Down to Earth Answer for EPA Rule

 Commentary by Doug Dougherty, GEO President and CEO for Illinois Country Living, Association of Illinois Electric Cooperatives

Climate Change is a hot-button issue worldwide, as nations wrangle with ways to cut carbon emissions that are warming the planet. The Obama Administration has voiced its commitment to the cause, and through Executive Order has directed the U.S. Environmental Protection Agency (EPA) to come up with solutions to our country’s burgeoning emissions from coal-fired power plants.

            Last June (2014), EPA proposed a rulemaking for new regulations under the Clean Air Act (section 111(d) that demands sharp reductions in carbon emissions from coal-fired generation facilities. The proposal has everyone involved —from utilities to state regulators—scrambling to offer ways that will meet EPA goals while causing the least harm to our still fragile economy.  Here’s the rub: coal still provides nearly 40% of the nation’s baseload electricity. It is cheap and abundant. And many utilities, especially in the Midwest, rely on coal to satisfy the needs of their ratepayers. So how can they continue to use coal and satisfy our collective need to save the planet from global warming? The answer in part is Geothermal Heat Pumps!

            The Geothermal Exchange Organization (GEO) submitted comments to EPA late last year, urging that renewable thermal energy and geothermal heat pumps (GHPs) be recognized in its proposed rulemaking. 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, we 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. Encouraging GHP technology is one of the few policy initiatives that can simultaneously and cost-effectively help states and EPA advance its renewable energy concepts, as well as its allowances for energy efficiency and reduction in demand.

            We then asked EPA to take the next logical step, to 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. We believe that 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, 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.

            That fact has certainly been recognized by Illinois electric cooperatives, which have successfully promoted the benefits of GHPs to their members since the 1980s. Indeed, nearly 10% of coop members in the state have opted for the efficiency and comfort of heating and cooling with GHP systems, tapping the renewable energy of the earth and reducing power and fossil-fuel use for the benefit of all.

            Furthering that end, GEO wants to partner with EPA to cut pollution that degrades our health and contributes to climate change. 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.

            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 hopes that our message to EPA rings loud and clear as the agency considers a mountain of comments on its controversial proposed rulemaking. If the agency specifically include renewable thermal energy technologies—including GHPs—as a utility compliance option for the states, we believe that 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.