July 29, 2014 

Southern Alliance for Clean Energy 

Docket ID: EPA-HQ-OAR-20 13-0602 

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Comments on Energy Efficiency in the Proposed Clean Power Plan 

Good morning, Regional Administrator Toney and staff of EPA Region 4. My 

name is Taylor Allred, and I am here speaking in place of John Bonitz on behalf 

of the Southern Alliance for Clean Energy, or SACE. SACE appreciates this 

opportunity to provide oral comments to the EPA on the proposed Clean Power 

Plan. Today, my comments will focus on energy efficiency. 

I would like to start by saying that SACE appreciates the EPA's use of energy 

efficiency as a building block in the proposed rule. SACE applauds the EPA's 

acknowledgement that energy efficiency is an abundant resource that can be 

used to reduce carbon emissions while also saving people money on their utility 

bills. SACE also appreciates that the EPA has proposed state-level efficiency 

goals that will significantly increase the level of energy efficiency in the 

Southeast. The proposed cumulative goals for Southeastern states will save 

approximately I 0% of retail electric sales by 2029. SACE believes that these goals 

are not only achievable, but also fairly conservative compared to the region's 

full energy efficiency potential. 

SACE believes that maximizing energy efficiency impacts is essential for our 

nation, and particularly for Southeastern states, for several reasons. First, the 

United States as a whole currently fails to lead in energy efficiency. In a recent 

energy efficiency scorecard published by the American Council for an Energy 

Efficient Economy, or AC EEE, the U.S. is ranked 13th out of the l 6 largest 

economies.' The scorecard considers energy efficiency policies and programs 

covering several differer. r c-:Jtegories, including buildings, industry and 

transportation, and data on overall energy use. 

Our country and our region cannot afford to fall behind on energy efficiency. 

Among the nations with higher energy efficiency rankings than the U.S. are 

Germany, China, India and South Korea- all of which enjoy a competitive 

advantage by being able to produce goods and services using less energy. 

Moreover, Southeastern states have lagged behind in energy efficiency in the 

U.S. In ACEEE's state-level energy efficiency scorecard, not a single Southeastern 

state is ranked in the to,: 302 Consumers in the Southeast also have some of the 

highest electricity bills in the country. Recent data from the Energy Information 

1 American Council for an Enerpy Efficient Economy. International Energy Efficiency Scorecard, 

http :I I aceee .org/portol/notic.i01· ~olicy /international-scorecard 

2 American Council for on Energy Efficient Economy. State Energy Efficiency Scorecard, 

http:/ I aceee .org/state-policy /scorecard 

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Administration indicates that eight out of the 15 states with the highest overage 

monthly electricity bills ore in the SoutheasP High electricity bills combined with 

low median incomes result in a higher-than-overage financial burden for 

Southeastern families, and U.S. Census data shows that Southeastern states make 

up nine out of the 15 states with the lowest median income rates' 

It is SACE's understanding that energy efficiency measures that hove been put 

into place after the proposed rule was released may count toward the initial 

annual goals. SACE applauds the EPA for allowing early action on energy 

efficiency to count toward the goals, and SACE has encouraged Southeastern 

utilities to consider this factor as they make decisions about energy efficiency 

investments today. 

Energy efficiency will also help the economy in several ways. To begin with. 

energy efficiency creates a lot of jobs. A study by Southface, a Georgia-based 

organization focused on green building services, found that over 4,1 00 

Georgians were employed fuli time in the energy efficiency and building 

sciences sector in 2013.5 In addition to direct job creation. energy efficiency puts 

more money in consumers' pockets, which drives economic growth and further 

job creation. Lower utility bills also position local businesses to be more profitable 

and create even more jobs. 

SACE is also aware of the EPA's request for comments on several other issues, 

including increasing the states' savings targets to 2% per year to reflect the 

impact of energy efficiency strategies outside the utility sphere, such as building 

efficiency codes and state appliance standards. SACE looks forward to 

commenting on this C'ld other topics in the coming weeks. 

Thank you for your time. 

3 Energy Information Administration, 2012 Average Monthly Bill- Residential, 

http:/ /www.eio.gov /electricity/soles_revenue _price /pdf /toble5_o.pdf 4 U.S. Census Bureau, State Med:'Jn Family Income, 

https: //www .census .g ov /h h es/www /income I do to I stat em edi on I 

5 Southfoce, Georgia Clean Energy Industry 2013 Census, http://www.southface.org/defoultin teri or I go en erg ycensusfina l.pdf