable through expanded use of EE policies and programs. Finally, we will discuss 

the costs and cost-effectiveness of EE programs, specifically. 

4.2.1 Rapid Growth in Demand-Side EE 

Funding for EE programs has increased rapidly in recent years driven by recent policy 

innovations and increasing evidence of the effectiveness of these new strategies. Table 2 presents 

levels of EE program funding in the U.S. since 2006 (ACEEE 2014c). In the previous five years, 

funding increased by more than 250%, from $1.6 billion in 2006 to $5.9 billion in 2011. 

                                                            

9 The number of EERS states is from ACEEE 2014c and includes states with explicit EERS, those with long-term energy savings 

targets for individual program administrators, and those with EE incorporated as an eligible resource in a renewable portfolio 

standard. The numbers for the other policy approaches are from LBNL 2013c. 

Commented [A21]: Recommend removing as it does not

appear to be beneficial.

Deleted: As discussed, states are employing a number of EE 

strategies with EE programs yielding the most significant impacts 

both historically as well as in terms of future potential

Deleted: . Furthermore, 
18 

Table 2. U.S. Electric Utility EE Program Funding (2006-2013) 

Year 

2006 2007 2008 2009 2010 2011 2012 2013 

Electric Efficiency Program 

Budgets 

(billions of $s, nominal) 

1.6 2.2 2.6 3.4 4.6 5.9 5.9 6.3 

Source: ACEEE 2014c 

Key new state policies that have helped to drive these rapid increases in EE program 

funding include EERS, electricity savings goals, and “all cost-effective EE” requirements. The 

adoption of EERS, in particular, increased through this period and clearly has been the primary 

driving force behind the increasing success of and investment in EE programs. Table 3 shows the 

number of states adopting EERS by year (ACEEE 2014c). 

Table 3. U.S. State Adoption of EE Resource Standards 

Year States Adopting an EERS Total 

1997-2004 California, Hawaii, Texas, Vermont 4 

2005 Nevada, Pennsylvania 2 

2006 Rhode Island, Washington 2 

2007 Colorado, Connecticut, Illinois, Minnesota, North Carolina 5 

2008 Maryland, Michigan, New Mexico, New Year, Ohio 5 

2009 Arizona, Indiana, Iowa, Maine, Massachusetts 5 

2010 Arkansas, Oregon 2 

2011 Wisconsin 1 

1997-2011 26 

Source: ACEEE 2014c 

4.2.2 EE Program Impacts 

4.2.2.1 Impacts to-date 

Due to the very limited, although growing, peer-reviewed work in the academic 

literature, the most comprehensive sources for EE program information (including costs and 

impacts) are annual EE program reports required by utility commissions, or cooperative or 

municipal utility boards of directors. Program impact results provided in these reports are based 

on evaluation, measurement, and verification (EM&V) procedures and methods used to estimate 

the electricity savings from EE programs within the program portfolio. The EIA has been 

collecting data on EE programs through Form 861, “Annual Electric Power Industry Report,” for 

Deleted: The 

Deleted: primary 
19 

more than three decades.10 The data collection reflects an increasing degree of breadth and detail 

over time. For example, third-party-administered programs were not initially required to report 

but were added beginning in 2011. Data fields have been added over the years to reflect industry 

trends (e.g., EE programs are now reported separately from load management programs). 

Outside organizations have taken the EIA data, supplemented it with additional sources 

including surveys of utility commissions and program administrators, and published their own 

annual reports that capture EE program impacts (ACEEE 2014c; CEE 2015).

The EPA has relied on the EIA Form 861 dataset for identifying historical impacts of EE 

programs by state, tribe and territory. Specifically, the reported sales data and incremental 

electricity savings in the 2013 EIA 861 dataset are used to estimate electricity EE impacts by 

state.11 EIA data is reported by program administrator (e.g., utility, third-party, or state agency) 

and requires the disaggregation of reported data by state for administrators with programs in 

multiple states (e.g., multi-state investor-owned utilities). Program administrators in 50 states 

and the District of Columbia reported savings in 2013. The EPA has compiled this information to 

derive aggregate electricity sales and incremental electricity savings at the state, tribal and 

territorial levels.12 

Three tribal areas (Navajo, Ute, and Fort Mojave) and two territories (Puerto Rico and 

Guam) have affected EGUs under the final rule. The 2013 EIA form 861 data contain 

information to identify historical electricity sales and EE activities in these tribal areas and 

territories. The tribes are located in three states – Arizona, New Mexico, and Utah. Electricity 

sales within the tribal areas are taken out of the total sales within these three states and reported 

separately. For Arizona, this includes utility sales in the “Navajo Tribal Utility Authority” 

(Navajo tribe) and the “Aha Macav Power Service” (Fort Mojave tribe). For New Mexico, this 

includes utility sales in the “Navajo Tribal Utility Authority” (Navajo tribe). For Utah, this 

includes utility sales in the “Navajo Tribal Utility Authority” (Navajo tribe) and the “Moon Lake 

Electric Assn, Inc.” (Ute tribe). 

                                                            

10 More information on EIA Form 861 can be found at http://www.eia.gov/electricity/data/eia861/. 11 The analysis uses 2013 EIA 861 data, available at http://www.eia.gov/electricity/data/eia861/. 12 The sub-form “Retail Sales 2013” is used to calculate electricity sales. The sub-form contains details on utility electricity sales 

by service type (energy, delivery, and bundled) and by sector, within each state and territory. In addition, while EIA’s 861 survey 

encompasses most of each state’s utility sales, EIA makes an adjustment to account for the small remainder of data not included

in each utility’s entry. The adjusted data for “delivery” and “bundled” sales from all sectors are used to calculate sales at the state 

and territory levels. 
20 

Table 4 provides a summary of the utility-reported estimated electricity savings data by 

state, tribal area and territory for the latest year of available data. At the national level, 

incremental electricity savings13 in 2013 was 0.66% of retail sales with individual state values 

ranging from 0.00% to 2.00%. Cumulative electricity savings14 (representing the remaining 

impacts of programs from all prior years) reported at the national level for 2012 represent 3.73% 

of retail sales with individual state values ranging from 0.0% to 15.44%.15 2012 was the most 

recent year that EIA Form 861 included cumulative savings data, which has been discontinued in 

the 2013 version of the form. 

Table 4. Aggregate Electricity Savings by State, Tribal Area and Territory 

State 

Incremental Savings as a 

Percent of Retail Sales (%)

2013

Cumulative Savings as a 

Percent of Retail Sales (%)

2012

Alabama 0.10% 0.78% 

Arizona 1.59% 5.43% 

Arkansas 0.49% 0.39% 

California 1.16% 13.67% 

Colorado 0.92% 4.67% 

Connecticut 1.00% 13.39% 

Delaware 0.01% 0.00% 

District of Columbia 0.45% 0.57% 

Florida 0.17% 3.60% 

Georgia 0.26% 0.67% 

Idaho 0.54% 6.20% 

Illinois 1.06% 2.15% 

Indiana 0.93% 1.72% 

Iowa 1.18% 7.80% 

Kansas 0.01% 0.24% 

Kentucky 0.38% 1.04% 

Louisiana 0.03% 0.00% 

                                                            

13 Incremental savings (also known as first-year savings) represent the reduction in electricity use in a given year associated with 

new EE activities in that same year, either new participants in DSM programs that already existed in the previous years, or new

DSM programs that existed for the first time in the current year. 

14 Cumulative savings (also known as annual savings) represent the reduction in electricity use in a given year from EE activities 

in that year and all preceding years, taking into account the lifetimes of installed measures. 15 EPA recognizes concerns associated with consistency and quality of 861 data that different reporting entities may have used 

different methodologies to estimate savings and the EIA 861 data are self-reported. Over time, there has been increased 

standardization in data reporting. We believe his dataset remains the most comprehensive publically available dataset. See section 

3.10 for further discussion. 
21 

State 

Incremental Savings as a 

Percent of Retail Sales (%)

2013

Cumulative Savings as a 

Percent of Retail Sales (%)

2012

Maine 1.14% 5.42% 

Maryland 1.07% 2.47% 

Massachusetts 1.06% 6.27% 

Michigan 1.15% 2.77% 

Minnesota 1.13% 13.10% 

Mississippi 0.23% 0.50% 

Missouri 0.49% 0.55% 

Montana 0.54% 5.85% 

Nebraska 0.15% 0.99% 

Nevada 0.48% 6.19% 

New Hampshire 0.15% 4.90% 

New Jersey 0.70% 1.04% 

New Mexico 0.57% 1.87% 

New York 1.20% 6.89% 

North Carolina 0.60% 1.26% 

North Dakota 0.02% 0.22% 

Ohio 1.04% 3.20% 

Oklahoma 0.26% 0.70% 

Oregon 1.20% 7.72% 

Pennsylvania 0.91% 3.08% 

Rhode Island 2.00% 11.22% 

South Carolina 0.46% 1.12% 

South Dakota 0.13% 0.33% 

Tennessee 0.31% 1.76% 

Texas 0.20% 1.54% 

Utah 0.82% 6.70% 

Vermont 1.77% 15.44% 

Virginia 0.02% 0.30% 

Washington 1.00% 7.37% 

West Virginia 0.25% 0.20% 

Wisconsin 1.32% 6.61% 

Wyoming 0.17% 0.71% 

Navajo 0.00% 0.00% 

Ute 0.00% 0.00% 
22 

State 

Incremental Savings as a 

Percent of Retail Sales (%)

2013

Cumulative Savings as a 

Percent of Retail Sales (%)

2012

Fort Mojave 0.00% 0.00% 

Continental U.S. Total 0.66% 3.76%

Alaska 0.05% 0.15% 

Hawaii 0.04% 0.33% 

Puerto Rico 0.00% 0.00% 

Guam 0.00% 0.00% 

U.S. Total and Territories 0.66% 3.73%

Source: EPA calculation based EIA 2013 and EIA 2012a 

4.2.2.2 Projected Impacts 

In 2013, Lawrence Berkeley National Laboratory (LBNL) published an update to a 2009 

analysis and projected future spending levels and savings through 2025 from EE programs 

funded by electric and gas utility customers in the United States under three scenarios (high, 

medium, and low cases) (LBNL 2013c). The scenarios represent “a range of potential outcomes 

under the current policy environment” and were based on detailed, bottom-up analysis of 

existing state EE policies. Significantly, the study presumes no new major policy developments 

such as a “national EE standard, clean energy standard, or carbon policy” and specifies that such 

policy changes could “result in customer-funded EE program spending and savings that exceed 

the values in our High Case.” 

The study concludes that efficiency programs are “poised for dramatic growth over the 

course of the next 10 to 15 years” with the most significant increases occurring in regions with 

lower levels of program spending, historically, including the Midwest and South. For example, 

under the medium scenario total U.S. spending on electric efficiency programs increase by 40% 

to $8.1 billion in 2025 from 2012 levels. Under the high scenario, spending more than doubles 

from 2012 levels to $12.2 billion in 2025. Incremental savings levels grow commensurately, to 

0.8% and 1.1% of sales under the medium and high scenarios, respectively. The study results 

indicate that under the high scenario 20 states would be achieving 1.5% or higher levels of 

incremental savings, with 11 of those reaching or exceeding 2.0%.16 Table 5 summarizes the 

results of the LBNL analysis. 

                                                            

16 LBNL provided these unpublished results from their analysis. 

Commented [A23]: Best would be to cite the authors. Barbose

et al. (2013), and again, it would be much better to reference the

peer‐reviewed journal article than the LBNL paper.
23 

Table 5. Summary of Impacts: Scenarios of Future Utility 

Customer-Funded Electric EE Programs 

Case 

2025 

Incremental Savings (% of 

Sales) 

Program Costs 

(billions of $, nominal) 

Programs Costs 

(% of Revenues) 

Low 0.5% 5.5 1.1% 

Medium 0.8% 8.1 1.7% 

High 1.1% 12.2 2.7% 

Source: LBNL 2013c 

4.2.3 EE Potential 

4.2.3.1 Evaluations of EE Potential 

EE potential studies are a common tool for informing the development of EE program 

plans and budgets, as well as supporting the development of electricity savings targets, required 

savings levels under an EERS, or “all cost-effective” EE requirement. In conducting these 

studies, states and utilities have developed a methodology that is often described as a “bottomup, engineering-based” approach (EPA and DOE 2007a). EE potential studies are conducted at 

various geographic scopes (national, regional, state, and utility service territory level) and at 

different degrees of aggregation (e.g., economy-wide, sectoral, and program), and can be broadly 

grouped into a few types: technical, economic, market, and program.17

 Technical potential represents the theoretical maximum amount of energy use that 

could be displaced by efficiency, without regard to non-engineering constraints such 

as costs and the willingness of energy consumers to adopt the efficiency measures. It 

often assumes immediate implementation of all technologically feasible energy 

saving measures, with additional efficiency opportunities assumed as they arise. 

 Economic potential refers to the subset of the technical potential that is economically 

cost-effective. Definition of “economic potential” can vary to some degree by study. 

Some estimate economic potential by evaluating technology upfront cost, operating 

costs that considers energy prices, product lifetime and discount rate, compared to a 

conventional alternative or the supply-side energy resources. Others incorporate 

consideration of consumer preferences in addition to consumers’ out-of-pocket 

                                                            

17 The definitions discussed below largely follow that outlined in EPA and DOE 2007a. 
24 

expenditure when evaluating the economic potential. Both technical and economic 

potential estimates assume immediate implementation of efficiency measures without 

regard to technology adoption process or real-life program implementation. In 

addition, these estimates do not always reflect market failures or barriers that impede 

EE and often fail to capture transaction costs (e.g., administration, marketing, 

analysis, etc.) beyond the costs of efficiency measures. Another key factor 

determining economic potential is the level of aggregation at which the costeffectiveness evaluation is applied. Applying the cost test at lower levels of 

aggregation (e.g., at the measure or program level, rather than the sector level) will 

typically lead to lower economic potential when evaluating a portfolio of programs. 

 Market potential (or “achievable” potential) refers to the subset of economic 

potential that reflects the estimated amount of energy savings that can realistically be 

achieved, taking into account factors such as technology adoption process, market 

failures or barriers that inhibit technology adoption, transaction costs, consumer 

preferences, social and institutional constraints, and possibly the capability of 

programs and administrators to ramp up program activity over time. 

 Program potential refers to the subset of market potential that can be realized given 

specific program funding levels and designs. Program potential studies can consider 

scenarios ranging from a single program to a full portfolio of programs.18 

As mentioned, the EE industry standard for potential studies is the bottom-up, 

engineering evaluation of EE potential of individual end-use technologies and measures (EPA 

and DOE 2007a). Bottom-up analyses all employ a similar methodology but can vary 

significantly in key assumptions (e.g., breadth of sectors and end-uses considered, aggregation 

level at which cost tests are applied, study period, discount rate, pattern of technology 

penetration, whether economically justified early replacement of technologies is allowed for, and 

whether continued improvement in efficiency of technology is provided for). As a result, 

estimated efficiency potential can vary significantly among studies.19

                                                            

18 Each subsequent potential estimate described above is a subset of the previous potential estimate, e.g., the market potential is a 

subset of the economic potential, and the economic potential is a subset of the technical potential. 

19 Because of the complex consumer behavior, energy market and macroeconomic drivers of energy use and energy efficiency, 

and in some cases due to the lack of consistent data, quantifying energy efficiency potential and energy savings from policies and 
25 

4.2.3.2 Overview of Results 

EE potential studies have been conducted for decades and in recent years numerous 

studies have been conducted at utility, state, regional, and national levels. This section presents a 

summary of more than 50 recent studies (2009 through 2014) collected by EPA. Further detail on 

the collection of studies is provided in Appendix 1, including a database of study sources and 

results. Studies were identified by reviewing three recent meta-studies (Sreedharan 2013; 

ACEEE 2014b; and EPA 2014a) and supplementing those reviewed studies with more recent or 

overlooked studies. By focusing on studies conducted after 2008, the potentially significant 

effects of the lighting provisions of the Energy Independence and Security Act of 2007 

(Congress 2007) are accounted for. The collected studies cover all major end-use sectors 

(residential, commercial and industrial) and all regions of the U.S. 

To normalize results of analyses addressing different study periods, we present average 

annual achievable potential by dividing cumulative percentage savings in the last year of the 

study by the duration (in years) of the study period. This is a common method of normalization 

for EE potential studies and allows for comparison with results from the EPA’s demand-side EE 

plan scenario later in this chapter (section 8) (Sreedharan 2013; ACEEE 2008, 2014b). Many 

studies provided multiple estimates of achievable potential. Some studies use the terms “high,” 

“medium” and “low” achievable potential, while others used terms such as “high achievable” 

and “achievable” potential or, in some cases “achievable” and “programmatic” potential. For 

studies that provided multiple levels of achievable potential, the highest value was classified as 

high potential and the lowest value was classified as low potential. If a study provided just a 

single value, it was used as both the high and low potential value for that study. In many 

instances, low potential values in the studies were arrived at using assumptions of limited 

budgets or other limiting factors. To be conservative, the EPA has included these low values but 

generally consider the high achievable values to be the more appropriate point of comparison in 

evaluating the magnitude and timing of savings represented in the illustrative EE plan scenario. 

Table 6 provides summary results of EPA’s review of recent EE potential studies. Across 

all sectors for all studies, average annual achievable potential ranges from 0.9% to 1.3% per year 

for low to high potential estimates, respectively. Results vary between end-use sectors with the 

                                                            

programs remains a challenging analytical task. Assumptions about consumer technology adoption behavior, market barriers and 

failures, and how technology diffusion occurs can also affect estimated potential. 

Commented [A24]: There should be more discussion of the

NAS report here, for that is probably the most credible of all of the

studies listed in the spreadsheet.
26 

industrial sector showing less potential than residential and commercial sectors. Results for all 

sectors indicate very substantial opportunity for achievable EE savings. 

Table 6. Summary of EE Potential Studies (2009 to 2014)20

Sector 

Average Annual Achievable Potential (% per year) 

High Low 

Median Mean Median Mean 

Residential 1.0%/year 1.2%/year 0.7%/year 0.8%/year 

Commercial 1.3%/year 1.3%/year 0.8%/year 0.9%/year 

Industrial 0.9%/year 1.0%/year 0.5%/year 0.7%/year 

All 1.3%/year 1.2%/year 0.9%/year 0.9%/year 

Source: Appendix 1 

4.3 Costs and Cost-Effectiveness of State EE Policies 

4.3.1 EE Cost-Effectiveness 

States enact EE policies to meet multiple policy objectives including reduction of 

customer electricity bills, lower costs of meeting electricity supply needs, energy reduction, 

environment and health benefits, and local economic development benefits (EPA and DOE 

2006). Most states evaluate their EE policy options through the application of cost tests, 

weighing the projected benefits with the costs of the EE technologies and practices (EPA and 

DOE 2008; RAP 2012). Each state determines their own policies for the specific costs and 

benefits to include in these tests. The costs and benefits are compared on an equal footing by 

using present value analysis. This is necessary because EE typically requires primarily upfront 

expenditures (e.g., a whole home retrofit) while the economic benefits (e.g., electricity bill 

savings) accrue over the life of the investment (“measure life”) which can range from a few to 

twenty or more years. As such, the choice of discount rate and the estimation of measure life are 

significant determinants of the cost-effectiveness results. Most states employ multiple tests, 

adjusting cost and benefit categories depending upon the economic perspective of interest (e.g., 

utility, ratepayer, program participant, society), and consider the results from each one, usually 

with an identified primary test type. Policies that are selected are those that are found to be cost-

                                                            

20All 53 of the studies reported results for all sectors but many did not report results for one or more of the individual sectors. At 

least 30 studies reported results for each sector shown in the table. 
27 

effective, with benefits greater than costs, as determined by the utility applying methods defined 

by their state utility commission. 

There are five primary cost-effective tests used in the U.S.: 

1. Participant cost test from the perspective of the customer installing the measure. 

Costs may include incremental equipment and installation costs; benefits include 

incentive payments, bill savings, and applicable tax credits or incentives. 

2. Utility/program administrator cost test from the perspective of utility, government 

agency or third-party implementing the program. Costs may include program 

incentive, installation, and overhead costs; benefits may include avoided energy and 

capacity costs - including generation, transmission and distribution - by the utility. 

3. Ratepayer impact measure test from the perspective of utility ratepayers not 

participating in available EE programs. This text includes the costs and benefits that 

will affect utility rates, including program and administration costs, as well as “lost 

revenues” to the utility; benefits include avoided energy and capacity costs, and 

additional resource savings. 

4. Total resource cost test from the perspective of all utility customers in the service 

area. Costs may include the full incremental cost of the measure, program installation 

and overhead costs; benefits may include avoided energy and capacity costs, and 

additional resource savings. 

5. Societal cost test from the social perspective. In addition to benefits considered in 

total resource cost test, may also include non-monetized benefits such as 

environmental and health benefits. 

While many states consider more than one cost test in evaluating EE programs, the most 

commonly used (29 states) primary test is the total resources cost test. This test is considered to 

be the best measure of the interests of all utility customers. The utility and societal cost tests are 

the next most commonly used primary tests, used by five states each. The utility cost test is 

considered to be the most comparable metric to compare with supply-side resource investments 

from a utility resource planning perspective. 

Economic and modeling analyses of climate change policy suggests that EE presents a 

large potential in reducing greenhouse gas emissions and plays a critical role in offsetting the 
28 

costs and enhancing the flexibility to achieve long-term GHG reduction targets (Kriegler et al. 

2014; Kyle et al. 2011). Consistently, evaluations of the economic potential for carbon dioxide 

reductions from the United States’ power sector identify demand-side EE as the lowest cost 

strategy (typically, as noted above, with positive net present value) as well as the strategy having 

the greatest reduction potential (EPA and DOE 2009). For example, McKinsey and Co. (2007) 

found that EE accounted for more than 60% of their mid-range potential for greenhouse gas 

reductions from the U.S. power sector and that it was available at positive net present value if 

“persistent barriers to market efficiency” could be addressed. 

4.3.2 Costs of Saved Energy 

A common metric for comparing alternative electricity resource options within utility 

resource plans is the levelized cost of energy (LCOE) or, for EE resources, the levelized cost of 

saved energy (LCSE) (EPA and DOE 2007b). LCSE EE is often compared favorably with LCOE 

of alternative new generation sources such as fossil-fueled or nuclear power plants, or renewable 

energy resources like wind or solar-power generation. In these comparisons, typically only utility 

(or program) costs are considered, not the total costs of saved energy that are discussed later in 

this chapter. The EE analysis literature reports average LCSE in the range of 1-6 cents/kWh 

based on program administrator cost.21 A recent review by ACEEE examined studies across 20 

states between 2009 and 2012, and estimated LCSE for electricity EE programs in the range of 

1.3-5.6 cents/kWh, with a mean value of 2.8 cents/kWh (ACEEE 2014d). Earlier reviews of 

utility EE programs identified a similar range of LCSE. In 2009 ACEEE reviewed 14 utility 

studies of LCSE and found a range from 1.6 to 3.3 cents/kWh, with a mean value of 2.5 

cents/kWh (ACEEE 2009). An earlier ACEEE study reviewed cost-effectiveness analysis results 

in nine states and suggested that reported utility LCSE ranged between 2.3-4.4 cents/kWh, with a 

mean value of 3 cents/kWh (ACEEE 2004). In 2014, an LBNL analyzed the program cost of 

saved energy based on data from their DSM Program Impacts Database. The database includes 

program results reported to state regulators by more than 100 program administrators in 31 state, 

primarily for the years 2009-2011 (LBNL 2014b). LBNL found a national average LCSE of 2.1 

cents/kWh of gross savings. 

                                                            

21 Unless otherwise noted, estimates of LCSE discussed in this section refer to program administrator cost (also known as utility

cost). The discount rates, average measure lives, and other assumptions affecting the calculation of LCSE were not always 

consistent or reported in all studies. 

Commented [A25]: This seems to be redundant with above and

not entirely about cost‐effectiveness. Recommend removing.

Commented [A26]: Recommend mentioning negawatt here.
29 

The economic literature also evaluates the LCSE from EE measures using other 

techniques (e.g., econometrics, top-down modeling), although this body of studies is much 

smaller compared to the bottom-up, engineering-based analysis. The economic literature has 

varying treatment of the free ridership, EE program endogeneity, and the rebound effect. The 

different assumptions used in these analyses make direct comparison challenging, but overall 

these empirical analyses present a wider range of estimates of cost of saved energy. For example, 

a 2008 study in the Energy Journal examining utility DSM programs estimated the average 

utility cost of saved energy in the range of 5.1 to 14.6 cents per kWh (Auffhammer et al. 2008). 

Some other studies in the economic literature suggest estimated LCSE in a similar range as from 

the bottom-up analyses. RFF calculated an average cost of 3.4 cents per kWh saved from utility 

EE programs, based on the utility-reported estimated savings in the EIA Form 861 (RFF 2004). 

A 2012 econometric analysis of utility rate-payer funded demand-side management and EE 

programs between 1992 and 2006 found that the estimated energy savings in electricity 

consumption were achieved at an expected average cost to utilities of approximately 5 

cents/kWh (Arimura et al. 2012). In 2011, using a top-down approach that evaluates the savings 

potential of EE investments using state- and region-specific price elasticity, an RFF study 

estimated that electricity savings of 1 to 3 percent were available at a marginal cost of 5 

cents/kWh and a corresponding average cost of 2.5-3.5 cents/kWh (RFF 2011). 

A number of analytical and data considerations related to LCSE estimation are also 

discussed in the literature, including the issue of “free riders” in EE programs, and the accuracy 

of utility reported costs and energy savings (Train 1994; Joskow and Marron 1992). EE 

practitioners also recognize the need to consider “free rider” and “spillover” effects in program 

evaluation. A slight majority of states adjust for free ridership in energy savings estimates, 

leading to higher LCSE values than otherwise would be the case (ACEEE 2012a). A smaller 

number of states adjust for spillover effects which reduce LCSE values when addressed. 

Another consideration related to LCSE estimation is the rebound effect. The economic 

literature has extensive discussion of the potential rebound effect, market interactions and 

economy-wide response of EE policies and investments. An improvement in EE would 

effectively reduce the cost of a service or production input, potentially boosting its demand or 

production output thus increasing energy use (“direct” rebound). In addition, money saved from 

EE can be used for consumption or investment that can increase energy consumption for other 

Commented [A27]: So does the literature that LBNL and ACEEE

review above! Bottom‐up, engineering analyses also need to make

assumptions about free‐riders, free‐drivers, and the rebound effect.

These also haven’t been defined yet. Maybe remove the sentence?

Deleted: estimated 

Commented [A28]: This paper (my own) should be cited as:

Gillingham, Newell, and Palmer (2006) Energy Efficiency Policies: A

Retrospective Examination, Annual Review of Environment and

Resources, Vol. 31: 161‐192

http://www.annualreviews.org/doi/abs/10.1146/annurev.energy.3

1.020105.100157?journalCode=energy

Commented [A29]: Paul et al. (2011)

Commented [A30]: You can cite Gillingham et al. (2006) for this

as well.

Deleted: 

Deleted: in other markets of the economy
30 

goods and services in the economy (two forms of “indirect” rebound). Reviews suggest that both 

direct and indirect rebound effects exist and the size of such effects varies among different 

studies, technologies, sectors and income groups (UKERC 2007). Overall, however, rebound 

effects are found to be relatively modest in most markets and settings (Greening et al. 2000; 

Davis 2008; Gillingham et al. 2013; UKERC 2007). 

5. Other EE Strategies 

In addition to ratepayer-funded EE programs, many other strategies are available to 

increase investment in EE and realize associated energy savings, emissions reductions and other 

benefits. In this section we address a few of the more significant opportunities for realizing 

additional EE potential: building energy codes, state appliance standards, energy service 

performance contracting, and volt/VAR optimization. 

5.1 Building Energy Codes 

5.1.1 Overview 

Building energy codes establish minimum efficiency requirements for new and renovated 

residential and commercial buildings. Building energy codes lock in long-term energy savings at 

a low cost during the building design and construction phase; some of which would not be 

feasible or cost-effective as building retrofits. The primary policy rationale for energy codes is 

the need to overcome large and persistent market barriers, the largest of which is the concern 

over split-incentives or “principal-agents,” in which builders’ incentives to minimize the initial 

costs of constructing a building are misaligned with occupants’ incentives to minimize total 

occupancy costs. Building energy codes are designed to eliminate inefficient technologies and 

building practices, minimizing total ownership and operating costs over the life of the building. 

Additional co-benefits of implementing building energy codes include pollution prevention, 

improved electric system reliability, avoidance of new energy supply investment, and improved 

occupant comfort and health. Energy building code requirements are also designed to overcome 

the complexity of advanced codes, lack of local-level implementation resources, and a shortage 

of empirical data on the costs and benefits of codes. 

Deleted: and lower

Deleted: energy prices as a result of EE improvement may 

increase energy consumption 

Commented [A32]: Lower energy prices are not a type of

indirect rebound.

Commented [A33]: This should be referenced as Sorrell et al.

(2007)

Deleted: compared to the importance of EE as an effective way of 

reducing energy consumption and carbon emissions

Deleted: 

Commented [A35]: The second part of this sentence is not at

all justified based on the four references (one of which is mine). To

be correct, just cut the sentence in half.
31 

Building energy codes specify thermal performance22 criteria for building thermal 

envelope components such as walls, ceilings, floors, and windows, and also set air leakage and 

duct leakage standards. They also address lighting system efficiency, hot water system 

efficiency, and heating and cooling equipment efficiency in cases where federal standards do not 

cover the affected equipment or system types. For the residential sector, the International Energy 

Conservation Code (IECC) is the prevailing model code, and ASHRAE 90.1 is the model code 

for the commercial sector (EPA 2014b). Various versions of these model codes are adopted and 

enforced at the state and local government levels. 

5.1.2 Authority / Obligated Parties 

Model energy building codes are typically developed at the national or international 

level, adopted at the state or local level, and administered and enforced locally. Local building 

industry parties, such as developers and property owners requiring building permits, are the most 

common obligated parties (EPA 2014b). Federal authority affecting state code adoption was 

established in the Energy Policy Act of 1992 (EPAct 1992); its provisions require the U.S. 

Department of Energy to review each new version of the IECC and ASHRAE 90.1, released 

about every three years, to determine whether they save energy compared to the previous version 

(EPA 2015). When DOE concludes that a new version of the code would improve energy 

efficiency, states must review and consider adopting the new code. However, since EPAct 1992, 

not all states have adopted or updated residential and commercial building energy codes per the 

current DOE determination. 

5.1.3 Building Code Regulations Over Time 

Federal authority for building codes was established in Energy Conservation and 

Production Act of 1976 (ECPA), which authorized DOE to create national Building Energy 

Performance Standards (BEPS) that would be legally binding nationwide. The BEPS provision 

was repealed by Congress in the early 1980s. States, however, continued to develop energy 

codes. In 1978, California became the first state to include energy requirements in its code (EPA 

2015). Other states, such as New York, Massachusetts, Florida, and Minnesota, developed their 

own energy codes during the 1980s. 

                                                            

22 The thermal performance of a building refers to how well the temperature of a building is insulated from the outside 

environment. 
32 

In response to the EPAct 1992 requirements, most states adopted various versions of the 

IECC and ASHRAE 90.1. Over the last decade, the number of states adopting residential and 

commercial energy codes has remained relatively stable at about 40 (EPA 2006, 2015). Figure 2 

shows this consistency for residential energy codes, as the states with the lightest shading are the 

ones that had either not adopted or recently updated their energy codes. However, the stringency 

of these codes has been updated multiple times since 2005 in most states. Eleven of the 40 states 

with residential building codes are using the 2012 IECC version, which DOE has determined 

would improve the energy efficiency of residential buildings by approximately 30 percent 

compared to the 2006 IECC (EPA 2015). A recent study estimated that upgrading the energy 

efficiency of a typical new home in Arizona from the 2006 IECC would save homeowners an 

average of $3,245 over 30 years with the 2009 IECC and $6,550 over 30 years with the 2012 

IECC (DOE 2012b). DOE estimates that currently-adopted building energy codes across the 

country will result in a financial benefit of nearly $2 billion annually by 2015 and over $15 

billion annually by 2030 (DOE 2014). Commented [A36]: Rather than citing these DOE numbers, we

would be much better off citing these two papers by Kotchen:

http://environment.yale.edu/kotchen/pubs/codes.pdf

http://environment.yale.edu/kotchen/wpapers/Codes2.pdf
33 

Figure 2. Residential Energy Building Code Adoption (2005 to 2014) 

Source: EPA 2006 and EPA 2015 

5.1.4 Remaining Market Potential 

There is still significant potential for savings from building energy code adoption. From 

1992 to 2012, building energy codes in the U.S. saved a cumulative 4 quadrillion Btu and 

reduced greenhouse gas emissions by 300 million metric tons. From 2013 to 2040, the continued 

adoption of increasingly stringent building energy codes in the U.S. is expected to save 40.1 

quadrillion Btu (ACEEE 2015a). A recent study by ACEEE also found that for residential and 

commercial building codes, the potential for energy savings by 2030 was 155 million megawatthours (MWh) annually, or 4.2 percent of annual electricity consumption relative to 2012 

(ACEEE 2014a). 

Commented [A37]: Is this technical potential? Economic

potential? Achievable potential?  

Commented [A38]: What type of potential do we mean here?
34 

5.2 State Appliance Standards 

5.2.1 Overview 

State appliance standards establish minimum energy efficiency levels for those 

appliances and other energy-consuming products that are not already covered by the federal 

government. These standards typically prohibit the sale of less efficient models within a state. A 

few states, such as California, are often implementing tighter standards on appliances than the 

federal standard, or standards on new product categories, although these standards are usually

superseded eventually by federal standards(EPA 2014b). 

The key objectives of appliance efficiency standards are to: 

 Raise the efficiency of a range of residential and commercial energy-consuming 

products, where cost-effective. 

 Overcome market barriers, such as split incentives between homebuilders and 

homebuyers and between landlords and tenants, and panic-purchase23 situations in 

which appliances break and must be replaced on an emergency basis. 

 Ensure energy use reductions to prevent criteria air pollution and greenhouse 

emissions, improve electric system reliability, and reduce consumer energy bills 

(EPA 2015). 

While state appliance standards can be useful in testing and exploring the effectiveness of 

standards for new products, many state appliance standards have been preempted or superseded 

by existing federal standards. States may apply to DOE for a waiver to implement more stringent 

standards. This is sometimes granted if a certain period of time has passed since the federal 

standard has been updated (EPA 2014b). 

5.2.2 Authority / Obligated Parties 

Establishing efficiency standards in a state typically requires enabling legislation from 

the state legislature. However, once legislation is enacted, it may allow an executive agency to 

set further standards administratively (EPA 2015). 

                                                            

23 In a panic purchase, customers usually do not have the time to consider a range of models, features, and efficiency levels, and 

the full range may not be available from all suppliers. 

Deleted: States

Deleted: finding that appliance standards offer a cost-effective 

strategy for improving energy efficiency and lowering

Deleted: energy costs for businesses and consumers

Commented [A40]: I don’t think the states have done analyses

of their state‐level standards, so I’m not sure that we can say

anything about how cost‐effective they are. I looked at the EPA

2014 document and didn’t see any evidence about actual cost‐

effectiveness.

Deleted: when 

Deleted: are enacted for new product categories 

Commented [A41]: Redundant with above?
35 

State energy offices, which typically administer the federal state energy program funds, 

have generally acted as the administrative lead for implementing standards. In contrast, 

inspection and enforcement of appliance standards regulations has typically involved selfpolicing among industry. Manufacturers of products being sold in a given state are typically 

obligated to ensure their appliances meet the appropriate energy efficiency standards (EPA 

2014b). 

5.2.3 Appliance Standards over Time 

California’s appliance standards program dates to the 1970s, when the state began to 

pursue standards before the enactment of federal legislation. When the federal government opted 

not to issue standards under its legislative mandate in 1982, other states joined California in 

developing state standards. These state initiatives helped create the impetus for new federal 

legislation in 1987 (the National Appliance Energy Conservation Act or NAECA), the Energy 

Policy Acts (EPAct) in 1992 and 2005, and the Energy Independence and Security Act (EISA) in 

2007 (EPA 2015). 

While the NAECA effectively preempted state action on federally covered consumer 

products, California has continued to develop efficiency standards for other products and 

technologies that aren’t included in the Act. California’s standards program has contributed to 

substantial improvements in energy efficiency. Since its inception, the program has saved 

consumers over $75 billion on electricity bills (CEC 2013).

Since 2001, 15 states and the District of Columbia have enacted appliance efficiency 

standards. While most of these individual standards have been superseded by federal standards, 

as of February 2014, 12 states25 and the District of Columbia have one or more appliance 

efficiency standards for products not covered by federal standards (ASAP 2014). 

5.2.4 Remaining Market Potential 

While federal appliance standards continue to expand, the direct economic and 

environmental benefits of state standards are still substantial. California draft regulations for 15 

new appliance standards are expected to save 50 billion gallons of water, 1,400 MW of peak 

                                                            

25 These states include Arizona, California, Connecticut, Georgia, Maryland, Nevada, New Hampshire, New York, Oregon, 

Rhode Island, Texas, and Washington. 

Deleted: These federal laws have established appliance efficiency 

standards for more than 50 products, representing about 90% of 

home energy use, 60% of commercial building energy use, and 

about 30% of industrial energy use (DOE 2015a). Bolstered by new 

standards contained in the EPAct 2005, EISA 2007, and additional 

DOE rules,24 these savings rose to 278 terawatt-hours (TWh), or 7 % 

of U.S. electricity use in 2010. By 2025, total electricity savings 

from existing federal standards are projected to increase to 682 TWh 

per year, or 14% of the projected annual U.S. electricity use. Net 

savings to consumers and businesses are also expected to increase 

from $27 billion in 2010 to $61 billion in 2025 (ASAP 2012).

Commented [A43]: Wait, all of these numbers are about the

federal standards. Aren’t they out of place? Remove?
36 

electricity, 9.8 TWh of electricity, and 162 million therms of natural gas per year. This is 

expected to result in annual savings of $2 billion (CEC 2014). 

From a national perspective, there is still untapped potential for states to move into 

product areas not yet covered by federal standards. Table 7 shows potential energy savings from 

products that do not currently have federal standards. The three products with the greatest 

potential in the residential, commercial and industrial, and lighting sectors are shown, along with 

a summary line for each sector. Some of the greatest potential savings in 2035 are in the 

residential sector, specifically improvements in water heater efficiency. Implementing all of 

these standards through federal regulations would result in annual savings of 212 TWh in 2025, 

or 5% of projected national electricity consumption (ASAP 2012; EIA 2015). 

Table 7. Estimated Energy Savings Potential of State Appliance Standards 

Annual savings in 2025 Annual savings in 2035 

Electricity 

savings 

Peak 

demand Natural gas Electricity savings 

Peak 

demand 

Natural 

gas 

Products (TWh) (GW) (Tbtu) (TWh) (GW) (Tbtu) 

RESIDENTIAL STANDARDS

Water heaters 18.2 2.5 — 43.0 5.9 — 

Set top boxes and digital 

communication equipment 14.7 2.0 — 14.7 2.0 — 

Air handlers 13.7 5.6 — 29.1 11.9 — 

Total (14 products) 98.5 16.8 51.6 142.3 27.0 51.6 

COMMERCIAL AND INDUSTRIAL STANDARDS

Walk-in coolers and freezers 14.7 3.4 — 14.7 3.4 — 

Distribution transformers 10.9 1.5 — 22.4 3.1 — 

Electric motors 9.0 1.4 — 18.6 2.9 — 

Total (13 products) 62.4 15.5 74.2 98.5 24.5 139.9 

LIGHTING STANDARDS

Incandescent reflector lamps 20.2 5.0 — 20.2 5.0 — 

Outdoor lighting fixtures 10.3 0.7 — 26.1 1.8 — 

General service fluorescent 

lamps 6.9 1.7 — 6.9 1.7 — 

Total (7 products) 50.8 9.3 — 65.6 15.6 — 

ALL PRODUCTS 212 42 126 306 67 235 

Source: ASAP 2012 
37 

5.3 Energy Service Performance Contracting 

5.3.1 Overview 

Energy service performance contracting (ESPC) uses cost savings from reduced energy 

consumption to repay the cost of installing energy conservation measures (HUD 2014). Under an 

EPC program, an Energy Service Company (ESCO) first conducts an energy audit. The ESCO 

then designs and constructs a project that achieves the building owner’s energy efficiency needs 

and arranges for the project’s financing, usually through a third party. The third party is repaid 

by the building owner/operator from the savings in their energy costs. In this type of ESPC 

arrangement, the builder owner/operator does not need to incur upfront expenses, and will 

experience the benefits of the upgrades, including monetary savings once the financer’s costs 

have been repaid (ICF 2007). 

ESPC programs have been used extensively by state, federal, and local facilities to reduce 

utility and operating costs and to help meet environmental and energy efficiency goals, which 

can include the use of combined heat and power (CHP). Forty-nine states have implemented 

performance contracting activities, primarily through legislation, covering a combination of 

entities that include public agencies, school districts, municipalities, state colleges and 

universities, counties, or the state as a whole (ORNL 2015).26 While ESPC programs are already 

widespread, states have found that they can further utilize this approach by extending eligibility 

to all public facilities in the state (EPA 2015). 

While ESCOs deliver ESPC projects, and the ESPC market is the main driver for ESCOs, 

the two markets do not overlap completely. Since 2006, the share of the ESCO market consisting 

of ESPC projects has remained stable at about 70 percent (ICF 2007; LBNL 2014a). The other 

30 percent of the market is comprised of design/build services; engineering, procurement, and 

construction services; consulting services; and operation and maintenance contracts. These 

services are not considered to be EPC projects since the project financial performance risk is not 

incurred by the ESCO or potential third party lenders (ICF 2007). 

                                                            

26 Wyoming currently has no performance contracting legislation. 
38 

5.3.2 History of ESPC Programs and the ESCO Business Model 

The ESCO business model emerged during the 1970s, supported in part by utilities 

paying ESCOs a fee for services such as energy audits provided to customers via their electric 

utilities and implementing federal energy management goals (NAESCO 2011). EPC activities 

emerged in the mid-1980s as power plants became more expensive to build and utilities were 

ordered to produce Integrated Resource Plans (IRPs) where energy efficiency measures could be 

used to meet projected demand. ESCOs were used to deliver energy savings from projects 

implemented at industrial and institutional sites, relying on advances in energy efficiency 

monitoring and verification techniques (ICF 2007). 

By the late 1990s, funding for utility-sponsored energy efficiency programs was reduced 

in about half of the states due to changed regulatory structures and increased political and 

regulatory pressures to maintain lower electricity prices (EPA 2006). Many restructured electric 

utilities shifted their focus away from sponsoring programs to starting new affiliated ESCOs to 

deliver energy services directly to customers. However, the business model for these marketbased ESCOs was limited in reach to mainly larger industrial, commercial and institutional 

customers. Several states and local governments also turned to EPC activities to provide services 

in public facilities via lead-by-example policies (see section 3). These governments also saw the 

benefits of addressing capital equipment and maintenance projects that would not have otherwise 

been addressed through the capital budget process (ICF 2007). Commercial lenders also became 

involved in EPC funding, lowering the cost of projects through competition and paving the way 

for new financing vehicles (ICF 2007). 

During the early 2000s, however, the growth of the EPC and ESCO market declined due 

to loss of both performance contracting in federal buildings and market confidence for industrial 

financing mechanisms (NAESCO 2011). This trend reversed in 2005 as the EPC and ESCO 

market increased focus on state and local public buildings and innovated program offerings to 

provide customers new technologies and financial models (see section 3 and ICF 2007). 

5.3.3 Remaining Market Potential 

The market potential for EPC programs and ESCOs remain significant. Annual revenues 

for the U.S. ESCO market was expected to increase from $5.3 billion in 2011 to about $6.4 

billion in 2013 (LBNL 2014a). An analysis by Lawrence Berkeley National Lab estimated the Commented [A44]: Cite the authors
39 

investment opportunity for ESCOs ranged between $71 billion and $133 billion (LBNL 2013a). 

Figure 3 shows a breakdown of investment opportunity by market segment. Commercial 

buildings, K-12 schools, and the health and hospital sectors have the highest remaining potential 

for ESCOs. Commercial buildings in particular have high barriers to implementing energy 

efficiency under EPC activities, as the private sector is generally averse to financing energy 

efficiency activities and has more stringent requirements for a lower payback period on projects 

(LBNL 2013a). While the two markets do not overlap completely, the potential for ESCO 

investments provide a strong indicator for the remaining potential of EPC activities. 

Figure 3. Remaining Market Potential for ESCOs 

Source: LBNL 2013a 

Commented [A45]: Cite the authors
40 

5.4 Volt/VAR Optimization 

5.4.1 Overview 

Volt/VAR optimization (VVO) refers to coordinated efforts by utilities to manage and 

improve the delivery of real and reactive power27 in order to increase the efficiency of electricity 

distribution. VVO is accomplished primarily through the implementation of Smart Grid 

technologies that improve the real-time response to the demand for real and reactive power. 

Technologies for VVO include load tap changers and voltage regulators, which can help manage 

voltage levels, as well as capacitor banks, which allow for the delivery of reactive power. By 

using local capacitor banks to respond to reactive power demand, rather than adjusting the output 

of remote generators, systems can achieve reductions in transmission line loss. The U.S. Energy 

Information Administration (EIA) estimates that on average, 7.5% of generated electricity is lost 

in transmission and distribution, a number that could be reduced by effective use of VVO (EIA 

2012b). 

VVO efforts are often closely related to conservation voltage reduction (CVR), which are 

actions taken to reduce initial delivered voltage levels in feeder transmission lines while 

remaining within the 114 volt to 126 volt range required at the customer meter (based on ANSI 

C84.1 standards). Like VVO, CVR relies on the use of Smart Grid technologies in order to more 

effectively manage voltage levels across all loads in a system. A simple presentation of these 

benefits are shown in Figure 4, where the implementation of VVO technologies allows electricity 

distributors to deliver electricity initially at a lower voltage, thus decreasing the generation fuel 

requirements, while still delivering within the acceptable range to all 7 loads. The combination of 

VVO and CVR can lead to a range of benefits, including reductions in peak electricity demand, 

reductions in energy requirements necessary to meet a certain level of demand, and a reduction 

in line loss. 

                                                            

27 Reactive power is experienced in alternating current systems, and is the result of a phase shift between the current and voltage. 

Reactive power does no work on resistive loads, but is necessary for circuits that include magnetic loads, most notably motors. It 

is measured in Volt-Ampere Reactive (VAR). 
41 

Figure 4. Hypothetical Voltage Profiles with and without VVO Technologies 

Source: DOE 2011 

5.4.2 History of VVO Programs 

VVO and CVR efforts were first introduced with partial implementation in California in 

1977 (UNLV 2014). In 1987, the Snohomish Public Utility District instituted a pilot CVR project 

that demonstrated the possibility of reducing voltage and energy requirements by approximately 

2.1% (NRECA 2013). More recently, the advent of Smart Grid technology with increased 

availability of energy use data, has led to a renewed interest in VVO and CVR as the potential 

for increased efficiency has become more apparent. Of the 99 projects funded by the Smart Grid 

Investment Grant program under the American Recovery and Reinvestment Act of 2009, 26 
42 

included the implementation of VVO technologies. These projects, which target reduced voltage 

during peak demand, electricity conservation due to reduced voltage, and reduced losses from 

feeder lines, are expected to achieve a 1% reduction in energy consumption for every 1% 

reduction in voltage level (DOE 2012a). 

There is no formal state requirement directing implementation of Volt/VAR optimization. 

However, in 2012, the National Association of Regulatory Utility Commissioners published a 

resolution in support of VVO implementation at the state-level. The resolution encouraged 

public utility commissions to work with state legislature to include deployment of VVO 

technologies as part of energy efficiency resource standards (NARUC 2012). 

5.4.3 VVO Market Potential 

Large market potential currently exists for the implementation of VVO. The Pacific 

Northwest National Laboratory estimates that implementing VVO nationwide could potentially 

yield as much as a 3.2% annual reduction in energy consumption (PNNL 2012). The Bonneville 

Power Administration estimates that the cost-benefit ratio for transmission and distribution 

optimization is positive and well understood, and that CVR is a key component of these positive 

effects (BPA n.d.). McKinsey estimates that VVO could provide $43 billion in gross annual 

benefits in 2019 in the U.S., with CVR comprising the largest share of these benefits (McKinsey 

2010). IHS Technology estimates that the shipments of VVO technology devices will double 

between 2013 and 2018, with a quadrupling of revenue over the same time period (IHS 2013). 

The Institute of Electrical and Electronics Engineers estimates that CVR has the potential to save 

approximately 750 trillion BTUs of electricity, equivalent to 5.4% of total U.S. electricity 

generation, at a total cost of $3.3 billion dollars (IEEE 2014). While these estimates vary in level 

of impact, they display the strong market potential that exists for VVO projects. 

6. Utility Regulatory Models for Supporting Demand-Side EE 

The electricity sector widely recognizes that state utility regulatory models for supporting 

energy efficiency are key to expanding utility investments and higher energy savings from 

programs (IEI 2014). Further, all states which regulate investor-owned utilities have adopted or 

modified one or more policies in order to better align utility incentives with the delivery of costeffective energy efficiency (IEI 2014). States with the highest per capita spending on energy 

Commented [A46]: We may want to be even more explicit that

these programs are very much in the fledgling stage.
43 

efficiency programs have the most comprehensive regulatory models for energy efficiency in 

place (NRDC 2012). 

The most common regulatory models for incentivizing energy efficiency through electric 

utilities include decoupling revenue from sales volumes, ensuring program cost recovery, and 

providing shareholder incentives linked to program performance. The Edison Foundation reports 

on the adoption of these policies across states through its Institute for Electric Innovation, as 

shown in Table 8. 

Table 8. Summary of State Regulatory Frameworks: December 2014

Energy Efficiency Incentive Mechanism Number of States Pending 

Fixed-Cost Recovery 

Mechanisms 

Lost Revenue Recovery 19 0 

Revenue Decoupling 14 1 

Performance Incentives 29 2 

Program Cost Recovery 46 0 

Source: IEI 2014 

These approaches have been widely used for over a decade, with performance incentives 

approved by Connecticut as early as 1988 (IEI 2014). In 2006, the need for such policies was 

recognized by the National Action Plan for Energy Efficiency Leadership Group of gas and 

electric utilities, state agencies, energy consumers, energy service providers, environmental 

groups, and energy efficiency organizations. Over 100 states, utilities, and key stakeholders 

across 49 states made aggressive commitments to energy efficiency under the Action Plan and 

endorsed the Action Plan five key policy recommendations which included modifying utility 

incentives (EPA 2006). In 2014, the Edison Electric Institute (EEI) and the Natural Resources 

Defense Council (NRDC) issued a joint statement urging state utility regulators to adopt a 

number of policies to sustain utility financial health given the greater investment being made in 

both energy efficiency and customer-sited electricity generation (NRDC 2014). 

The need for states to adopt utility financial incentive policies is due in part to how 

traditional ratemaking allows utilities to recovery costs based on the volume of electricity sold. 

This creates an incentive to maximize the volume of sales (often referred to as the “throughput 

incentive”), which in turn creates a disincentive to invest in energy efficiency since such 

programs will reduce sales volume. A decoupling policy counteracts the financial incentive to 
44 

increase sales by fixing a utility’s revenue for a specific term, in order to match the amount of 

anticipated costs incurred plus an appropriate profit. If the utility can reduce its costs during the 

term through energy efficiency, the utility will be able to increase its profits. Alternately, lost 

revenue adjustment mechanisms may be used to diminish the throughput incentive by allowing 

utilities to directly recover the lost revenue associated with not selling energy due to energy 

efficiency programs. 

Reduced electricity sales may affect utility finances in additional ways, including 

reducing the utility’s opportunity to earn additional profit from the regulated rate of return on 

new capital projects which would otherwise be needed to meet higher load growth, such as new 

generators and transformers upgrades. As an alternative, performance incentive policies are used 

to allow utilities to earn a profit for achieving high levels of energy savings, recognizing that 

multiple benefits of energy efficiency resources that are not otherwise explicitly accounted for in 

traditional regulatory models. Performance incentive policies come in different forms, such as 

earning bonuses and allowing a utility to earn a higher rate of return on capital invested in energy 

efficiency. 

The level of capital investment made by a utility is often informed by electricity resource 

planning. Most states require one or more forms of electricity resource planning, such processes 

used to inform long-term integrated resources plans (IRPs) and regulatory approvals for large 

projects often referred to as Certificates of Public Convenience and Necessity (CPCNs). IRPs 

are required or present in more than 30 states, including most vertically integrated states, and at 

least 19 states have some form of CPCN (EPA 2015). Incorporating energy efficiency into 

electricity resource planning enables the utility to consider a broad range of electricity resource 

options and avoid capital investment in more expensive electricity supply or delivery 

infrastructure. 

Due to the shifts in long-term incentives from regulators, utilities are also increasing 

seeing energy efficiency as part of their business model. According to a 2015 survey of utility 

executives, 71% of utilities are developing new business models for energy efficiency and 

demand response (UtilityDIVE 2015). A significant number of the utilities surveyed see their 

business model changing from a traditional vertically integrated utility, to an energy services or 

smart integrator businesses model. Further, states such as New York and Hawaii have initiated 

Deleted: U
45 

actions at their public utility commissions to examine and encourage changes to the utility 

business model.28 Both of these state are experiencing growth in distributed electricity generation 

and can build upon their existing energy efficiency regulatory frameworks which include energy 

efficiency program cost recovery, decoupling, and performance incentives. 

7. Energy Efficiency Certificates 

In the U.S., extensive consideration of tradable energy efficiency credits (EEC) 

developed almost a decade ago, most often framed as a potential compliance mechanism for state 

energy efficiency resource standards (EERS), a widely adopted and effective policy mechanism 

for achieving cost-effective electricity savings through utility energy efficiency programs.29 State 

EERS as a key policy strategy and the use of EECs for compliance were concepts borrowed from 

the earlier adoption of renewable portfolio standards (RPS) and the use of renewable energy 

credits (RECs) for compliance. 

Building from the successful experience with EERS/RECs, several significant policy 

papers discussed how the generation, tracking, and trading of energy efficiency credits could 

work as a means for supporting compliance with EERS or as a mechanism for achieving 

greenhouse gas reductions (NREL 2008; CRS 2007; IEA 2012a). A few states put regulations in 

place that allowed for the use of EECs for EERS or RPS compliance.30 Consistent with these 

developments, several of the regional tracking systems developed to support the use of RECs for 

compliance with state RPS also included a capability to perform the same functions for the use of 

EECs for potential compliance with state policies.31 However, these capabilities have yet to be 

widely used as significant levels of EEC transactions have not developed in the U.S. 

There are, however, some voluntary markets for energy savings credits. For example, 

North American Renewable Registry extended its certificate tracking system to energy 

efficiency, and registered the first voluntary energy efficiency certificates for IBM Corporation 

                                                            

28 For more information, see the New York Reforming Energy Vision proceeding 

(http://www3.dps.ny.gov/W/PSCWeb.nsf/All/26BE8A93967E604785257CC40066B91A?OpenDocument) and Summary from 

Hawaii PUC of the Commissions Inclinations on the Future of Hawaii’s Electric Utilities (http://puc.hawaii.gov/wpcontent/uploads/2014/04/Commissions-Inclinations.pdf). 29 Many terms have been used or suggested including energy efficiency certificates, energy savings certificates, white tags, and 

white certificates. 

30 These states include Connecticut, Michigan, and North Carolina. 

31 NEPOOL Generation Information System issues energy efficiency certificates for CT. PJM Generation Attribute Tracking 

System issues energy efficiency certificates for PA. NC Renewable Energy Tracking System allows energy efficiency to count 

towards compliance with the NC RPS. 
46 

in March 2010 (NARR 2010). Sterling Planet, a retailer of RECs and carbon offsets, also offers 

White Tags® trading instruments that recognize the meter-measured, performance-based results 

of energy efficiency projects. In June 2012, Sterling Planet completed the first White Tags 

transaction by purchasing Michigan’s Selfridge Air National Guard Base’s 2011 White Tags in 

order to fulfill energy efficiency compliance requirements for a Michigan utility (Sterling Planet 

2012). The Climate Registry has a program called “Cool Planet Energy Efficiency” which 

provides assistance to utility company business customers with measuring and managing their 

energy and carbon outputs (TCR 2015).

Even though experience with EECs in the U.S. is limited, their use internationally has 

been significant. Nine energy efficiency policies across seven countries outside of the United 

States allow for trading of the energy savings used for compliance (IEA 2012a). Trading has 

been incorporated in the design of these policies to help identify cost-effective opportunities 

from a broader pool of participating projects and parties. Table 9 summarizes the types of 

energy savings and trading included in policy design. Over half of these policies allow for 

trading through the creation and sale of EECs. 
47 

Table 9. International Examples of Trading Energy Savings 

Country (Jurisdiction) Eligible Energy savings Type of Trading 

Australia 

(New South Wales) 

Preapproved projects implemented by 

obligated and accredited nonobligated parties 

EECs 

Australia 

(South Australia) 

Activities undertaken by, or on behalf 

of, obligated energy retailer 

Limited transfer of credits among 

obligated parties 

Australia 

(Victoria) 

Installation of preapproved energy 

efficiency products by obligated and 

accredited non-obligated parties 

EECs 

China 

Achieved by grid companies and 

energy service companies subsidiaries 

of grid companies 

Obligated parties may purchase 

savings from customers and ESCOs 

under bilateral contracts 

Denmark 

Distributors must engage third parties 

to achieve energy savings across 

energy types 

Energy savings may only be traded 

among obligated energy distributors 

France 

Produced by obligated parties, local 

authorities, and social housing 

landlords 

Over-the-counter trading of EECs 

Italy Produced by obligated distributors ad 

accredited energy service providers 

Over-the-counter and spot market 

trading of EECs 

Poland Projects selected through annual 

auctions 

EECs fully tradable on the Polish 

Power Exchange 

United Kingdom Projects implemented by obligated 

parties or their contractors 

Transfers of emissions reductions 

and trading of obligations allowed 

among obligated parties 

Source: IEA 2012a 

Two good international examples are provided by programs in Italy and in Australia 

(New South Wales) that have been trading EECs successfully and at significant scale over the 

past decade (Pavan 2008; NSW 2015). Italy uses EECs as part of its White Certificates system, a 

key policy supporting their international climate commitments (Italy 2014). In implementing this 

policy, electricity and gas distribution utilities use EECs to meet established energy savings 

targets. These utilities may either generate their own EECs or buy from third parties through the 

market. Approximately one-third of EECs are generated by third parties and subsequently trade 

on the open market. EECs are also exchanged between energy efficiency providers and utilities 

through bilateral contracts.32 The majority of energy savings from the Italian White Certificates 

system are realized from reducing electricity usage through a set of pre-established eligible 

project types (IEA 2012a). 

                                                            

32 From 2005-2009, electricity savings met 77% of the overall energy savings targets, as reported in The Fifth National 

Communication under the UN Framework Convention on Climate Change, submitted by Italy in November 2009. 
48 

In Australia, the state of New South Wales initially incorporated EEC trading as part of 

their Greenhouse Gas Emissions Trading scheme. In 2009, New South Wales began trading 

EECs via the Energy Savings Scheme recognizing that unique barriers to energy efficiency 

persisted. Obligated parties, which include electric utilities, are required to acquire and surrender 

EECs to meet the energy savings targets of the Energy Savings Scheme. Other organizations also 

use EECs to voluntarily reduce their greenhouse gas emissions. Energy efficiency projects across 

residential, commercial and industrial sectors are used to create EECs in New South Wales. 

Active trading of EECs also exists in New South Wales. Trading markets have been 

established by the private sector with some organizations, such as the Australian Financial 

Markets Association and individual brokers of environmental commodities, providing regular 

updates on EEC wholesale market prices (NSW 2015). Even though most EECs are traded via 

bilateral contracts, trading of EECs has also developed across spot, forward, and options 

contracts. Since any party who is an “Accredited Certificate Provider” may create EECs, the 

Energy Savings Scheme policy has fostered the development of a robust energy services industry 

of firms implementing energy efficiency projects supported in part by revenues from the sale of 

associated EECs. 

8. Demand-Side EE Plan Scenario: Magnitude and Timing of Savings 

8.1 Approach 

Chapter 3 of the Regulatory Impacts Analysis (RIA) presents illustrative analysis of the 

final rule by making assumptions about the approaches that states might pursue as they develop 

their state plans. These approaches are embodied in the illustrative plan scenarios developed by 

EPA for the RIA and used to estimate the costs, benefits, and impacts of the final rule. The final 

CPP provides the states the flexibility to use demand reductions resulting from demand-side EE 

as a component of their state plan strategy, either directly recognized towards compliance with a 

rate-based goal or as a complimentary approach for achieving a mass-based goal (see section 

VIII, State Plans, of the final rule preamble for details). The EPA has included in the illustrative 

plan scenarios (both rate- and mass-based) a level of demand reduction that could be achieved, 

and the associated costs incurred, through implementation of demand-side EE measures. In this 

section, the EPA provides the basis for the illustrative demand-side EE plan scenario that is 

Commented [A47]: Here’s a paper worth citing about the

European experience with white certificates:

http://www.iaee.org/en/publications/eeeparticle.aspx?id=83
49 

included as a component of the plan scenarios presented in the RIA and, then, in the following 

section, the basis for associated EE cost estimates are provided. 

The demand-side EE plan scenario is derived from state and utility experience with 

ratepayer-funded EE programs and the resulting energy savings, as described in preceding 

sections of this TSD. Demand-side EE is included in the illustrative analysis contained in the 

RIA for several reasons including the current use of such programs in every state, the substantial 

savings relative to other opportunities to reduce CO2 emissions from the power sector, overall 

cost-effectiveness, and the quality of available information on their impacts and associated costs. 

The ratepayer-funded EE programs are the basis for the levels of demand-side EE that are 

included as part of the RIA, although there are other strategies and measures that states may 

employ for purposes of the final CPP. For example, the final rule provides states the flexibility to 

use building codes, appliance standards, and energy service performance contracting (to name a 

few examples), and those strategies also offer substantial, low-cost opportunities to reduce CO2

emissions from affected EGUs. 

8.2 Inputs 

The following steps were taken to establish the inputs for development of the illustrative 

demand-side EE plan scenario for each state, tribal area, and territory: 

 Step 1: Determine current level of demand-side EE performance 

 Step 2: Determine EE plan scenario level of performance 

 Step 3: Determine start year for EE plan scenario 

 Step 4: Determine start year level performance 

 Step 5: Determine pace of improvement from start year to EE plan scenario level of 

performance 

 Step 6: Determine average portfolio measure life and distribution of measure lives 

 Step 7: Determine sustainability of EE plan scenario level of performance 

8.2.1 Step 1: Determine Current Level of Demand-Side EE Performance 

A fundamental indicator of the level of EE program performance is incremental annual 

savings (also known as first-year savings) as a percent of retail sales. This is a common metric 
50 

defining savings levels for state EERS and is readily calculated from EIA Form 861 data for each 

state, tribal area and territory (hereafter, just referred to as “states”). Incremental annual savings 

are also more directly estimated and evaluated than are cumulative savings.33 To determine the 

current level of demand-side EE performance, the EPA aggregated the most recent (2013) EIA 

Form 861 data to the state level to establish their current level of performance. Estimated 

incremental savings results are presented in Table 4. 

8.2.2 Step 2: Determine EE Plan Scenario Level of Performance 

As discussed previously (section 4.2.3), achievable demand-side EE potential exists at 

significant and comparable levels (on the basis of total cumulative potential over a period of ten 

to twenty years) in all regions of the country. While varied regional characteristics (e.g., avoided 

power system costs, economic growth, sectoral mix, climate, and level of past EE efforts) affect 

estimates of achievable potential, ongoing improvements in energy-efficient technologies and 

practices, economic growth, population increases, and continually improving strategies for 

program delivery have resulted in persistent and substantial levels of achievable potential 

regardless of specific regional characteristics. 

Direct indicators of the achievable incremental levels of energy savings performance is 

provided by past performance at the state and utility levels, and by requirements states have put 

in place for levels of savings to be achieved by 2020. As discussed, these requirements are often 

in the form of EERS or similar savings goals that are applied to utilities in the state. 

Table 10 summarizes incremental savings levels as a percentage of retail sales from EIA 

Form 861 (2013) data, aggregated to the state level, and categorized into four ranges of savings 

levels (< 0.5%, 0.5% to 0.99%, 1.0% to 1.49%, and >= 1.5%). As shown, three states achieved 

the highest level of performance (> 1.5%) and an additional fourteen states achieved the second 

highest level of performance (1.0% to 1.49%). 

                                                            

33 Estimates of cumulative savings impacts in a given year are derived from incremental savings values and information on 

measure lives. Information on measure lives is less consistently gathered than is information on incremental savings values. 
51 

Table 10. 2013 State Levels of Incremental Annual Savings 

Incremental Savings as 

% of Retail Sales # of States States 

>= 1.5% 3 AZ, RI, VT 

1.0% to 1.49% 14 CA, CT, IL, IA, ME, MD, MA, MI, MN, NY, OH, OR, WA, WI 

0.5% to 0.99% 9 CO, ID, IN, MT, NJ, NM, NC, PA, UT 

< 0.5% 25 AL, AK, AR, DE, DC, FL, GA, HI, KS, KY, LA, MS, MO, NE, 

NV, NH, ND, OK, SC, SD, TN, TX, VA, WV, WY 

Source: EPA calculation using EIA 2013 

In addition to the state levels of performance represented in Table 10, numerous utilities 

of all ownership types and in all regions of the country have achieved significant levels of 

incremental savings. Tables 11, 12, and 13 provide examples of investor-, cooperative-, and 

municipal-owned utilities and their incremental savings levels for 2013 based on EIA Form 861 

data. 

Table 11. 2013 Incremental Annual Savings – Investor-Owned Utilities 

Investor-Owned Utility State Incremental Savings as 

% of Retail Sales 

Arizona Public Service Company AZ 1.6% 

Commonwealth Edison Company IL 1.2% 

DTE Electric Company MI 1.3% 

Niagara Mohawk Power Corporation NY 2.2% 

Pacific Gas & Electric Company CA 1.7% 

Potomac Edison Company MD 1.8% 

Source: EPA calculation using EIA 2013 

Table 12. 2013 Incremental Annual Savings – Cooperative-Owned Utilities 

Cooperative-Owned Utility State Incremental Savings as 

% of Retail Sales 

French Broad Electric Membership Corporation NC 2.2% 

Jackson Electric Cooperative Inc. WI 2.6% 

KEM Electric Cooperative Inc. ND 1.6% 

Southern Maryland Electric Cooperative Inc. MD 1.4% 

Southern Pine Electric Power Association MS 2.4% 

Umatilla Electric Cooperative Association OR 1.5% 

Source: EPA calculation using EIA 2013 
52 

Table 13. 2013 Incremental Annual Savings – Municipal-Owned Utilities 

Municipal-Owned Utility State Incremental Savings as 

% of Retail Sales 

Austin Energy TX 0.9% 

City of Fort Collins CO 2.2% 

City of Oberlin OH 2.6% 

City of Seattle WA 1.5% 

City of Saint Peter MN 2.1% 

Jacksonville Electric Authority FL 0.8% 

Los Angeles Department of Water & Power CA 0.9% 

Source: EPA calculation using EIA 2013 

Table 14 summarizes incremental savings levels required by state EERS and categorized 

into the same four ranges as Table 10 (ACEEE 2015b). Seven states are required to achieve the 

highest level of performance (> 1.5%) and an additional eight states are required to achieve the 

next highest level of performance (1.0% to 1.49%). 

Table 14. Levels of Incremental Savings Required by State EERS 

Incremental Savings as 

% of Retail Sales # of States States 

>= 1.5% 7 AZ, ME, 

MA, MN, RI, VT, WA 

1.0% to 1.49% 8 CO, CT, HI, IA, MD, MI, NY, OR 

0.5% to 0.99% 4 AR, CA, IL, WI 

< 0.5% 1 TX 

Source: ACEEE 2015b 

For the illustrative demand-side EE plan scenario level of performance, the EPA has 

determined that a 1.0% incremental savings, as a percentage of retail sales, is appropriate. This 

level was achieved by seventeen states and by numerous utilities of all ownership types in 2013. 

An additional two states (CO and HI), accounting for overlap, are expected to achieve this level 

by 2020 as shown in Table 14. Thus, nineteen states have either achieved or are required to 

achieve this level of performance. 
53 

8.2.3 Step 3: Determine Start Year for EE Plan Scenario 

For construction of the EE plan scenario, the EPA has determined that 2020 is 

appropriate as the first year for state demand-side EE efforts. The EPA believes this is reasonable 

for the illustrative plan scenario as efforts are ramped up in advance of the 2022-2029 interim 

plan performance period. This allows sufficient time – for than four years – after issuance of the 

final rule for planning of these efforts. This reflects a three year delay from the 2017 start year 

used for the proposal. 

8.2.4 Step 4: Determine Start Year Level of Performance 

For construction of the best practices scenario, the EPA has set each state’s level of 

performance in the start year (2020) to the level of performance observed in 2013, based on the 

aggregate state-level incremental electricity savings based on EIA Form 861 data (Table 4). 

8.2.5 Step 5: Determine Pace of Improvement from Start Year to EE Plan Scenario Level 

of Performance 

To determine a reasonable trajectory of incremental savings levels from the 2020 level to 

the EE plan level of performance, the EPA considered past performance of individual program 

administrators34 as well as requirements of existing state EERS. For the past performance of 

individual program administrators, the EPA first screened the data and divided them into 

moderate and high performing sub-groups. The moderate group (47 entities) was defined as 

programs that achieved from 0.8% to 1.5% maximum incremental savings levels and the high 

group (26 entities) was defined as programs that achieved greater than 1.5% maximum 

incremental savings levels. The EPA then calculated the rate at which each entity had increased 

savings over time and calculated average values for each sub-group. For the moderate group, the 

average rate of improvement of incremental annual savings rate was 0.30% per year. For the 

high group, the average rate of improvement of incremental annual savings rate was 0.38% per 

year. See Appendix 2 for supporting data and analysis. 

EPA also considered requirements of existing state EERS and evaluated the rate at which 

their incremental savings levels increase over time. For several EERS, the EPA was unable to 

clearly identify ramp-up schedules. The EPA identified ten states with clear schedules and 

                                                            

34 EIA 861 was the primary data source; however, EIA 861 data was supplemented with data for third-party program 

administrators. Prior to 2011 EIA did not collect data from third-party program administrators. 

Commented [A48]: Perhaps a sentence to justify this choice? It

seems arbitrary.
54 

calculated the average rate of improvement for each. The average rate of improvement of 

incremental annual savings rate required for these ten states is 0.21% per year. See Appendix 2 

for supporting data and analysis. 

Based on these results, the EPA has chosen 0.2% per year for the demand-side EE plan 

scenario rate of improvement. These values are at the low end of the range in comparison with 

our analysis of past state performance and state requirements. 

8.2.6 Step 6: Determine Average Portfolio Measure Life and Distribution of Measure 

Lives 

The next step in defining the EE plan scenario entails projecting the cumulative future 

impacts of the annual incremental savings levels for each state. The incremental (or first-year) 

savings impacts in a year reflect the savings from EE measures put in place in that year. The 

cumulative incremental savings in a given year represents the total impacts of all EE measures, 

those put in place in that year and all prior years, that still have remaining savings impacts in the 

given year. The cumulative savings account for the continuing impacts of EE measures that 

remain in place for a period of time (the “measure life”) before being replaced. For example, the 

purchase of a high-efficiency refrigerator may lead to savings for twelve years, before being 

replaced with a new model. To estimate cumulative impacts of a series of years of incremental 

savings, the industry uses the concept of an average measure life for the entire portfolio of EE 

programs being administered. Rather than use a single, average measure life to represent a 

diverse portfolio of programs, that range in measure lives from less than ten years (e.g., 

commercial lighting technologies and applications, residential behavioral feedback) to as long as 

twenty years or more (e.g., residential HVAC, residential building insulation), the EPA is 

assuming a distribution of measure lives around the average to account for future impacts of 

incremental savings levels. 

To approximate a distribution of measure lives across a portfolio of EE programs 

represented by the EE plan scenario, EPA relied on a recent analysis by the Lawrence Berkeley 

National Laboratory (LBNL) of the distribution of EE program lifetimes (LBNL 2015a). The 

analysis was based on the LBNL DSM Program Database. The database consists of programlevel data, including first-year savings and program savings lifetimes, reported directly by the EE 

program administrators since 2009. Across the database of nearly 6,000 program years of data, 
55 

program savings lifetimes are available for about 1,600 program years (27% of the program 

years). More than 50 utilities and other EE program administrators in 25 states contributed to 

those data through their regulatory filings, statewide databases, and other sources. The weighted 

average of EE measure lifetimes for the entire population in the LBNL analysis is 10.2 years. 

The LBNL analysis further partitions the measure lifetimes of the EE programs into four tiers 

based on a cluster analysis – a statistical approach for grouping values based on their similarity.35

The four-tier distribution of EE program measure lifetimes, as well as the associated weightedaverage measure lifetime and the shares of first-year savings of each tier, are used in the analysis. 

Figure 5 presents LBNL’s four-tier distribution of the EE program measure lifetimes, and the 

associated weighted average measure lifetime and share of first-year savings for each tier. 

Figure 5. The Four-Tier Distribution of Demand-Side EE Program Measure Lifetime 

Source: LBNL 2015a 

                                                            

35 The method used for the cluster analysis is the k-means approach. The method starts with assignment of each data point to a 

cluster so as to minimize the distance of cluster members from the center of the cluster, which is designated randomly. In 

essence, the method seeks to minimize differences within each cluster and maximize differences among the clusters. In this case, 

the programs within each cluster would have similar lifetimes and program types. 
56 

The weighted-average EE program measure lifetime of 10.2 years for the entire 

population of data in the LBNL analysis is roughly consistent with a 2014 ACEEE study that 

found an average measure life of 10.6 years based on electricity EE program data across all 

sectors in 20 states (ACEEE 2014d). A more common approach in other studies is to assume a 

portfolio with no diversity of measure lives, with the entirety of incremental savings being 

realized in each year from the first through the full average measure life and then dropping to 

zero in the following year. By comparison, the approach used here is a conservative one, leading 

to the same quantity of total energy savings, but with a greater portion of the savings occurring in 

later years than occur with the more common, simpler approach of using a single average 

measure life to represent the entire portfolio of EE programs. 

8.2.7 Step 7: Determine Sustainability of EE Plan Scenario Level of Performance 

For construction of the best practices scenario, once a state achieves the best practices 

level of performance, the EPA has kept the level of performance constant through the analysis 

period. Limited empirical data suggests the reasonableness of this approach; however, 

comprehensive data, across all regions and states, does not exist because these levels of 

performance have not been achieved and sustained nationwide previously. The Northwest Power 

Conservation Council (NPCC) provides one such example. NPCC has been conducting the most 

consistent and long-running series of evaluations of achievable cost-effective potential in the 

country, updated every five years, as part of their five-state36 regional energy resource plans 

(NPCC 2010). These analyses have become more detailed, reliable, and purposeful over time. 

Since 1998, NPCC’s estimates of achievable potential have more than tripled even as evaluated 

electricity savings from EE programs have increased rapidly, more than quadrupling between 

1998 and 2010 (while levelized costs of saved energy achieved have remained flat), and 

exceeding plan targets every year since 2005. A study of the NPCC results concludes: “our 

research shows that when programs invest in higher levels of efficiency, this helps drive 

measurement improvements and technical innovation, resulting in larger and more reliable 

conservation supply estimates” (NPCC 2008). Table 15 summarizes the NPCC’s achievable 

potential estimates and evaluated savings since 1998 (NPCC 2010). 

                                                            

36 NPCC’s resource plans cover Idaho, Oregon, and Washington in their entirety, and western regions of Montana and Wyoming. 
57 

Table 15. NPCC Achievable EE Potential and Achieved Incremental Savings (1998-2010) 

Year 

1998 2005 2010 

Achievable Potential over 20 Years 

(GWh) 13,447 24,651 51,684 

Achieved Incremental Savings 

from EE Programs 

(GWh) 

547 1,184 2,248 

Source: NPCC 2010 

Additional substantiation of this approach is provided by average annual achievable rates 

from reviewed studies, as discussed previously, and comparison of those with the rates resulting 

from the best practices scenario. We address this in a later section, 8.4.2, after presenting those 

results. 

8.2.8 Summary of the Demand-Side EE Plan Scenario Construction 

Table 16 provides a summary of inputs for the demand-side EE plan scenario. The pace 

of improvements, average measure life, and distribution of measure lives are each conservative 

and, therefore, lead to lower cumulative savings than would otherwise result. Similarly, the EE 

plan scenario, being based solely on results from and requirements of EE programs, is less 

stringent than a level would be that accounted for potential impacts of other EE strategies such as 

building energy codes, state appliance standards, or energy services performance contracting. 

Table 16. Summary of Demand-Side EE Plan Scenario Inputs 

Input Demand-Side EE Plan Scenario 

Current Level of Performance 

(incremental savings as % of retail sales) Calculated using data from EIA 861 (2013) 

EE Plan Scenario Level of Performance 

(incremental savings as % of retails sales) 1.0% 

Start Year 2020 

Start Year Level of Performance 2013 level of performance 

Pace of Improvement 

(increase in incremental savings rate per year) 0.20% per year 

Average Measure Life and Distribution of 

Measure Lives 

10.2 years with a 4-tier distribution of measure 

lifetimes (LBNL database and analysis) 

Continued Performance Once achieved, EE plan scenario savings level is 

sustained 

Source: Section 8.2 
58 

8.3 Calculations 

This section presents the calculations for determining cumulative savings levels for each 

state, for each year based on the demand-side EE plan scenario. The cumulative savings levels 

are derived based upon the key inputs summarized in Table 16. 

Calculating the net cumulative savings of the demand-side EE plan scenario involves six 

steps. For each state, for each year (2020-2030) the following steps are taken: 

1. Determine annual business-as-usual (BAU) sales 

2. Determine annual incremental EE savings as a percentage of sales 

3. Determine annual incremental EE savings (GWh) 

4. Determine annual expiring EE savings (GWh) 

5. Determine net cumulative EE savings (GWh) 

6. Determine sales after net EE (GWh) 

7. Determine net cumulative EE savings as a percentage of BAU sales 

To illustrate these calculations, each step is described and results provided for one state 

(using South Carolina as an example) for 2020 through 2027. We truncate the results at 2027 for 

simplicity, but all calculations and full results are presented for all states for all years in the 

spreadsheet file included as Appendix 3. 

8.3.1 Step 1: Determine Annual Business as Usual (BAU) Sales 

BAU sales are derived by aggregating 2013 sales to the state level using EIA Form 861 

data and increasing the value for each subsequent year by the average annual growth rate 

(AAGR) from the AEO 2015 Reference Case for the region corresponding to the state. 

Specifically, the AAGR from AEO 2015 for 2013-2040 is used to derive BAU sales for 2014 

through 2040, and the AAGR from AEO 2015 for 2030-2040 is used to derive BAU sales for 

2041 through 2050. For South Carolina the corresponding region is SRVC and the AAGR from 

2013-2040 is 0.88% per year and from 2030-2040 is 0.76% per year. The resulting values are 

provided in Table 17 for South Carolina. 
59 

Table 17. BAU Sales for South Carolina 

Year 

2020 2021 2022 2023 2024 2025 2026 2027 

BAU Sales 

(GWh) 83,601 84,341 85,087 85,840 86,599 87,365 88,138 88,918 

8.3.2 Step 2: Determine Annual Incremental EE Savings as a Percentage of Sales 

Next, the 2020 value for annual incremental EE savings as a percentage of sales is set at 

the 2013 value based upon aggregated EIA-861 reported data (see Table 4). For South Carolina 

that value is 0.46%. This value is then increased by the pace of improvement of 0.2% per year 

until the goal level of 1.0% is reached and then held constant. The resulting values are provided 

in Table 18 for South Carolina. 

Table 18. Annual Incremental EE Savings as a Percentage of Sales for South Carolina 

Year 

2020 2021 2022 2023 2024 2025 2026 2027 

Annual 

Incremental 

EE Savings 

(% sales) 

0.46% 0.66% 0.86% 1.00% 1.00% 1.00% 1.00% 1.00% 

8.3.3 Step 3: Determine Annual Incremental EE Savings (GWh) 

Annual incremental EE savings (also known as first-year savings) are calculated by 

multiplying the annual incremental savings as a percentage of sales times the prior year sales 

after net EE. The resulting values are provided in Table 19 for South Carolina. 

Table 19. Annual Incremental EE Savings (GWh) for South Carolina 

Year 

2020 2021 2022 2023 2024 2025 2026 2027 

Annual 

Incremental 

EE Savings 

(GWh) 

385 553 721 834 833 833 832 832 
60 

8.3.4 Step 4: Determine Annual Expiring EE Savings (GWh) 

As discussed above (section 8.2.6), the annual incremental (or first-year) EE savings of 

the portfolio decline (or expire) over time according to the four-tier distribution of measure lives. 

Expiring EE savings are calculated as the sum of all expired savings in a given year from all 

prior years’ incremental (first-year) savings. The resulting values for expiring EE savings are 

provided in Table 20 for South Carolina. 

Table 20. Expiring EE Savings for South Carolina 

Year 

2020 2021 2022 2023 2024 2025 2026 2027 

Expiring 

EE 

Savings 

(GWh) 

0 0 0 0 0 0 69 165 

8.3.5 Step 5: Determine Net Cumulative EE Savings (GWh) 

Net cumulative EE savings in a given year are equal to annual incremental savings for 

that year minus total expiring savings for that year plus net cumulative savings for the prior year. 

The resulting values are provided for South Carolina in Table 21. 

Table 21. Net Cumulative EE Savings for South Carolina 

Year 

2020 2021 2022 2023 2024 2025 2026 2027 

Net 

Cumulative 

EE Savings 

(GWh) 

385 938 1,659 2,493 3.327 4,159 4,922 5,589 

8.3.6 Step 6: Determine Sales after Net EE (GWh)

Sales after net EE are calculated by subtracting net cumulative savings from BAU sales. 

The resulting values are provided in Table 22 for South Carolina. 
61 

Table 22. Sales after Net EE Savings for South Carolina 

Year 

2020 2021 2022 2023 2024 2025 2026 2027 

Sales after 

Net EE 

Savings 

(GWh) 

83,216 83,403 83,428 83,346 83,272 83,206 83,216 83,329 

8.3.7 Step 7: Determine Net Cumulative EE Savings as a Percentage of BAU Sales 

Net cumulative EE savings as a percentage of BAU sales are equal to net cumulative 

savings divided by BAU sales. The resulting values are summarized for South Carolina in Table 

23. 

Table 23. Net Cumulative EE Savings as a Percentage of BAU Sales for South Carolina 

Year 

2020 2021 2022 2023 2024 2025 2026 2027 

Net 

Cumulative 

EE Savings 

as % of 

BAU Sales 

0.46% 1.11% 1.95% 2.90% 3.84% 4.76% 5.58% 6.29% 

8.3.8 Summary of Calculation Formulas and Results by Step for South Carolina 

Table 24 provides summaries of the results for South Carolina for each step, respectively. 

Table 24. Summary of Results by Step for South Carolina 

Year 

2020 2021 2022 2023 2024 2025 2026 2027 

BAU Sales 

(GWh) 83,601 84,341 85,087 85,840 86,599 87,365 88,138 88,918 

Annual 

Incremental 

EE Savings 

(% sales) 

0.46% 0.66% 0.86% 1.00% 1.00% 1.00% 1.00% 1.00% 

Annual 

Incremental 

EE Savings 

(GWh) 

385 553 721 834 833 833 832 832 
62 

Year 

2020 2021 2022 2023 2024 2025 2026 2027 

Annual 

Expiring EE 

Savings 

(GWh) 

0 0 0 0 0 0 69 165 

Net 

Cumulative 

EE Savings 

(GWh) 

385 938 1,659 2,493 3.327 4,159 4,922 5,589 

Sales after 

Net EE 

(GWh) 

83,216 83,403 83,428 83,346 83,272 83,206 83,216 83,329 

Net 

Cumulative 

EE Savings 

as % of BAU 

Sales 

0.46% 1.11% 1.95% 2.90% 3.84% 4.76% 5.58% 6.29% 

8.4 Results 

8.4.1 Summary of Results 

As discussed, the EE plan scenario results in reduced electricity demand in each state, in 

each year of the plan scenario. Table 25 provides the results for 2020, 2025, and 2030, as 

electricity demand reduced in gigawatt-hours and as a percentage of BAU sales for the year. Full 

results are presented for all states for all years in the spreadsheet file included as Appendix 3. 

Table 25. Demand-Side EE Plan Scenario: Magnitude and 

Timing of Net Cumulative Savings 

States 

Net Cumulative Savings 

2020 2025 2030 

GWh % of BAU 

Sales 

GWh % of BAU 

Sales GWh % of BAU Sales 

Alabama 91 0.10% 3,287 3.37% 7,258 7.13% 

Arizona 797 0.99% 4,786 5.65% 7,195 8.09% 

Arkansas 241 0.48% 2,519 4.81% 4,279 7.80% 

California 2,735 0.99% 16,310 5.70% 24,310 8.19% 

Colorado 524 0.91% 3,367 5.58% 5,116 8.06% 

Connecticut 305 1.00% 1,805 5.77% 2,658 8.34% 

Delaware 1 0.01% 352 2.98% 849 7.06% 

District of Columbia 51 0.45% 556 4.81% 938 7.99% 

Florida 389 0.17% 9,054 3.69% 18,673 7.31% 

Georgia 357 0.26% 5,889 4.07% 11,314 7.48% 
63 

States 

Net Cumulative Savings 

2020 2025 2030 

GWh % of BAU 

Sales 

GWh % of BAU 

Sales GWh % of BAU Sales 

Idaho 137 0.54% 1,327 4.98% 2,195 7.91% 

Illinois 1,458 1.00% 8,633 5.76% 12,742 8.31% 

Indiana 1,006 0.92% 6,347 5.69% 9,459 8.29% 

Iowa 484 0.99% 2,878 5.73% 4,270 8.25% 

Kansas 2 0.01% 1,265 2.95% 3,080 6.97% 

Kentucky 337 0.37% 4,232 4.50% 7,544 7.68% 

Louisiana 23 0.02% 2,905 3.02% 6,983 6.92% 

Maine 121 1.00% 717 5.77% 1,056 8.34% 

Maryland 632 1.00% 3,729 5.78% 5,482 8.36% 

Massachusetts 566 1.00% 3,344 5.77% 4,925 8.34% 

Michigan 1,055 1.00% 6,232 5.77% 9,176 8.34% 

Minnesota 712 0.99% 4,230 5.73% 6,275 8.25% 

Mississippi 119 0.23% 2,159 3.95% 4,244 7.40% 

Missouri 420 0.49% 4,324 4.89% 7,230 7.97% 

Montana 79 0.53% 770 4.98% 1,274 7.91% 

Nebraska 49 0.15% 1,205 3.65% 2,500 7.35% 

Nevada 176 0.47% 1,862 4.81% 3,162 7.84% 

New Hampshire 17 0.15% 425 3.67% 875 7.42% 

New Jersey 531 0.69% 4,202 5.40% 6,514 8.24% 

New Mexico 138 0.56% 1,300 5.02% 2,140 7.87% 

New York 1,477 1.00% 8,637 5.86% 12,537 8.51% 

North Carolina 814 0.59% 7,385 5.12% 11,984 7.95% 

North Dakota 3 0.02% 517 3.00% 1,244 7.00% 

Ohio 1,545 1.00% 9,150 5.76% 13,506 8.31% 

Oklahoma 168 0.26% 2,744 4.07% 5,276 7.45% 

Oregon 500 0.99% 2,986 5.69% 4,460 8.17% 

Pennsylvania 1,351 0.90% 8,677 5.70% 12,915 8.33% 

Rhode Island 80 1.00% 471 5.77% 693 8.34% 

South Carolina 385 0.46% 4,159 4.76% 7,117 7.79% 

South Dakota 16 0.13% 464 3.54% 986 7.28% 

Tennessee 320 0.31% 4,586 4.26% 8,503 7.57% 

Texas 801 0.20% 16,359 3.82% 32,959 7.32% 

Utah 257 0.81% 1,823 5.53% 2,789 8.12% 

Vermont 57 1.00% 338 5.77% 498 8.34% 

Virginia 28 0.02% 3,707 3.02% 8,907 6.94% 

Washington 975 0.99% 5,822 5.69% 8,696 8.17% 
64 

States 

Net Cumulative Savings 

2020 2025 2030 

GWh % of BAU 

Sales 

GWh % of BAU 

Sales GWh % of BAU Sales 

West Virginia 79 0.24% 1,347 4.06% 2,580 7.59% 

Wisconsin 710 1.00% 4,201 5.76% 6,197 8.31% 

Wyoming 31 0.17% 700 3.73% 1,433 7.33% 

Navajo 0 0.00% 21 2.90% 53 6.85% 

Ute 0 0.00% 17 2.91% 41 6.90% 

Fort Mojave 0 0.00% 2 2.90% 4 6.85% 

Continental U.S. 23,150 0.59% 194,126 4.81% 327,092 7.83% 

Alaska 2 0.04% 161 3.13% 376 7.04% 

Hawaii 3 0.04% 284 3.10% 668 7.03% 

Puerto Rico 0 0.00% 528 2.97% 1,271 7.14% 

Guam 0 0.00% 46 2.97% 112 7.14% 

U.S. Total 23,156 0.59% 195,145 4.80% 329,518 7.82% 

Source: Appendix 3 

8.4.2 Results in Context 

To provide context for state cumulative savings results provided in Table 26, the average 

annual savings were calculated for each state through 2030, starting from 2020. Table 22 

summarizes the results. 

Table 26. Average Annual Savings Rates of Demand-Side EE Plan Scenario 

Years Number 

of Years 

Range of Cumulative 

Savings (% of Sales) 

across States in 2030 

Range of Average 

Annual Savings Rates 

across States 

National Average Annual 

Savings Rate 

2020-

2030 11 6.92% to 8.36% 0.63%/year to 0.76%/year 0.71% per year 

Source: EPA calculations based on Table 25 

The state range and national value for the average annual savings rate represented in the 

demand-side EE plan scenario are below the range of values found in recent utility, state, and 

regional studies (0.9% to 1.3% per year) as summarized in Table 6. These results provide 

additional support for the reasonableness and feasibility of the demand-side EE plan scenario and 

associated state-specific results. 
65 

8.4.3 Representation of Demand-Side EE in Modeling of the Illustrative Plan Scenario 

To reflect the implementation of the illustrative energy efficiency plan scenario in power 

sector modeling, as discussed in the RIA (Chapter 3), the IPM base case electricity demand was 

adjusted exogenously to reflect the estimated future-year demand reductions described and 

summarized above. State-level demand reductions were scaled up to account for transmission 

losses and applied to base case generation demand in each model year to derive adjusted demand 

for each state, reflecting the energy efficiency plan scenario energy reductions. The demand 

adjustments were applied proportionally across all segments (peak and non-peak) of the load 

duration curve. This approach to allocating annual electricity reductions is consistent with the 

significant levels of savings represented in the illustrative demand-side plan scenario. Achieving 

1.0% incremental savings typically require robust EE program portfolios, employing a diverse 

set of measures across all sectors and most end-use categories. The impacts of such 

comprehensive portfolios occur across the full annual load duration curve with higher periods of 

demand providing proportionally greater EE potential. In other words, potential demand 

reductions through EE measures tend to mirror the underlying load duration curve which, in turn, 

is formed from the demands from all end uses, across all end-use sectors. Appendix 1 provides 

summary results from more than 50 recent EE potential studies – conducted between 2009 and 

2014 – from across the U.S. The detailed results of these studies indicate the breadth of end-uses, 

across all end-use sectors, which provide cost-effective EE potential. 

9. Demand-Side EE Plan Scenario: Assessment of Costs 

9.1 Approach 

This section provides the basis for estimating the costs that would be incurred to achieve 

the magnitude and timing of EE savings represented by the EE plan scenario. Chapter 3 of the 

Regulatory Impacts Analysis (RIA) presents illustrative analysis of the final rule by showing 

approaches that states might pursue as they develop their state plans. The scenarios used in the 

RIA are the basis for costs, benefits, and other power sector impacts of the final rule. The final 

rule allows states to use demand-side EE as a component of their state plan strategy, either 

directly recognized towards compliance with a rate-based goal or as a complimentary approach 

for achieving a mass-based goal. The EPA has included in the illustrative plan scenarios (both 

rate- and mass-based) a level of demand reduction that could be achieved, and the associated 

Commented [A49]: Recommend providing an example of a

state that has achieved this and describe exactly what they did.
66 

costs incurred, through implementation of demand-side EE measures as shown in this TSD. In 

this section, the EPA provides the basis for the costs of the illustrative demand-side EE plan 

scenario that is included as a component of the plan scenarios presented in the RIA. 

The electricity savings resulting from the demand-side EE methodology was used to 

adjust electricity demand levels in an exogenous manner, applied to the power sector modeling 

for the illustrative plan scenarios of the RIA. In other words, the degree to which EE is employed 

is not determined endogenously within the power sector modeling based upon optimization of 

costs but, rather, “hard wired” into the illustrative plan scenarios. The electricity savings 

represented in the demand-side EE plan scenario lead to substantial reductions in power system 

costs due to the reductions in specified electricity demand. Since EE is not represented 

endogenously as an abatement measure within the power sector modeling, the costs associated 

with the EE plan scenario must be estimated outside of the power sector modeling and integrated 

with the results from that modeling. These EE cost estimates, their basis, and calculations are 

addressed in the following sections. 

9.2 Inputs 

The following steps were taken to establish the inputs for development of the EE cost 

estimates for each state in each year. 

 Step 1: Determine incremental electricity savings 

 Step 2: Determine first-year program costs and cost factors 

 Step 3: Determine the ratio of program to participant costs 

9.2.1 Step 1: Determine Incremental Electricity Savings 

Results from section 8 provide the starting basis for estimation of EE costs used in the 

RIA. The resulting incremental savings (MWh) by state and by year provide the first step in 

calculating EE plan scenario costs. 

9.2.2 Step 2: Determine First-Year Program Costs and Cost Factors 

First-year program costs refer to the full costs (e.g., incentive payments, administration, 

technical support, marketing, evaluation, measurement and verification (EM&V), information to 

consumers, etc.) incurred by a utility or other administrator of EE programs in a given year that 
67 

lead to EE measures (technologies and practices) put in place in that year, and result in 

reductions in electricity demand in that and future years (driven by the mix of measure lives 

across the portfolio of EE programs employed). First-year program costs are represented as these 

costs divided by the incremental (or first-year) savings for that year. Unlike participant costs, 

program costs are readily known by the administrator of EE programs and are, therefore, an 

appropriate starting point for cost analysis of the demand-side EE plan scenario. 

Recent studies have collected and analyzed first-year program cost data directly from EE 

program administrators from across the U.S. In 2009, ACEEE conducted a national review of 

data on EE program costs from program annual reports, evaluation reports, and information 

compiled from contacts at program administers in 14 states (ACEEE 2009). The program cost 

data were compiled from multiple EE program administrators over multiple years in each state. 

ACEEE found average first-year net37 program costs of $275/MWh (2011$). Two newer national 

analyses have found lower program costs than the 2009 ACEEE study. In 2014, ACEEE updated 

their analysis from 2009, expanding the number of states to 20, and including a greater number 

of program administrators and years (ACEEE 2014d). In this analysis ACEEE found average 

first-year net program costs of $230/MWh (2011$). In 2014, an LBNL study presented results 

from a uniquely comprehensive study of EE program costs (LBNL 2014b). The LBNL analysis 

reviewed program-level data from over 100 program administrators in 31 states. Data were 

collected from over 1,700 individual programs for up to three years (2009-2011), covering more 

than 4,000 individual program-years data points. Because of the broad scope of their study and 

the lack of net savings information for many programs, LBNL focused on gross, rather than net, 

savings values.38 LBNL found national average first-year program cost of gross savings of 

$162/MWh (2012$). Applying an average net-to-gross ratio of 0.9 and deflating costs at 1.8%, 

results in an estimated national average first-year cost of net savings of $177 (2011$).39 The 

results cited from these three studies represent average first-year costs from program 

administrators across the U.S. 

                                                            

37 “Net costs” refers to costs per electricity saved after accounting for effects of free-ridership on those savings. Depending upon 

the state, spillover effects may also be accounted for in net costs. 

38 “Gross savings” refers to electricity savings before any accounting for effects of free-ridership or spillover. 

39 Source: BEA National Income and Product Accounts Table 1.5.4 Price Indexes for Gross Domestic Product (version revised 

on March 27, 2015). 

Commented [A50]: Why are we using these costs, one of which

is from the advocacy group ACEEE, instead of some mid‐range value

from the peer reviewed academic literature? The literature was

discussed above.

From a quick calculation, it looks like the all‐in megawatt costs from

these are probably way below that from the peer‐reviewed

literature.
68 

There are two factors that would influence first-year EE costs as higher levels of 

performance are achieved. Economies of scale in the operation of larger EE programs and larger 

portfolios of EE programs, and learning and expertise gained over time from the continued 

implementation of programs, are two factors that would lower costs as programs scale up and 

expand to realize higher levels of performance (Jaffe et al. 2003). However, the limited supply of 

EE abatement measures and the need to employ higher cost measures, over time, to reach higher 

levels of performance, and to sustain high levels of performance, are factors that would increase 

costs as higher levels of performance are achieved. Several analyses of EE program costs and 

savings based on empirical data are consistent with the economic theory, indicating significantly 

declining costs up to incremental savings levels of 1.0% or higher, and then level or increasing 

costs as higher savings levels are achieved (Synapse 2008; GEEG 2012; LBNL 2015b). Based 

on analysis like these, a recent LBNL study adopted an approach that generically represented 

declining costs at lower savings levels and increasing costs at higher savings levels (LBNL 

2013c). Counter to these studies, other analysis of empirical data has indicated only steadily 

rising costs as savings levels increase even from levels below 0.5% (ACEEE 2014d). 

In consideration of the above discussion, the EPA has chosen to use a three-tier approach 

to generically represent declining first-year program costs through the maximum savings level of 

1.0% represented in the EE plan scenario. The first tier is used for incremental savings levels less 

than 0.5%; the second tier is used for incremental savings levels equal to or greater than 0.5% 

and less than 1.0%; and the third tier is used for incremental savings levels of 1.0% (the highest 

level assumed for demand-side EE plan scenario). To reflect the significantly higher costs found 

at the lowest savings levels, program costs for the first tier are set at two times the level found in 

the 2009 ACEEE study. This results in first-year program costs of $550/MWh ($2011) for the 

first tier. For the second and third tiers, these costs are reduced by 20% and 40%, respectively, 

resulting in first-year program costs of $440/MWh and $330/MWh. The approach results in 

reasonable but conservative cost assumptions for analyzing the demand-side EE plan scenario. 

9.2.3 Step 3: Determine the Ratio of Program to Participant Costs 

As noted above, while program costs are readily known and consistently tracked and 

reported by program administrators, participant costs are not easily known, and are less 

consistently estimated and reported. The ratio between program and participant costs will vary 
69 

significantly from one program to the next within a utility’s portfolio. To determine an 

appropriate ratio for the impacts assessment of the CPP proposed rule, EPA conducted research 

and analysis of industry data (annual EE program reports from administrators in 22 states) and 

found that on average program costs represented 53% of total measured costs (with direct

participant costs representing the remaining 47%) (EPA 2014a). Based on this analysis, the EPA 

used a ratio of 1-to-1 for program to participant costs for the EE cost estimates contained in the 

CPP proposed rule. In April 2015 the Lawrence Berkeley National Laboratory (LBNL) 

published a technical brief that analyzed program and participant costs for EE programs based on 

their extensive LBNL DSM Program Database (LBNL 2015b). The database contains 

information on approximately 1,700 individual EE programs across multiple years from 34 

states. The LBNL summary findings indicate a ratio of program to participant costs of 51% to 

49%. These results are consistent with the earlier analysis and support the use of the 1-to-1 ratio 

for the current analysis. This ratio is used to derive participant and total costs based upon 

program costs. 

9.2.4 Summary of Inputs for Demand-Side EE Cost Analysis 

Table 27 provides a summary of inputs for the EE cost analysis including incremental 

electricity savings, first-year costs and cost factors, and ratio of program to participant costs. 

Table 27. Summary of EE Cost Analysis Inputs 

Input Source or Value 

Incremental Electricity 

Savings Results from demand-side EE plan scenario 

First-Year Program Cost $550/MWh (2011$) 

Ratio of Program to 

Participant Costs 1:1 

First-Year Participant 

Cost $550/MWh (2011$) 

First-Year Total Cost $1100/MWh (2011$) 

Cost Factors and Total 

Costs by Level of 

Incremental Savings 

Incremental Savings Rate 

< 0.5% 0.5% to < 1.0% 1.0% 

100% of first-year costs 

$1100/MWh (2011$) 

80% of base costs: 

$880/MWh (2011$) 

60% of base costs: 

$660/MWh (2011$) 

Source: Section 9.2 

Commented [A51]: This is strange, because most utilities do

not appropriately calculate all of the participant costs. Recommend

clarifying and state “direct participant costs.”
70 

9.3 Calculations 

This section addresses the methodology for calculating the cost associated with the EE 

levels included in the illustrative plan scenarios. Specifically, three values are calculated (annual 

first-year costs, levelized cost of saved energy (LCSE), and annualized costs); for each, program 

and participant components are then calculated using the 1:1 ratio (i.e., 50% of total for each) 

derived above. Specific results from prior sections on timing and magnitude of savings, and costs 

inputs are used for these calculations. For each state, the following steps are taken for each year: 

1. Calculate annual first-year costs of saved energy 

2. Calculate levelized cost of saved energy (LCSE) 

3. Calculate annualized costs 

To illustrate these calculations, each step is described and results are provided for one 

state (using South Carolina as an example) for 2020 through 2027 (truncated for simplicity). The 

full national results (for 2020, 2025, and 2030) are presented following the step-by-step example 

for South Carolina. 

9.3.1 Step 1: Calculate Annual First-Year Costs 

Annual total first-year costs are calculated by multiplying annual total incremental 

savings (MWh) (from Table 19) by the first-year total cost of saved energy (from Table 27, using 

the corresponding incremental savings rate). Program and participant portions of the first-year 

costs are then calculated as 50% of total first-year costs for each per Table 27. 

The resulting values are summarized for South Carolina in Table 28. 

Table 28. Calculation of Annual First-Year Costs for South Carolina 

Year 

2020 2021 2022 2023 2024 2025 2026 2027 

Annual 

Incremental 

Savings 

(GWh) 

385 553 721 834 833 833 832 832 

First-Year 

Total Cost of 

Saved Energy 

(2011$/MWh) 

1100 880 880 660 660 660 660 660 
71 

Year 

2020 2021 2022 2023 2024 2025 2026 2027 

First-Year 

Total Cost 

(millions 

2011$) 

423.4 486.6 634.5 550.6 550.1 549.6 549.2 549.2 

First-Year 

Program 

(millions of 

2011$) 

211.7 243.3 317.3 275.3 275.0 274.8 274.6 274.6 

First-Year 

Participant 

(millions of 

2011$) 

211.7 243.3 317.3 275.3 275.0 274.8 274.6 274.6 

9.3.2 Step 2: Calculate Levelized Cost of Saved Energy 

The LCSE calculation algorithm is based on the 2002 California Standard Practice 

Manual (California GOPR 2002). This approach was adopted in order to appropriately allocate 

the cost of a single year EE program over declining lifetime savings. The net present value of all 

savings from a single year’s EE activities (i.e., over the entire distribution of program lifetimes) 

is calculated using the real discount rate rates of 3% and 7%. The levelized cost of saved energy 

is then calculated by dividing the annual first-year costs (from Table 28) by the net present value 

of the savings. The resulting values are summarized for South Carolina in Table 29. 

Table 29. Levelized Cost of Saved Energy for South Carolina (at 3% discount rate) 

Year 

2020 2021 2022 2023 2024 2025 2026 2027 

Levelized Savings 

(GWh) 3,279 4,710 6,141 7,105 7,099 7,092 7,087 7,087 

First-Year Total 

Cost (millions 

2011$) 

423.4 486.6 634.5 550.6 550.1 549.6 549.2 549.2 

Total LCSE 

(2011$/MWh) 129.2 103.3 103.3 77.5 77.5 77.5 77.5 77.5 

Program LCSE 

(2011$/MWh) 64.6 51.7 51.7 38.7 38.7 38.7 38.7 38.7 

Participant LCSE 

(2011$/MWh) 64.6 51.7 51.7 38.7 38.7 38.7 38.7 38.7 
72 

9.3.3 Step 3: Calculate Annualized Costs 

Annualized costs are calculated by multiplying the LCSE for each year by the estimated 

savings of the demand-side EE plan scenario in that year through the full distribution of measure 

lifetimes. For a given year in the analysis, the total annualized costs resulting from all current 

and past investments are summed to calculate the total annualized costs for that year. The 

resulting values are summarized for South Carolina in Table 30. 

Table 30. Annualized Costs for South Carolina 

Year 

2020 2021 2022 2023 2024 2025 2026 2027 

Annualized 

Total Costs 

(millions 

2011$) 

49.7 106.9 181.4 246.0 310.6 375.1 430.7 476.4 

Annualized 

Program 

Costs 

(millions 

2011$) 

24.9 53.4 90.7 123.0 155.3 187.6 215.3 238.2 

Annualized 

Participant 

Costs 

(millions of 

2011$) 

24.9 53.4 90.7 123.0 155.3 187.6 215.3 238.2 

9.3.4 Summary of General Formulas and Results by Step for South Carolina 

Table 31 provides results for South Carolina for each step. 

Table 31. Summary of Results by Step for South Carolina. 

Year 

2020 2021 2022 2023 2024 2025 2026 2027 

Total FirstYear Costs 

(millions 

2011$) 

423.4 486.6 634.5 550.6 550.1 549.6 549.2 549.2 

Total LCSE 

(2011$/MWh) 129.2 103.3 103.3 77.5 77.5 77.5 77.5 77.5 

Annualized 

Total Costs 

(millions 

2011$) 

49.7 106.9 181.4 246.0 310.6 375.1 430.7 476.4 
73 

9.4 Results 

9.4.1 Summary of National Results 

Tables 32 and 33 provide the national first-year and annualized EE costs for the best 

practices EE scenario for 2020, 2025, and 2030. Table 34 provides the estimated national LCSE 

for the same years. Each of the three tables includes values for program, participant, and total 

costs. 

Table 32. First-Year Demand-Side EE Costs (billions 2011$) 

(Continental U.S.) 

Year 

2020 2025 2030 

Program 9.1 12.7 12.7 

Participant 9.1 12.7 12.7 

Total 18.1 25.4 25.3 

Table 33. Annualized Demand-Side EE Costs (3% discount rate, billions 2011$) 

(Continental U.S.) 

Year 

2020 2025 2030 

Program 1.1 8.4 13.2 

Participant 1.1 8.4 13.2 

Total 2.1 16.7 26.3 

Table 34. Levelized Cost of Saved Energy (3% discount rate, 2011$/MWh) 

(Continental U.S.) 

Year 

2020 2025 2030 

Program 46.0 43.1 40.3 

Participant 46.0 43.1 40.3 

Total 92.0 86.3 80.5 

Full calculations and results are presented for all states for all years in the spreadsheet file 

included as Appendix 3. The file includes results for LCSE (total, program and participant, 

discounted at 3% and 7%), first-year costs (total, program and participant), and annualized costs 

(total, program and participant, discounted at 3% and 7%). 
74 

9.4.2 Results in Context 

To provide context for the pace of increase in EE program spending levels represented by 

the demand-side EE plan scenario, we consider the compound annual growth rate (CAGR) of the 

recent rapid increase in historic investment (2006 to 2011) and the CAGR from 2013 (the most 

recent historic value) through 2020, 2025, and 2030 represented by program costs of the plan 

scenario. Historic data is from Table 2 and EE plan scenario data is from Table 32. Table 35 

provides a summary of the results. The CAGRs represented by the EE plan scenario through 

2020, 2025, and 2030 vary from 4% to 6%. The historic growth rate reflecting the rapid recent 

growth in EE program spending is 30%, roughly six times the EE plan scenario values. The pace 

of increase in EE program spending represented by the demand-side EE plan scenario is modest 

and much lower than recently achieved increase in spending. 

Table 35. Annual Growth Rates of Demand-Side EE Program Spending – Historic and 

Demand-Side EE Plan Scenario 

Time Period (Years) Compound Average Growth Rate 

Historic (2006-2011) 29.8% 

Demand-Side EE Plan Scenario (2013-2020) 5.4% 

Demand-Side EE Plan Scenario (2013-2025) 6.0% 

Demand-Side EE Plan Scenario (2013-2030) 4.2% 

9.4.3 Costs per Tonne CO2 Reduced 

For the CPP proposed rule, the EPA analyzed a scenario incorporating the reductions in 

electricity demand associated with the proposal’s “EE scenario” and compared the results with 

the base case scenario (EPA 2014a). Both analyses were conducted using the Integrated Planning 

Model (IPM) described in RIA. Combining the resulting power system cost reductions with the 

energy efficiency cost estimates associated with the EE scenario, net cost impacts were derived 

for 2020, 2025, and 2030. Dividing these net cost impacts by the associated CO2 reductions for 

each year, the average cost of the CO2 reductions achieved were found to range from $16 to $24 

per metric tonne of CO2. These results confirmed the general cost-effectiveness of demand-side 

EE at the levels and costs of the proposal, and relative to the IPM base case used at that time 

(since updated). The final rule incorporates changes to the IPM base case, and the levels 

(significantly lower) and costs (higher in 2020, lower in 2025 and 2030) of demand-side EE 

incorporated into the illustrative plan scenario. These changes are likely to result in similar or 

Deleted: performance
75 

lower average costs per tonne of CO2 achieved through the demand-side EE plan scenario in the 

final rule. 

10. Analysis Considerations 

Two considerations are worth noting in regards to the analysis described in the previous 

two sections (9 and 10) which characterize the energy savings and costs of the demand-side EE 

plan scenario: 1) the implicit representation of demand-side EE policies and programs in the base 

case electric demand forecast and 2) Form EIA-861 as a data source. 

10.1 State EE Policies in the Baseline Electricity Demand 

The AEO 2015 reference case provides the basis for the base case electric demand 

forecast used for EPA’s power sector modeling of the final rule (as discussed in the RIA) and 

also serves as a basis for estimates of electricity savings for the demand-side EE plan scenario. 

The AEO 2015 reference case does not explicitly represent existing EE programs, the 

continuation of EE programs or policies, or future requirements (e.g., EERS) to achieve savings 

through such programs. For example, existing state EERS are not evaluated and represented in 

the AEO 2015 reference case. However, to some degree, AEO 2015 may implicitly reflect a 

continuation of the effects of past or existing EE programs in the electricity demand projections 

represented in the reference case. This implicit representation is captured in part through a 

calibration process that is affected by several historic factors including reported electricity sales 

and sectoral energy consumption surveys. 

As noted, the estimates of electricity savings for the demand-side EE plan scenario do 

rely on AEO 2015 as a basis for base case electricity demand projections. The underlying 

mechanics of the calculations are such that modest changes in base case demand growth rates 

lead to minor impacts on cumulative savings levels relative to other inputs such as 2020 starting 

savings levels (based on 2013 EIA 861 data), the target savings level (i.e., 1.0% incremental 

annual savings), and the pace of improvement from the starting to target savings levels (i.e., 

0.2% per year). Any implicit representation of the effects of existing EE programs in the base 

case demand forecast would also, to some degree, affect estimates of the impacts of the final rule 

in the RIA. The effects of these considerations would have some degree of influence on the 

assessment of demand-side EE, however, for purposes of the RIA, the methodology for 
76 

determining levels of demand-side EE, and associated costs, is appropriate in the context of the 

final rule. 

10.2 Energy Information Administration Form EIA-861 as Data Source 

Comprehensive national data on electricity savings are limited for evaluating and 

comparing energy efficiency programs and their effectiveness at the utility, state, and national 

scale. Issues related to the lack of standardized definitions and reporting, and data quality are 

noted to limit evaluation of EE programs (MJ Bradley 2011). The EIA Form 861, “Annual 

Electric Power Industry Report,” remains the most comprehensive effort that collects data 

annually on demand-side management (DSM) programs, including their spending and energy 

savings impacts, nationally.40 The form is requested for electric utilities, electric power 

producers, energy service providers, wholesale power marketers, and all DSM program 

managers and entities responsible to estimate the DSM activity for the reporting year using their 

best available data, including costs and electricity savings from EE and load management 

programs. 

This analysis uses only two EIA-861 data variables. Specifically, we use the 2013 sales 

data and reported incremental annual electricity savings of EE programs to estimate the current 

performance of EE programs (aggregated to the state level) to inform the illustrative demandside EE plan scenario discussed in this chapter. 

EPA notes potential concerns associated with consistency and quality of reported DSM 

program data in Form EIA-861. Specifically, the data are self-reported by utilities and other 

DSM program administrators. The definitions and data categories may not be consistently 

applied across different program administrators, utilities, and states, and may vary by data year. 

Over time, however, the data quality has improved significantly and there is increased 

standardization in data reporting and more detailed and up-to-date data categories are being 

reported. For instance, in 2011, EIA began collecting data from third-party administrators of 

programs and now requires that entities operating programs in multiple states report results 

disaggregated to the state level. While now comprehensive, outside entities have found that the 

                                                            

40 More information on EIA Form 861 can be found at http://www.eia.gov/electricity/data/eia861/. 
77 

EIA-861 data can be improved through supplementation with publicly available annual EE 

program reports.41

                                                            

41 See, for example, ACEEE 2014c and CEE 2015. 
78

Appendices 

Appendix 1: 

Summary of Recent Energy Efficiency Potential Studies (2009-2014) 

Appendix 2: 

Incremental Electricity Savings Pace of Improvement Analysis 

Appendix 3: 

Demand-Side Energy Efficiency Plan Scenario: Data, Calculations and Results 
79

Appendix 1: 

Summary of Recent Energy Efficiency Potential Studies (2009-2014) 

The EPA conducted an extensive review of energy efficiency potential studies of 

electricity savings. Studies were identified from recent published meta-analyses (Sreedharan 

2013; ACEEE2014b) and supplemented with additional studies identified through research. 

Comprising results from more than 50 potential studies conducted between 2009 and 2014, the 

resulting database of results is one of the most comprehensive of its kind. 

See the attached file for detailed information on the sources, data, calculations, and 

results: 

 GHG Abatement TSD – Demand-Side EE Potential Studies.xlsx 
80

Appendix 2: 

Incremental Electricity Savings Pace of Improvement Analysis 

This appendix summarizes and analyzes data to characterize the pace of improvement of 

incremental (or first-year) savings as a percentage of retail sales for electricity energy efficiency 

(EE) programs. We considered two different perspectives: 1) historical data reflecting achieved 

savings of EE programs and 2) requirements of existing state energy efficiency resource 

standards (EERS). For the historical perspective, we reviewed data from the Energy Information 

Administration’s Form EIA-861 on EE program electricity savings (supplemented as needed 

with program administrator reports) and identified the pace at which entities reaching higher 

savings levels have historically increased energy savings over time.42 Specifically, we reviewed 

the historical savings data in the following two groups of energy efficiency program 

administrators. 

1. Top saver 1% - a group with 47 entities that achieved a maximum first-year savings 

level of 0.8% to 1.5%. 

2. Top saver 2% - a group with 26 entities that achieved a maximum first-year savings 

level of 1.5% to 3.0%.43

For the existing state requirements perspective, we reviewed energy savings ramp-up 

schedules established under EERS for states that provide clear ramp-up schedules. According to 

ACEEE’s 2013 State Energy Efficiency Scorecard, there are a total of 26 states that have 

mandatory EERS policies (ACEEE 2013a). Our analysis contains 10 states for which clear rampup schedules were identifiable. 

Our research findings on historical savings performance are: 

 The “Top Saver 1%” group (savings between 0.8% and 1.5%) exhibits a trend that 

these entities took or would take about 3.4 years on average to increase first-year 

                                                            

42 The EIA 861 was the main data source (EIA 2012a). However, we have supplemented the EIA 861 with third-party program 

administrator data because the EIA 861 just started to collect third-party administrator data in 2011. The third-party entities

included in our analysis are Efficiency Vermont, Energy Trust of Oregon, Efficiency Maine Trust, and Cape Light Compact. In 

addition, we supplemented the EIA 861 database with additional data for two utilities that we found achieved high energy 

savings, but did not report savings data in the EIA 861 data for one or two years. These entities are Burlington Electric and 

Massachusetts Electric Company (now part of National Grid). 

43 In addition to these maximum first-year savings thresholds, we screened program administrators for the following conditions: 

(a) the maximum savings levels occurs after the minimum savings levels; (b) sufficient amounts of increase in first-year savings 

are provided to evaluate reasonable ramp-up schedules to gain an incremental 1% first-year savings; and (c) savings data series

are continuous between the years for the minimum and maximum savings levels. 
81

savings by 1% (with a range of 1.6 years to 10 years) (see Table 2-1). The entities in 

this group have increased the level of first-year savings by 0.30% per year on average 

from their minimum to their maximum first-year savings levels (with a range of 

0.10% per year to 0.63% per year).44 

 The “Top Saver 2%” group (savings between 1.5% and 3%) exhibits a trend that took 

or would take about 2.6 years on average to increase savings by 1% (with a range of 

0.8 years to 7.3 years) (see Table 2-1). The entities in this group have increased the 

level of first-year savings by 0.38% per year on average from the minimum to the 

maximum first-year savings levels (with a range of 0.14% per year to 1.28% per 

year).45 

Table 2-1. Energy savings ramp-up trends in first-year savings 

for “Top Saver 1%” and “Top Saver 2%” groups 

 

Top Saver 1% Top Saver 2% 

Average Annual 

First-Year 

Savings Increase 

Estimated Years 

to Gain 

Incremental 1% 

Average Annual 

First-Year 

Savings Increase 

Estimated Years 

to Gain 

Incremental 1% 

Average 0.30% 3.4 0.38% 2.6 

Median 0.29% 3.4 0.34% 3.0 

Max 0.63% 1.6 1.28% 0.8 

Min 0.10% 10 0.14% 7.3 

# of sample entities 47 26 

Sources: EIA 2012a and third-party program administrator data 46 

Our research findings on incremental electricity savings ramp-up based on existing state 

EERS policies are: 

                                                            

44 This is a simple average estimate of the annual average increase in first-year savings from each entity in this group. 45 This is the simple average estimate of the annual average increase in first-year savings from each entity in this group. 46 Data sources: The EIA 861 was the main data source (EIA 2012a). However, we have supplemented the EIA 861 with thirdparty program administrator data because the EIA 861 just started to collect third-party administrator data in 2011. The thirdparty entities included in our analysis are Efficiency Vermont, Energy Trust of Oregon, Efficiency Maine Trust, and Cape Light 

Compact. In addition, we supplemented the EIA 861 database with additional data for two utilities that we found achieved high 

energy savings, but did not report savings data in the EIA 861 data for one or two years. These entities are Burlington Electric 

and Massachusetts Electric Company (now part of National Grid). 
82

 The states with EERS policies which exhibit savings ramp-up schedules are requiring 

increases in first-year energy savings at a pace that ranges from 0.11% (Colorado and 

Oregon) to 0.40% (Rhode Island) as shown in Table 2-2. 

 The first-year savings pace of increase averages 0.21% per year across the 10 states. 

This savings level translates to about 4.7 years to achieve an incremental 1% firstyear savings increase. 

Table 2-2. First-Year Energy Savings Ramp-up Review of State EERS Policies 

State 

Minimum Target Maximum Target Climb 

Time 

(years) 

Annual 

Average % 

Increase 

Years to 

Achieve 1% 

Min Year Max Year Increase 

 a b c d e=d-b f=(c-a)/e g=1/f 

Arizona 1.25% 2011 2.5% 2016 5 0.25% 4.0 

Arkansas 0.25% 2011 0.9% 2015 4 0.16% 6.2 

Colorado 0.80% 2011 1.7% 2019 8 0.11% 9.3 

Illinois 0.20% 2008 2.0% 2015 7 0.26% 3.9 

Indiana 0.30% 2010 2.0% 2019 9 0.19% 5.3 

Massachusetts 1.4% 2010 2.6% 2015 5 0.24% 4.2 

Michigan 0.3% 2009 1.0% 2012 3 0.23% 4.3 

Ohio 0.3% 2009 1.2% 2019 10 0.17% 5.9 

Oregon 0.8% 2010 1.0% 2013 3 0.07% 15.0 

Rhode Island 1.7% 2011 2.5% 2013 2 0.40% 2.5 

Average 0.21% 4.8 

Sources: ACEEE 2014c and APSC 2013 
83

Appendix 3: 

Demand-Side Energy Efficiency Plan Scenario: Data, Calculations and 

Results 

See attached files for comprehensive data, calculations, and results supporting the 

illustrative demand-side energy efficiency (EE) plan scenario. These files address the magnitude 

and timing of savings, and the assessment of costs of the demand-side energy efficiency included 

in the illustrative plan scenario of the Regulatory Impacts Assessment (RIA). The two files 

reflect costs discounted at 3% and 7%, respectively: 

 GHG Abatement Measures TSD – Demand-Side EE @ 3%.xlsx 

 GHG Abatement Measures TSD – Demand-Side EE @ 7%.xlsx 
84

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not RFF 2010.  

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