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 agolden 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.