Fri May 23 13:49:50 EDT 2014 Leavy.Jacqueline@epamail.epa.gov FW: AHAM-NRDC Joint Letter Regarding 111(d) Proposed Rule To: CMS.OEX@epamail.epa.gov

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From: McArver, Rob [mailto:rmcarver@aham.org]

Sent: Friday, May 23, 2014 1:45 PM

To: Mccarthy, Gina

Cc: 'the.secretary@hq.doe.gov'; McCabe, Janet; Goffman, Joseph; 'Dan_G._Utech@who.eop.gov'; 'Richard_Duke@ceq.eop.gov'; amcconville@ceq.eop.gov; 'Candace_M_Vahlsing@ceq.eop.gov'; 'Rohan_Patel@who.eop.gov'; 'dmurrow@nrdc.org' Subject: AHAM-NRDC Joint Letter Regarding 111(d) Proposed Rule

Please find attached a joint letter from the president of the Association of Home Appliance Manufacturers and NRDC regarding support for inclusion of an appliance early replacement program in the 111(d) proposed rule. We are available to discuss this matter at your convenience and thank you for your consideration of this important program.

Robert D. McArver

Vice President, Policy & Government Relations

1111 19th Street NW, Suite 402, Washington, DC 20036

t 202.872.5955 ext316 f 202.872.9354 c 703.582.1324 e rmcarver@aham.org

Visit www.aham.org or AHAM's Blog aham.typepad.com

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Attachment type: [image/jpeg]May 23, 2014

Honorable Gina McCarthy

Administrator U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, NW Washington DC

Re: Energy Efficiency and Carbon Standards for Existing Power Plants

– Highlighting Appliance Early Replacement/Recycling Programs

Dear Administrator McCarthy:

Our organizations share a common interest in maximizing the role of energy efficiency in reducing U.S. emissions of greenhouse gases (GHGs). Lowering demand for electricity through improvements in efficiency is often a more cost

- effective strategy than controlling emissions directly or investing in other sources of energy. While the U.S. has made progress in reducing energy consumption, ther e are many untapped opportunities for substantial energy savings and capturing these savings should be a top priority.

Our organizations believe the upcoming EPA rulemaking to reduce carbon emissions from power plants under section 111(d) of the Clean Air Act (CAA) can take advantage of this efficiency resource both in setting the standard and as an essential compliance option for states as they develop plans to meet the rule’s emission reduction goals. The June notice of proposed rulemaking to be issued b y EPA should jumpstart innovative thinking on energy efficiency by identifying the minimum elements of energy efficiency programs and providing a framework for using these programs to generate energy efficiency credits.

States, utilities, and other enti ties have developed a wide range of successful energy efficiency programs that can and should be encouraged to expand in response to electricity sector carbon

standards. In this letter

, we highlight the opportunity and benefits of a program that combines

p urchase and recycle rebates for appliances.

Cooperative efforts between the appliance industry , other stakeholders , EPA and DOE have

resulted in a dramatic improvement in refrigerator energy efficiency since 1990. These gains are reflected in the most recent DOE and ENERGY STAR efficiency requirements. Refrigerators have a long useful life and retain value for consumers. With 147 million refrige rators expected to be on the grid in 2016, replacing a significant number of working refrigerators with new models that comply with the 2014 standards will yield immediate, large

- scale energy savings and

associated GHG emission reduction benefits. Prelimi nary AHAM estimates of expanded refrigerator early replacement and recycling programs indicate 30

- 60 million MtCO 2 could bep 2 reduced over a five year period at a cost of approximately 2.3 ¢/kWh . US consumers could save an estimated $5

- 10 billion over a fiv e year period from lower electricity bills.

Rebates are a proven motivator for replacing and recycling older refrigerators that would otherwise remain on the grid. States have achieved success with appliance rebate programs, but

their effectiveness could be expanded and improved through a national framework that links purchase rebates and recycling rebates and is actively supported by the industry’s marketing and sales network. Properly framed, the carbon standard would create strong incentives for utilit ies, states, the appliance industry, retailers and NGOs to work together to launch such an effort. Reasonable work is needed at the federal and state levels to refine the requirements for such an initiative, but we believe this effort can proceed quickly b ased on our collective experience with existing rebate programs. As we move forward, we look forward to working with EPA and DOE

on the details.

The June carbon standard proposal for existing power plants should send a powerful signal of support for energ y efficiency by highlighting concrete examples of opportunities for states to reduce energy use and lower GHG emissions. Our organizations strongly encourage EPA to identify appliance early replacement and recycling in the proposal as one such example to demonstrate the potential value of energy efficiency under the standards and provide support for state and industry efficiency initiatives.

Thank you for considering our views.

Sincerely,

Joseph M. McGuire Derek K. Murrow

President Director, Federa l Energy Policy

Association of Home Appliance Manufacturers Natural Resources Defense Council

cc: Honorable Ernest Moniz, Secretary of Energy Ms. Janet McCabe, Acting Assistant Administrator for Air and Radiation Mr. Joseph Goffman, Associate Assistant Administrator and Senior C ounsel Mr. Dan Utech, Special Assistant to the President for Energy and Climate Change