# kNAUf /,-,·, TALKING POINTS EPA PUBLIC HEARINGS CLEANAIRACT 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 III(d) proposal.
• We appreciate the EPA for understandingthe importance ofenergyefficiency
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 carbonreduction. 2. Knaufstrongly 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. Knaufurges EPAto give credit for adoption, enforcement, orupgrades 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 approximately40percent ofGHG 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 mostimportant and cost-effective method for states to achieve greenhouse gas emissions reductions at existing powerplants.
• 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 benefitofstates, utilities andthe public. • Additiona_U;@porting_ReasO!l§:

- Buildings are woefully under insulated and According to EPA, heating and cooling buildings account for 40% ofenergy use and greenhouse gas emissions in the U.S.

- So, improving the energy efficiency performance ofbuildings is the truly low-hanging fruit in greenhouse gas emissionsreduction strategy

- Based on calculations from authoritative sources, insulation currently in place in U.S. buildings reduces the amount ofcarbon dioxide emissions by 780 milliontons peryear; this is the equivalentof: • Over !50coal-firedpowerplants; or • Theelectricityuseofover90 million homes for one year;



### - We believe that a comprehensive insulation strategy could reduce energyand associated GHGemissions by20 to 30%
• Additional PQsitiveAttributes9fInsulatio[}

- Insulation products savemore energy than is usedto 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 ofthese products, 12 Btu·s are saved each yearbythe use ofinsulation.

- 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 efficiencycan be determined.

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