{"id":6488,"date":"2014-03-13T16:09:39","date_gmt":"2014-03-13T16:09:39","guid":{"rendered":"http:\/\/blogs.edf.org\/energyexchange\/?p=6488"},"modified":"2026-04-02T15:00:44","modified_gmt":"2026-04-02T19:00:44","slug":"will-texas-step-up-to-the-plate-on-energy-efficiency-and-carbon-pollution-standards","status":"publish","type":"post","link":"https:\/\/blogs.edf.org\/energyexchange\/2014\/03\/13\/will-texas-step-up-to-the-plate-on-energy-efficiency-and-carbon-pollution-standards\/","title":{"rendered":"Will Texas Step Up to the Plate on Energy Efficiency and Carbon Pollution Standards?"},"content":{"rendered":"

\"Coal-Plant-225x3001\"<\/a>A couple of weeks ago, I wrote about energy efficiency and the Clean Air Act section 111(d)<\/a> provisions in anticipation of the SPEER Second Annual Summit<\/a>, a gathering of top energy efficiency industry leaders from Texas and Oklahoma. At the Summit, I co-led a session on Environmental Protection Agency\u2019s (EPA\u2019s) push to regulate power plant emissions. Session attendees agreed that Texas would be an unlikely leader in developing innovative ways to comply with carbon pollution standards for existing power plants.<\/p>\n

This is a missed opportunity on Texas\u2019 part, as states will get the first crack at drafting plans to comply with new federal standards. This is an important opportunity because individual states are in the best position to craft frameworks that enable maximum flexibility and are appropriately tailored to local circumstances. So, this begs the question: is there an alternative, more constructive path that is most beneficial to Texas?<\/p>\n

The Kentucky Way<\/b><\/p>\n

Texas should take a serious look at Kentucky – another unlikely leader in climate policy. Last year, Kentucky sent a report<\/a> to EPA\u2019s Administrator, Gina McCarthy, laying out Kentucky\u2019s proposed framework to guide its discussions with the Federal Government. State officials clearly had some concerns about the impending standards, but they also demonstrated commitment to meeting President Obama\u2019s emissions reductions goals<\/a> and improving the health of Kentuckians.<\/p>\n

The state leaders advocated for an approach that allows for maximum flexibility to comply based on the state\u2019s unique energy portfolio and economy. Among a suite of compliance options, the Kentucky report included two noteworthy techniques. First, the state asked EPA to develop a mass-emission reduction standard (reduction of total average carbon dioxide (CO2) emissions) as opposed to a rate-emission standard (reduction of CO2 emissions per unit of energy produced). This approach opens the door for more easily measured and verified energy savings. Secondly, Kentucky proposed participating in a regional or national market-based CO2 credit trading program (similar to the Regional Greenhouse Gas Initiative<\/a> adopted by nine states), which would enhance electric reliability while also allowing for more flexibility in meeting clean air standards.<\/p>\n

All told, Kentucky\u2019s roadmap found that a significant reduction in emissions (nearly 30 million metric tons worth of CO2) could be achieved by 2020 at a very reasonable cost. Moreover, customer-facing energy efficiency would yield significant net savings<\/i> for consumers \u2013 making it by far the most cost-effective means to reduce emissions for the state.<\/p>\n

Proactive, Realistic Approach<\/b><\/p>\n

This proactive and constructive stance is smart, and Texas should take note. Rather than spending millions<\/a> of taxpayer dollars suing EPA to try to stall implementing life-saving standards, as Texas has done in the past<\/a>, Kentucky\u2019s state leaders have developed a realistic approach. The result is a proposal that aims to achieve significant, cost-effective reductions in carbon pollution \u2013 while simultaneously setting an example of robust, state-federal collaboration. This mutually beneficial plan will improve air quality, save lives, and spur a clean energy economy.<\/p>\n

On that note, I have a few recommendations as other states begin creating their own plans:<\/p>\n