Georgia Energy Efficiency Trade Association's Comments on Energy 

Efficiency in the Proposed Clean Power Plan 

Good afternoon Regional Administrator Toney and staff of EPA Region 4. My name is 

Howard Katzman, and I am here speaking in place of Allie Brown on behalf of Georgia 

Energy Efficiency frade Association, or GEETA. We appreciate this opportunity to 

provide oral comments to the EPA on the proposed Clean Power Plan. Today, my 

comments will focus on energy efficiency. 

I am self employed in metro Atlanta as an energy efficiency consultant. A major part of 

my business is performing home assessments for Georgia Power customers looking to 

improve their home's comfort and reduce energy bills. Thankfully business is strong, 

largely because once people learn that there are workable cost-effective solutions to 

their problems they are eager to get the house fixed. They are seeing their energy bills 

go down by 15 or 20 or even 40%. I am working with over a dozen companies to form 

GEETA because we know that there is a huge need out there. Plus GEETA will give our 

industry a combined voice to advocate for the economic development of energy 

efficiency in Georgia. 

The houses we are fixing are not unusual. There are literally tens if not hundreds of 

thousands of homeowners across Georgia who can benefit from this type of program. 

Georgia has several paths for meeting its C02 reduction goals, as outlined in the 

proposed Clean Power Plan, and energy efficiency is a very inexpensive way to meet the 

goal. 

The only utility in the state with energy efficiency goals, Georgia Power, saved 450 

million kilowatt-hours from 2011-2013. Moving forward, Georgia Power's goal is 

slightly higher, and it is projected to save 0.4% of retail sales each year. While this goal is 

not robust, it is significantly higher than the energy efficiency impacts of the EMCs and 

municipal utilities, which make up approximately half of the state's electricity sales. 

A statewide energy efficiency program for homes and businesses modeled on Georgia 

Power's current programs should be key component of the state's plan. We are seeing 

homeowners implement cost-effective improvements, like duct and air sealing and 

adding insulation and getting a large bang for their buck. 

Given the need for Georgia Power, the EMCs and the municipal utilities, to work 

together to achieve Georgia's energy efficiency goal, I suggest that a statewide entity, 

such as the Georgia Environmental Finance Authority, could manage a statewide energy 

efficiency program. There are many advantages to this approach in Georgia. A 

consistent statewide program: 
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Reduces confusion in the market and simplifies promoting the program 

Streamlines and economizes delivery by contractors 

Allows savings in natural gas/propane as well as kWh to be recognized by the 

programs (GA Power's programs only recognize kWh reduction) 

Could provide financing allowing customers to repay improvement costs on 

either utility or property tax bills. These are proven approaches with very low 

delinquency rates and allow improvement costs to be paid for out of utility 

savings, usually at no net cost increase to the homeowner 

Achieves a triple bottom line: Property owners, homeowners and tenants, 

businesses all benefit with savings 

Assures the state's C02 goals are more easily met 

Is fair because citizens statewide benefit from lowered utility bills 

Creates jobs locally, generating tax base 

Property owners easily embrace energy efficiency when shown how it can benefit them. 

The nucleus of the energy efficiency industry already exists and can easily ramp up. 

Georgia has over 4000 people employed in improving the energy efficiency of buildings 

according to the 2013 Southface Clean Energy Industry Census. Businesses will put 

people to work locally in meaningful jobs with translatable skills. 

Improving energy efficiency in buildings and homes in Georgia CAN be a major 

component of the Clean Power Plan. This is a grand opportunity to reduce carbon 

emissions while creating jobs, saving citizens money and growing businesses like mine. 

Georgia Energy Efficiency Trade Association's Comments on Energy Efficiency 

in the Proposed Clean Power Plan 

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