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TALKING POINTS 

EPA PUBLIC HEARINGS 

CLEAN AIR ACT SECTION lll(d) 

I am Scott Miller, I am Director of Sustainability and Product Affairs at Knauf 

Insulation HQ'd in Shelbyville, Indiana 

• We appreciate the EPA providing this opportunity to provide testimony on the 

I II (d) proposal. 

• We appreciate the EPA for understanding the importance of energy efficiency 

Three Main Messages: 

I. We strongly urge EPA to give credit for early action for GHG emissions 

reductions achieved through energy efficiency measures such as 

insulation. This provides immediate and ongoing energy savings and 

carbon reduction. 

2. Knauf strongly urges EPA to adopt insulation incentives that are simple 

and easy to validate and quantify the energy savings and pollution 

reductions achieved through insulation; these incentives should apply to 

installation of insulation in both new and existing buildings. Energy 

savings achieved through insulation is the most cost-effective deep 

reduction strategy available. 

3. Knauf urges EPA to give credit for adoption, enforcement, or upgrades to 

building energy codes. Studies conducted by Harvard University, now 

being updated by Boston University, demonstrate significant energy 

savings and pollution reduction through improvement to energy codes. 

Buildings account for approximately 40 percent of GHG emissions. 

• Encourage EPA, in establishing the Best System of Emission 

Reductions ("BSER") under Section 11\(d), to go beyond just 

recognizing energy efticiency, but indeed promote, end-use energy 

et1iciency enhancements, specifically insulation, as the most 
important and cost-effective method for states to achieve 

greenhouse gas emissions reductions at existing power plants. 

• EPA should give states wide latitude under Ill (d) to take such actions, which 

will achieve significant reductions in energy demand and emissions at a low 

cost, to the benefit of states, utilities and the public. 

• Additiona_U;@porting_ReasO!l§: 

- Buildings are woefully under insulated and According to EPA, heating 

and cooling buildings account for 40% of energy use and greenhouse gas 

emissions in the U.S. 

- So, improving the energy efficiency performance of buildings is the truly 

low-hanging fruit in greenhouse gas emissions reduction strategy 

- Based on calculations from authoritative sources, insulation currently in 

place in U.S. buildings reduces the amount of carbon dioxide emissions 

by 780 million tons per year; this is the equivalent of: 

• Over !50 coal-fired power plants; or 

• The electricity use of over 90 million homes for one year; 

- We believe that a comprehensive insulation strategy could reduce 

energy and associated GHG emissions by 20 to 30% 

• Additional PQsitiveAttributes 9f Insulatio[} 

- Insulation products save more energy than is used to manufacture them. 

- Insulation saves 12 times as much energy per pound in its first year of 

use as the energy used to produce it, which means that for every Btu 

consumed in the production of these products, 12 Btu· s are saved each 

year by the use of insulation. 

- Insulation saves over 600 times more energy each year than all the 

compact fluorescent lights, Energy Star appliances, and Energy Star 

windows combined. 

• Agplies to Industrras _\\!~U 

- Energy efficiency opportunities in steam systems can deliver significant 

energy savings without incurring substantial implementation costs. 

- Using NAIMA's 3E Plus Insulation Thickness computer program, an 

industrial energy management tool, annual benefits from insulation 

upgrades can be calculated and how much insulation is necessary to use 

less energy, reduce plant emissions, and improve system process 

efficiency can be determined. 

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