Testimony of Alison L. Steele, Manager of Community Programs & Advocacy at
Conservation Consultants, Inc.
Before the Pennsylvania Department of Environmental Protection
Regarding Pennsylvania’s Compliance with the EPA’s Clean Power Plan
September 21, 2015 - Pittsburgh, PA
Members of the DEP and fellow Pennsylvanians, good evening and thank you for the opportunity to testify
today regarding Pennsylvania’s compliance with the EPA’s Clean Power Plan. My name is Alison Steele, I am a
Pennsylvania native, and I am speaking this evening as the Manager of Community Programs and Advocacy at
Conservation Consultants, Inc. (CCI) in Pittsburgh.
CCI was founded in 1978 as a 501(c)3 non-profit organization with the purpose of promoting responsible
energy and resource use in the residential sector. Serving a variety of clients throughout western Pennsylvania
from utility companies to homeowners, our mission is to educate energy users about the benefits of energy
efficiency and to assist in home weatherization, thereby making homes healthier and more affordable for their
residents, while at the same time reducing their impact on the environment. I am also on the board of the
Keystone Energy Efficiency Alliance (KEEA), which represents 50 member organizations and advocates on behalf
of energy efficiency and advanced energy professionals at the local, state, and federal levels.
We come before you this evening to applaud Governor Wolf and the DEP for holding these listening sessions
early and often throughout the state, ensuring an early start and an open process in developing Pennsylvania’s
State Implementation Plan. We have more detailed feedback to the list of questions provided by the DEP, which
we will submit in writing, but given the limited time tonight, we will use this speaking opportunity to provide a
more concise testimony.
The final version of the Clean Power Plan, released in August, does not list demand side energy efficiency as
a specific method of emissions reduction, however, we encourage the state to promote and incorporate energy
efficiency as a key component of the Pennsylvania State Implementation Plan. Energy efficiency represents the
cleanest, cheapest, and fastest method of emissions reduction. The benefits of demand-side energy efficiency
are many: reduced energy costs for consumers as well as demand on the grid, job creation and workforce
development, improved health of our citizens and environment, and a significant step toward reaching our
emissions reduction goals under the Clean Power Plan. We have already seen significant energy savings
statewide under existing programs like PA Act129. Projections by the EPA suggest that energy efficiency could
contribute toward 22% of Pennsylvania’s reduction target. In the course of exploring ways to incorporate
CCI Testimony – Page 2
energy efficiency into the State Implementation Plan, we recommend the DEP take advantage of existing energy
efficiency programs, like Act 129.
Stakeholders tied to the conventional fuel sector have expressed concern about the impact the Clean Power
Plan will have on local jobs and the economy. There is every indication that the Clean Power Plan will support a
healthy and growing energy economy in Pennsylvania. As of 2014, a study by KEEA shows that the
Commonwealth is home to over 4,200 clean energy businesses, many of which are small, local businesses that
employ a total of over 57,000 workers. Pennsylvania is already home to more than a dozen manufacturers of
energy efficient products, solar PV modules, wind turbines, and solar thermal collectors. As the Clean Power
Plan ramps up over the next several years, those numbers are poised to grow.
Implementation of the Clean Power Plan will support innovation and investments in clean energy like wind,
solar, and geothermal, but it will also support energy efficiency and the industry that surrounds it, provided our
State Implementation Plan includes a place for it. Energy efficiency, far from simply “using less energy,”
supports a variety of occupations from consulting to construction. Furthermore, it ensures that we will be more
responsible about our resource use: the less energy we use in the first place, the less we have to worry about
how it is generated. Energy efficiency should be the first step taken toward emissions reduction, before we do
anything else.
The market for energy efficiency services is clear: operation of the buildings in which we live and work
accounts for 39% of total energy consumption (and 38% of total carbon dioxide emissions) in the United States.
Western Pennsylvania especially has very old and inefficient housing stock: 76% of Pittsburgh homes were built
prior to 1960, before building codes were implemented in the mid 1970s. There is a need to improve the
performance of our buildings through weatherization and other upgrades. That demand calls for a welldeveloped workforce of architects, engineers, auditors, and contractors who can incorporate the principles of
energy efficiency into high-performance buildings. In order to provide a standardized method of evaluation for
building energy efficiency, we recommend the DEP consider adopting a framework such as the DOE’s Home
Energy Score, which provides an objective, asset-based, miles-per-gallon-type score based on the level of
efficiency of the home.
We will take this opportunity to respond to some of the specific questions posed by the DEP regarding
compliance with the Clean Power Plan:
Compliance Targets/Timeline:
CCI Testimony – Page 3

Should the state plan use rate-based or mass-based targets?
Mass-based – KEEA supplying background info and argument (mention protection of low-income
communities)
Participation in Trading:

Should the commonwealth adopt a trade-ready program without a formal multistate agreement?
We applaud Pennsylvania’s drive to start early in development of a State Implementation Plan and
meet the submission deadline. The guidelines of the Clean Power Plan provide flexibility to develop a
plan that works best for the state and leaves the option open for collaboration with other states. We
support moving forward with the development of a trade-ready agreement, which would allow easy
incorporation of Pennsylvania’s efforts and interests into a multi-state plan.
Energy efficiency and Renewables:

How can the commonwealth best use energy efficiency in meeting its compliance obligations
We encourage the DEP to make energy efficiency the first method of emissions reduction. As
described above, energy efficiency provides environmental and economic benefits. We recommend the
DEP make use of existing energy efficiency programs like Act 129. Many consumers are already aware
of Act 129 as a program run through their electric utility companies that provides rebates for installing
energy efficient equipment like lower wattage light bulbs and Energy Star rated appliances. Act 129 is
current in its seventh year and has saved so much energy that if we were to count statewide savings
since 2012 toward our state’s emission reduction plan, we would already be 6% of the way toward our
energy efficiency target.1 There is a clear synergy between existing efficiency programs and our state’s
compliance pathway – it makes sense to capitalize on that connection and strengthen Pennsylvania’s
plan by incorporating steps we already know to be successful. Because of Pennsylvania’s previous
successes with Act 129, we have hard numbers to point to that show a clear economic benefit related to
energy efficiency and the industry that supports it.

What other energy conservation measures could be considered?
Education and communication on the importance of energy efficiency are crucial, particularly to
increase adoption of responsible resource use on the demand side. In order to increase visibility and
1
KEEA/AEE fact sheet: http://info.aee.net/hubfs/CPPstates/Pennsylvanias_Electric_System_and_the_Clean_Power_Plan.pdf
CCI Testimony – Page 4
understanding of issues like energy efficiency and home performance, we recommend the DEP adopt a
standardized framework for building performance evaluation. For example, the DOE’s Home Energy
Score enables homeowners to understand how their homes rate in a miles-per-gallon sense, and
pinpoint where improvements can be made, thus empowering homeowner and providing them with a
tool to make visible the often-overlooked factor of home efficiency.
Least-Cost Compliance and Reliability Issues

What compliance pathway represents the least-cost option for the commonwealth
Energy efficiency represents the lowest-cost method of emissions reduction. The cheapest kWh is
the one that is not used. We recommend the DEP employ energy efficiency as the first step in reaching
our statewide emissions reduction target. After reducing our electricity waste, we will be able to turn to
cleaner sources of electricity generation.

How can the commonwealth ensure electric reliability?
Using less energy eases strain on the grid, particularly in the heat of summer and cold of winter
when reliable electricity is not just a matter of convenience – for some people it’s a matter of health.
Vulnerable, Over-Burdened and Environmental Justice Communities

What specific communities of this commonwealth may currently be experiencing adverse,
disproportionate impacts of climate change and air pollution?
Energy efficient technologies and responsible energy use support a healthy environment. There are
clear health benefits associated with energy efficiency and renewable energy production. Improved air
quality means improved health for our citizens, which is reason enough to take action, but we also know
that healthier citizens means a healthier workforce. The EPA projects that the Clean Power Plan will
help reduce air-quality related health issues, reducing the number of asthma attacks in children by
90,000 and preventing 300,000 missed work and school days.
Once again, we thank you for the opportunity to speak in support of energy efficiency as the cleanest,
cheapest, and fastest method of compliance with the Clean Power Plan. We encourage the DEP to recognize
demand side energy efficiency as the best system of emissions reduction and to establish it as the first method
of emissions reduction within the State Implementation Plan.
CCI Testimony – Page 5
Alison L. Steele
Manager of Community Programs & Advocacy
Conservation Consultants, Inc.
412.773.7160
alisons@ccicenter.org
www.ccicenter.org
CCI Testimony – Page 6
Notes

Benefits of energy efficiency:
o
Energy efficiency represents the cleanest, cheapest, fastest method of emissions reduction

The Clean Power Plan, as it is designed now, contains suggestions as to how each state can
develop its own emissions reduction plan. These suggestions are specifically related to
actions and decisions that can be made at the point of generation – related to what the
power plants can do, and what fuel sources we can use to produce our electricity. There is
another way to reduce emissions not listed because it is not one that the generators control:
this is energy efficiency, which falls to us, the users. Using electricity more responsibly
through energy efficient technologies and greater awareness of our own behavior has many
benefits: it can lower our energy costs, increase the reliability of our grid, create jobs,
develop a skilled workforce, improve the health of our people and planet, and help us work
toward Pennsylvania’s emissions reduction goal under the Clean Power Plan.

As I mentioned, energy efficiency, is not an enumerated building block for a state plan as
directed by the EPA, but it is a legitimate and supported method for compliance with our
state goal. Because the final version of the Clean Power Plan, which was released earlier
this month, governs generator actions, it could not call out something tied specifically to
end-user behavior because the generators cannot control that. However the EPA strongly
supports energy efficiency as a compliance method, and for good reason: it represents the
cheapest, fastest, and easiest road toward emissions reduction, and it is a method we are
already employing through statewide programs like Act 129.
o

EPA projected that EE could contribute 22% toward PA’s targeted reduction

EE supports energy savings  demand reduction  emissions reduction
EPA has shown job growth projections in clean energy / EE industry

Groups tied to the conventional fuel sector have expressed concern about the impact the
Clean Power Plan will have on local jobs and the economy. There is every indication that the
Clean Power Plan will have a strong impact on the economy – a positive one. As of 2014, a
study by the Keystone Energy Efficiency Alliance shows that Pennsylvania is home to over
4200 clean energy businesses (“clean energy” being solar, wind, energy efficiency), many of
CCI Testimony – Page 7
which are small, local businesses that combined employ over 57,000 workers. 2
Pennsylvania is already home to more than a dozen manufacturers of energy efficiency
products, solar photovoltaic modules, wind turbines, and solar thermal collectors. As the
Clean Power Plan ramps up over the next several years, those numbers are expected to
grow. KEEA projected that there will be 27,000 new jobs in the clean energy sector in
Pennsylvania by 2025.3

Implementation of the Clean Power Plan will support innovation and investments in clean
energy like wind, solar, and geothermal, but it will also support energy efficiency and the
industry that surrounds it. Energy efficiency isn’t just “using less energy,” though that is
part of it. Yes, the cheapest kWh is the one that is not used. The more energy that can be
saved by end users, the less energy needs to be generated in the first place. But the energy
efficiency sector needs a variety of organizations providing services from consulting to
construction in order to be effective. Residential and commercial buildings account for
almost 39% of total U.S. energy consumption – the buildings themselves account for 39% of
our energy consumption (and 38% of U.S. carbon dioxide emissions).4 Pennsylvania
especially has very old housing stock. The majority of Pittsburgh homes were built prior to
1960, before building codes were implemented in the mid 1970s. There is a growing
demand – and need – to improve the performance of our buildings through weatherization
and other upgrades. That demand calls for a well-developed workforce of architects,
engineers, auditors, contractors who can incorporate the principles of energy efficiency into
high-performance buildings.

2
EE supports contractors, consultants, engineers ,etc  job growth/industry support
KEEA position paper
KEEA position paper
4
Center for Climate and Energy Solutions: www.c2es.org/technology/overview/buildings
3