ADS urges EPA to put smart grid in carbon-plan options

Smart Grid Today

The Assn for Demand Response & Smart Grid (ADS) was hoping EPA's Clean Power Plan would make more mention of the role of smart grid technology, DR and conservation voltage reduction (CVR) in the reduction of CO2 emissions rather than their more simple role in increasing energy efficiency, ADS Executive Director Dan Delurey told us yesterday, summarizing public comments his group filed.

The ADS filing was yesterday – EPA's deadline for comments.

"One of the things we at ADS had called early attention to is the confusing way in which the draft was constructed as a document," he said. "It made it seem to many people that the 'building blocks' were intended to be a menu from which you selected items to put your compliance plan together."

Smart grid and DR were not mentioned "in many of those building blocks," Delurey warned. Some state commissioners have said that the plans the firms they regulate could use would have to pull only from the building blocks, he added.

The EPA's Clean Power Plan also should focus more on stating outright the environmental benefits resulting from smart grid technology, DR programs and CVR, Delurey said. "We cited research – reports on pilots and programs showing that DR has a net conservation response in almost all cases," he added.

The EPA is not expected to provide exact numbers in quantitative benefits of smart grid and DR programs, but ADS had still hoped the agency would highlight how they could make a measurable impact on CO2 emissions, Delurey said.

ADS previously raised such concerns with the EPA (SGT, June-4). In response, the agency met with Delurey and started an outreach effort to educate states about how smart grid and DR technologies can cut CO2 emissions (SGT Aug-18).

APPA, western states chime in

Other groups weighed in with comments to the EPA, too, including the APPA, warning in its filing that, "If implemented in its current form, EPA's proposed rule will create economic inefficiency, impose additional costs on electricity customers, threaten the reliability of the electricity system, and force risky over-reliance on a single fuel – natural gas – to generate electricity."

EPA should change the proposal to provide credit for investments, renewable energy and efficiency improvements already made that reduced CO2 emissions, APPA added.

The EPA should clarify whether states can count resources generated in other states toward their goals of meeting renewable energy generation targets, an alliance of 13 western states convened by the Center for the New Energy Economy at Colorado State University told the press.

"Western states are mixed on how [the] EPA should credit renewable generation," but agree the agency "should ensure the final rule is clear on how renewable generation is used in demonstrating compliance," the alliance said.


© 2014 Modern Markets Intelligence, Inc. IMPORTANT: This article was reproduced from the December 2, 2020 issue of Smart Grid Today with the limited permission of the owner. To view the full story on Smart Grid Today’s website, please visit

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