GEO Comments on EPA 111(d) Proposed Rulemaking

Why GHPs Should be a Carbon Reduction Offset for Coal-Fired Power Plants

The Geothermal Exchange Organization (GEO) submitted comments to the U.S. Environmental Protection Agency (EPA) urging that renewable thermal energy and geothermal heat pumps (GHPs) be recognized in its proposed rulemaking under Section 111(d) of the U.S. Clean Air Act to cut carbon pollution from existing power plants. The proposed rule allows flexibility in meeting the agency’s desired emissions reductions across the nation, including renewable energy and energy efficiency.

In building its case for GHPs, GEO emphasized the efficiency that the technology can bring to EPA’s expected mandates, and benefits of more widespread use by reducing fossil-fuels consumption, leveling utility loads, and cutting carbon emissions from existing power plants across the United States.

“The encouragement of GHP technology is one of the few policy initiatives that can simultaneously and cost-effectively help states and EPA advance the concepts in Building Block 3 (with respect to renewables) and Building Block 4 (with respect to energy efficiency and reduction in demand),” said GEO President and CEO Doug Dougherty. “GEO asks that another, logical step be taken by EPA and State clean air regulators: Specifically recognize within the 111(d) Final Rulemaking the role that renewable thermal energy can play in avoiding production of megawatts generated by existing power plants—thus offsetting their carbon and other polluting emissions. GHPs should be specified among the most efficient renewable thermal energy technologies for accomplishing that goal.”

“Given the high proportion of energy and electricity used by buildings in the United States,” he continued, “GHPs offer a unique and efficient renewable energy technology for heating and cooling that provides both renewable energy and efficiency offsets that can help EPA and the states attain their carbon emission reduction targets.” 

Seeking a partnership with EPA to cut pollution that degrades our health and contributes to climate change, Dougherty said, “Energy efficiency is the least-cost, lowest risk energy resource—and GHPs are the most energy efficient technology for satisfying the thermal loads of buildings. Our ability to use the earth for the exchange of free, renewable and readily available energy exchange to homes, buildings of all sizes and even district heating projects, is limitless. The technology is (proven and) waiting to be used…. Efficient use of geothermal energy for heating and cooling produces Negawatts, the cheapest units of energy produced and consumed.           

“It is of paramount importance for energy efficiency offsets to be implemented under EPA’s carbon reduction rulemaking. Those energy efficiency considerations should specifically include the benefits of renewable thermal energy technologies as a way to avoid power generation and therefore cut carbon emissions. A primary component of such plans must include GHPs.

“To ensure that the full potential of GHPs is realized toward the goal of carbon reductions, EPA must recognize that GHPs may increase electricity use, but at the same time replace heating and cooling systems that rely on natural gas, propane and fuel oil. Elimination of such onsite fossil fuel use can be an important offset to carbon emissions by power plants. EPA should consider both the renewable thermal energy (BTUs) that GHPs can provide in lieu of electricity generation and the elimination of fossil-fuel burning for heating and cooling of buildings.

“GEO asks that EPA’s Final 111(d) Rulemaking specifically include renewable thermal energy technologies—including GHPs—as a utility compliance option for the states. GHPs can be flexibly incorporated into utility, state and multi-state carbon emission reduction programs as appropriate tools to reduce consumer energy costs and cut greenhouse gas emissions.” Complete copy of GEO’s comments urging EPA to consider thermal energy and GHPs as a renewable energy and efficiency offset under its proposed Section 111(d) rulemaking are available on the GEO website, here. (GEO)