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 

104 Town Park 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 wasted energy, improving efficiency, and reducing 

1 
pollution- while still having all the power we need to grow our economy and maintain 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 other things 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 of why 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 half the 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 during the 

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 of the 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 environmentally friendly by as much as 53%. Nothing could be further from the truth. The same 

logic applies to other thermal 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 .sta tista. co m/sta tisti cs/2 20303/ manu factu red-sh i pments-of-residen tial-sto rage-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 moving to 

green labels, which could display true efficiency in terms of the full-fuel cycle, and quantify the 

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 of the Gas Authority. 

On behalf of the 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. 

3 
.. ,,-

SOURCE EFFICIENCY ILLUSTRATION 

100 92 

;, l , ', ., L·' 

''"'-' '= \o·' 

NATURAL GAS 

100 88 29 

', 

·; ;-- ' - -, 

ELECTRICITY 

8a5f·d Gil C:.rre:ll Fossil Fuel elf Coal 0!1 .-md Gas 

'>(JL•RCt: Ererg; '"duti0!1; t._.nte• 

" 

90 

, 

., 

27 

\lr 1."' 'J'l;-

":l -,, 

APPLIANCE 

EFFICIENCY 

APPLIANCE 

EFFICIENCY 

95% 

SOURCE 

EFFICIENC

l 5Ji

SOURCE 

EFFICIEN

..... 
• 

T :'rc?e Une' more energy reaches the 

customer with natural gas direct use. 

//~-,i,\\ 

37.1 ./ \ 

'/~~--~/ 

El ectri city Natural Gas 

Total Annual Energy Cost of a Typical Home 

$L748 N:Jturo! Gas Home $1,031 

' -·. -'----' -~' 

---"'::'-~~:]'J~~-T-. ~ J '-"'j -" J;!:~_\)~/'TJ·J'' · ··<~,-~,. ___ - ~-- J.·: J.l>.' ·-·~'' ···J"Jo·• -~;, ·J~ ''J '1-'':' 

~. 1"-J'"-_o-:"r, >J..,'- -c'j· :=_.:-J- '' -_]._,.--J, ...occ:··-•·-J· L'KJ' '•'•l, ''C'.·> ···:,;1•' 

.:._"'·::~-~-':- <:·X r"_J t.-·J"'7' ·e·.-:1 ·__: _ "~3 y·.j. · -"-c-. J, r··-J 

Residential Energy Eff1ciency Ratings for Space Heatmg 

Electnc Resrstance Electnc Heat .t. Natural Gas 

Furnace Pump ~ Furnace 

81.762 

7.). 7 

6;).2 

- Jl i=·_,e ~~-·;:-:1..:.; r:::r:e'-g'; 

.J::- :JTptl::::' ·-··.·--<~. "' ·:· 

F9derJI ,'v\.!liT.~.J:Y'r 

~tf·-::er~:v R ...l :lg 

.. ' . ,.., '' ,~, " 

.,. ,.,- '"''' -··-" ;-- .r •o ,,,., 

A source or full-fuel 

cycle analysis examines 

all impacts associated 

with energy use, 

including those from 

extraction/production, 

conversion/generation, 

transmission, 

distribution, and 

ultimate energy 

consumption. The 

current site-based 

measurement methods 

only calculate the 

energy consumed at 

the end-use point and 

fails to account for the 

energy loss from 

delivery to the point of 

final consumption. 

Direct use of natural 

gas results in 34'111 

less carbon dioxide 

emissions from a 

typical home's 

heating, water 

heating, cooking 

and clothes drying 

energy uses during 

the full-fuel cycle. 

While the DOE rates 

an electric appliance 

with a more efficient 

energy rating than a 

similar gas appliance, 

in reality that electric 

appliance consumes 

more source energy, 

costs the consumer 

more to operate, 

produces more 

pollution than 

natural gas. 
Residential Energy E.:c,c1ency Ratings for Cook1ng Equipment 

Electnc Natural Gas 

;p~: -r::~. Nit' J "i r":.: 

P ~~:·::L ::ork:·e" 1~ .,,) 

--1-'>N~;·i:'.· - _T .Ll: .]:;::1'; . " '~ 

2 J •' C'"'lf:<'· r-J~ ;--_:::d -r-..:..; ~. ;p 

J:.J:_l :-}JO -!:;,... ~ 

2-~ ~ :-:--r· 2---- ..._ • ~·<:..- '-'-:; 

F ,;..:.;1 ::-, ,__, - -~; :.1, :J·t-_.::_.; j ·;< ':t-::' 

--, :___. --.--,~· -:,r- . 

Resldent1a! Energy Effic1ency Ratmgs for Water Heater Effic1ency 

IO.;J 

:J.O 

Elednc Res! stance Natural Gas 

:-~· 1-:,0 J \,, '•~:f''-,·Y•I 

.c-:r- - - •• ~ .,. .ct:-1- .,,j ·, _' 

.:-_,_."--?''~ '":;':+ ·: ~-'. __ ·; ~-J':···J: 

Joj?':o.·:- "::':":"·-~+-,~ .... _r-'o· 

t:• -:;3-\~ l-; ~" C'> '.0<7' r ,\·.J•.;o.• 

···.::cr7':'·< F":. J~~~"=" J·::: ~bl'-"' ·:~:: 

~ __.·l 2:-v',;;~ -.-.. -.-~- :r,J·' __ 1: ·:LL 

Residential Energy Eff1oency Ratings for Clothes Dry1ng 

Electnc Natural Gas 

·'"'-.. )'"'·' -J \·~ '!>'y' .. J~I 

t_if -.-_ ~,--' Y:::l~ -~·j • 

0.6 Sll7 

:_:p_; JP)'I-.)- -_:::,. r .. t _, ·-.c1t·~: J 

JT ,-,. :j ,c:-· "·.T ~-::!t 

··,.:::, t·.: L-::' , _ "':': s-c·-~1:._;1.' 

:-~~~~ ;" :J' j =/~~:] 

r.:::.r ,..:;';]; ·>J" -J ,- T_,._J, 

~:_L ~ ;d-,::._; j, ""-''