Comments to Iowa Utilities Board on Energy Efficiency Program Benefits
The Iowa Utilities Board is currently reviewing its policies on energy efficiency planning. We submitted comments supporting some of the suggestions made by stakeholders to better gauge the benefits of the energy efficiency programs.
A complete accounting of an energy efficiency program’s cost-effectiveness should consider all the benefits that are significant and quantifiable, including those that affect utilities, ratepayers, and society as a whole. Our comments support Black Hills Energy’s recommendation that the Board include “non-energy benefits” in the definitions of the cost-effectiveness tests, which would provide Iowa’s utilities with a more comprehensive mandate to estimate all of the benefits resulting from their energy efficiency programs. We also suggest that the administrator of the Iowa Technical Reference Manual (TRM) make changes and additions to ensure that utilities capture the non-energy benefits of their energy efficiency programs. In particular, the TRM should include valuations of avoided emissions, both of greenhouse gases and ambient air pollutants.