# WRAP Policy

Renewable Energy and Energy Efficiency As Pollution Prevention Strategies For Regional Haze

Prepared by the

Air Pollution Prevention Forum For the Western Regional Air Partnership

April 2003i 

### Executive Summary

The Regional Haze Rule (Rule) requires each state t o prepare a State Implementation Plan (SIP) and includes a separate section (Section 51.309) which allows the nine states that participated in the Grand Canyon Visibility Transpo rt Commission (GCVTC) to base their SIPs on the regional recommendations of the GCVTC. Trib es wishing to assume the regional haze requirements outlined in the Rule may, according to the Tribal Authority Rule (TAR), seek approval under 40 CFR 49 to be treated in the same manner as States. Tribes may adopt Tribal Implementation Plans (TIPs) that include all of the Section 308 or 309 provisions of the Regional Haze Rule or only “severable” provisions applicable to their specific situation.

The Western Regional Air Partnership (WRAP) was est ablished by western states and tribes to coordinate and oversee implementation of the GCVTC recommendations and provide policy and technical tools to assist states and tri bes in filing regional haze implementation plans. The GCVTC concluded that renewable energy and energ y efficiency measures could result in “emissions reductions, improvements in visibility a nd provide secondary environmental and economic benefits to the region.” Accordingly, EPA requires states choosing to file a SIP under Section 309 to include descriptions of programs and policies each state will rely on to “preserve and expand energy conservation efforts” and to con tribute to meeting the regional goal for renewable energy established by the GCVTC. 1

The WRAP created the Air Pollution Prevention Fo rum (AP2 Forum) to develop policies and programs states and tribes could adopt to demonstrate progress towards achieving the GCVTC 10/20 renewable energy goal and to increa se the use of energy efficiency in the nine state GCVTC region.

The AP2 Forum and its Tribal Issues Committee devel oped energy efficiency and renewable energy policy and program recommendations for states and tribes over a three-year period. In addition, the AP2 Forum commissioned I CF Consulting Group to conduct a regional analysis of the emissions and economic impacts of i mplementing the AP2 Forum’s policy and program recommendations. The results of the region al modeling analysis, which apply to both states and tribes, demonstrated energy efficiency a nd renewable energy could result in emissions reductions, improvements in visibility, energy cost s savings and provide secondary environmental and economic benefits to the region.

The WRAP has not specifically adopted every one of the 40-plus policy and program recommendations developed by the AP2 Forum in this policy statement. However, the WRAP Policy is informed by and embodies the results of t he AP2 Forum’s examination of barriers, policy analysis, economic modeling results and reco mmended policies and programs to increase

1 The GCVTC recommended that “[t]he goal of the state s in the Transport Region should be to achieve annual additions in order that renewables will comp rise 10% of the regional power needs by 2005 and 20 % by

2015.”ii

the use of energy efficiency and renewable energy i n the GCVTC region. Based on the AP2 Forum’s modeling, it can also reaffirm conclusions of the GCVTC that found “renewable energy and energy efficiency measures could result in emis sions reductions, improvements in visibility and provide secondary environmental and economic be nefits to the region.”

It is the policy position of the WRAP that state an d tribal implementation of both renewable energy and energy efficiency policy and p rogram recommendations of the AP2 Forum, as appropriate to circumstances within each jurisdiction will reduce emissions and electricity production costs in the region, will re sult in a larger emissions benefit than either measure by itself, and will contribute to fulfillin g the SIP and TIP requirements of the Regional Haze Rule. The most significant progress towards m eeting the GCVTC renewable energy goals and increasing the use of energy efficiency in the region is accomplished through the adoption of state and tribal policies that provide financial in centives. States and tribes in the WRAP region should also adopt complementary polices that will i mprove the efficiency of the market place. Finally, the WRAP acknowledges that federal policie s and regional actions have important roles in removing market barriers and increasing the deve lopment of renewable energy and deployment of energy efficiency technologies and pr actices in the WRAP region.

The policy adopted by the WRAP is purposely broad. The WRAP acknowledges state and tribal diversity in the nine state region and r ecognizes that circumstances unique to each jurisdiction such as climate, culture, social, econ omic, regulatory and political conditions will dictate which policies and programs recommended by the WRAP and AP2 Forum are most appropriate for individual states and tribes. Acco rdingly, the WRAP’s policy statement should be viewed as guidance for the region as a whole. A s individual circumstances warrant, states and tribes may use these policy statements to provide a regional context in developing renewable energy and energy efficiency policies and programs that are appropriate to use in their individual implementation plans for regional haze.iii 

### Table of Contents

Page

Executive Summary

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Table of Contents

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WRAP Policy on Renewable Energy and Energy Efficien cy - - - - - - - - - - - - - - - 1

Background

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Grand Canyon Visibility Transport Commission - - - - - - - - - - - - - - - - - - - - - - - - - 4

Regional Haze Rule: Renewable Energy and Energy Eff iciency - - - - - - - - - - - - - - - 5

Western Regional Air Partnership - - - - - - - - -

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Air Pollution Prevention Forum - - - - - - - - - -

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Findings of the Air Pollution Prevention Forum - - - - - - - - - - - - - - - - - - - - - - - - 8

Renewable Energy - - - - - - - - - - - - - - - - -

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Energy Efficiency - - - - - - - - - - - - - - - -

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Regional Emissions and Economic Impact Analysis - - - - - - - - - - - - - - - - - - - - - - 12 Regional Generation Capacity

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Emissions Reductions

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Policy Recommendations of the Air Pollution Prevent ion Forum - - - - - - - - - - - - 17

Renewable Energy Policies for States and Tribes - - - - - - - - - - - - - - - - - - - - - - - - - 17 Specific Tribal Recommendations

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Energy Efficiency Policies for States and Tribes -

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Appendices

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Appendix I – Pollution Prevention 51.309(d)(8) - - - - - - - - - - - - - - - - - - - - - - - - - - 28

Appendix II – Membership of the Air Pollution Preve ntion Forum - - - - - - - - - - - - - - 29

Appendix III – Meetings of the AP2 Forum - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 29iv

Appendix IV – Reports of the AP2 Forum - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 30

Appendix V – List of Energy Efficiency “Best Practi ces” - - - - - - - - - - - - - - - - - - - - 31

Appendix VI – Energy Efficiency “Best Practices: C osts of Saved Energy - - - - - - - - 331 

### WRAP Policy on Renewable Energy and Energy Efficien cy

The policy and program recommendations the AP2 Foru m have been developed over a three-year period through a stakeholder-based conse nsus process. As is the expectation of all WRAP forums, the objective of the AP2 Forum was to provide a policy, program and analytical

framework that would be available for states and tr ibes to consider in responding to the SIP and TIP requirements of the Pollution Prevention section of the Regional Haze Rule. Informed by the findings and recommendations of the AP2 Forum, the WRAP Board adopted and issued a policy finding on energy efficiency and renewable e nergy as pollution prevention strategies for regional haze at a meeting of the Board on November 13, 2002. In issuing its policy WRAP did not explicitly adopt every one of the 40-plus polic y and program recommendations developed by the AP2 Forum. However, the WRAP policy on renewab le energy and energy efficiency is informed by and embodies the results of the AP2 For um’s three-year examination of barriers, policy analysis, emissions and economic modeling re sults, and recommended policies and

programs.

WRAP Policy

Following on the findings of the Grand Canyon Visib ility Transport Commission and the (GCVTC), the WRAP finds that energy efficiency and renewable energy can be effective tools to reduce regional haze and, if adopted by states a nd tribes in the Transport Region, could result in emissions reductions, improvements in visibility , energy costs savings and provide secondary environmental and economic benefits to the region. The WRAP expects these tools will be implemented by states and tribes in a manner consis tent with local economic, regulatory, political conditions and in a way that protects cul tural resources unique to these jurisdictions.

The WRAP believes that states and tribes 2 can make progress towards meeting the GCVTC 10/20 renewable energy goal 3 and increase the use of energy efficiency technolo gies in the Grand Canyon Visibility Transport region, and adopt s the following policy statements:

1. Joint implementation of the AP2 Forum’s renewable e nergy and energy efficiency policy and program recommendations will reduce emissions a nd electricity production costs in the region, will result in a larger emissions benef it than either measure by itself, and will contribute to meeting the SIP and TIP requirements of Section 309(d)(8).

2 Under the Regional Haze Rule (40 CFR 51.309(d)(12) ) and the Tribal Authority Rule (40 CFR 49.1-49.11) , tribes within the Grand Canyon Visibility Transport Region may, but are not required to, receive delegation o f federal authority to adopt Tribal Implementation Plans (TIP s) under Section 308 or 309 of the Regional Haze Ru le. Tribal selection of Section 308 or 309 is independent of t he strategy adopted by the state(s) in which the tr ibe is located. In addition, tribes may apply for approval of “reasona bly severable” elements of Clean Air Act programs. Further, deadlines for plan submittal that apply to states d o not apply to tribes. Where a tribe opts not to develop a TIP, EPA may work with the tribe to adop a Federal Implemen tation Plan (FIP) if necessary and appropriate to p rotect air quality.

3 The GCVTC goal is: 10 percent of generation from r enewable resources in 2005 and 20 percent in 2015. With respect to the requirements of Section 309(d)(8), a chieving the 10/20 goal is not mandatory or “enforc eable.”. This

section of the rule does establish an “enforceable” requirement for States “to assess progress toward a goal established by the GCVTC with respect to renewable energy”. To the extent they are not able meet the goal, States are required to provide an explanation of why the g oals cannot be met. See Federal Register, Vol. 64, No. 126, page 35754, July 1, 1999. Regional Haze Regulations Final Rule.2 2. State and federal economic incentives and policy ch anges are necessary if states and

tribes are to successfully make progress towards me eting the GCVTC 10/20 renewable energy goal (10 percent of generation will come fro m renewable energy by 2005 and 20 percent by 2015) and increase energy efficiency in the Transport Region.

3. Electricity consumers in the Transport Region shoul d be given the opportunity to choose renewable electricity products and services through viable green marketing or green pricing programs.

4. States and tribes should take policy actions to imp rove the efficiency of the market place, such as providing 1) access to information about th e price, sources of power and environmental impacts of their power purchases, and 2) accurate price signals.

5. States and tribes should: encourage utility and/or State sponsored demand side management programs; develop minimum energy efficie ncy standards for buildings; and modify regulatory approaches to include in SIPS and TIPS credit for emissions reductions of criteria pollutants from energy effic iency measures.

6. Actions should be taken to reform transmission acce ss, pricing and interconnection policies that create barriers to the movement of re newable energy generation from
generators to customers.

7. An emissions cap-and-trade program is an economical ly efficient method of achieving emissions reductions and provides economic incentiv es to develop renewable energy generation and energy efficiency measures.

8. Some policies are more effective if implemented on a regional scale. States, tribes and regional energy organizations should act in concert to: establish a regional institution for issuing and trading renewable energy certificates; institute a regional generation tracking system; reform transmission management practices th at discriminate against intermittent renewable resources; and participate in energy effi ciency market transformation

programs.

9. States and tribes should support Federal policies t hat would increase development of renewable energy in the Transport Region including extension of the federal production tax credit for wind, biomass and geothermal through 2015, or until these renewable energy resources become cost-competitive in the reg ion.

10. States and tribal governments and federal agencies should “lead-by-example” by becoming early adopters of renewable energy and ene rgy efficient products, services, and practices in a manner that protects cultural resour ces.

In consideration of the above policy on renewable e nergy and energy efficiency, the WRAP forwards the following Management Directive to the Initiatives Oversight Committee:3 1. Forward the recommendations and reports of the Air Pollution Prevention Forum to states

and tribes for their consideration and use in the d evelopment of State/Tribal Implementation Plans for regional haze;

2. Provide states and tribes who follow the 309 path w ith technical assistance (including data, information, analytical tools) and policy ass istance (including model legislation, rules and policies) needed to incorporate the renew able energy and energy efficiency

recommendations of the AP2 Forum into the Pollution Prevention section of their regional haze SIPs and TIPS;

3. Monitor the Transport Region’s progress towards ach ieving the GCVTC 10/20 renewable energy goal and implementation of the renewable ene rgy and energy efficiency recommendations of the AP2 Forum; and,

4. Assist the efforts of Western states and tribes to establish a single institution in the WRAP region that will register, certify, issue, tra ck and oversee trading of renewable energy certificates in the west.

The policy adopted by the WRAP is purposely broad. The WRAP acknowledges state and tribal diversity in the nine-state region and r ecognizes that circumstances unique to each jurisdiction such as climate, culture, social, econ omic, regulatory and political conditions will dictate which policies and programs recommended by the WRAP and AP2 Forum are most appropriate for individual states and tribes. Acco rdingly, the WRAP’s policy statement should be viewed as guidance for the region as a whole. A s individual circumstances warrant states and tribes may use these policy statements to provide a regional context in developing renewable energy and energy efficiency policies and programs that are appropriate to include in their individual implementation plans for regional haze.4



### Background

Grand Canyon Visibility Transport Commission

In 1977 Congress established provisions to improve visibility in 156 national parks and wilderness areas across the United States as part o f the Clean Air Act Amendments of 1977 (Act). Congress further addressed visibility in we stern Class I areas in creating the Grand Canyon Visibility Transport Region (Transport Regio n) and directing EPA to establish the Grand Canyon Visibility Transport Commission (GCVTC) to a ddress haze causing pollutants in a nine state region whose emissions affect visibility in t he Grand Canyon. 4 The Commission was charged with making recommendations on how to prote ct and improve visibility in 16 national parks and wilderness areas on the Colorado Plateau.

In 1996, after 5 years of technical assessment and policy development, the Commission issued its report to EPA recommending a suite of 12 emissions control strategies that, if adopted as a single package, would improve visibility throu ghout the Colorado Plateau. 5

The report concluded that although the GCVTC did no t have the resources necessary to “model or completely quantify the effects” of renew able energy and energy efficiency on visibility, if implemented these measures could res ult in “emissions reductions, improvements in visibility and provide secondary environmental and economic benefits to the region.” 6 With regard to renewable energy 7 , the GCVTC recommended that “[t]he goal of the sta tes in the Transport Region should be to achieve annual additi ons in order that renewables will comprise 10% of the regional power needs by 2005 and 20% by 2015” (the 10/20 goals). The GCVTC also found there was an opportunity to realize visi bility improvements from energy efficiency. 8

4 The Commission was comprised of the governors of ei ght states (Arizona, California, Colorado, Nevada, New Mexico, Oregon, Utah, and Wyoming) as well as the President of the Navajo Nation, the Chairman of the Hopi Tribe, the Pueblo of Acoma Governor., Columbia River Inter-Tribal Fish Commiss ion, the Hualapai tribe and ex-officio members from the Environmental Protection Agency, the Bureau of Land Management, t he National Park Service, the U.S. Forest Service a nd the U.S. Fish and

Wildlife Service.

5 Report of the Grand Canyon Visibility Transport Com mission to the U.S. Environmental Protection Agency : Recommendations for Improving Western Vistas , June 10, 1996.

6 Ibid, pg.28

7 The Air Pollution Prevention Forum adopted the foll owing definition of renewable energy. "Renewable energy" is defined as electricity generated by non-nuclear and non-fossil low or no air emission technologies usi ng resources that are virtually inexhaustible, reduce haze, and are environmentally beneficial. The term includes e lectricity generated by wind energy technologies; solar photov oltaic and solar thermal technologies; geothermal t echnologies; technologies based on landfill gas and biomass sour ces, and new low-impact hydropower that meets the L ow-Impact Hydropower Institute criteria. Biomass includes agr icultural, food and wood wastes. The term does not include pumped storage or biomass from municipal solid wast e, black liquor or treated wood.

8 “The Commission supports the continued development and implementation of national energy efficiency standards for motors, appliances and lighting and r ecommends the national adoption of the California e nergy efficiency standards 8 . The Commission also supports the construction of energy efficient buildings, both residential and commercial, and proposes the reinst atement of incentives for building energy efficient

structures....The Commission also suggests the continuation of demand -side management programs, despite current funding restrictions. The Commission recomm ends that continuing attention be paid to maintaini ng the role of energy conservation within the changing electric power industry markets. Energy conservat ion programs should be preserved and expanded through s uch mechanisms as “system benefit charges” paid at5

Regional Haze Rule and Renewable Energy and Energy Efficiency

In July 1999, the Environmental Protection Agency i ssued its final regional haze regulations. 9 The final “Regional Haze Rule” requires each stat e to prepare a State Implementation Plan (SIP) for regional haze and inc ludes a separate section (Section 51.309) which allows the nine Transport Region states (Ariz ona, California, Colorado, Idaho, Nevada, New Mexico, Oregon, Utah, and Wyoming) to implement a regional approach to reducing haze and base their SIPS on the regional recommendations of the GCVTC. 10 As provided by the “tribal authority rule 11 ,” (TAR) eligible tribes may implement Clean Air Ac t programs to protect
air resources “within the exterior boundaries of th e reservation or other areas within the tribe’s jurisdiction.” Tribes too, may choose to participa te in the regional approach granted to the states in the Transport region and submit a Tribal Impleme ntation Plan (TIP) containing elements

described in section 51.309.

States choosing to pursue the 309 path are required to include a variety of information addressing energy efficiency programs, renewable en ergy production and consumption, and descriptions of programs and policies each state wi ll rely on to contribute to meeting the GCVTC’s regional goal for renewable energy. The r equirements of the regional haze rule regarding energy efficiency and renewable energy ar e found in 40 CFR 51.309(d)(8). This section addresses the GCVTC’s recommendations on po llution prevention, renewable energy, energy efficiency and conservation. With respect t o renewable energy and energy efficiency Section 51.309(d)(8) requires each state SIP to pro vide:

• A description of the programs relied on to achieve the State's contribution to the Commission's goal that renewable energy will compri se 10 percent of the regional power needs by 2005 and 20 percent by 2015 (10/20 goal).

• A demonstration of the progress toward achievement of the renewable energy goals in the years 2003, 2008, 2013, and 2018.

• A summary of programs to preserve and expand energy conservation efforts.

• Projections of the short- and long-term emissions r eductions, visibility improvements, cost savings, and secondary benefits associated with the renewable energy goals, energy efficiency and pollution prevention activities.

The GCVTC goal is: 10 percent of generation from renewable resources in 2005 and 20 percent in 2015. With respect to the requirements of Section 309(d)(8), achieving the 10/20 goal is not a mandatory, enforceable requirement. This section of the rule does establish an “enforceable” requirement for States “to assess pro gress toward a goal established by the GCVTC with respect to renewable energy”. To the ex tent they are not able meet the goal, States are required to provide an explanation of why the g oals cannot be met.

the distribution level....” Report of the Grand Canyon Visibility Transport Com mission to the United States Environmental Protection Agency , June 1996, pages 31-32.

9 Federal Register, Vol. 64, No. 126, pages 35714-35774 (July 1, 1999)

10 States other than those that participated in the G CVTC must utilize the rules and standards adopted b y EPA under

Section 308.

11 40 CFR Part 496 For tribes that choose to submit a TIP following th e GCVTC regional approach, the

content may contain elements similar or identical t o that just described for a Section 309 SIP. However, there is considerable flexibility in how, when, and whether a tribe may develop a TIP. Under the TAR, tribes are not subject to deadlines for TIPs, nor to sanctions if TIPS are not adopted. To encourage tribes to develop air-qualit y management programs, however, the TAR authorizes a modular approach to tribal programs; t hat is, tribes can build their technical and management capacity at the same time they begin to address concerns specific to their priorities. This modular approach provides several opportunitie s:

• Tribes can pick and choose among Clean Air Act prov isions to craft a program that addresses the tribe’s specific air-quality concerns

.

• The EPA can approve these modular programs provided that they do not depend on any other program element for enforceability.

• To encourage tribes to develop air quality manageme nt programs, grants are available from the EPA pursuant to Sections 103 and 105 of th e Clean Air Act.

Thus, it may be possible for a tribe to obtain EPA approval to implement renewable energy or energy efficiency measures, or both, as p art of a 309 TIP without implementing other parts of 309 which are not appropriate for the trib e.

Western Regional Air Partnership

Western Regional Air Partnership (WRAP) was establi shed in 1997 as the successor organization to the GCVTC. The WRAP was created by western states and tribes to coordinate and oversee the implementation of the recommendatio ns of the GCVTC and “identify regional or common air management issues, develop and implement strategies to address these issues, and formulate and advance western regional policy posit ions on air quality.” 12 WRAP policies, strategies and technical tools are developed throug h an inclusive stakeholder-based process that includes state air agencies, tribes, EPA, federal a nd state land management agencies, local government, industry, utilities, environmental grou ps, academia and other interested parties.

Air Pollution Prevention Forum

The Air Pollution Prevention (AP2) Forum was create d September 1998 by the WRAP’s Initiatives Oversight Committee (IOC) and charged t o:

“Recommend legislative actions, economic incentives and regulatory policies states can adopt to meet the 10/20 renewable energy goal and i ncrease the use of energy efficiency technologies in the Grand Canyon Visibility Transpo rt region.”

12 WRAP Charter,, Purpose, p. 1.7 As is the expectation of all WRAP forums, the objec tive of the AP2 Forum and its 25

members has been to provide the states and tribes o f the WRAP region with the policy and analytical framework needed to respond to the requi rements of the Pollution Prevention section of the Regional Haze Rule. 13 To accomplish this purpose the AP2 Forum’s work p lan called for

the Forum to:

• Examine barriers restricting the penetration of ren ewable energy, energy efficient technologies, and adoption of energy efficient prac tices in the Transport Region;

• Identify and evaluate economic incentives, legislat ive actions, and regulatory policies that will increase investments in renewable energy and e nergy efficiency, including actions currently underway in the Transport Region; and

• Recommend market-based incentives and public polici es that will support increased investment in renewable energy within the Transport Region and improve the efficiency of the region’s energy production and end-use secto rs.

The AP2 Forum’s policy and program recommendations have been developed over a three-year period through a stakeholder-based conse nsus process supported, in part, by nationally recognized renewable energy and energy efficiency e xperts, including the National Renewable Energy Laboratory. The Forum and workgroups held m ore than 11 meetings and workshops to examine barriers and identify policies that would l ead to increased investment in renewable energy and energy efficiency in the Transport Regio n. The Forum also commissioned ICF Consulting Group to analyze the potential emissions reductions, energy costs, and secondary environmental and economic benefits to the Transpor t Region of meeting the GCVTC 10/20 goal and implementing a suite of cost-effective energy e fficiency programs and policies the AP2 Forum identified as “best practices” for the region

.

As a result of its investigation the AP2 Forum prep ared seven reports that provide policy, analytical and technical support for the Forum’s po licy recommendations to the WRAP, states and tribes. These documents are listed in Appendix IV.

13 40 CFR 51.309(d)(8).8 

### Findings of the Air Pollution Prevention Forum

Renewable Energy

A substantial increase in power generation from ren ewable energy is needed for the Transport Region to attain the GCVTC 10/20 goal. I n 1999 the Transport Region supported 6,190 MW of renewable generation capacity, represen ting six percent of the regions electricity supply. Based on forecasts of demand for electrici ty in the region for the period 2001-2018, the AP2 Forum estimates that in order to meet the goal of 20 percent renewable energy generation in 2015 , over 20,000 MW of new renewable energy gener ation capacity will need to be brought on-line in the Transport Region over the next 16 ye ars .

The AP2 Forum finds that despite the enormous renew able energy potential of the West

there are a number of barriers that are preventing the greater use of renewable e nergy in the region. The biggest barrier renewable energy curre ntly faces is cost. With the exception of high quality wind resources, generation from renewables is, in most cases, more expensive than conventional electric technologies. Higher costs ca n be accounted for by market imperfections and other barriers renewables face. For example, e xisting tax structures penalize capitalintensive renewable energy technologies compared to competing conventional technologies. Current transmission pricing and access protocols p enalize intermittent generation resources such as wind and solar. Benefits of renewable energy, su ch as reduced environmental impacts, are not monetized in the power market and there is a lack o f information and consumer knowledge about electricity sources and their environmental impacts . Monopoly electricity providers are often not required to provide “choice” in sources of electric ity supplied to end-use consumers.

The Forum finds that the most significant progress towards meeting the 10/20 renewable energy goals can best be accomplished through the a doption of state policies which provide financial incentives for the production and consumption of renewable en ergy. The Forum believes that renewable portfolio standards (RPS) a nd system benefits charges (SBC) are the most effective state policy options for encouraging the growth of renewables. Other financial

incentives include state and federal tax incentives 14 , and State government agency renewable energy purchase requirements. Tribes may also find adoption of RPSs and SBCs useful policy tools in promoting renewable energy and may wish to consider these in the context of an overall tribal energy policy. Furthermore, since tribes gen erally don’t benefit from tax incentives, tribes may consider seeking alternative yet equitable ince ntives to encourage development of renewable energy on tribal lands (such as tribal bl ock grants).

The Forum finds that electricity customers who want to purchase renewable generated electricity should be given the option of purchasin g a percentage of their power from renewable energy through a viable green market or green pricing program . In order to improve the performance of these programs, states and tribes sh ould also adopt complementary policies that

will improve the efficiency of the marketplace and lower transaction costs for “green” electricit y products and services.

14 Including production tax incentives, personal and c orporate income tax credits, property tax incentive s and sales tax exemptions from purchases of renewable energy e quipment or electricity.9 In addition, complementary federal and regional policies are necessary to encourage

progress towards meeting the GCVTC 10/20 goal. The Forum finds that there are a number of federal policies and programs that can help the Tra nsport Region make progress in meeting the GCVTC 10/20 goal. There are also several necessary policies that, if implemented in conjunction with other public policies, are more ef fective on a regional scale. These include trading of renewable energy certificates and creati on of a generation tracking system for the western interconnected system.

States are already making progress toward implement ing the GCVTC’s recommendations including adoption of significant Renewable Portfol io Standards (e.g., 20 percent in California and 15 percent in Nevada and New Mexico), tax incen tives (e.g., Arizona, Idaho, Nevada, New Mexico, Oregon, Utah), green power purchase program s, and implementation of utility least-cost resource plans that include significant investments in renewable energy and demand side resources(e.g., PacifiCorp’s five state IRP and Ex cel in Colorado).

Tribal lands in the WRAP region have great potentia l for the development and delivery of electricity generated from renewable resources. Fur thermore, many tribes are interested in generating, selling, and using such electricity. Co nsequently, tribal energy programs can be significant contributors to the 10/20 goal. Substan tial barriers exist, however, to the full implementation of tribal opportunities for developm ent of renewable energy resources. For example, many tribes do not have an energy authorit y or an energy policy, and are consequently not well positioned to take advantage of opportunit ies related to renewable energy. Also, and of particular importance to rural residents, is the fu ndamental need for basic electric service or for reliable electric service. Because development of r enewable resources is a capital-intensive activity, access to capital can also be a significa nt barrier. Thus, while the potential to develop renewable energy exists, tribes with the desire to do so will face significant challenges beyond

those cited above for states.

The AP2 Forum has recognized that the special relat ionship of Indians Tribes and their lands within the federal framework has great bearin g on strategies to enhance renewable energy development. That is, tribal-state-federal relation s must be considered in their legal, economic, and cultural contexts when exploring the developmen t and delivery of electric energy across political boundaries. Because these relationships a re markedly varied, appropriate strategies will differ from tribe to tribe, and the concept of sett ing priorities among alternative strategies must be left to individual tribes. Tribes may select and pursue these strategies in the context of their overall goal of maintaining and strengthening their cultural, social, economic, and political integrity. The recommendations presented to tribes by the AP2 Forum represent a broad selection of opportunities from which the tribes in the WRAP region and their collaborators can choose according to their specific circumstances.10

Energy Efficiency

The Forum began its work on Energy Efficiency in Ju ne of 2000 with an initial examination of demographic and economic trends like ly to affect future electricity consumption in the WRAP region. Existing state and tribal poli cies were reviewed along with federal/state programs relating to energy efficiency, and opportu nities were identified to improve energy efficiency in the region’s economy. The Forum then identified market and institutional barriers that could restrict penetration of energy efficienc y technologies and conservation practices and developed a list of state policies and “best practi ces” that, if adopted by states and tribes would enable the region to increase the level of efficien cy in the production and end-use of electricity. Also developed was a set of recommendations specifi cally directed to tribal leaders that could foster implementation of energy efficiency on triba l lands. The impact these policies and energy efficiency programs and measures would have on regi onal emissions and energy costs were then

evaluated.

The AP2 Forum found that a wide range of cost-effec tive energy efficiency measures exist that provide a substantial opportunity to imp rove the efficiency of electricity use in the region. 15 However, there are also a number of barriers that prevent widespread penetration and use of energy efficiency technologies and adoption of energy conservation practices. 16

Adoption of energy efficiency measures in the econo my is a dynamic process involving interactions between technology, consumer behavior, market conditions, and public policy. Given the persistence of market barriers, the Forum finds that there are a number of important public policies and programs that can help overcome these barriers and increase market penetration of energy efficiency technologies in th e Transport Region’s economy. This can best be accomplished through financial incentives and ma ndatory energy efficiency standards. The Forum found there are other programs and policies t hat can help promote energy efficiency and conservation including consumer information and edu cation, utility and environmental regulatory policies, and utility rate reforms.

Western tribes have the potential to implement and, in some cases, to lead innovative programs that improve energy efficiency. This Forum recognizes the great diversity of tribal lands in the region and the inherent need for triba l governments to selectively pursue energyefficiency opportunities. For example, some tribes place a high priority on the need to provide

15 The AP2 Forum identified 43 programs and measures that represented “best” energy efficient practices in the region. No measure’s cost of “saved energy” excee ded $0.054/kWh and all measures taken together aver aged $0.0186/kWh of energy saved. By comparison, “avoid ed costs” for electricity from new gas-fired genera tion averages between $0.036 and $0.046 kWh. These measu res were not meant to represent all cost-effective options or all technically feasible energy efficiency options that would have environmental benefits. Rather the y represented a set of achievable, cost-effective programs that wou ld provide significant energy savings if a state ch ose to pursue a moderately ambitious level of energy efficiency.

16 Barriers include lack of consumer awareness and li mited access to information about energy efficient products, services and effectiveness of energy efficiency mea sures in reducing energy use and costs; emphasis on lowest first cost in purchasing equipment or constructing buildi ngs; limited product availability in the marketpla ce; energy price distortions, e.g. “average cost” pricing of electricity prevents consumers from seeing the true costs of electricity use; and competition for limited intern al investment capital results in business decisions to invest in energy efficiency being delayed or poorly executed.11

basic reliable electric service to their residents and businesses; there are innovative opportunities for energy conservation measures in the design and development of these services. Other tribes fully-served with reliable electricity may want to concentrate on improving the efficiency of electricity applications. Virtually every tribe may be interested in the economic benefits offered by energy-efficiency programs as well as the relate d social and cultural benefits. With potential cost savings on electricity expenditures (as well a s other energy sources) on the order of 15% to 50%, energy-efficiency programs and policies could have a significant positive impact that extends beyond air quality and economics to tribal sovereignty, energy independence, and increased revenues to fund other tribal priorities. The Forum recommendations offer a broad selection of options from which tribes in the WRAP region can choose according to their specific

circumstances.12

Regional Emissions and Economic Impact Analysis

In its 1996 report, the Grand Canyon Visibility Tra nsport Commission (GCVTC) recommended future modeling work be conducted to an alyze the potential emissions reductions, visibility improvements, costs savings, and seconda ry benefits associated with the use of renewable energy and energy efficiency. 17 The AP2 Forum commissioned ICF Consulting to conduct modeling analysis using policy scenarios an d cost assumptions developed by the Forum. This analysis was conducted to help the AP2 Forum u nderstand the potential emissions reductions, costs and secondary regional economic i mpacts of implementing the 10/20 goals and the energy efficiency recommendations. The AP2 For um developed two types of scenarios in order to examine the emissions, costs and secondary regional economic impacts of meeting the 10/20 goals and implementing the energy efficiency recommendations

.

17 Report of the Grand Canyon Visibility Transport Com mission to the U.S. Environmental Protection Agency : Recommendations for Improving Western Vistas , June 10, 1996, pg. 29.

P h a s e III: M o d e lin g o f S e c o n d a ry E c o n o m ic Im p a c t R E M ITM M o d e lin g

• S e co n d a ry re g io n a l e co n o m ic im p a cts
 E m p lo ym e n t Im p a cts

 G ro ss R e g io n a l P ro d u ct Im p a cts
 In co m e Im p ac ts 

### W R E c o n o m ic Im p a c ts o f Im p le m e n tin g a R e g io n a l S O 2 E m is s io n s P r o g r a m in th e G ra n d C a n y o n V is ib ility T r a n s p o r t R e g io n

V o lu m e I

P re p are d fo r:

W es ter n R e g io n al A ir P a r tn e r s h ip M a r k et T ra d in g F o r u m

P re pa re d b y:

IC F C o n su ltin g

Se p te m b e r 2 0 0 0 W R A P /M T F E c o n o m ic A n a ly s is

• S e rv ed a s s ta rtin g p o in t fo r a n a lysis

• A P 2 se le cte d A n n e x S c e n a rio a s
B u sin e ss -A s -U su a l s ce n a rio

P h a s e I: A s su m p tio n s a n d S c e n a rio D e ve lo p m e n t A P 2 F o ru m

• R e v ie w ed a n d re v ise d a ss u m p tion s for re n e w a b le e n e rg y te c h n o lo g y

• D e v e lo p e d e n e rg y e fficie n cy c o s t a n d p e rfo rm a n ce a ssu m p tio n s

• D e v e lo p e d s ce n a rio s fo r a n a lys is o f 1 0 /2 0 g o a ls a n d e n e rg y e fficie n c y (E E )

In te g ra te d A p p ro a c h

E n v iro n m e n ta l

M a rke ts Fu e l

M a rke ts E le ctric

M a rk e ts

IP M ® M o d elin g

• M od e le d 1 0 /2 0 a n d E E S ce n a rio s d e ve lo p e d u n d e r P h a se I
 E le ctric/S te a m S e cto r S yste m Im p a cts

 E m is sio n Im p a cts  P ro d u ctio n C os t Im p a c ts P h a s e II: M o d e lin g o f E le ctric
a n d S te a m S e cto r

D e m an d

E m p lo y m en t

D e m a n d

b y Ind u stry, b y O ccu p ation M ark et S h ares

L o ca l an d ex p ort

m ark et sh ar es

b y Ind us try O u tp u t

F in al D e m a n d
b y T yp e

O u tp u t b y Ind u stry

W ag e R ate

W a g e R ate, P ric es an d P r ofits

b y In du stry S u p p ly

P op u la tio n
b y A g e, G end er, R ace

L a b o r Su p p ly13 The first was the Business-As-Usual (BAU) scenario that characterized how the future

might unfold with the proposed regional backstop SO 2 trading program but without any policy measures designed to accomplish the 10/20 goals and energy efficiency recommendations. The

second set of scenarios reflected a future with the regional backstop SO 2 trading program and policy drivers designed to meet the 10/20 goals or energy efficiency recommendations, or both. Assessments of emissions, costs and secondary regio nal economic impacts were estimated by analyzing the changes in the policy scenarios relat ive to the BAU scenario.

Changes in Regional Generation

Implementation of the energy policy recommendations to achieve the 10/20 goals will lead to significant growth in renewable energy capa city, totaling 20 GW by 2018. The growth reflects the requirements of the 10/20 goals and th e assumption that the policy climate of the 10/20 goals may better align incentives to spur the improvements in renewable technology cost and performance through accelerated learning by doi ng and by easing some of the barriers to entry for renewable energy. Figure 1 below summari zes the growth in renewable energy capacity under the 10/20 goals. On the basis of ec onomics, wind power dominates most of the growth in new renewable capacity and the increased use of renewable energy displaces new gasfired generation.

Figure 1: Renewable Energy Capacity Additions Under the 10/20 Goals

0 5 10 15 20 25

Wind Geothermal Landfill GasCapacity Additions by 2018 (GW)

Achieving the energy efficiency “best practices” re commendations developed by the AP2 Forum will lead to electricity demand reductions in the Transport Region of 8 percent by 2018 resulting in energy savings of 54,000 Gigawatt hour s (GWh) and summer peak demand savings of over 16,000 MW of capacity.

Emissions Reductions

The important results in capacity changes due to ac hieving the 10/20 goals and modestly improving energy efficiency in the region is that n ew renewable energy capacity and energy conservation compete against new conventional fossi l fuel-fired capacity while leaving the14

existing electricity generation stock relatively un disturbed. This has important implications for

size of emissions reductions.

The modeling analysis of emissions reductions indic ates that implementation of the 10/20 goals and energy efficiency “best practices” could result in savings in NO

x emissions of between 8,000 tons and 14,000 tons (or 1 percent to 2 perce nt relative to baseline conditions in the BAU scenario). 18 The reduction potential is relatively modest beca use the displaced generation consists almost entirely of new cleaner burning gas -fired combined cycle units. Nonetheless, the modeling shows that the 10/20 goals and energy effi ciency can provide a hedge against future emissions growth. In conjunction with other WRAP e mission control strategies, the emission reductions from efficiency and renewable energy can help improve visibility in the region.

Figure 2: Potential NO

x Emissions Reductions Under the 10/20 Goals and Ene rgy Efficiency Recommendations

Implementation of the 10/20 goals and energy effici ency scenarios in the ICF modeling

demonstrated SO 2 emissions in the region were reduced because new r enewable energy generation capacity displaces an estimated 2,000 MW of new coal-fired generation capacity. However, even though real SO 2 emissions are offset, because of the regional SO 2 cap and trade program proposed under a separate part of Section 3 09 of the regional haze rule, total SO 2 emissions in the region will not change. Under a c ap and trade program any SO 2 emissions reductions from renewable energy and energy efficie ncy is fully offset by increases in SO 2 emissions from sources that are allowed to emit up to the emissions cap. However, the 10/20 goals and energy efficiency could decrease the comp liance cost of the SO 2 trading program by as much as $ 7 million (or 10 percent of projected com pliance cost 19 ) in 2018 and could displace the need to install 1,200 MW to 1,700 MW of new scr ubber capacity by 2018.

18 In Figure 1 the bars labeled “10/20 goals” represen ts the policy scenario with the 10/20 goals, “EE” r epresents the policy scenarios with the energy efficiency recomme ndations and “EE + 10/20 goals” represents the poli cy scenario with both the 10/20 goals and the energy efficiency recommendations.

19 MTF 2000. - 2 4 6 8 10 12 14 16

2005 2010 2015 2018Change in NOxEmission Relative to BAU(Thousands Tons of NOX) 10/20 Goals

EE

EE + 10/20 Goals15 A secondary environmental benefit of implementing t he 10/20 goals and energy

efficiency recommendations is the reductions in CO 2 emissions. CO 2 emissions savings in 2018 are estimated to range between 40 million metric to nnes and 55 million metric tones (or 10 percent to 14 percent relative to the BAU scenario)

.

Energy Costs Impacts

Meeting the 10/20 renewable energy goals would incr ease annual levelized electricity production costs in the region by an estimated $300 million, a 2 percent increase above a

business-as-usual scenario. 20 Implementing the Forum’s efficiency measures would save the region roughly $1 billion annually. Together, rela tive to business-as-usual scenario, meeting the 10/20 goal and implementing the efficiency measures would reduce annual levelized electricity production costs in the region by approximately $70 0 million.

Figure 3 compares the electricity production cost b etween the business-as-usual and energy efficiency-only scenarios; and business-as-u sual and the energy efficiency plus renewable energy policy scenario.

Figure 3: Annual Levelized Production Cost Under t he BAU

and Energy Efficiency Policy Scenarios

$16.4 $16.7 $17.4

$0 $5 $10 $15 $20

BAU EE EE + 10/20 GoalsAnnual Levelized Production Costs (Billion 2001$)

In addition, implementation of both the 10/20 goals and energy efficiency recommendations will reduce demand and expenditures for natural gas in the region by nearly $2 billion annually. This also serves to provide some security benefits against increases in electricity costs due to natural gas price increase s and supply volatility.

20 The $300 million cost increase reflects the assump tion that renewable energy technology will improve over time, which the AP2 Forum believes to be the most likely scenario. To provide an an upper bound estimate of the potential cost increase resulting from achievin g the 10/20 goals the Forum also asked ICF to mode l a scenario in which renewable energy costs remain at today's l evels and do not improve over time. Under this sce nario the annual production costs of meeting the 10/20 goals increased to $900 million.16

Secondary Regional Economic Impacts

The results of the regional economic analysis indic ate that the 10/20 goals and energy efficiency may, on average, lead to an increase in economic activity. Over time, the policies lead to small increases in economic activity in the earl y years, and a small decline in later years. The impacts in the 2005 to 2015 time period are largely the result of investment in new renewable energy facilities that increase labor demand and ha ve secondary impacts on output and income. Following the investment and construction boom, the region will see some decline in employment, gross regional product and personal dis posable income.

Table 1: Annual Average (2005 – 2020) Changes In K ey Economic Indicators for the Transport Region Und er the Policy Scenarios

On average, the 10/20 goals will lead to small incr eases in employment and personal income along with a small decline in gross regional product. Implementation of the energy efficiency recommendations results in small increas es in employment, personal disposable income and gross regional product. The boom in con struction sparked by the investments appears to be the key reason for growth.

Conclusions of Modeling Results

The analysis indicates that the 10/20 goals and ene rgy efficiency recommendations could both serve as cost-effective air pollution preventi on strategies. The 10/20 goals will lead to increases renewable energy capacity, while the ener gy efficiency recommendations will result in lower energy demand through conservation. Because both the 10/20 goals and energy efficiency displace new additions of fossil fuel capacity and generation, they are likely to provide a hedge against future emissions growth in NO

x and CO 2 . The 10/20 goals can be achieved under modest cost impacts, while energy efficiency will result i n some cost savings and both the objectives have little or no regional economic impacts. Employment Gross Regional Product Personal Disposable Income (Persons) (% Change) (Million 2001$) (% Change) (Million 2001$) (% Change)

10/20 Goals 627 0.00% -312 -0.01% 73 0.00% Energy Efficiency (EE) 8,415 0.02% 450 0.02% 776 0.04%

10/20 Goals + EE 4,097 0.01% -58 0.00% 547 0.03%17 

### Policy Recommendations of the Air Pollution Prevent ion Forum

Renewable Energy Policies for States and Tribes

The AP2 Forum recommends states and tribes in the T ransport Region consider the following policies and programs as strategies they could adopt to promote development and use of renewable energy in their respective jur isdictions for the purposes of satisfying some of the requirements of Section 309(d)(8) of th e regional haze rule

1. Adopt a Renewable Portfolio Standard Systems Benefi t Charge applied to electricity sold, or both, as “core” financial incentives to pr omote the use of renewable energy

sources.

Due to existing costs and institutional barriers St ate and federal financial incentives will be necessary to achieve the 10/20 goals. If adopted by states and tribes it is recommended that financial incentives be structured to ensure they are: offered on a competitive basis; of sufficient duration to provi de certainty to investors in renewable energy projects; and do not discriminate against o ut-of-state renewable energy generation.

2. Implement tax incentives to encourage renewable ene rgy development.

State tax policies can promote increased investment in renewable energy technologies. These policies include, but are not limited to, e p roduction tax credits, personal and corporate income tax credits, property tax incentiv es and sales tax exemptions from purchases of renewable energy equipment and electri city.

3. Support regulatory and/or legislative policies that incent to utilities to offer customers the choice of purchasing electricity generated from ren ewables and the option to choose other “green” products and services

Market research and early experience with green pow er marketing and utility sponsored green pricing programs show a significant number of electricity customers are willing to pay a premium to purchase electricity generated fro m renewable energy. Customers of regulated, retail electric service providers should be given the option to chose a green electricity product or service.

4. Adopt information disclosure rules and power labels on utility bills that provide consumers with accurate information on the price, s ource of power, and environmental attributes of their electricity supply.

Consumer research and experience from states with r etail competition indicate consumer choice is strongly influenced by the price, resourc e mix, and environmental impacts of power supplies in an electric service-providers’ po rtfolio. For green power markets and green pricing programs to operate efficiently and b e effective in increasing demand for18 renewable energy, consumers need access to accurate and consistent information about

their electricity supply. Efforts to institute lab eling and disclosure rules should be coupled with consumer education programs.

5. Establish a generation tracking system in concert w ith other states, tribes, regional electricity reliability entities and/or regional tr ansmission organizations.

A generation tracking system for the entire western interconnected system will provide verification of information needed to ensure consum er confidence in the information on power labels, protect “green power” consumers from electricity from the resale of renewable energy, facilitate monitoring compliance with state RPS’, and verification and certification of renewable energy certificates.

6. Develop policies that eliminate transmission and distribution system barriers that hinder consumer access to renewable energy supplies, produ cts, and services while ensuring the reliability, safety and operational integrity of th e system.

State and tribal transmission and distribution syst em policies should: 1) support uniform interconnection standards; 2) support transmission protocols being developed by regional transmission organizations that do not pen alize intermittent renewable resources; and 3) allow net metering for renewable energy technologies at the

customer’s meter.

7. Opt in to the Section 309 regional SO2 “cap-and-tra de program”, as outlined in the Annex, under the Regional Haze Rule and as adopted by states and tribes..

States and tribes opting into the Section 309 regio nal SO2 cap-and-trade program will limit regional SO2 emissions and create a market i n which emission credits can be bought and sold. Such a market puts a monetary va lue on SO2 emissions and provides an economic incentive to engage SO2 reducing activi ties such as investments in renewable energy.

8. Establish policies and processes to improve the siting of renewable energy generation

facilities.

States and tribes should improve siting processes f or renewable energy facilities including: 1) training for regulators on land use a nd environmental issues surrounding the siting of renewable energy facilities; 2) creat ing a process to enable government decision makers in a jurisdiction which has conside red a renewable energy facility siting application to share their experience and lessons l earned with other jurisdictions considering applications for similar projects; and 3) coordination between states and tribes in siting review processes, including resolu tion of jurisdictional issues for projects

that involve both state and tribal lands.19 9. Support creation of a single institution in the Western Interconnection to register, certify,

and oversee trading of renewable energy certificate s in the West. 21

Environmental attributes of electricity generated f rom renewable sources have economic value and can be sold separately from the electrici ty as renewable energy certificates (RECs). Selling of RECs represents a market-based s trategy that improves the economics, overcomes transmission barriers, and pro vides consumers access to the most economic renewable energy resources. In combinatio n with other policies recommended by the AP2 Forum, RECs can contribute to accelerati ng development of the West’s most promising renewable resources.

10. Endorse cooperative actions and complementary e fforts by the federal government to promote the development of renewable energy that do not undermine historical

authorities of the states.

Complementary action by the federal government is n eeded to achieve the 10/20 goal because of the significant presence of the federal government in the WRAP region. Actions that states and tribes should consider sup porting include, but are not limited to, funding for research, development and commercial de monstration of near competitive renewable technologies, a national renewable portfo lio standard, extension of the existing federal production tax credit (FPT) for wi nd and biomass through 2015 and broadening the credit to include geothermal, develo pment of other tax incentives, and mandatory federal agency renewable energy purchase requirements.



### Additional Renewable Energy Policies Specifically f or Tribes

When appropriate, tribes may wish to implement some or all of the renewable energy recommendations presented above. Due to the diversi ty of the tribes and their unique circumstances, the Forum recommends tribes consider the following additional recommendations. Tribes may best implement some of these recommendations individually, while others may be more appropriate as collaborati ve efforts with other tribes, states, or the federal government.

1. Develop a tribal energy policy

A formal energy policy statement that incorporates specific provisions for renewable electric energy is an important beginning to a larg er set of strategies. A program to stimulate renewable energy generation will be most effective as part of a more comprehensive energy policy developed by and adapte d to each tribe.

21 Western governors support the renewable energy cer tificates as a market based strategy to support the development of renewable energy in the Western Inte rconnect. See WGA Policy Resolution 02-26, section (B)(4)(c), pg. 4-5.20 2. Develop renewable energy resources

Virtually every tribe in the WRAP region enjoys an abundance of renewable energy

resources. Tribes with an established tribal electr ic utility are already well positioned to expand the role of that utility to develop viable s ources of renewable energy. The AP2 Forum encourages tribal utilities to consider explo ring these opportunities. Other tribal governments that lack the infrastructure of an exis ting utility might consider establishing such an enterprise.

3. Initiate energy training and education programs

The Forum recommends that all consumers have the op portunity to select the purchase of energy supplies from renewable sources. Tribal impl ementation of this recommendation may include consumer education programs addressing purchasing options and their associated environmental impacts.

4. Create an Economic Development Corporation

Tribes that choose to pursue a renewable energy ent erprise may consider setting up a tribal Economic Development Corporation (EDC). Trib es with an EDC or comparable entity already in place may utilize it to advance t he opportunities for entrepreneurial energy development. The somewhat autonomous role of an EDC has been shown to be useful when pursuing a long-term economic developme nt initiative such as required for most energy projects.

5. Purchase electricity generated by renewable sour ces

Tribal governments could demonstrate leadership in renewable energy advocacy through the purchase of electricity from renewable energy s uppliers as part of their tribal energy policy.

6. Expedite the permitting process for renewable en ergy projects

Tribal governments could streamline the permitting process for renewable energy projects located within their jurisdiction. Such a process will encourage rather than discourage innovative energy supply and distributio n enterprises.

7. Multi-party renewable energy actions for on-reserva tion programs

• Renewable energy programs at federal facilities
– There are many federal facilities on tribal lands. Tribal governments could consider requiring that such federal facilities comply with a tribal energy policy that stipulates the purchase of electricity from a renewable energy supplier, including the tri bal utility where applicable.21 • Federal financing of authorized renewable energy as sistance
– Several federal statutes authorize funding for energy conservation and renewable energy incentives on tribal lands. Most notable is the Energy Policy Act of 1992 and its amendments. Tribal leaders could formally request adequate appr opriations from the U.S. Congress and appropriate agencies to implement the energy conservation and renewable energy development provisions of these la ws. This should include funding of training programs for tribal energy professional s related to renewable energy and energy efficiency.

• Federal project grants and subsidies
– One federal mechanism to encourage private sector development and use of renewable ene rgy is tax credits. Because this mechanism is of little use to most tribes, tribes m ay request equivalent federal financial subsidies for tribal renewable energy pro jects (for example, a tribal energy block grant).

• Utilize tribal SO2 and renewable energy emissions allowances
– Referring to the “cap-and-trade” program mentioned earlier, the Foru m recommends that tribes consider seeking allowances under this program to e ncourage renewable energy generation on tribal lands through both the tribal set-aside allocation and the renewable energy set aside allocation.

8. Tribal leadership in renewable energy activities be yond tribal lands

• Develop a Tribal Implementation Plan – Consider developing a Tribal Implementation Plan under the provisions of the Reg ional Haze Rule and the Tribal Authority Rule that commits the tribe to expanding its use of renewable energy in the generation and use of electricity

.

• Develop inter-tribal energy collaborations – Some renewable energy development opportunities require resources beyond those availa ble to small tribal populations

and lands. The Forum recommends that small tribes c onsider expanding existing intertribal relationships and forging new ones wher e renewable energy development projects exceed the capacity of an individual triba l government.

• Secure tribal authority over non-Indian lands with in reservation boundaries – For many tribes an effective energy policy, includi ng full development of renewable energy resources, will depend on tribal authority o ver all lands within reservation boundaries, which can include non-Indian lands. The Forum recommends that tribes, federal agencies, and states, as appropriate, enter into agreements that recognize such tribal authority for the purpose of developmen t and implementation of renewable energy policies and practices.

• Encourage creating a federal renewable portfolio st andard – Tribal governments could support a national renewable portfolio standa rd.22 • Expand federal government’s “Buy Indian” policy – The “Buy Indian” policy is advantageous to suppliers of selected products and services that are purchased by specific federal agencies. The Forum recommends 1) that this policy be expanded to include the purchase of electricity generated from renewable sources on tribal lands, and 2) that the participating agencies be expanded to include all relevant federal

energy procurement.

• Expand the federal government’s program for procure ment of green energy – Tribes may consider requesting that the Federal gov ernment encourage Power Marketing Agencies to obtain electricity generated from renewable resources on tribal lands, combined with the Federal government programs in Executive Order 13123 for the Federal Government’s procurement of g reen energy. A portion of the electricity generated from these renewable resource s could be made available for tribal use, similar to hydropower electricity made available from the Western Area

Power Administration.

• Encourage federal tax credits for renewable generat ion

– As discussed previously, the Forum recommends that tribes consider engaging in the preferential procurement of electricity from suppliers of renewable energy. Concurrently, private sector suppliers of renewable energy, in response to these policies, should be awarded appropriate federal tax credits. This practice will stimulate short-term competitive pricing while limiting financial penalties to both purchasers and providers.

• Create partnerships with Independent Power Producer s – Tribal governments seeking to develop renewable resources may find it desirable to collaborate with an Independent Power Producer to expedite resource dev elopment and to limit tribal financial exposure.

• Explore state-tribal agreements for renewable energ y projects on tribal lands – Some tribes may want to explore with states the pos sibility of a state-tribal agreement for renewable energy projects on tribal lands as pa rt of a state’s strategy to meets its own 10/20 goal for renewable energy.



### Energy Efficiency Policies for States and Tribes

Section 309(d)(8)(iii) of the regional haze rule re quires SIPs and TIPs to provide for “Programs to preserve and expand energy conservatio n efforts.” The AP2 Forum recommends states and tribes in the Transport Region consider the following policies and programs as strategies they could adopt as part of their SIPs and TIPs to improve the efficiency of energy use and increase the adoption of energy efficient techn ologies and practices in the economies of the their respective jurisdictions

1. Adopt policies that provide ratepayer funding to su pport cost-effective utility and/or State sponsored demand-side energy efficiency programs.23 Increasing the penetration of energy efficiency and conservation in the region can best be accomplished through state policies that provide fu nding to utility or State sponsored demand side energy efficiency programs supported by ratepayers, and whose costs are included in rates or appear separately on customer bills as a “tariff rider” or a systems benefits charge.

2. Develop tax incentives to promote investments in en ergy efficiency and conservation by

residential consumers and businesses.

Tax incentives that should be considered by states and tribes, include, but should not be limited to, income tax credits, and sales tax exem ptions for investments in high efficiency appliances, equipment, designs and services.

3. Support minimum efficiency standards for appliances , equipment, and buildings.

Minimum energy efficiency standards can be very eff ective strategies for transforming the region’s economy to be more energy efficient. While states are free to develop energy standards for buildings, they are preempted by fede ral law from developing state standards for equipment covered by the federal appl iance standards program, unless they apply to and receive a waiver from the U.S. Departm ent of Energy. The increasing prevalence of electronic devices and expanding digi tal economy, coupled with the West’s hot dry climate that causes a substantial peak in s ummer demand, provides an important opportunity for the region to develop “regional” ef ficiency standards for electronic devices, air conditioning and other appliances and equipment that impact summer peak.

4. Implement utility rate reforms that send accurate p rice signals to consumers.

Implementation of utility rates structures such as real-time, time of use, inclined block, and other pricing approaches more effectively commu nicate the cost of electricity (and gas) supply to consumers and provide market-based p rice incentives to reduce electricity consumption.

5. Participate in regional market transformation progr ams to increase access and availability of energy efficient equipment, appliances and pract ices in the market place.

Market transformation programs are designed to brin g about lasting change in consumer behavior and increase access and availability of en ergy efficient equipment, appliances and practices in the market place. States and trib es in the Transport Region can effect lasting change by participating in regional market transformation programs similar in scope to the successful horizontal axis washing mac hine program promoted in the Pacific

Northwest.

6. Governmental “Lead-By-Example” Energy Efficiency P rograms.

The public sector can create “market pull” for ener gy efficient products and services in states and the region by adopting policies that imp rove energy efficiency of public24 buildings and support energy efficient management p ractices and procurement.

Specifically, states should develop a comprehensive public buildings efficiency plan, including mandatory efficiency standards for state and municipal new construction; public building retrofit programs employing perform ance contracting as appropriate; life-cycle cost procurement standards for energy-us ing equipment and systems; and train building operation and maintenance staff in retro-c ommissioning to ensure public buildings energy systems are operated to maximize p erformance and efficient use of

energy

.

7. Modify environmental regulatory approaches to creat e opportunities for energy efficiency improvements that result in measurable, verifiable and permanent emissions reductions to be counted as pollution control measures for criter ia pollutant SIPs and TIPs.

State and tribal air quality officials can investig ate how to modify their regulatory approach to create opportunities for energy efficie ncy improvements to be counted as pollution control measures that provide “measurable , verifiable, and permanent” emissions reductions within the regulatory framewor k provided by the CAAA for criteria pollutant SIPs. 22



### Additional Energy Efficiency Policies Specifically for Tribes

Tribes may wish to implement some or all of the ene rgy efficiency recommendations for states as presented above. The Forum recognizes the unique and special circumstances of many tribes, and submits the following additional recomm endations for tribes to consider. Some of these recommendations may best be implemented by in dividual tribes, while others are suitable for collaborations with other tribes, states, or th e federal government.

1. Development of an energy plan

For tribes that do not have one, the Forum recommen ds that tribes consider developing an energy plan or policy. Establishing an energy pl an is the first necessary step in gaining control over the energy use and costs incur red by a tribe. The plan can enhance tribal sovereignty and energy independence.

2. Tribal energy manager

For tribes without an energy manager, the Forum rec ommends such a position be established. An energy manager within an energy au thority can direct and manage energy programs including those related to energy e fficiency. The energy manager can also recommend policies for consideration by the tr ibal council. For tribes without an energy authority, an energy manager position can be created elsewhere within the tribal

government.

22 Western Governor’s Policy Resolution 02-26, sectio n (4)(g)(viii) page 7, calls for western states and tribes to “develop mechanisms to encourage energy efficiency measures in air quality planning documents.”25 3. Tribal energy authority

Tribes without an energy (utility) authority might consider establishing such an entity (either individually or in collaboration with other tribes). Perhaps the most important recommendation to tribes concerning energy efficien cy is that of designing a tribal energy plan that is managed by an energy manager wi thin a tribal energy authority. A tribal energy authority also has the effect of impr oving a tribe’s sovereignty and promises improved self-determination.

4. Establish energy-conserving building codes and i ncorporate them into new construction and building renovations

As new buildings are constructed and older building s are renovated, there is a great opportunity for energy savings by employing energy- efficiency methods. Tribes can adopt energy-efficient building codes such as the Interna tional Energy Conservation Code. It is also recommended that energy efficiency be integrat ed into housing plans, and that life cycle cost methods be used when evaluating the ener gy systems within buildings

.

5. Electrification expansions

With new electrification comes the opportunity to i mplement energy efficiency. New customers in rural areas may spend a large fraction of their monthly income on energy, in some cases as much as 20 percent. In these cases it is critical that cost-effective, energy-efficient appliances and building materials be employed.

6. Education programs

Education can make the difference between an effect ive, successful, comprehensive energy management program and a fragmented program with little support. Educating tribal members, leaders, facility managers, staff m embers, and contractors about the benefits of monitoring and conserving energy will b uild support for an energy program and will lead to significant savings in energy cost s.

7. Tribal Implementation Plan

A Tribal Implementation Plan under the provisions o f the Regional Haze Rule and the Tribal Authority Rule would commit the tribe to dev eloping an energy plan and to employing energy efficiency as a method to reduce e lectricity consumption. Such a plan would be a good step toward tribal energy conservat ion.

8. Intertribal collaborations

Many tribes may lack the resources to establish the ir own energy authority or even to hire their own energy manager. In these cases it ma y be beneficial to initiate partnerships with other tribes for that purpose. Be yond this, tribes could work collaboratively to encourage the federal government , through its trust responsibility, to26 fund energy-efficiency programs (including educatio n programs and rebate programs)

and to provide funding to tribes for energy managem ent.

9. Federal facilities

There are numerous federal facilities on tribal lan ds, and these facilities consume an appreciable amount of electrical energy. Tribes cou ld adopt energy conservation policies that require federal facilities on tribal lands to meet modern energy-efficiency codes such as the International Energy Conservation Code.

10. Federally sponsored programs

There are several federally sponsored programs in w hich tribes may participate to implement energy efficiency. These programs include the Weatherization Assistance Programs (WAP) and the DOE Rebuild America Program. The forum recommends that tribes, as part of their overall energy plan, parti cipate in existing federally sponsored programs related to energy efficiency. Tribes may a lso consider requesting funding for efficiency programs from the federal government via several existing statutes. This could include funding of training programs for tribal ene rgy professionals related to renewable energy and energy efficiency.

11. Tribal leadership beyond tribal lands

The mitigation of haze throughout the West will dep end upon all users of electricity and other energy forms that impact haze. Thus, tribes m ay consider supporting demand-side management programs and national energy efficiency policies and standards.27 

### Appendix I

EPA Regional Haze Rule Section 51.309(d)(8)

Pollution Prevention

The plan must provide for:

(i) An initial summary of all pollution prevention programs currently in place, an inventory of all renewable energy generation capacity and production in use, or planned as of the year 2002 (expressed in megawatts and megawatt-hours), the to tal energy generation capacity and production for the State, the percent of the total that is renewable energy, and the State’s anticipated contribution toward the renewable energ y goals for 2005 and 2015, as provided in §51.309(d)(8)(vi).

(ii) Programs to provide incentives that reward eff orts that go beyond compliance and/or achieve early compliance with air-pollution related require ments.

(iii) Programs to preserve and expand energy conser vation efforts.

(iv) The identification of specific areas where ren ewable energy has the potential to supply power where it is now lacking and where renewable e nergy is most cost-effective.

(v) Projections of the short- and long-term emissio ns reductions, visibility improvements, cost savings, and secondary benefits associated with the renewable energy goals, energy efficiency and pollution prevention activities.

(vi) A description of the programs relied on to ach ieve the State's contribution toward the Commission's goal that renewable energy will compri se 10 percent of the regional power needs by 2005 and 20 percent by 2015, and a demonstration of the progress toward achievement of the renewable energy goals in the years 2003, 2008, 201 3, and 2018. This description must include documentation of the potential for renewable energy resources, the percentage of renewable energy associated with new power generation project s implemented or planned, and the renewable energy generation capacity and production in use and planned in the State. To the

extent that it is not feasible for a State to meet its contribution to the regional renewable energy goals, the State must identify in the progress repo rts the measures implemented to achieve its contribution and explain why meeting the State's co ntribution was not feasible.28 

### Appendix II

Membership of the Air Pollution Prevention Forum

Robert “Hap” Boyd, GE Wind, Co-Chair

Jeff Burks, Utah Energy Office, Co-Chair

Bill Becker, U.S. Department of Energy

Trisha Frank, Manzanita Tribe

Rich Ferguson, Center for Energy Efficiency and Ren ewable Technologies

Bob Green, Kennecott

Brian Hedman, Quantec, Inc.

Van Jamison, PowerAir Consulting

Ursula Kramer, Pima County DEQ

John Nielsen, Land and Water Fund of the Rockies

Terry O’Connor, Arch Mineral, Inc.

Stan Price, Northwest Energy Efficiency Coalition

John Savage, Oregon Department of Energy

Rachel Shimshak, Renewable Northwest Project

Rich Sperberg, Onsite Sycom Energy Corp

Julie Simpson, Nez Perce Tribe

Barrett Stambler, Pacific Power Marketing

Dick Watson, Northwest Power Planning Council

Chris Wentz, New Mexico Energy Office

Alan Davis, Montana Department of Environmental Qua lity

Cynthia Praul, California Energy Commission

Steve Ellenbecker, Wyoming PUC

Amanda Ormond, Arizona Energy Office/Ormond Group

Tom Hines, Arizona Public Service

Virinder Singh, PacifiCorp29 

### Appendix III

Meetings of the Air Pollution Prevention Forum

1) August 12-13, 1999, Denver, Colorado First meeting of the Forum Overview of: regional haze rule, the charge to the forum, and the WRAP

2) November 8-9, 1999, Scottsdale, Arizona Presentations from panel of experts on renewable e nergy Adopted working definition of renewable resources

3) January 31 – February 1, 2000, San Diego, Califo rnia

Reviewed first draft of Sections A and B of Renewa bles Report

Discussion on what should be covered in sections C and D

4) March 13-14, 2000, Portland, Oregon Reviewed first draft of full report Made changes and modifications, set deadline for comments

5) May 31 – June 1, 2000 , San Francisco Efficiency scoping Examined changes in the demographics and economy in the WRAP region including growing demand for electricity and inter net issue

6) October 2, 2000, Denver, Colorado “Brainstorming” meeting on modeling and energy eff iciency

7) December 5-6, 2000, Portland, Oregon Developed outline for Energy Efficiency Report Assignments for sections of the report Created quantification work group to oversee model ing

8) March 15-16, 2001, Sacramento, California Reviewed write-ups for best energy efficiency prac tices Discussed SIP guidebook Presentation on tribal renewable and energy effici ency reports

9) November 5-6, 2001, Denver, Colorado Quantitative work group meeting SIP guidebook work group

10) February 19-20, 2002, Denver, Colorado Review modeling results Discuss report to be delivered to WRAP

11) June 5-6, 2002, Portland, Oregon Discuss final modeling results Comments on draft final report30 

### Appendix IV

Reports of the Air Pollution Prevention Forum

Final Report on Energy Efficiency and Renewable Ene rgy, Prepared by the Air Pollution Prevention Forum for the Western Regional Air Partn ership, January 2002.

Economic Assessment of Implementing the 10/20 Goals and Energy Efficiency Recommendations, Draft Report , prepared by ICF Consulting for the Air Pollution Prevention Forum, October 2002

Reducing Energy Consumption and Improving Air Quali ty through Energy Efficiency in Indian Country: Recommendations to Tribal Leaders from th e Western Regional Air Partnership,

November 2002

Recommendations for the Western Regional Air Partne rship’s Air Pollution Prevention Forum to Increase the Generation of Electricity from Rene wable Resources on Native American Lands

, Draft Report, April 2002

Recommendations of the Air Pollution Prevention For um to Increase Energy Efficiency and Conservation in the GCVTC States, (forthcoming)

Draft Background Report: Identification and Analys is of “Best” Energy Efficiency Measures and Practices for the West, prepared by the Air Pol lution Prevention Forum, September 1, 2001.

Discussion Paper: Scoping the Energy Efficiency Wo rk of the Air Pollution Prevention Forum, prepared for the Air Pollution Prevention Forum by WIEB staff, September 30, 2000.

Recommendations of Air Pollution Prevention Forum T o Increase the Generation of Electricity from Renewable Resources , June 30, 2000

A Background White Paper: Increasing the Use of Re newable Energy in the WRAP Region, Western Interstate Energy Board, September 1998.31 

### Appendix V

AP2 Forum’s Selected Energy Efficiency “Best Practi ces” 23

Interior West -- Residential Sector
Major Option Types of Measures Efficient cooling systems Evaporative cooling – installation, retention and r enewal of systems Appliance recycling Removal of older refrigerators and freezers Efficient lighting Mix of compact fluorescent lamp based measures Appliance standards ** Clothes washers – mix of Energy Star vertical axis machines and horiz ontal

axis machines
Appliance standby loss – reduce loss to one watt pe r electronic device Building thermal performance Weatherization – exist ing buildings

Interior West -- Commercial Sector
Major Option Types of Measures
Efficient lighting Mix of better technologies Efficient refrigeration Mix of better technologies Efficient cooling systems Cooling efficiency – mix of better systems
Indirect/direct evaporative cooling Efficient space heating system Ground source heat pump
Fuel switching from electric to gas Multi-measure strategies for existing building stock Miscellaneous devices (LED traffic lights and signs , clothes washers, computers, monitors and other office electronics) Retro-commissioning Operations and maintenance of existing building sto ck Water heating Mix of efficiency and fuel switching from electric

Transformers Efficiency improvements

Interior West -- Industrial Sector
Major Option Types of Measures

Transformers Efficiency improvements Motors Premium motors (including replace rather tha n rewind) and motor downsizing Motor drive systems System upgrades of fans, air compressors, pumps

Oregon / w. Idaho -- Residential Sector
Major Option Types of Measures Efficient cooling systems Evaporative cooling – installation, retention and r enewal of systems Appliance recycling Removal of older refrigerators or freezers Efficient lighting Mix of compact fluorescent lamp–based systems Appliance standards** Clothes washers – mix of ener gy star vertical axis machines and horizontal

axis machines
Appliance standby loss – reduce loss to 1 watt per electronic device

23 Demand Side Management Type Programs Except where Indicated32

Oregon / w. Idaho -- Commercial Sector
Major Option Types of Measures
Efficient lighting Mix of better technologies Efficient refrigeration Mix of better technologies Efficient cooling systems Cooling efficiency – 20 t on package units

Efficient space heating system Ground source heat pump
Fuel switching from electric to gas Multi-measure strategies for existing building stock Miscellaneous devices (LED traffic lights and signs , clothes washers, computers, monitors and other office electronics) Retro-commissioning Operations and maintenance of existing building sto ck Water heating Mix of efficiency and fuel switching from electric

Transformers Efficiency improvements

Oregon / w. Idaho -- Industrial Sector
Major Option Types of measures

Transformers Efficiency improvements Motors Premium motors (including replace rather tha n rewind) and motor downsizing Motor drive systems System upgrades of fans, air compressors, pumps Aluminum process improvements Retrofit options to improve efficiency of cells (re duce anode-cathode spacing) and reduce heat loss

California/Las Vegas -- All Sectors
Major Option Types of measures System benefit fund Demand-side management for ligh ting, appliances, air conditioning, motor systems, other Equipment efficiency

standards** Distribution transformers, commercial refrigeration , exit signs and traffic lights, torchieres, commercial unit heaters, air co nditioners, ice makers, residential refrigerators, dishwashers, standby los s reduction Tax incentives for efficiency** Clothes washers, refrigerators, air conditioning, g as heat pumps, heat pump water heating, furnaces, efficient new construction (residential and commercial)33 

### Appendix VI

Cost Of Saved Energy Results Sorted By Cost Per kWh :

Measure Discounted

TRC Cost ($1000) MWh Savings

Through 2026 Real Levelized

Cost of Saved Energy ($/kWh) Percent of

Total

Cummul. Package Savings Cummulative

MWh Savings through 2026 Percent of

Total

Cummul. Package

Costs Cummulative

Discounted

TRC Cost Residential Evaporative Cooling (111,017) $ 5,007,946

(0.0489)

$ 1.7% 5,007,946 -4.4% (111,017) $ Residential IDDEC Cooling (15,554) $ 2,305,001

(0.0151)

$ 2.5% 7,312,947 -5.0% (126,571) $ Comml/Instit. Space Heat Std. Gas Boiler (458) $ 465,659

(0.0022)

$ 2.6% 7,778,606 -5.0% (127,029) $ Comml/Instit. Space Heat High Eff. Gas Boiler (565) $ 962,327

(0.0013)

$ 3.0% 8,740,933 -5.1% (127,594) $ Comml/Instit. Water Heat Gas Boiler Fuel Switch (1,1 45) $ 3,325,686

(0.0008)

$ 4.1% 12,066,619 -5.1% (128,739) $ Comml/Instit. Water Heater Fuel Switching (505) $ 3,484,222

(0.0003)

$ 5.3% 15,550,841 -5.1% (129,244) $ Comml/Instit. Space Heat Gas Unit Heater 422 $ 803,719

0.0011

$ 5.6% 16,354,560 -5.1% (128,821) $ Industrial Fan System Measures 7,041 $ 2,473,382

0.0062

$ 6.4% 18,827,942 -4.8% (121,780) $ Industrial Air Compressor System Measures 23,789 $ 8,347,664

0.0062

$ 9.2% 27,175,606 -3.9% (97,991) $ Residential CFL Torchiere 62,045 $ 21,232,172

0.0067

$ 16.5% 48,407,778 -1.4% (35,946) $ Industrial Motor Downsizing 3,416 $ 865,684

0.0086

$ 16.8% 49,273,462 -1.3% (32,531) $ Comml/Instit. Refrigeration, Low-cost Measures 29,22 4 $ 6,446,877

0.0098

$ 19.0% 55,720,339 -0.1% (3,307) $

Residential CFL Bulbs 49,797 $ 8,999,064

0.0099

$ 22.0% 64,719,403 1.8% 46,490 $ Comml/Instit. Water Heating, Heat Pump Unit 4,169 $ 833,390

0.0106

$ 22.3% 65,552,793 2.0% 50,659 $ Comml/Instit. LED Exit Signs 10,551 $ 2,212,350

0.0109

$ 23.1% 67,765,143 2.4% 61,210 $ Comml/Instit. Lighting, Efficient Fluorescent 120,84 2 $ 22,406,144

0.0117

$ 30.7% 90,171,287 7.2% 182,052 $ Residential CFL Fixtures--Indoor 24,370 $ 4,477,776

0.0124

$ 32.2% 94,649,063 8.2% 206,422 $
Industrial Premium Motors 32,469 $ 4,640,110

0.0137

$ 33.8% 99,289,173 9.5% 238,891 $ Residential Appl. Standby Loss Red.--Mandatory 186,8 08 $ 31,092,432

0.0138

$ 44.4% 130,381,605 16.9% 425,699 $ Residential Appl. Standby Loss Red.--Incentive 19,09 1 $ 2,018,494

0.0148

$ 45.1% 132,400,099 17.7% 444,789 $ Comml/Instit/Industrial Transformers (C/I) 14,260 $ 1,903,312

0.0172

$ 45.7% 134,303,411 18.2% 459,050 $ Industrial Pump System Measures 130,051 $ 15,459,078

0.0183

$ 51.0% 149,762,489 23.4% 589,101 $ Comml/Instit. Retrocommissioning 35,765 $ 4,203,554

0.0186

$ 52.4% 153,966,043 24.8% 624,866 $ Comml/Instit. Refrigeration, High-cost Measures 30,1 51 $ 3,487,028

0.0188

$ 53.6% 157,453,071 26.0% 655,018 $ Residential Appliance Recycling 40,598 $ 2,593,122

0.0204

$ 54.5% 160,046,193 27.6% 695,616 $ Comml/Instit/Industrial Transformers (Industrial) 2, 150 $ 223,428

0.0220

$ 54.6% 160,269,621 27.7% 697,766 $ Residential CFL Fixtures--Outdoor 5,562 $ 515,112

0.0228

$ 54.7% 160,784,733 27.9% 703,328 $ Comml/Instit. AC Impr., 20-ton Package Units 296,085 $ 28,046,667

0.0236

$ 64.3% 188,831,400 39.7% 999,414 $ Comml/Instit. Ground-source HP, 3000 hrs/yr 30,955 $ 2,745,355

0.0249

$ 65.2% 191,576,755 40.9% 1,030,369 $ Comml/Instit. Lighting, Advanced Measures 795,012 $ 64,744,193

0.0266

$ 87.2% 256,320,948 72.4% 1,825,380 $ Comml/Instit. AC Impr., Residential-type CAC 57,876 $ 4,042,410

0.0307

$ 88.6% 260,363,358 74.7% 1,883,257 $ Comml/Instit. LED Traffic Signals 13,697 $ 931,600

0.0322

$ 88.9% 261,294,958 75.3% 1,896,954 $ Comml/Instit. Efficient Clothes Washers 15,511 $ 914,946

0.0335

$ 89.2% 262,209,904 75.9% 1,912,465 $ Comml/Instit. AC Impr., Small Heat Pump 93,753 $ 5,867,466

0.0343

$ 91.2% 268,077,370 79.6% 2,006,218 $ Comml/Instit. Ground-source HP, 2000 hrs/yr 30,955 $ 1,830,237

0.0373

$ 91.9% 269,907,607 80.9% 2,037,173 $ Comml/Instit. AC Impr., Res. Room-type AC 66,814 $ 3,738,494

0.0383

$ 93.1% 273,646,101 83.5% 2,103,987 $
Residential Weatherization 109,264 $ 5,824,614

0.0402

$ 95.1% 279,470,715 87.8% 2,213,251 $ Comml/Instit. Gas AC, w/ heat recov. (EWH) 53,763 $ 2,896,170

0.0420

$ 96.1% 282,366,885 90.0% 2,267,014 $ Comml/Instit. Cooling Tower VSD--Desert Climate 6,40 8 $ 336,718

0.0431

$ 96.2% 282,703,603 90.2% 2,273,422 $
Industrial Prem. Motor vs. Rewind 10,383 $ 436,716

0.0464

$ 96.4% 283,140,319 90.6% 2,283,805 $ Residential SEHA Clothes Washer 66,392 $ 3,052,546

0.0476

$ 97.4% 286,192,865 93.3% 2,350,197 $ Residential Energy Star Clothes Washer 57,518 $ 2,527,540

0.0498

$ 98.3% 288,720,405 95.6% 2,407,715 $ Comml/Instit. AC, IDDEC, 150-ton Equiv. Units 111,95 8 $ 5,072,414

0.0501

$ 100.0% 293,792,819 100.0% 2,519,673 $
ALL MEASURES/ALL PROGRAMS 2,519,673 $ 293,792,819

0.0186

$