National Energy Efficiency EM&V Standard

Lawrence Berkeley National Laboratory (LBNL), in collaboration with Schiller Consulting and Itron, has issued a new study, “National Energy Efficiency Evaluation, Measurement and Verification (EM&V) Standard: Scoping Study of Issues and Implementation Requirements.” The study was funded by the U.S. Department of Energy’s Office of Electricity Delivery and Energy Reliability (OE) and the work underlying this report was conducted to support the State Energy Efficiency Action Network EM&V Working Group.  The State Energy Efficiency Action Network, chaired by DOE and EPA, is a group of state officials and other interested groups that are focusing on the assistance states and local governments need in their critical role in advancing policies and practices that bring energy efficiency to scale.

This scoping study identifies issues associated with developing a national evaluation, measurement and verification (EM&V) standard for energy efficiency activities undertaken by efficiency program administrators (e.g., electric and gas utilities), including defining EM&V requirements and issues that will need to be addressed. To explore these issues, we provide and discuss:
• a set of definitions applicable to an EM&V standard;
• a literature review of existing state and regional guidelines, standards, and ‘initiatives’ relating to EM&V standards as well as a review of “bottom-up” versus “top-down” evaluation approaches;
• a summary of EM&V related provisions of recent Federal legislative proposals; and
• an annotated list of issues that that are likely to be central to, and need to be considered when, developing a national EM&V standard.

Primary reasons for developing a national efficiency EM&V standard are: (1) some state utility and air regulators and practitioners believe that a national standard would streamline EM&V implementation, reduce costs and complexity, and improve comparability of results
across jurisdictions, (2), if energy efficiency is determined by the US Environmental Protection Agency to be a Best Available Control Technology (BACT) for avoiding criteria pollutant and/or greenhouse gas emissions, then a national EM&V standard may be required for documenting the emission reductions resulting from efficiency actions and (3) a national EM&V standard might be required if future Federal legislation is enacted that includes a national energy resource standard (e.g., an energy efficiency resource standard, a renewable
electricity standard or a clean energy  standard) that allows end-use efficiency to qualify as an eligible resource for purposes of complying with the standard.  This report uses language proposed in various recent energy bills to provide a framework to guide an examination of the issues that would need to be resolved in developing a national EM&V standard.

Developing a national EM&V standard is likely to be a lengthy process.  We identify four high-level issues that need to be considered and addressed as part of developing a new national EM&V standard for energy efficiency resources:
• What level of detail will be provided in the EM&V standard and how much flexibility will be left to professional discretion?
• Will requirements be performance-based (i.e. a requirement for a level of certainty) or prescriptive (i.e. requiring certain EM&V approaches for any given efficiency activity)?
• Who is responsible for documenting EM&V savings from energy efficiency measures or programs that have been implemented to comply with a national energy resource standard – a state agency, administrators of ratepayer-funded energy efficiency programs, or independent, third-party EM&V professionals?
• What entities will be the users (audiences) for the results (information) that the EM&V standard generates beyond the Federal entity responsible for enforcing a national energy resource standard (e.g., will regional electricity system operators use the results for system planning and/or will environmental regulators use the results to determine compliance with emission reduction requirements)?

To address these four high-level issues, the authors  identify and discuss nine issue topic categories that if addressed and resolved should generate answers for these high-level issues:
1.      Legislative Structure for Energy Efficiency if part of a national energy resource standard
2.      Scope and Metrics of a Standard, including net versus gross savings requirements
3.      Baselines
4.      EM&V Approaches
5.      Certainty of Savings Determination
6.      Who Conducts the Evaluation Activities
7.      Reporting and Schedules
8.      Dispute Resolution
9.      Regulatory Audiences and Requirements for Standards/Protocols

The report concludes with a discussion of suggested next steps for developing an EM&V standard. The report may be downloaded here: http://eetd.lbl.gov/EA/EMP/ee-pubs.html

We welcome any feedback or questions.