### Georgia Energy EfficiencyTrade Association's Comments on Energy Efficiency in the Proposed Clean Power Plan

Good afternoon Regional AdministratorToney and staffof EPA Region 4. My name is Howard Katzman, and I am here speaking in place ofAllie Brown on behalfofGeorgia Energy Efficiencyfrade Association, or GEETA. We appreciate this opportunityto provide oral comments to the EPA on the proposed Clean Power Plan. Today, my comments will focus on energyefficiency.

Iam selfemployed in metroAtlanta as an energy efficiency consultant. A major part of my business is performing home assessments for Georgia Powercustomers looking to improvetheir 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 eagertogetthe house fixed. They are seeing theirenergy bills go down by 15 or 20 oreven 40%. Iam working with overadozen companies to form GEETA because we knowthat there is a huge needoutthere. Plus GEETA will give our industry a combinedvoice to advocate forthe economic development ofenergy efficiency in Georgia.

The houses we are fixing are not unusual. There are literallytens ifnot hundreds of thousands of homeowners across Georgia who can benefitfrom this type ofprogram. Georgia has several paths for meeting its C02 reduction goals, as outlined in the proposed Clean Power Plan, and energy efficiency is avery inexpensive wayto meetthe goal.

The only utility in the state with energy efficiency goals, Georgia Power, saved 450 million kilowatt-hours from 2011-2013. Movingforward, Georgia Power's goal is slightly higher, and it is projectedto save 0.4% of retail sales each year. While this goal is not robust, it is significantly higherthan the energy efficiency impacts ofthe EMCs and municipal utilities, which make up approximately halfofthe state's electricitysales.

A statewide energy efficiency program for homes and businesses modeled on Georgia Power's current programs should be key component ofthe state's plan. We are seeing homeowners implement cost-effective improvements, like duct and airsealing and adding insulation and getting a large bang fortheir buck.
Given the need for Georgia Power, the EMCs and the municipal utilities, to work togetherto achieve Georgia's energy efficiency goal, I suggest that astatewide 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 propertytax 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 atriple 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 benefitfrom lowered utility bills Createsjobs locally, generatingtax base
Property owners easily embrace energyefficiency when shown how it can benefit them.

The nucleus ofthe energy efficiency industry already exists and can easily ramp up. Georgia has over4000 people employed in improvingthe energy efficiency of buildings according to the 2013 Southface Clean Energy Industry Census. Businesses will put people to work locally in meaningfuljobs with translatable skills.
Improving energyefficiency in buildings and homes in Georgia CAN be a major component ofthe Clean Power Plan. This is a grand opportunityto reduce carbon emissions while creatingjobs, saving citizens money and growing businesses like mine.

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