Listening sessions held by the Department of Environmental Protection around the state are gathering comments on EPA’s Clean Power Climate Plan requirements to help Pennsylvania develop a plan for meeting those requirements.   The Keystone Energy Efficiency Alliance presented these comments by Art Olson from SmartWatt Energy, Inc. at the September 28 session--

Thank you for the opportunity to testify today on Pennsylvania’s compliance with EPA’s Clean Power Plan.  My name is Art Olson, and I am employed by SmartWatt Energy, Inc. a design-build energy efficiency contractor and implementer of utility energy efficiency programs across the country.

Today I am representing the Keystone Energy Efficiency Allliance as its Secretary and a member of the Board of Directors.

We would like to take this opportunity to thank Gov. Wolf and the DEP for holding these listening sessions to ensure a robust and open public process for implementation of the Clean Power Plan in Pennsylvania.

KEEA is a nonprofit, tax-exempt 501(c)(6) trade association dedicated to informing the public and policymakers on the energy efficiency industry in Pennsylvania, and to advancing policies that will help grow our state’s energy efficiency and advanced energy economy.

KEEA advocates on behalf of energy efficiency and advanced energy professionals on the local, state and federal levels.

I come before you today representing our association of 50 members Working in the building energy efficiency And renewable energy industries. From replacing incandescent light bulbs for energy-saving compact fluorescent bulbs, to installing more efficient heating and air-conditioning systems, the comprehensive energy efficiency and energy management projects, energy efficiency can be a powerful resource able to make our power grid more reliable, reduce, cost for all consumers, and significantly reduce carbon emissions.

Advanced energy including Energy efficiency and renewable energy represents some of this surest, most cost effective strategies for Pennsylvania to meet EPA's targets while also growing the state’s economy.

Our industry knows this first-hand; robust state policies have helped the advanced energy sector of PA’s economy grow to some 4,200 businesses supporting more than 57,000 local workers.

About 40,000 Pennsylvanians work in the energy efficiency sector alone, helping residents and business reduce energy consumption and save money.  So far, installed energy efficiency improvements have generated nearly $2 billion of benefits to Pennsylvania electric customers and demonstrated a significant positive return on investment.

PA has made significant progress in attracting innovative companies that are putting Pennsylvanians to work.  Yet we’ve only scratched the surface of the state’s full advanced energy potential.  There is much more to be done.

KEEA will be submitting comprehensive written comments to DEP regarding Clean Power Plan compliance, but given limited time tonight, I will briefly address a few questions that DEP put forward.

1. KEEA applauds the Wolf Administration’s commitment to submitting a plan on time, as opposed to delaying action or seeking an extension.  An on-time plan, coupled with ambitious targets for advanced energy, will send a clear signal to advanced energy companies and investors that Pennsylvania is the place to invest and to grow.

2. A recent Pennsylvania Public Utility Commission report has show that our state’s advanced energy potential is significant and largely untapped.  Indicating that the state could economically save 11.8 percent of electricity between now and 2020.

In compliance with PA-129, the PUC’s Phase III energy efficiency and conservation plan for 2016-2021 directs electric utilities to make energy efficiency improvements resulting in 5.1 million MWh savings, equivalent to just 3.5 percent electricity consumption across PA, just a fraction of the state’s energy saving potential.

We urge the DEP to develop a CPP that will maximize investment in advanced energy-the compliance strategy that will deliver the greatest benefits to consumers and the economy.

3. Since the guidelines of the Clean Power Plan provide significant flexibility to develop a plan that works best for the state, and leaves the option open for collaboration with other states, we support moving toward development of a trade-ready arrangement, which would easily allow Pennsylvania’s compliance efforts to be incorporated into a multi-state alliance.

4. Given that all ratepayers benefit from a Clean Power Plan that invests in energy efficiency, it is important that all ratepayers be a part of the state’s efficiency compliance plans.  A handful of the state’s largest energy consumers are currently pushing to be exempt from participation in PA’s Act 129 energy efficiency programs [Senate Bill 805 (Boscola-D-Lehigh) sponsor summary].

Annie Gilleo at ACEEE stated it well: “Allowing large consumers to opt out has two problems.  First, large-consumer energy savings tend to be lower-cost than are savings from other sectors, particularly important in view of the cost cap.  Secondly, energy efficiency is a resource that benefits all users, so energy efficiency deployed anywhere in a system benefits everyone.  Allowing large customers to “go it alone” and not participate in Act 129 programs would eliminate a proven low-cost resource.  The bill would lead to lower overall energy savings and higher costs for all ratepayers (including the very customers leading the opt-out charge).”

There is ample evidence that Act 129 programs are helping large energy users improve competitiveness in the marketplace. 

For example, SmartWatt recently completed a comprehensive energy efficiency program for a manufacturer in Northeast Pennsylvania through the local utility’s Act 129 program.  The customer is now saving 835,000 kWh and $85,000 to $90,000 annually and reduced peak demand by 62 kw.  These savings help the company hire new employees, re-invest the savings in R&D, and complete in global markets.

[The House Consumer Affairs Committee held an informational meeting September 1 to update the Committee on the Act 129 program.]

Projects like these have helped SmartWatt grow in Pennsylvania, starting with just six employees and quickly growing to its current staff of over 30 workers in three offices across the state.

A Clean Power Plan focused on energy efficiency can help more PA businesses like SmartWatt help more Pennsylvanians save energy and reduce emissions in the years ahead.

KEEA’s current thinking regarding the best Plan for Pennsylvania centers on a couple of primary themes:

1. DEP should avoid relying too heavily on only a couple emission reduction technologies and instead focus on implementing a broad array of emission reduction technologies that take into account robust energy infrastructure.

2. Select a strategy that allows the full measure of energy efficiency technologies and renewable energy technologies-- solutions that represent the cheapest, fastest, and most readily available strategies for compliance.

The PA-PUC has proven its ability to manage a broad portfolio of energy efficiency and renewable energy programs that can make a significant contribution to achieving the required emissions reductions of the CPP.

In closing, we thank you again for the opportunity to share our thoughts on the Clean Power Plan, and we urge DEP to seize this opportunity to reduce emissions, cut electric costs, and grow the economy - the compliance scenario where all Pennsylvanians benefit.

A copy of the complete testimony and footnotes are available online.

For more information and a schedule of the remaining sessions, visit DEP’s Climate Change webpage.  Comments on the Clean Power Plan can be submitted online.  Click Here to see comments submitted by others so far.

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10/5/2015