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 2003
i 

Executive Summary 

The Regional Haze Rule (Rule) requires each state to 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 Transport Commission (GCVTC) to base their SIPs 

on the regional recommendations of the GCVTC. Tribes 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 established by western states and 

tribes to coordinate and oversee implementation of the GCVTC recommendations and provide 

policy and technical tools to assist states and tribes in filing regional haze implementation plans. 

The GCVTC concluded that renewable energy and energy efficiency measures could result in 

“emissions reductions, improvements in visibility and 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 contribute to meeting the regional goal for 

renewable energy established by the GCVTC.1

 The WRAP created the Air Pollution Prevention Forum (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 increase the use of energy efficiency in the nine 

state GCVTC region. 

The AP2 Forum and its Tribal Issues Committee developed energy efficiency and 

renewable energy policy and program recommendations for states and tribes over a three-year 

period. In addition, the AP2 Forum commissioned ICF Consulting Group to conduct a regional 

analysis of the emissions and economic impacts of implementing the AP2 Forum’s policy and 

program recommendations. The results of the regional modeling analysis, which apply to both 

states and tribes, demonstrated energy efficiency and renewable energy could result in emissions 

reductions, improvements in visibility, energy costs 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 the AP2 Forum’s examination of barriers, 

policy analysis, economic modeling results and recommended policies and programs to increase 

 

1

The GCVTC recommended that “[t]he goal of the states in the Transport Region should be to achieve 

annual additions in order that renewables will comprise 10% of the regional power needs by 2005 and 20% by 

2015.” 
ii 

the use of energy efficiency and renewable energy in 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 emissions reductions, improvements in visibility 

and provide secondary environmental and economic benefits to the region.” 

It is the policy position of the WRAP that state and tribal implementation of both 

renewable energy and energy efficiency policy and program recommendations of the AP2 

Forum, as appropriate to circumstances within each jurisdiction will reduce emissions and 

electricity production costs in the region, will result in a larger emissions benefit than either 

measure by itself, and will contribute to fulfilling the SIP and TIP requirements of the Regional 

Haze Rule. The most significant progress towards meeting 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 incentives. States and tribes in the WRAP region 

should also adopt complementary polices that will improve the efficiency of the market place. 

Finally, the WRAP acknowledges that federal policies and regional actions have important roles 

in removing market barriers and increasing the development of renewable energy and 

deployment of energy efficiency technologies and practices 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 recognizes that circumstances unique to each 

jurisdiction such as climate, culture, social, economic, 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. Accordingly, the WRAP’s policy statement should 

be viewed as guidance for the region as a whole. As 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 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - i 

Table of Contents - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - iii 

WRAP Policy on Renewable Energy and Energy Efficiency - - - - - - - - - - - - - - - 1

Background - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 4

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

Regional Haze Rule: Renewable Energy and Energy Efficiency - - - - - - - - - - - - - - - 5 

Western Regional Air Partnership - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 6 

Air Pollution Prevention Forum - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 6 

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

Renewable Energy - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 8 

Energy Efficiency - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 10 

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

Regional Generation Capacity - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 13 

Emissions Reductions - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 13

Energy Costs Impacts - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 15

Secondary Regional Economic Impacts - - - - - - - - - - - - - - - - - - - - - - - - - - 16

Policy Recommendations of the Air Pollution Prevention Forum - - - - - - - - - - - - 17

Renewable Energy Policies for States and Tribes - - - - - - - - - - - - - - - - - - - - - - - - - 17

Specific Tribal Recommendations - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 19

Energy Efficiency Policies for States and Tribes - - - - - - - - - - - - - - - - - - - - - - - - - - 22 

Specific Tribal Recommendations - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 24

Appendices - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 27

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

Appendix II – Membership of the Air Pollution Prevention Forum - - - - - - - - - - - - - - 29 

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

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

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

Appendix VI – Energy Efficiency “Best Practices: Costs of Saved Energy - - - - - - - - 33 
1 

WRAP Policy on Renewable Energy and Energy Efficiency 

The policy and program recommendations the AP2 Forum have been developed over a 

three-year period through a stakeholder-based consensus 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 tribes 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 energy 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 policy and program recommendations developed by 

the AP2 Forum. However, the WRAP policy on renewable energy and energy efficiency is 

informed by and embodies the results of the AP2 Forum’s three-year examination of barriers, 

policy analysis, emissions and economic modeling results, and recommended policies and 

programs. 

WRAP Policy 

Following on the findings of the Grand Canyon Visibility 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 and 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 consistent with local economic, regulatory, 

political conditions and in a way that protects cultural resources unique to these jurisdictions. 

The WRAP believes that states and tribes2

 can make progress towards meeting the GCVTC 

10/20 renewable energy goal3 and increase the use of energy efficiency technologies in the 

Grand Canyon Visibility Transport region, and adopts the following policy statements: 

1. Joint implementation of the AP2 Forum’s renewable energy and energy efficiency policy 

and program recommendations will reduce emissions and electricity production costs in 

the region, will result in a larger emissions benefit 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 of federal 

authority to adopt Tribal Implementation Plans (TIPs) under Section 308 or 309 of the Regional Haze Rule. Tribal 

selection of Section 308 or 309 is independent of the strategy adopted by the state(s) in which the tribe is located. In 

addition, tribes may apply for approval of “reasonably severable” elements of Clean Air Act programs. Further, 

deadlines for plan submittal that apply to states do not apply to tribes. Where a tribe opts not to develop a TIP, EPA 

may work with the tribe to adop a Federal Implementation Plan (FIP) if necessary and appropriate to protect air 

quality. 

3

 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 mandatory or “enforceable.”. 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 goals 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 changes are necessary if states and 

tribes are to successfully make progress towards meeting the GCVTC 10/20 renewable 

energy goal (10 percent of generation will come from renewable energy by 2005 and 20 

percent by 2015) and increase energy efficiency in the Transport Region. 

3. Electricity consumers in the Transport Region should 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 improve the efficiency of the market place, 

such as providing 1) access to information about the 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 efficiency standards for buildings; and 

modify regulatory approaches to include in SIPS and TIPS credit for emissions 

reductions of criteria pollutants from energy efficiency measures. 

6. Actions should be taken to reform transmission access, pricing and interconnection 

policies that create barriers to the movement of renewable energy generation from 

generators to customers. 

7. An emissions cap-and-trade program is an economically efficient method of achieving 

emissions reductions and provides economic incentives 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 that discriminate against intermittent 

renewable resources; and participate in energy efficiency market transformation 

programs. 

9. States and tribes should support Federal policies that 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 region. 

10. States and tribal governments and federal agencies should “lead-by-example” by 

becoming early adopters of renewable energy and energy efficient products, services, and 

practices in a manner that protects cultural resources. 

In consideration of the above policy on renewable energy 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 development of State/Tribal 

Implementation Plans for regional haze; 

2. Provide states and tribes who follow the 309 path with technical assistance (including 

data, information, analytical tools) and policy assistance (including model legislation, 

rules and policies) needed to incorporate the renewable 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 achieving the GCVTC 10/20 renewable 

energy goal and implementation of the renewable energy 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, track 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 recognizes that circumstances unique to each 

jurisdiction such as climate, culture, social, economic, 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. Accordingly, the WRAP’s policy statement should 

be viewed as guidance for the region as a whole. As 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 of the Clean Air Act Amendments of 1977 

(Act). Congress further addressed visibility in western Class I areas in creating the Grand 

Canyon Visibility Transport Region (Transport Region) and directing EPA to establish the Grand 

Canyon Visibility Transport Commission (GCVTC) to address haze causing pollutants in a nine 

state region whose emissions affect visibility in the Grand Canyon.4 The Commission was 

charged with making recommendations on how to protect 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 throughout the Colorado Plateau.5

 

The report concluded that although the GCVTC did not have the resources necessary to 

“model or completely quantify the effects” of renewable energy and energy efficiency on 

visibility, if implemented these measures could result in “emissions reductions, improvements in 

visibility and provide secondary environmental and economic benefits to the region.” 6 With 

regard to renewable energy7, the GCVTC recommended that “[t]he goal of the states in the 

Transport Region should be to achieve annual additions 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 visibility improvements from energy efficiency.8 

 

4

The Commission was comprised of the governors of eight 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 Commission, the Hualapai tribe and ex-officio members from the Environmental 

Protection Agency, the Bureau of Land Management, the National Park Service, the U.S. Forest Service and the U.S. Fish and 

Wildlife Service. 

5 Report of the Grand Canyon Visibility Transport Commission 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 following definition of renewable energy. "Renewable energy" is 

defined as electricity generated by non-nuclear and non-fossil low or no air emission technologies using resources 

that are virtually inexhaustible, reduce haze, and are environmentally beneficial. The term includes electricity 

generated by wind energy technologies; solar photovoltaic and solar thermal technologies; geothermal technologies; 

technologies based on landfill gas and biomass sources, and new low-impact hydropower that meets the Low-Impact 

Hydropower Institute criteria. Biomass includes agricultural, food and wood wastes. The term does not include 

pumped storage or biomass from municipal solid waste, 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 recommends the national adoption of the California energy 

efficiency standards8. The Commission also supports the construction of energy efficient buildings, both 

residential and commercial, and proposes the reinstatement of incentives for building energy efficient

structures....The Commission also suggests the continuation of demand-side management programs, despite 

current funding restrictions. The Commission recommends that continuing attention be paid to maintaining 

the role of energy conservation within the changing electric power industry markets. Energy conservation 

programs should be preserved and expanded through such mechanisms as “system benefit charges” paid at 
5 

Regional Haze Rule and Renewable Energy and Energy Efficiency 

In July 1999, the Environmental Protection Agency issued its final regional haze 

regulations.9

 The final “Regional Haze Rule” requires each state to prepare a State 

Implementation Plan (SIP) for regional haze and includes a separate section (Section 51.309) 

which allows the nine Transport Region states (Arizona, 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 rule11,” (TAR) eligible tribes may implement Clean Air Act programs to protect 

air resources “within the exterior boundaries of the reservation or other areas within the tribe’s 

jurisdiction.” Tribes too, may choose to participate in the regional approach granted to the states 

in the Transport region and submit a Tribal Implementation 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 energy production and consumption, and 

descriptions of programs and policies each state will rely on to contribute to meeting the 

GCVTC’s regional goal for renewable energy. The requirements of the regional haze rule 

regarding energy efficiency and renewable energy are found in 40 CFR 51.309(d)(8). This 

section addresses the GCVTC’s recommendations on pollution prevention, renewable energy, 

energy efficiency and conservation. With respect to renewable energy and energy efficiency 

Section 51.309(d)(8) requires each state SIP to provide: 

• A description of the programs relied on to achieve the State's contribution to the 

Commission's goal that renewable energy will comprise 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 reductions, 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 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 goals cannot be met. 

 

the distribution level....” Report of the Grand Canyon Visibility Transport Commission 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 GCVTC must utilize the rules and standards adopted by EPA under 

Section 308. 

11 40 CFR Part 49 
6 

For tribes that choose to submit a TIP following the GCVTC regional approach, the 

content may contain elements similar or identical to 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-quality management programs, however, the TAR 

authorizes a modular approach to tribal programs; that 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 opportunities: 

 

• Tribes can pick and choose among Clean Air Act provisions 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 management programs, grants are available 

from the EPA pursuant to Sections 103 and 105 of the 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 part of a 309 TIP without implementing other 

parts of 309 which are not appropriate for the tribe. 

Western Regional Air Partnership 

Western Regional Air Partnership (WRAP) was established 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 recommendations 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 positions on air quality.”12 WRAP policies, 

strategies and technical tools are developed through an inclusive stakeholder-based process that 

includes state air agencies, tribes, EPA, federal and state land management agencies, local 

government, industry, utilities, environmental groups, academia and other interested parties. 

Air Pollution Prevention Forum 

The Air Pollution Prevention (AP2) Forum was created September 1998 by the WRAP’s 

Initiatives Oversight Committee (IOC) and charged to: 

“Recommend legislative actions, economic incentives and regulatory policies states can 

adopt to meet the 10/20 renewable energy goal and increase the use of energy efficiency 

technologies in the Grand Canyon Visibility Transport region.” 

 

12 WRAP Charter,, Purpose, p. 1. 
7 

As is the expectation of all WRAP forums, the objective of the AP2 Forum and its 25 

members has been to provide the states and tribes of the WRAP region with the policy and 

analytical framework needed to respond to the requirements of the Pollution Prevention section 

of the Regional Haze Rule.13 To accomplish this purpose the AP2 Forum’s work plan called for 

the Forum to: 

• Examine barriers restricting the penetration of renewable energy, energy efficient 

technologies, and adoption of energy efficient practices in the Transport Region; 

• Identify and evaluate economic incentives, legislative actions, and regulatory policies that 

will increase investments in renewable energy and energy efficiency, including actions 

currently underway in the Transport Region; and 

• Recommend market-based incentives and public policies 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 sectors. 

 

The AP2 Forum’s policy and program recommendations have been developed over a 

three-year period through a stakeholder-based consensus process supported, in part, by nationally 

recognized renewable energy and energy efficiency experts, including the National Renewable 

Energy Laboratory. The Forum and workgroups held more than 11 meetings and workshops to 

examine barriers and identify policies that would lead to increased investment in renewable 

energy and energy efficiency in the Transport Region. The Forum also commissioned ICF 

Consulting Group to analyze the potential emissions reductions, energy costs, and secondary 

environmental and economic benefits to the Transport Region of meeting the GCVTC 10/20 goal 

and implementing a suite of cost-effective energy efficiency programs and policies the AP2 

Forum identified as “best practices” for the region. 

As a result of its investigation the AP2 Forum prepared seven reports that provide policy, 

analytical and technical support for the Forum’s policy 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 renewable energy is needed for the 

Transport Region to attain the GCVTC 10/20 goal. In 1999 the Transport Region supported 

6,190 MW of renewable generation capacity, representing six percent of the regions electricity 

supply. Based on forecasts of demand for electricity 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 generation capacity will need to be brought 

on-line in the Transport Region over the next 16 years . 

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

there are a number of barriers that are preventing the greater use of renewable energy in the 

region. The biggest barrier renewable energy currently 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 can be accounted for by market imperfections 

and other barriers renewables face. For example, existing tax structures penalize capitalintensive renewable energy technologies compared to competing conventional technologies. 

Current transmission pricing and access protocols penalize intermittent generation resources such 

as wind and solar. Benefits of renewable energy, such as reduced environmental impacts, are not 

monetized in the power market and there is a lack of information and consumer knowledge about 

electricity sources and their environmental impacts. Monopoly electricity providers are often not 

required to provide “choice” in sources of electricity 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 adoption of state policies which provide 

financial incentives for the production and consumption of renewable energy. The Forum 

believes that renewable portfolio standards (RPS) and 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 incentives14, 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 generally don’t benefit from tax incentives, tribes 

may consider seeking alternative yet equitable incentives to encourage development of 

renewable energy on tribal lands (such as tribal block grants). 

 

The Forum finds that electricity customers who want to purchase renewable generated 

electricity should be given the option of purchasing 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 should also adopt complementary policies that 

will improve the efficiency of the marketplace and lower transaction costs for “green” electricity 

products and services. 

 

14Including production tax incentives, personal and corporate income tax credits, property tax incentives and sales 

tax exemptions from purchases of renewable energy equipment 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 Transport 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 effective on a regional scale. These include 

trading of renewable energy certificates and creation of a generation tracking system for the 

western interconnected system. 

States are already making progress toward implementing the GCVTC’s recommendations 

including adoption of significant Renewable Portfolio Standards (e.g., 20 percent in California 

and 15 percent in Nevada and New Mexico), tax incentives (e.g., Arizona, Idaho, Nevada, New 

Mexico, Oregon, Utah), green power purchase programs, 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 Excel in Colorado). 

Tribal lands in the WRAP region have great potential for the development and delivery of 

electricity generated from renewable resources. Furthermore, many tribes are interested in 

generating, selling, and using such electricity. Consequently, tribal energy programs can be 

significant contributors to the 10/20 goal. Substantial barriers exist, however, to the full 

implementation of tribal opportunities for development of renewable energy resources. For 

example, many tribes do not have an energy authority or an energy policy, and are consequently 

not well positioned to take advantage of opportunities related to renewable energy. Also, and of 

particular importance to rural residents, is the fundamental need for basic electric service or for 

reliable electric service. Because development of renewable resources is a capital-intensive 

activity, access to capital can also be a significant 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 relationship of Indians Tribes and their 

lands within the federal framework has great bearing on strategies to enhance renewable energy 

development. That is, tribal-state-federal relations must be considered in their legal, economic, 

and cultural contexts when exploring the development and delivery of electric energy across 

political boundaries. Because these relationships are markedly varied, appropriate strategies will 

differ from tribe to tribe, and the concept of setting 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 June of 2000 with an initial 

examination of demographic and economic trends likely to affect future electricity consumption 

in the WRAP region. Existing state and tribal policies were reviewed along with federal/state 

programs relating to energy efficiency, and opportunities 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 efficiency technologies and conservation practices and 

developed a list of state policies and “best practices” that, if adopted by states and tribes would 

enable the region to increase the level of efficiency in the production and end-use of electricity. 

Also developed was a set of recommendations specifically directed to tribal leaders that could 

foster implementation of energy efficiency on tribal lands. The impact these policies and energy 

efficiency programs and measures would have on regional emissions and energy costs were then 

evaluated. 

The AP2 Forum found that a wide range of cost-effective energy efficiency measures 

exist that provide a substantial opportunity to improve 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 economy 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 the Transport Region’s economy. This can best 

be accomplished through financial incentives and mandatory energy efficiency standards. The 

Forum found there are other programs and policies that can help promote energy efficiency and 

conservation including consumer information and education, 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 tribal 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” exceeded $0.054/kWh and all measures taken together averaged 

$0.0186/kWh of energy saved. By comparison, “avoided costs” for electricity from new gas-fired generation 

averages between $0.036 and $0.046 kWh. These measures were not meant to represent all cost-effective options or 

all technically feasible energy efficiency options that would have environmental benefits. Rather they represented a 

set of achievable, cost-effective programs that would provide significant energy savings if a state chose to pursue a 

moderately ambitious level of energy efficiency. 

16 Barriers include lack of consumer awareness and limited access to information about energy efficient products, 

services and effectiveness of energy efficiency measures in reducing energy use and costs; emphasis on lowest first 

cost in purchasing equipment or constructing buildings; limited product availability in the marketplace; energy 

price distortions, e.g. “average cost” pricing of electricity prevents consumers from seeing the true costs of 

electricity use; and competition for limited internal 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 related social and cultural benefits. With potential 

cost savings on electricity expenditures (as well as 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 Transport Commission (GCVTC) 

recommended future modeling work be conducted to analyze the potential emissions reductions, 

visibility improvements, costs savings, and secondary 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 and cost assumptions developed by the Forum. 

This analysis was conducted to help the AP2 Forum understand the potential emissions 

reductions, costs and secondary regional economic impacts of implementing the 10/20 goals and 

the energy efficiency recommendations. The AP2 Forum 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 Commission 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

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 M a rke ts

Fu e l

 M a rke ts

E le ctric

 M a rk e ts

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• 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

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m ark et sh ar es

b y Ind us try

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F in al D e m a n d 

b y T yp e

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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

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b y A g e, 

G end er, R ace

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13 

The first was the Business-As-Usual (BAU) scenario that characterized how the future 

might unfold with the proposed regional backstop SO2 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 SO2 trading program and 

policy drivers designed to meet the 10/20 goals or energy efficiency recommendations, or both. 

Assessments of emissions, costs and secondary regional economic impacts were estimated by 

analyzing the changes in the policy scenarios relative 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 capacity, totaling 20 GW by 2018. The growth 

reflects the requirements of the 10/20 goals and the 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 doing and by easing some of the barriers to 

entry for renewable energy. Figure 1 below summarizes the growth in renewable energy 

capacity under the 10/20 goals. On the basis of economics, 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 Gas

Capacity Additions by 2018 (GW)

Achieving the energy efficiency “best practices” recommendations 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 hours (GWh) and summer peak demand savings 

of over 16,000 MW of capacity. 

Emissions Reductions 

The important results in capacity changes due to achieving the 10/20 goals and modestly 

improving energy efficiency in the region is that new renewable energy capacity and energy 

conservation compete against new conventional fossil fuel-fired capacity while leaving the 
14 

existing electricity generation stock relatively undisturbed. This has important implications for 

size of emissions reductions. 

The modeling analysis of emissions reductions indicates that implementation of the 10/20 

goals and energy efficiency “best practices” could result in savings in NOx emissions of between 

8,000 tons and 14,000 tons (or 1 percent to 2 percent relative to baseline conditions in the BAU 

scenario).18 The reduction potential is relatively modest because 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 efficiency can provide a hedge against future 

emissions growth. In conjunction with other WRAP emission control strategies, the emission 

reductions from efficiency and renewable energy can help improve visibility in the region. 

Figure 2: Potential NOx Emissions Reductions Under the 10/20 Goals and Energy 

Efficiency Recommendations 

 

 

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

demonstrated SO2 emissions in the region were reduced because new renewable energy 

generation capacity displaces an estimated 2,000 MW of new coal-fired generation capacity. 

However, even though real SO2 emissions are offset, because of the regional SO2 cap and trade 

program proposed under a separate part of Section 309 of the regional haze rule, total SO2

emissions in the region will not change. Under a cap and trade program any SO2 emissions 

reductions from renewable energy and energy efficiency is fully offset by increases in SO2

emissions from sources that are allowed to emit up to the emissions cap. However, the 10/20 

goals and energy efficiency could decrease the compliance cost of the SO2 trading program by as 

much as $ 7 million (or 10 percent of projected compliance cost19) in 2018 and could displace 

the need to install 1,200 MW to 1,700 MW of new scrubber capacity by 2018. 

 

18 In Figure 1 the bars labeled “10/20 goals” represents the policy scenario with the 10/20 goals, “EE” represents the 

policy scenarios with the energy efficiency recommendations and “EE + 10/20 goals” represents the policy scenario 

with both the 10/20 goals and the energy efficiency recommendations. 

19 MTF 2000. 

-

2

4

6

8

10

12

14

16

Change in NO

2005 2010 2015 2018

x Emission Relative to BAU 

(Thousands Tons of NOX)

10/20 Goals

EE

EE + 10/20 Goals
15 

A secondary environmental benefit of implementing the 10/20 goals and energy 

efficiency recommendations is the reductions in CO2 emissions. CO2 emissions savings in 2018 

are estimated to range between 40 million metric tonnes 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 increase 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, relative 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 $700 million. 

Figure 3 compares the electricity production cost between the business-as-usual and 

energy efficiency-only scenarios; and business-as-usual and the energy efficiency plus renewable 

energy policy scenario. 

Figure 3: Annual Levelized Production Cost Under the BAU 

and Energy Efficiency Policy Scenarios 

$16.4 $16.7 $17.4

$0

$5

$10

$15

$20

BAU EE EE + 10/20 Goals

Annual 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 increases and supply volatility. 

 

 

20 The $300 million cost increase reflects the assumption 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 achieving the 10/20 goals the Forum also asked ICF to model a scenario 

in which renewable energy costs remain at today's levels and do not improve over time. Under this scenario 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 indicate 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 early 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 have 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 disposable income. 

Table 1: Annual Average (2005 – 2020) Changes In Key Economic Indicators for the Transport Region Under the 

Policy Scenarios 

On average, the 10/20 goals will lead to small increases in employment and personal 

income along with a small decline in gross regional product. Implementation of the energy 

efficiency recommendations results in small increases in employment, personal disposable 

income and gross regional product. The boom in construction 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 energy efficiency recommendations could 

both serve as cost-effective air pollution prevention strategies. The 10/20 goals will lead to 

increases renewable energy capacity, while the energy 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 NOx and CO2. The 10/20 goals can be achieved under modest 

cost impacts, while energy efficiency will result in 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 Prevention Forum

Renewable Energy Policies for States and Tribes 

The AP2 Forum recommends states and tribes in the Transport Region consider the 

following policies and programs as strategies they could adopt to promote development 

and use of renewable energy in their respective jurisdictions for the purposes of satisfying 

some of the requirements of Section 309(d)(8) of the regional haze rule 

1. Adopt a Renewable Portfolio Standard Systems Benefit Charge applied to electricity 

sold, or both, as “core” financial incentives to promote the use of renewable energy 

sources. 

Due to existing costs and institutional barriers State 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 provide certainty to investors in renewable 

energy projects; and do not discriminate against out-of-state renewable energy 

generation. 

2. Implement tax incentives to encourage renewable energy development. 

State tax policies can promote increased investment in renewable energy technologies. 

These policies include, but are not limited to, e production tax credits, personal and 

corporate income tax credits, property tax incentives and sales tax exemptions from 

purchases of renewable energy equipment and electricity. 

3. Support regulatory and/or legislative policies that incent to utilities to offer customers the 

choice of purchasing electricity generated from renewables and the option to choose other 

“green” products and services 

Market research and early experience with green power marketing and utility sponsored 

green pricing programs show a significant number of electricity customers are willing to 

pay a premium to purchase electricity generated from 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, source of power, and environmental 

attributes of their electricity supply. 

Consumer research and experience from states with retail competition indicate consumer 

choice is strongly influenced by the price, resource mix, and environmental impacts of 

power supplies in an electric service-providers’ portfolio. For green power markets and 

green pricing programs to operate efficiently and be effective in increasing demand for 
18 

renewable energy, consumers need access to accurate and consistent information about 

their electricity supply. Efforts to institute labeling and disclosure rules should be 

coupled with consumer education programs. 

5. Establish a generation tracking system in concert with other states, tribes, regional 

electricity reliability entities and/or regional transmission organizations. 

A generation tracking system for the entire western interconnected system will provide 

verification of information needed to ensure consumer 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, products, and services while ensuring the 

reliability, safety and operational integrity of the system. 

State and tribal transmission and distribution system policies should: 1) support uniform 

interconnection standards; 2) support transmission protocols being developed by 

regional transmission organizations that do not penalize 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-trade 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 regional SO2 cap-and-trade program will 

limit regional SO2 emissions and create a market in which emission credits can be 

bought and sold. Such a market puts a monetary value on SO2 emissions and provides 

an economic incentive to engage SO2 reducing activities 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 for renewable energy facilities 

including: 1) training for regulators on land use and environmental issues surrounding 

the siting of renewable energy facilities; 2) creating a process to enable government 

decision makers in a jurisdiction which has considered a renewable energy facility siting 

application to share their experience and lessons learned with other jurisdictions 

considering applications for similar projects; and 3) coordination between states and 

tribes in siting review processes, including resolution 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 certificates in the West.21 

Environmental attributes of electricity generated from renewable sources have economic 

value and can be sold separately from the electricity as renewable energy certificates 

(RECs). Selling of RECs represents a market-based strategy that improves the 

economics, overcomes transmission barriers, and provides consumers access to the most 

economic renewable energy resources. In combination with other policies recommended 

by the AP2 Forum, RECs can contribute to accelerating development of the West’s most 

promising renewable resources. 

10. Endorse cooperative actions and complementary efforts 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 needed 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 supporting include, but are not limited to, 

funding for research, development and commercial demonstration of near competitive 

renewable technologies, a national renewable portfolio standard, extension of the 

existing federal production tax credit (FPT) for wind and biomass through 2015 and 

broadening the credit to include geothermal, development of other tax incentives, and 

mandatory federal agency renewable energy purchase requirements. 

 

Additional Renewable Energy Policies Specifically for Tribes 

When appropriate, tribes may wish to implement some or all of the renewable energy 

recommendations presented above. Due to the diversity 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 collaborative 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 larger 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 adapted to each tribe. 

 

21 Western governors support the renewable energy certificates as a market based strategy to support the

development of renewable energy in the Western Interconnect. 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 electric utility are already well positioned to 

expand the role of that utility to develop viable sources of renewable energy. The AP2 

Forum encourages tribal utilities to consider exploring these opportunities. Other tribal 

governments that lack the infrastructure of an existing utility might consider establishing 

such an enterprise. 

3. Initiate energy training and education programs 

The Forum recommends that all consumers have the opportunity to select the purchase of 

energy supplies from renewable sources. Tribal implementation 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 enterprise may consider setting up a 

tribal Economic Development Corporation (EDC). Tribes with an EDC or comparable 

entity already in place may utilize it to advance the opportunities for entrepreneurial 

energy development. The somewhat autonomous role of an EDC has been shown to be 

useful when pursuing a long-term economic development initiative such as required for 

most energy projects. 

5. Purchase electricity generated by renewable sources 

Tribal governments could demonstrate leadership in renewable energy advocacy through 

the purchase of electricity from renewable energy suppliers as part of their tribal energy 

policy. 

6. Expedite the permitting process for renewable energy 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 distribution enterprises. 

7. Multi-party renewable energy actions for on-reservation 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 tribal utility where applicable.
21 

• Federal financing of authorized renewable energy assistance – 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 appropriations from the U.S. 

Congress and appropriate agencies to implement the energy conservation and 

renewable energy development provisions of these laws. This should include funding 

of training programs for tribal energy professionals related to renewable energy and 

energy efficiency.

• Federal project grants and subsidies – One federal mechanism to encourage 

private sector development and use of renewable energy is tax credits. Because this 

mechanism is of little use to most tribes, tribes may request equivalent federal 

financial subsidies for tribal renewable energy projects (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 Forum recommends that tribes 

consider seeking allowances under this program to encourage 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 beyond tribal lands 

• Develop a Tribal Implementation Plan – Consider developing a Tribal 

Implementation Plan under the provisions of the Regional 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 available to small tribal populations 

and lands. The Forum recommends that small tribes consider expanding existing 

intertribal relationships and forging new ones where renewable energy development 

projects exceed the capacity of an individual tribal government.

• Secure tribal authority over non-Indian lands within reservation boundaries – 

For many tribes an effective energy policy, including full development of renewable 

energy resources, will depend on tribal authority over 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 development and implementation of 

renewable energy policies and practices.

• Encourage creating a federal renewable portfolio standard – Tribal governments 

could support a national renewable portfolio standard.
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 procurement of green energy – 

Tribes may consider requesting that the Federal government 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 green energy. A portion of the 

electricity generated from these renewable resources 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 generation – 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 Producers – Tribal governments 

seeking to develop renewable resources may find it desirable to collaborate with an 

Independent Power Producer to expedite resource development and to limit tribal 

financial exposure.

• Explore state-tribal agreements for renewable energy projects on tribal lands –

Some tribes may want to explore with states the possibility of a state-tribal agreement 

for renewable energy projects on tribal lands as part 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 requires SIPs and TIPs to provide for 

“Programs to preserve and expand energy conservation 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 technologies and practices in the economies of the 

their respective jurisdictions 

1. Adopt policies that provide ratepayer funding to support 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 funding 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 energy 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 exemptions 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 effective 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 federal law from developing state 

standards for equipment covered by the federal appliance standards program, unless they 

apply to and receive a waiver from the U.S. Department of Energy. The increasing 

prevalence of electronic devices and expanding digital economy, coupled with the West’s 

hot dry climate that causes a substantial peak in summer demand, provides an important 

opportunity for the region to develop “regional” efficiency standards for electronic 

devices, air conditioning and other appliances and equipment that impact summer peak. 

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

Implementation of utility rates structures such as real-time, time of use, inclined block, 

and other pricing approaches more effectively communicate the cost of electricity (and 

gas) supply to consumers and provide market-based price incentives to reduce electricity 

consumption. 

5. Participate in regional market transformation programs to increase access and availability 

of energy efficient equipment, appliances and practices in the market place. 

Market transformation programs are designed to bring about lasting change in consumer 

behavior and increase access and availability of energy efficient equipment, appliances 

and practices in the market place. States and tribes in the Transport Region can effect 

lasting change by participating in regional market transformation programs similar in 

scope to the successful horizontal axis washing machine program promoted in the Pacific 

Northwest. 

6. Governmental “Lead-By-Example” Energy Efficiency Programs. 

The public sector can create “market pull” for energy efficient products and services in 

states and the region by adopting policies that improve energy efficiency of public 
24 

buildings and support energy efficient management practices 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 performance contracting as appropriate; 

life-cycle cost procurement standards for energy-using equipment and systems; and train 

building operation and maintenance staff in retro-commissioning to ensure public 

buildings energy systems are operated to maximize performance and efficient use of 

energy. 

7. Modify environmental regulatory approaches to create opportunities for energy efficiency 

improvements that result in measurable, verifiable and permanent emissions reductions to 

be counted as pollution control measures for criteria pollutant SIPs and TIPs. 

State and tribal air quality officials can investigate how to modify their regulatory 

approach to create opportunities for energy efficiency improvements to be counted as 

pollution control measures that provide “measurable, verifiable, and permanent” 

emissions reductions within the regulatory framework 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 energy efficiency recommendations for 

states as presented above. The Forum recognizes the unique and special circumstances of many 

tribes, and submits the following additional recommendations for tribes to consider. Some of 

these recommendations may best be implemented by individual tribes, while others are suitable 

for collaborations with other tribes, states, or the federal government. 

1. Development of an energy plan 

For tribes that do not have one, the Forum recommends that tribes consider developing 

an energy plan or policy. Establishing an energy plan is the first necessary step in 

gaining control over the energy use and costs incurred by a tribe. The plan can enhance 

tribal sovereignty and energy independence. 

2. Tribal energy manager 

For tribes without an energy manager, the Forum recommends such a position be 

established. An energy manager within an energy authority can direct and manage 

energy programs including those related to energy efficiency. The energy manager can 

also recommend policies for consideration by the tribal 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, section (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 efficiency is that of designing a tribal 

energy plan that is managed by an energy manager within a tribal energy authority. A 

tribal energy authority also has the effect of improving a tribe’s sovereignty and 

promises improved self-determination. 

4. Establish energy-conserving building codes and incorporate them into new construction 

and building renovations 

As new buildings are constructed and older buildings 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 International Energy Conservation Code. It is 

also recommended that energy efficiency be integrated into housing plans, and that life 

cycle cost methods be used when evaluating the energy systems within buildings. 

 

5. Electrification expansions 

With new electrification comes the opportunity to implement 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 effective, successful, comprehensive 

energy management program and a fragmented program with little support. Educating 

tribal members, leaders, facility managers, staff members, and contractors about the 

benefits of monitoring and conserving energy will build support for an energy program 

and will lead to significant savings in energy costs. 

7. Tribal Implementation Plan 

A Tribal Implementation Plan under the provisions of the Regional Haze Rule and the 

Tribal Authority Rule would commit the tribe to developing an energy plan and to 

employing energy efficiency as a method to reduce electricity consumption. Such a plan 

would be a good step toward tribal energy conservation. 

8. Intertribal collaborations 

Many tribes may lack the resources to establish their own energy authority or even to 

hire their own energy manager. In these cases it may be beneficial to initiate 

partnerships with other tribes for that purpose. Beyond this, tribes could work 

collaboratively to encourage the federal government, through its trust responsibility, to 
26 

fund energy-efficiency programs (including education programs and rebate programs) 

and to provide funding to tribes for energy management. 

9. Federal facilities 

There are numerous federal facilities on tribal lands, and these facilities consume an 

appreciable amount of electrical energy. Tribes could 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 which 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, participate in existing federally sponsored 

programs related to energy efficiency. Tribes may also consider requesting funding for 

efficiency programs from the federal government via several existing statutes. This could 

include funding of training programs for tribal energy professionals related to renewable 

energy and energy efficiency. 

11. Tribal leadership beyond tribal lands 

The mitigation of haze throughout the West will depend upon all users of electricity and 

other energy forms that impact haze. Thus, tribes may 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 total 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 energy goals for 2005 and 2015, as provided in 

§51.309(d)(8)(vi). 

(ii) Programs to provide incentives that reward efforts that go beyond compliance and/or achieve 

early compliance with air-pollution related requirements. 

(iii) Programs to preserve and expand energy conservation efforts. 

(iv) The identification of specific areas where renewable energy has the potential to supply 

power where it is now lacking and where renewable energy is most cost-effective. 

(v) Projections of the short- and long-term emissions 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 achieve the State's contribution toward the 

Commission's goal that renewable energy will comprise 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, 2013, and 2018. This description must include 

documentation of the potential for renewable energy resources, the percentage of renewable 

energy associated with new power generation projects 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 reports the measures implemented to achieve its 

contribution and explain why meeting the State's contribution 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 Renewable 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 Quality 

Cynthia Praul, California Energy Commission 

Steve Ellenbecker, Wyoming PUC 

Amanda Ormond, Arizona Energy Office/Ormond Group 

Tom Hines, Arizona Public Service 

Virinder Singh, PacifiCorp 
29 

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 energy 

 Adopted working definition of renewable resources 

3) January 31 – February 1, 2000, San Diego, California 

 Reviewed first draft of Sections A and B of Renewables 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 internet issue 

6) October 2, 2000, Denver, Colorado 

 “Brainstorming” meeting on modeling and energy efficiency 

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 modeling 

8) March 15-16, 2001, Sacramento, California 

 Reviewed write-ups for best energy efficiency practices 

 Discussed SIP guidebook 

 Presentation on tribal renewable and energy efficiency 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 report 
30 

Appendix IV 

Reports of the Air Pollution Prevention Forum 

Final Report on Energy Efficiency and Renewable Energy, Prepared by the Air Pollution 

Prevention Forum for the Western Regional Air Partnership, 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 Quality through Energy Efficiency in Indian 

Country: Recommendations to Tribal Leaders from the Western Regional Air Partnership, 

November 2002 

Recommendations for the Western Regional Air Partnership’s Air Pollution Prevention Forum 

to Increase the Generation of Electricity from Renewable Resources on Native American Lands, 

Draft Report, April 2002 

Recommendations of the Air Pollution Prevention Forum to Increase Energy Efficiency and 

Conservation in the GCVTC States, (forthcoming) 

Draft Background Report: Identification and Analysis of “Best” Energy Efficiency Measures 

and Practices for the West, prepared by the Air Pollution Prevention Forum, September 1, 2001. 

Discussion Paper: Scoping the Energy Efficiency Work 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 To Increase the Generation of Electricity 

from Renewable Resources, June 30, 2000 

A Background White Paper: Increasing the Use of Renewable Energy in the WRAP Region, 

Western Interstate Energy Board, September 1998. 
31 

 Appendix V 

AP2 Forum’s Selected Energy Efficiency “Best Practices”23

Interior West -- Residential Sector

Major Option Types of Measures

Efficient cooling systems Evaporative cooling – installation, retention and renewal 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 horizontal 

axis machines 

Appliance standby loss – reduce loss to one watt per electronic device 

Building thermal performance Weatherization – existing 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 stock 

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 than 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 renewal 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 energy 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 Indicated 
32 

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 ton 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 stock 

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 than rewind) and motor 

downsizing 

Motor drive systems System upgrades of fans, air compressors, pumps 

Aluminum process 

improvements 

Retrofit options to improve efficiency of cells (reduce anode-cathode 

spacing) and reduce heat loss 

California/Las Vegas -- All Sectors 

Major Option Types of measures

System benefit fund Demand-side management for lighting, appliances, air conditioning, motor 

systems, other 

Equipment efficiency 

standards** 

Distribution transformers, commercial refrigeration, exit signs and traffic 

lights, torchieres, commercial unit heaters, air conditioners, ice makers, 

residential refrigerators, dishwashers, standby loss reduction 

Tax incentives for efficiency** Clothes washers, refrigerators, air conditioning, gas 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 $ 3,325,686 45) (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 $ 6,446,877 4 0.0098 $ 19.0% 55,720,339 -0.1% (3,307) $ 

Residential CFL Bulbs $ 8,999,064 49,797 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 $ 22,406,144 2 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 $ 31,092,432 08 0.0138 $ 44.4% 130,381,605 16.9% 425,699 $ 

Residential Appl. Standby Loss Red.--Incentive 19,09 $ 2,018,494 1 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 $ 3,487,028 51 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, $ 223,428 150 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 $ 336,718 8 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 $ 5,072,414 8 0.0501 $ 100.0% 293,792,819 100.0% 2,519,673 $ 

ALL MEASURES/ALL PROGRAMS 2,519,673 $ 293,792,819 0.0186 $