Testimony on Carbon Pollution Emission Guidelines for Existing Stationary 

Sources 

Efficiency First 

J u ly 30, 2014 

Thank you for the opportunity to testify today on the EPA proposed rule on 

Carbon Pollution Emission Guidelines for Existing Stationary Sources. My name is 

Cynthia Adams, and I am Chair of the Virginia Energy Efficiency Council, appointed 

member of Governor McAuliffe's Virginia Energy Council, and a board member of 

Efficiency First whom I am here today to represent. 

Efficiency First is the national business association for the home performance 

industry, whose members are home performance contractors and companies 

across the U.S. With state and local chapters across the country, we work with 

companies to retrofit America's homes and bring them—and our economy—into 

the future. Together, we advocate for policies that accelerate the growth of the 

industry, creating huge opportunities for companies and delivering meaningful 

value to homeowners. 

First, we want to applaud the Administration for this important effort to regulate 

carbon emissions and for the recognition in the rule that energy efficiency should 

be a part of the answer to carbon reductions. We believe home performance 

meets the "Best System of Emission Reduction" (BSER) test and is a crucial part of 

Building Block #4 (Energy Efficiency) in the proposed rule. In fact, with more than 

113 million residences consuming 22% of all U.S. energy, this sector is a critical 

part of any program that targets emission reductions. We are here today to offer 

suggestions for improvement to the draft regulations and we will provide further 

details in our October 16th Comments. 

We urge EPA to consider allowing states to account for natural gas savings in 

energy efficiency programs. We urge EPA to recognize the unintended 

consequences that could be associated with fuel switching and the carbon that 

would not be captured and measured, as well as the inefficiencies in delivery of 

energy efficiency services that may come by excluding efficiency gains from gas 

and other heating fuels under the rule. 
For example in the residential sector, current home energy performance 

programs that aim to reduce the overall energy use of a home, may instead be 

encouraged by the rule to switch from electric heating to natural gas heating, 

without ensuring that this effort is coupled with air sealing and insulation. Unless 

the home is well insulated, the opportunity to achieve potential savings through 

the upgrade will be lost. Further, the carbon emitted from the natural gas heater 

will not be measured. We recommend that EPA offer states best practices for 

ensuring that energy savings is maximized in residential programs. 

Please know that not all energy efficiency programs are created equal. 

Today, rate-payer funded programs are usually required to pass a costeffectiveness test. These tests are based on five tests originally developed in the 

1970s California Standards Practice Manual. Despite more recent updates, these 

tests are often implemented in ways that are biased against deeper energy 

efficiency investments because they account for all the costs, but frequently 

ignore many of the benefits. A new screening effort that Efficiency First has 

participated in, called the Resource Value Framework (RVF) provides a powerful 

tool for public utility commissions to ensure that their cost effectiveness tests are 

balanced, transparent, and account for public policy goals. We urge EPA to 

recommend the use of the RVF to states that wish to test their 111D compliance 

programs for cost-effectiveness in order to encourage deeper energy savings 

opportunities. 

Home performance programs have many different designs, as noted in the 

proposed rule. For example, with each method for calculating savings (deemed, 

modeled, measured, etc), there are best practices that we urge EPA to include in 

its guidance to states developing their implementation plans. We will provide 

further input in our comments, but as a preliminary statement we urge the EPA 

today to consider that there are new technologies -- smart meters to measure 

energy efficiency as a resource, home energy management devices and others -- 

emerging every day in the marketplace that can assist with program design and 

carbon measurement. These technologies are providing crucial communications 

between utilities and homeowners. Standards, protocols, and platforms are just 

being developed. We strongly recommend that EPA recognize this nascent 

revolution and ensure that their regulation not close the door to new 

technologies and program designs that encourage innovation. 
As EPA develops its rules for evaluation, measurement, and verification (EMV), we 

urge the consideration of energy consumption data as provided by utilities. This 

data, in the form of both traditional utilities bills and more advanced technologies 

such as "smart devices" and home energy management systems, can provide 

valuable information about energy use and contribute to accurate quantification 

of savings. This information should be recognized and considered for use in EMV 

protocols. However, protocols and policies that allow for both data access and 

analysis may take time to develop. We encourage EPA to include the use of this 

data specifically in its EMV rules. 

Finally and importantly, we ask EPA to consider the non-ratepayer funded 

solutions to energy savings in the private sector and encourage aggregation and 

the development of a registry to register and retire emissions that private 

contractors and companies can provide from electricity reduction outside the 

utility programs. 

Thank you on behalf of the Efficiency First for the opportunity to testify. While 

there are great gains to be made overall, please ensure that continued attention 

is paid to the only element of the rule that directly both includes small business 

and average Americans — the energy reductions in the residential sector. 

Thank you.