### Docket No. EPA-HQ-OAR-2013-0602: Clean Power Plan for Existing Power Plants Public Hearing- Atlanta, Georgia July 29, 2014 Public Comments of: Municipal Gas Authority of Georgia 104TownPark Drive Kennesaw, Georgia 30144 770.590.1000 My name is Chris Strippelhoff. I am the Chief Membership Officer ofthe Municipal Gas Authority of Georgia. The Gas Authority, headquartered in Kennesaw, Georgia is the largest nonprofit natural gas joint action agency in the United States. We serve 78 municipally owned natural gas distribution systems in five states, as well as 9 partner organizations. Collectively, our member systems provide retail natural gas service to nearly 250,000 consumers, and annually the Gas Authority delivers more than 60 billion cubic feet of wholesale natural gas to its members and partners. Twenty-four of our members also provide retail electric service to consumers. Because future generations are dependent on our actions, the Gas Authority strongly believes in the effective stewardship of our environment, and recognizes the unique and important role natural gas plays in helping our nation achieve better air quality, while at the same time consuming our natural resources as responsibly as possible. And for the sake of our economy, we must all remain vigilant in our efforts to minimize cost impacts on energy consumers as we consider changes in policies and rules. Natural gas, used efficiently and responsibly has the potential to actually reduce overall energy expenditures for consumers too. Some have referred to natural gas as a "bridge fuel to a sustainable energy future," and perhaps they are right. What we do know presently, and are convinced of, is the fact that the direct use of natural gas in thermal applications is the most efficient, clean and cost effective way in which to use this abundant, domestic resource. The role of natural gas is actually far more important than simply serving as the back-up fuel for renewables. It has the potential to be the most effective tool in constructing truly successful demand-side energy efficiency programs. In fact, maximizing the direct use of natural gas closest to the point of consumer application may be the single most effective way to help EPA meet its stated goals of, 

### "cutting wastedenergy, improving efficiency, and reducing 1

### pollution- while still having all thepower we need to grow our economyandmaintain our competitive edge." 1 We cannot manage what we cannot measure, but what we measure must be meaningful. Because emissions are directly related to energy consumption, our universal focus must be on "Source Efficiency" when measuring energy use. All otherthings being equal, less energy consumed equates to lower emissions. We must embrace an efficiency standard encompassing the full-fuelcycle. Full-fuel-cycle energy is defined by DOE as, "Point-of-use energy, the energy losses associated with generation, transmission, and distribution of electricity, and the energy consumed in extracting, processing, and transporting or distributing primary fuels.'' 2 Very simply, we must consider the entire energy chain, from source to site, and establish rules and policies accordingly. DOE has recognized the shortcomings of site-based analysis as well as the National Academy of Sciences in a 2009 report. EPA's own ENERGY STAR® Portfolio Manager program is already using and promoting source-based energy analysis. Let me give you an example ofwhy this is so critical. I will use the application of residential water heating to make the point. The typical tank-style natural gas water heater consumes 26.6 MMBtu annually. Its electric resistance counterpart consumes 49.8 MMBtu annually. The natural gas unit emits 

### C02 at less than halfthe rate of an electric unit. In terms of energy costs, the consumer using natural gas pays $265 annually while his neighbor relying on an electric water heater pays $562. Interestingly, sales of residential electric water heaters over the last 13 years were running neck and neck with gas water heaters, and in fact exceeded sales of gas units three years running duringthe period. 3 Why? Let me suggest two reasons: (1) The yellow labels on appliances only report site-based efficiency figures; and (2) Many electric utilities are incentivizing consumers to purchase electric models. Because ofthe current methodology of measuring efficiency only at the point of use, yellow labels on appliances suggest to consumers that the electric resistance water heater is more efficient and environmentallyfriendly by as much as 53%. Nothing could be further from the truth. The same logic applies to otherthermal applications such as space heating, cooking, and clothes drying. Importantly, it also applies to larger commercial and industrial applications such as combined heat

1 EPA FACT SHEET: Clean Power Plan- June 2, 2014 2 Federal Register/Vol. 76, No. 160/Thursday, August 18, 2011/Proposed Rules 51282) 3 http://www.statista.co m/statistics/220303/manufactured-shipments-of-residential-storage-water-heaters/ 2

# .. and power units. We owe it to the consuming public to properly inform them, and if incentives are to be employed by utility companies, they should be offered such that consumers are purchasing the most efficient, environmentally-friendly, and cost-effective appliances; again, using the full-fuel cycle methodology. In fact, it is past time to create a new appliance labeling program, perhaps movingto green labels, which could display true efficiency in terms ofthe full-fuel cycle, and quantifythe appliance's actual carbon footprint. In addition to what I have shared verbally this afternoon, I have attached two sheets with illustrations that more fully explain the issue. I respectfully ask that these be included in the comments ofthe Gas Authority. On behalf ofthe Gas Authority I wish to thank the EPA for conducting these public hearings. We are grateful for the opportunity to share our thoughts on this important matter.

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