The critical element needed to integrate energy efficiency and renewable energy policies, programs and projects into air quality compliance plans is a clear link between emissions and energy production and use within the regulatory framework. Energy officials see a direct connection. They assume that reductions in energy use and renewable energy developments reduce or displace new or existing energy production. In their minds, these hypothesized reductions or displacements of energy production translate directly into actual emissions reductions. Energy officials use generic, theoretical resources to measure the emissions that might otherwise have been released. Historically, they have not concerned themselves with demonstrating where, when or whether emissions reductions occur at actual, specified emissions sources.

Air quality officials, on the other hand, focus on emissions sources, the "activities" they perform and the "emissions rates" associated with their activities to determine allowable emissions levels and emissions reductions. The amount of activity at a source is measured in terms of production, use, raw materials input, vehicle miles traveled (VMT), or other similar units that have a direct correlation with the economic output and emission rate of the source. Air quality officials account for lowered activity and emission rates at actual, specified energy production sources, but they ignore separate, specific energy end-uses except in the transportation sector where VMT for each of several different vehicle categories measures end-use and activity simultaneously.

Since air quality officials do not use end-uses to calculate emissions levels, reducing electricity demand in a nonattainment area does not necessarily translate into an emissions reduction within the airshed. Only reduced activity or lowered emissions rates at powerplants located within the nonattainment area qualify as emissions reductions in air compliance plans. The measurements are made at the point of production and not the point of ultimate use. Thus, the geographic location of the powerplants serving loads within a nonattainment area may destroy the relationship energy officials believe exists between energy efficiency improvements, renewable energy developments, emissions levels and air compliance plans.

Air quality officials, probably, have not seen reduced activities at powerplants despite seeing economic growth fueled with less intense electricity usage. In all likelihood, any emissions reductions that might have occurred at powerplants have resulted from lowered emission rates, i.e., new controls. Older plants have not been retired in response to more efficient electricity use. In fact, electricity demand has continued to grow nationally, regionally and in most localities. To an air quality official, this means new sources and more emissions to address. Reserve margins have been declining throughout the country forcing older plants to operate more rather than less. This increased activity leads to greater emissions within airsheds, not lowered ones. In fact, in many areas standby generators that may be relatively polluting compared to new technologies are seeking to amend their permits so they can operate more often.

A similar disparity between the parameters used to measure emissions from natural gas use by air quality officials and the ones employed by energy officials precludes specific natural gas efficiency improvements from being counted explicitly as emissions reductions. Air quality officials use the total natural gas consumption within a nonattainment area by customer class to measure activity. They do not distinguish natural gas consumption by end-use application, only end-use sector. More efficient use of natural gas reduces the activity level and lowers emissions within the airshed when counted this way. However, the emissions reductions are captured through an aggregated rather than a dissociated measure of use. An aggregated measurement may justify using a lower emissions baseline growth rate for natural gas consumption in an air compliance plan than econometric models might suggest, but it would not substantiate reductions from specific natural gas end-use energy efficiency measures.

What is measured and how it is recorded in air compliance plans is a pivotal issue that must be resolved before air quality and energy officials can begin to identify opportunities for energy efficiency improvements and renewable energy developments within air quality compliance strategies. Because air quality officials focus exclusively on activities that pollute and energy efficiency improvements and renewable energy developments are inherently non-polluting, air quality officials have not historically accounted for them. Until they do, the opportunities for energy efficiency improvements and renewable energy developments will be restricted.

A broader set of strategies for integrating energy efficiency improvements and renewable energy developments into air quality compliance plans could be pursued if state air quality and energy officials could agree on protocols for directly linking them to actual emissions. For example, discrete energy end-uses could be tied directly to emissions and/or output based emissions rates could be applied to all electric generating sources regardless of the fuel used to produce the electricity. In this air quality regulatory framework, emissions reductions from energy efficiency programs and offsets from renewable energy developments could be verified, measured and incorporated into air compliance plans as discrete "creditable" measures. Also, switching to output-based emissions rates would promote more efficient generation and the construction of more combined heat and power facilities. Alternatively, state air quality officials could modify their regulatory approach to create separate opportunities for energy efficiency improvements and renewable energy developments within their air quality compliance plans. For example, they could change the way they allocate allowances to permitted sources and set-aside some of them for efficiency and renewable energy programs and/or projects. This would need be accomplished within the context of an emissions cap and trade program.

The opportunities for energy efficiency improvements and renewable energy developments to address air quality problems may also be restricted because air quality officials are required to model "allowable" emissions and not "actual" emissions when they prepare their compliance plans. This requirement can create situations where "actual" emissions have been lowered by energy efficiency and renewable energy policies, programs or projects, but where "allowable" emissions within the model remain unchanged.