Testimony on Carbon Pollution Emission Guidelines for Existing Stationary Sources 

By Nate Natale 

Vice President of Operations, Home Performance Coalition 

July 31, 2014 

10:00am 

Thank you for the opportunity to testify today on the EPA proposed rule on Carbon Pollution 

Emission Guidelines for Existing Stationary Sources. My name is Nate Natale and I am the Vice 

President of Operations for the Home Performance Coalition, a non-profit 501c3 that advances 

policy change through policymaker education, stakeholder engagement, and research. 

First, we want to applaud the Administration for this important effort to regulate carbon 

emissions and for the recognition in the rule that energy efficiency should be a part of the 

answer to carbon reductions. We believe home performance meets the BSER test and is a 

crucial part of Building Block #4 in the proposed rule. In fact, with more than 113 million 

residences consuming 22% of all U.S. energy, this sector is a critical part of any program that 

targets emission reductions. We are here today to offer suggestions for improvement to the 

draft regulations and we will provide further details in our October 16thComments. 

We urge EPA to consider allowing states to account for natural gas savings in energy efficiency 

programs. While we recognize that "off sets" are not allowed by the Clean Air Act, we urge EPA 

to recognize the unintended consequences that could be associated with fuel switching and the 

carbon that would not be captured and measured, as well as the inefficiencies in delivery of 

energy efficiency services that may come by excluding efficiency gains from gas and other 

heating fuels under the rule. 

For example in the residential sector, current home energy performance programs that aim to 

reduce the overall energy use of a home, may instead be encouraged by the rule to switch from 

electric heating to natural gas heating, without ensuring that this effort is coupled with air 

sealing and insulation. Unless the home is well insulated, the opportunity to achieve potential 

savings through the upgrade will be lost. Further, the carbon emitted from the natural gas 

heater will not be measured. We recommend that EPA offer states best practices for ensuring 

that energy savings is maximized in residential programs. 

Please know that not all energy efficiency programs are created equal. 

Today, rate-payer funded programs are usually required to pass a cost-effectiveness test. 

These tests are based on five tests originally developed in the 1970s California Standards 

Practice Manual. Despite more recent updates, these tests are often implemented in ways that 

are biased against deeper energy efficiency investments because they account for all the costs, 

but frequently ignore many of the benefits. A new screening effort developed by the Home 

Performance Coalition and numerous partners called the Resource Value Framework (RVF) 

provides a powerful tool for public utility commissions to ensure that their cost effectiveness 
tests are balanced, transparent, and account for public policy goals. We urge EPA to 

recommend the use of the RVF to states that wish to test their 111D compliance programs for 

cost-effectiveness in order to encourage deeper energy savings opportunities. 

Home performance programs have many different designs, as noted in the proposed rule. 

From deemed savings, to modeled savings, to measured savings there are best practices that 

we urge EPA to include in its guidance to states developing their implementation plans. We will 

provide further input in our comments, but as a preliminary statement we urge the EPA today 

to consider that there are new technologies emerging every day in the marketplace that can 

assist with program design and carbon measurement. Smart meter proliferation is providing 

crucial new data sources on home energy consumption. Home energy management (HEM) 

devices from technology that measures plug loads and energy current signatures, are further 

disaggregating that data. Furthermore, advanced thermostats and smart phone applications are 

providing crucial communications between utilities and homeowners. 

We are at a turning point for new home energy technology and data analytics. Standards, 

protocols, and platforms are just being developed. We strongly recommend that EPA recognize 

this nascent revolution and ensure that their regulation not close the door to new technologies 

and program designs that encourage innovation. 

As EPA develops its rules for evaluation, measurement, and verification (EMV), we urge the 

consideration of energy consumption data as provided by utilities. This data, in the form of 

both traditional utilities bills and more advanced technologies such as "smart devices" and 

home energy management systems, can provide valuable information about energy use and 

contribute to accurate quantification of savings. This information should be recognized and 

considered for use in EMV protocols. However, protocols and policies that allow for both data 

access and analysis may take time to develop. We encourage EPA to include the use of this data 

specifically in its EMV rules. 

Finally and importantly, we ask EPA to consider the non-ratepayer funded solutions to energy 

savings in the private sector and encourage aggregation and the development of a registry to 

register and retire emissions that private contractors and companies can provide from 

electricity reduction outside the utility programs. 

Thank you on behalf of the Home Performance Coalition for the opportunity to testify. While 

there are great gains to be made in the other four BSERs, please ensure that continued 

attention is paid to the only element of the rule that directly includes small business and 

average Americans — the energy reductions in the residential sector. 

Thank you.