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

_____________________________________________________________________________________________________

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 202.872.9354c 703.582.1324 e rmcarver@aham.org

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

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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, there 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 by 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 entities 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 

purchase 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 refrigerators 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. Preliminary AHAM estimates of expanded 

refrigerator early replacement and recycling programs indicate 30-60 million MtCO2 could be
p 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 five 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 utilities, 

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 based 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 energy 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, Federal 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 Counsel 

Mr. Dan Utech, Special Assistant to the President for Energy and Climate Change