111(d) Released Today in Federal Register, Home Performance Coalition Plans Comments

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The 90-day comment period begins today.

EPA's plan for addressing carbon emissions through the Clean Air Act (CAA) section 111(d) was released today in the federal register. This begins a 90-day comment period, where stakeholders have an opportunity to comment on the Federal Plan (for states who do not submit their own plans for compliance), the Clean Energy Incentive Program (CEIP), and the sections related to Evaluation, Measurement and Verification (EM&V).

"It is important that the plan is flexible enough for states to allow opportunities for improvements in residential buildings as a means to meet their carbon reduction goals," said Home Performance Coalition President and CEO Brian Castelli.

The Home Performance Coalition will be commenting in detail on these provisions, including urging EPA to:

  • Utilize a broad definition of "low-income communities" in the CEIP to ensure maximum use of energy efficiency within the incentive plan;
  • Allow for the inclusion of new and innovative technologies in the future of Evaluation Measurement and Verification (EM&V) so that technology continues to improve data acquisition and opportunities for technology-based EM&V; and
  • Ensure that residential energy efficiency is included in the Federal Plan so that states that do not have compliance plans do not overlook their homes and residential rate-payers in compliance.

The Home Performance Coalition and Efficiency First submitted comments last December that focused on the following provisions in the proposed rule:

  • Energy Efficiency as a Resource: EM&V of Home Performance and Energy Efficiency;
  • Privately-Delivered, Non-Ratepayer Funded Carbon Dioxide Emission Reductions in The Residential Sector;
  • Cost-Effectiveness - Current State Cost Effectiveness Testing is a Barrier to Energy Efficiency and Carbon Reductions; and
  • Unintended Consequences - Unaccounted for Carbon Dioxide Emissions Associated with Fuel Switching leading to diminished net Carbon Reductions.

The Home Performance Coalition will continue to educate states that residential energy efficiency should be a part of states' compliance plans and help states and stakeholders tailor residential solutions.

"The Home Performance Coalition urges EPA to further enhance the potential for residential energy efficiency by ensuring that the federal plan, CEIP, and EM&V take into account the unique qualities of home energy use so that homeowners can be a part of the solution and allow American homes to serve as an effective, low-cost strategy for states to meet their carbon reduction goals," Castelli said.

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Stephanie Rex
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