CPP Public Hearing (Washington, DC) on 07/30/2014 

I would like to thank EPA for the opportunity to give this presentation at 

today's hearing on the Clean Power Plan. My name is Adam Carpenter and I 

am with the American Water Works Association. For those unfamiliar with 

AWWA, we are a membership association of approximately 50,000 

members, representing the whole range of the water sector including 3,900 

water utilities and several thousand service companies and manufacturers. 

Importance of Energy Efficiency Measures 

I would like to commend EPA for including building block 4, demand side 

energy efficiency, within the Clean Power Plan. By including demand-side 

energy efficiency measures, impacted sectors that are not directly regulated 

by the plan will be able to nevertheless offset at least some of their 

increased costs through increasing electricity prices by reducing 

consumption. 

The water utility sector is estimated to use approximately 1 percent of the 

nation's electricity supply to provide their vital service — and in some areas 

an even larger percentage. By translating the projected increase costs of 

electricity to the water sector, it is likely that this rule will cost utilities $250 

million per year by 2020, which is more expensive than most drinking water 

regulations have been. If the sector is able to secure just 1 percent of the 

funding likely to become available for energy efficiency measures, the 

sector's cost will likely be reduced by $100 million per year. 

Water Utilities can be Part of the Solution 

AWWA strongly believes that the water utility sector can be an important 

part of reaching the state goals laid out in EPA's clean power plan. There is 

an ever increasing body of literature about ways to increase energy 

efficiency at water treatment plants, in drinking water distribution, and in 

wastewater collection and treatment. In many ways, water utilities are a 
golden opportunity for energy efficiency programs as they are professionally 

staffed, continuously operated, are present in most communities around the 

country, and their efficiency gains can easily be verified as needed. 

Need for flexible state plans, including custom efficiency improvements 

Although water utilities can participate to some extent in the more common 

replacement of lighting and heating and air conditioning system, we believe 

there are great gains to be made throughout the Water-Energy nexus not 

generally covered by existing state rebate and incentive programs such as 

more efficient pumps and motors, reducing lost water, and rehabilitation or 

replacement of worn and less efficient infrastructure with more efficient 

equivalents. 

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Therefore, AWWA would like to encourage EPA to include language in the 

final rule as well as in guidance and supporting materials for states, electric 

utilities, and the public that the water sector can be included an important 

part of achieving the goals of energy efficiency upgrades. We further 

encourage EPA in their discussions with and guidance to states to allow for 

custom energy efficiency improvements to be eligible for funding, rebates, 

and incentives as many of the solutions throughout the water sector will be 

custom soiutions for the particular circumstances of that area. Thank you 

for your time and attention and AWWA looks forward to submitting 

additional written comments during the remainder of the comment period.