CNAIMA Urges EPA to Count Electrical Utilities’ Energy Efficiency Measures Toward Emission Reductions

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EPA should not only allow utilities to use energy efficiency projects to achieve emissions reductions, but should actively encourage them to do so.

Federal officials should count utilities’ actions aimed at upgrading home insulation and other energy efficiency measures toward federally mandated emission reduction standards, America’s leading insulation manufacturers association has told the Environmental Protection Agency (EPA).

“EPA should not only allow utilities to use energy efficiency projects to achieve emissions reductions, but should actively encourage them to do so. In fact, an existing EPA guidance does just that,” wrote Kate Offringa, the CEO and president of the Council of the North American Insulation Manufacturers Association (CNAIMA) in comments filed with the EPA.

The CNAIMA comments were written in response to EPA’s proposed “transport rule” mandating significant emissions reductions at electric generating plants and utilities in 38 states throughout the Northeast, Midwest, and South. EPA’s proposed rule has been noticed for comment; if adopted, the rule could enter into full effect as early as 2012.

A 2004 EPA guidance already recognizes the importance of both renewable energy and energy efficiency and encourages utilities to install insulation and take other energy efficiency measures to achieve both energy savings and SIP credit eligible emissions reductions, Offringa pointed out.

“Energy efficiency retrofits in tens of millions of under-insulated homes and businesses are consistently ranked as among the most economic, rapid, and effective methods of reducing emissions,” wrote Offringa. “And energy efficiency has important ‘side benefits’ that frequently make it one of the best choices for emissions reductions.” Among energy efficiency’s benefits, Offringa argued, are:

  • Reduced heating and cooling costs;
  • Enhancement of public health;
  • Increased comfort of home occupants;
  • Creation of new jobs to complete labor-intensive retrofit projects;
  • Reduced dependence on foreign sources of fuel; and
  • Enhancement of energy security and, ultimately, national security.

Offringa concluded, “CNAIMA and its members hope that EPA will recognize the opportunity it has in the transport rule to widen the call for emissions reductions via energy efficiency.”

About the Council of NAIMA
The Council of the North America Insulation Manufacturers Association advocates for policies and programs that encourage and incentivize increased energy efficiency through insulation in new and existing residential and commercial buildings and industrial applications. Membership in the Council of NAIMA is open to thermal and acoustical insulation manufacturers – regardless of insulation product type – and their suppliers located in North America.

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Tim Gay

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