# ~SEEA Statementfrom the Southeast Energy Efficiency Alliance (SEEA)

Provided by: Jenah Zweig, Policy Director,

Event:

Location: Date: Southeast Energy EfficiencyAlliance, 50 Hurt Plaza, Suite 1250, Atlanta, GA Environmental Protection Agency (EPA)'s Public Hearing on Clean Power Plan: Regulation 111(d) Omni Hotel, 190Marietta Street NW, Atlanta, GA 30303 July 30, 2014

I. SEEA Introduction Good morning, my name is Jenah Zweig, and I serve as Policy Director for SEEA (the Southeast Energy Efficiency Alliance). SEEA is a 501(c)(3) nonprofit, nonpartisan organization headquartered in Atlanta, Georgia that serves an 11-state territory-from Virginia, down to Florida, and overto Louisiana and Arkansas-which includes all ofEPA Region 4, and portions ofRegion 3and Region 6. SEEA leverages its extensive network-consistingof utilities, trade allies and manufacturers all working towards greater energy efficiency in the Southeast-to convene partners, strengthen enabling policies and strategic programs, and educate stakeholders through technical advisory services. SEEA is also one ofsix Regional Energy Efficiency Organizations (or REEOs) across the U.S., and works closely with the five other REEOs, and the regions they represent. SEEA does not take a position on EPA's authorityto issue the 11l(d) draft guidelines. Instead, SEEAis heretodaytoprovide productive perspectiveon how EPAcan facilitatetheuseofenergyefficiency as acompliance pathway.

II. Requestfor More Energy Efficiency Compliance Guidance Ifthefinal rules move forward, SEEA requests that EPA provide more guidance and resources on: (1) the kinds of energy efficiency compliance options EPA would definitively accept as a component of compliance plans, and (2) how plans that incorporate energyefficiency as acompliance optionshould be structured. More specific guidance and resources will help states incorporate energy efficiency into their compliance plans, expanding the role of least-cost, market-based solutionsfor meeting EPA's targets. EPA's currently proposed guidelines w·,sely include energy efficiency as a compliance option. However, little-to-no guidance has yet been provided on how energy efficiency can be effectively incorporated into these plans through potential mechanisms such as utility-funded programs, statefunded projects, energy codes and appliance standards, and energy efficiency financing options. Many key southern stakeholders have expressed a need for greater certainty and guidance when considering how to approach energy efficiency as a compliance option. EPA's assurance that it will be flexible and work with states on compliance plans once submitted is not enough. The necessary investment in new metrics and infrastructuretosupportenergy efficiency compliance is understandablyadeterrenttosuch

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investments, without (1) the certainty that it will then be included, and (2) guidance on how it will be included. In particular, utility energy efficiency program protocols for Evaluation, Measurement and Verification (EM&V) has manyyearsof"triedand true" experience determiningthe energy-saving impacts of energy efficiency programs, and has been fully vetted within most public utilities commission jurisdictional proceedings. States and the EPA do not need to rebuild a duplicate EM&V infrastructure. However, the value of cost-effective energy efficiency for utility resource planning purposes, versus the value and cost-effectiveness for emissions purposes are not the same. Moreover, valuation and "scorekeeping" ofthe emission reductions attributableto end-use energy efficiency is not nearlyas well-developed, and in mostcases, is quite unfamiliarto state-level implementingagencies, such as state env"tronmental protecfton agenc"tes. Accordingly, EPA should develop the tools necessary to help states bridge this gap, such as emissions valuation protocols, deemed emissions values, a scoring system, or other quantification guidelines. A strong analogy can also be drawn between quantification ofenergy efficiency and mobile source emission reductions. For example, providingatool comparabletothe EPAOffice ofTransportation and Air Quality's MOtorVehicle Emission Simulator (or MOVES) model could help alleviate concerns that energy efficiency EM&Vwill be onerous and cost-prohibitive. Doing so could also help clarify responsible parties and provide resources to more effectively support non-utility EM&V. Most significantly, such a frameworkwould allowstatesto moreconfidently pursue energyefficiencystrategiesappropriatetotheir circumstances. Additionally, in the Southeast where most utilities remain vertically integrated, incentive mechanisms will likely be needed to eliminate return-on-investment gaps that utilities experience with energy efficiency as compared to other capital investments. Accordingly, EPA should consider how the framework they put forth may encourage market-based solutions that can address the regional implications of state-based plans in light of ISOs/RTOs, multi-state utilities, and the inherent interconnectednessofthe electrical grid.Without moreguidance and resources to increase confidence in energy efficiency as an assured compliance option, southeastern states are less likely to incorporate energy efficiency as a part oftheir compliance plans, foregoing the opportunityto secure this least-cost resource and the many benefits itcan provide.


### Ill. Beyond lll(d): Energy Efficiency as a least-Cost, Multi-Pollutant Solution Providing guidance and resources to encourage and set the stage forthe incorporation ofenergy efficiency into compliance plans has applicability far beyond lll(d). This process represents an unprecedented opportunityfor energy efficiencyto be comprehensively embraced as a least-cost, multipollutant solution, addressing not only 

# co, emissions, but also facilitating compliance with other environmental regulations. For example, energy efficiency simultaneously reduces sulfur dioxide (or S02) and oxides of nitrogen (or NOx) emissions, and can thus help reduce ozone and fine particle nonattainment designation risks. Accordingly, energy efficiency will also be relevant as a least-cost approach ifnewozone orfine particle NAAQS orregional haze requirements are established.Additionally, energy efficiencygenerateswaterquantityand quality benefits-issuesofincreasing concern in Southeast.



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IV. Conclusion: Maximizingthe Benefits and Economic Opportunity of Energy Efficiency To conclude, energy efficiency is a proven economic development tool. In addition to offsetting C02 and other criteria pollutant emissions, energy efficiency enhances the reliability ofthe electric grid, reduces powersector risks, improves public health, and supportsjob creation and economic growth. On average, $1M invested in the U.S. economy supports approximately 17 totaljobs, while an investment in energy efficiency supports approximately 

### 20 jobs, according to the American Council for an EnergyEfficient Economy (ACEEE). A recent 

### 2014 SEEA study further supports above-average energy efficiency job creation findings, reinforcingthe advantage ofenergy efficiencyto local economies. With more guidance and resources, we believe thatenergyefficiency can be an equally effective emission reduction tool. The Southeast is well positioned to leverage its current energy efficiency momentum as a part of potentiallll(d) compliance-where appropriate and cost-effective-to build a stronger, more vibrant region. Thank you for your thoughtful consideration of our comments and requests, and please do not hesitate to reach out ifwe may be furtherassistance.
Respectfully Submitted,

Jenah Zweig Policy Director Southeast Energy EfficiencyAlliance (SEEA) jzweig@seealliance.org Office: 

### 404-602-9663

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