From: Chris Miller [mailto:cmiller@ajw-inc.com] 

Sent: Thursday, July 23, 2015 4:42 PM

To: Vaught, Laura

Subject: Fwd: Letter from the third party EE coalition

Hi Laura - I hope all's well and imagine you're ready for a serious August vacation. 

Would you mind routing the attached to the appropriate place/person in GM's office? I know one must 

go in the docket, but I wasn't sure who to email. 

If I should do it directly, to whom should it be sent?

Thanks, Chris

Sent from my iPad

Begin forwarded message:

From: Chris Hessler <CHessler@ajw-inc.com>

Date: July 23, 2015 at 4:32:09 PM EDT

To: "'Joseph Goffman (Goffman.joseph@Epa.gov)'" <Goffman.joseph@Epa.gov>, "' 

(dunham.sarah@epa.gov)'" <dunham.sarah@epa.gov>

Cc: Ted Michaels <TMichaels@ajw-inc.com>, Chris Miller <cmiller@ajw-inc.com>, Mona Sheth 

<msheth@ajw-inc.com>

Subject: Letter from the third party EE coalition

Joe & Sarah, 

Please find attached a letter to the Administrator from select members of the coalition we are 

representing. (Due to time constraints, not all members could sign on.)

We remain concerned that the final proposal may not provide clear incentives that will lead to increased 

demand for electricity demand reduction activities. We are happy to discuss this matter with you at the 

appropriate time.

Regards, 

Chris 

Christopher J. Hessler | Partner | AJW, Inc.

2200 Wilson Blvd, Suite 310, Arlington, VA 22201

O: 202.296.8086 ext.101 / C: 202.460.0945

Chessler@ajw-inc.com

@AjwHessler

Enhancing market opportunities for innovative technologies. 
 

July 23, 2015

The Honorable Gina McCarthy

Administrator

Environmental Protection Agency

1200 Pennsylvania Avenue, N.W.

Washington, DC 20460

Dear Administrator McCarthy: 

As the Agency works to finalize the Clean Power Plan (CPP), we write to reiterate our request for the 

explicit clarification of third-party (non-ratepayer) energy efficiency projects as an eligible source of 

cost-effective compliance with greenhouse gas (GHG) emission reduction targets. The proposed rule 

failed to do this. Should EPA’s rule overlook energy demand reduction delivered through performance 

contracts and industrial projects, more than half of the nation’s total energy efficiency savings could be 

excluded from state plans submitted under the CPP. 

Third-party efficiency projects increase jobs in the engineering, manufacturing, and construction sectors 

and contribute to a more sustainable, cleaner energy economy. As President Obama stated in Executive 

Orders 13693 and 13624, these projects also improve the competitiveness of our nation’s industrial 

base and reduce wasteful use of taxpayer funds on excessive utility bills. Our prior comments make clear 

that these projects are a ready source of quantifiable, non-duplicative, verifiable and enforceable GHG 

reductions that require no government or ratepayer funding. Third-party efficiency projects already 

attract more than six billion dollars in annual investment, produce substantial GHG reductions, and scale 

significantly and quickly in response to demand – demand which the CPP could deliver. 

We urge you to ensure the CPP clarifies for states that third party efficiency projects are a qualified –

and beneficial – GHG reduction approach that can be included in CPP compliance strategies and plans.

We appreciate EPA’s consideration of our comments and look forward to continuing to work with states 

toward successful implementation.

Sincerely,

ABB

Acuity Brands

AECOM

Ameresco

Danfoss

Energy Systems Group

Honeywell 

Ingersoll Rand/Trane

Lockheed Martin

Lutron Electronics

Johnson Controls, Inc. 

National Association of Energy Service 

Companies 

National Electrical Manufacturer’s Association

Philips 

Regal Beloit

Schneider Electric

Siemens

United Technologies Corporation