U.S. EPA Comments

Comments on EPA Proposed Clean Power Proposal for Existing Facilities

 Why Geothermal Heat Pumps Should be a Specified Energy Efficiency Compliance Option for Offsetting Power Generation and Carbon Emissions

Docket ID: EPA-HQ-OAR-2013-0602

November 4, 2014

GEO – The Geothermal Exchange Organization


On June 2, 2014, the U.S. Environmental Protection Agency (EPA) proposed a plan under Section 111(d) of the U.S. Clean Air Act to cut carbon pollution from existing power plants. EPA’s proposal builds on actions already being applied to address the risk of climate change. The proposed rule allows flexibility in meeting the agency’s desired emissions reductions across the nation.

The Geothermal Exchange Organization (GEO) is a non-profit 501(c)(6) trade association representing the interests of all businesses involved in the geothermal heat pump industry across the nation. Geothermal, or ground-source, heat pumps (GHPs) are a widely available renewable heating and cooling technology that is proven efficient in all 50 states for homes and businesses, as well as commercial, industrial and institutional buildings. Use of GHPs can reduce power consumption, level utility loads, and cut carbon emissions from existing power plants in 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). But these goals will only be realized if EPA takes the opportunity to specifically articulate the important role that thermal energy savings can play in achieving compliance with their 111(d) proposed rule.

Energy Efficiency Offsets

EPA’s 111(d) proposal builds on the many sensible actions of the states regarding our most important tool for reductions in carbon emissions—energy efficiency.

The American Council for an Energy Efficient Economy (ACEEE) says, “One of the most promising compliance strategies for low-cost pollution abatement is end-use energy efficiency. The energy savings from end-use efficiency measures have already resulted in significant, cost-effective greenhouse gas emission reductions from the electric power sector…. Energy efficiency enables states to use the cheapest and most readily available approaches to achieving substantial and reliable emission reductions.”1

GEO agrees with ACEEE, and the following joint statement from the National Association of Regulatory Utility Commissioners, National Association of Clean Air Agencies and the National Association of State Energy Officials. “Energy efficiency should be an integral, creditable part of State and tribal plans to be developed in response to EPA Clean Air Act Section 111(d) emission guidelines…. EPA should invite multiple approaches to allowing energy efficiency emissions reductions to be part of State plans.”2

GEO asks that another, logical step be taken by EPA and State clean air regulators: Specifically recognize within the EPA 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.

Buildings and GHPs

Buildings of all shapes, sizes and uses across the United States are energy gluttons. According to the U.S. Department of Energy (DOE), buildings are the largest single sector of total U.S. energy consumption. Indeed, the buildings sector accounted for over 40% of primary energy use in 2010.3 The buildings sector consumes approximately one third more energy than either the industrial or the transportation sectors.4 Some 60% of energy used in buildings is for “thermal loads,” including space heating, cooling and water heating. And a third of that load—3.2 quadrillion BTUs—is satisfied with electricity.5

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.

Using a concept called “geothermal exchange,” GHPs tap the clean energy of the sun naturally stored in the near-surface of the earth, where temperature is constant around 50° F depending upon latitude. GHPs transfer this free heat to buildings in winter and back to the ground in summer. Whether they are in heating or cooling mode, GHPs offer significant savings in energy use and emissions compared to conventional heating and cooling equipment.

Most GHPs work by circulating water in a closed system through a loop of durable, high-density polyethylene pipe installed either horizontally or vertically in the ground beside or even beneath a building. Besides vertical or horizontal orientations, ground source heat exchangers can also be installed in water wells, lakes and ponds. Another example of a GHP is “direct exchange” (DX), in which a refrigerant circulates through copper tubes placed in the ground. The refrigerant exchanges heat directly with the ground through the highly conductive walls of the copper tubing.

During the summer, GHPs provide cooling by rejecting unwanted heat from buildings back to the ground, using the earth as a heat “sink,” and provide free hot water in the process. During the winter, GHPs transfer free renewable heat energy from the ground back to buildings for comfortable warmth.

In either season, the efficiency of GHP systems offer significant savings in costs and emissions compared to the use of electrically powered air conditioners, resistance heating systems and water heaters. And even though GHPs use a small amount of electricity to operate, they can completely eliminate the use of polluting fossil fuels like natural gas, fuel oil and propane in on-site heating applications for buildings.

GHPs are Most Efficient

GHPs are today’s most efficient, “green” alternative to traditional heating and air conditioning equipment, offering significant environmental, economic and societal benefits. Indeed, GHPs are widely recognized by experts and agencies as the most efficient technology for heating and cooling homes, businesses and commercial/ institutional buildings.

According to EPA, “Geothermal heat pumps are among the most efficient and comfortable heating and cooling technologies currently available.” And EPA’s Energy Star Program website says that, “…qualified geothermal heat pumps are over 45% more energy efficient than standard options.”6

EPA says that GHPs can reduce energy consumption—and corresponding emissions—up to 44% compared with conventional air-source heat pumps, and 72% compared with electric resistance heating with standard air-conditioning equipment.7 Recent advancements in GHP efficiencies enhance the numbers provided by EPA.

More importantly, says DOE, “The biggest benefit of GHPs is that they use 25% to 50% less electricity than conventional heating or cooling systems. This translates into a GHP using one unit of electricity to move three units of heat from the earth.”8 So while a standard electric heater can provide no more than 100% of the energy it uses, GHPs in heating mode can offer efficiencies of 400% and even more.

In cooling mode, GHPs have significantly higher energy efficiency ratings than competing air-source heat pump systems. A recent working paper by Western Farmers Electric Cooperative (Anadarko, OK) describes dramatic drops in efficiency for air-source heat pumps struggling in air temperatures exceeding 95° F on hot summer days. In comparison, efficiency degradation of GHPs under the same conditions is negligible.9

Measuring GHP Efficiencies

The measure of efficiency for a GHP in heating mode is called “Coefficient of Performance” (COP). Simply put, COP is the ratio of the amount of useful energy relative to the amount of energy used in the process. COP is calculated by dividing Heating Capacity in Btu/hr. by Power Input in Btu/hr. 

GHPs typically move 3 to 4 times more energy to or from the earth than is used to operate them. A GHP with a COP of 4.0 uses one unit of energy (electricity) to transfer three equivalent units of renewable thermal energy from the ground to a building. Innovations in multi-stage and variable speed compressors during the past few years have significantly lowered the energy needed to power GHPs, resulting in COPs even greater than 5.0.  

GHPs Produce “Negawatts”  

A 2012 study by Ceres, “Practicing Risk-Aware Electricity Regulation: What Every State Regulator Needs to Know,” concluded that the least-cost and least-risk solution for future energy resources is energy efficiency.10 Indeed, GEO believes that the lowest cost—and least polluting—unit of energy is one that is not used.

A typical 3-ton residential GHP can reduce summer peak electricity demand by approximately two kilowatts (kW).11 Take that times 500 homes equipped with GHPs, and you have a peak power demand reduction of a megawatt. That’s a megawatt of electricity NOT used, which creates what energy experts around the world call a “Negawatt.”12  Recent data from the Illinois Association of Electric Cooperatives and the American Heating and Refrigeration Institute confirm those figures (an average four-ton GHP reduces the peak load of an electricity provider by 2.6 kW).13

The idea of a Negawatt is cutting electricity consumption (and therefore production) with energy efficiency. GHPs produce Negawatts, which have a higher value than any megawatt of costly power generation. Because they are a renewable energy technology, GHPs produce the thermal equivalent of a Negawatt at a fraction of installation cost compared to a megawatt of electricity produced by renewable power sources.12 Adding to that cost efficiency is the fact that distributed thermal energy producers like GHPs avoid the need for expensive transmission lines required by power plants, whether they be renewable, fossil- or nuclear-powered.

Given the superior efficiencies offered by GHPs, it is obvious that one of the best ways to attain cost savings and reduce carbon and other emissions is to install more of them. Utilities should have the option to promote GHPs across their service territories to achieve 111(d)-mandated reductions in carbon emissions under federal and State guidelines.

GHPs Level Utility Loads

 By providing essentially free renewable thermal energy from the earth, GHPs can help lighten the load on our strained electrical grid. This is especially true on sweltering summer days when consumer demand spikes for air conditioning and power generation is maxed out, threatening brownouts. GHPs are up to 400% more efficient than conventional air conditioners, which lose efficiency as ambient temperatures soar. That’s when efficiency is needed most—when electric utilities are straining to provide power to air conditioners that are cooling tens of thousands of buildings at the same time.

Flattening such peaks in electrical load with GHPs at such critical times lessens the amount of peak-load generation capacity that must be installed, as well as smoothing out electrical generation use, saving utilities and ratepayers money while stabilizing the electrical grid.  

For electric utilities and the transmission grid, GHPs reduce summer peak demand and actually build load (and power sales) during the winter—while reducing carbon emissions and saving the high cost of new power and transmission infrastructure

An excellent example of GHP benefit to utilities is an efficiency project now under review in New York. According to utility PSEG-Long Island’s Long Range Plan, “A typical PSEG-Long Island residential customer uses approximately 10,000 kWh annually and has an average peak demand of 4 kW.” The utility says that with a GHP system, their typical residential customer would slash total electric and fossil fuel consumption for space heating, cooling and water heating by an estimated 4,500-5,000 kW, while cutting peak demand by 1.5 kW.14

GHPs Slash Carbon Emissions

Perhaps the most important benefit of GHPs is carbon emission reduction to help in the fight against climate change. Continued growth in U.S. carbon dioxide (CO2) emissions is a wake-up call telling us that more must be done to accelerate deployment of energy efficient, renewable energy sources like GHPs. GEO supports EPA’s approach of establishing enforceable, State-specific greenhouse gas emissions targets while allowing the states flexibility through energy efficiency measures to help reach those levels. Government research supports our contention that offsets for renewable thermal energy provided by GHPs is an effective tool in that endeavor:

A 2010 study15 from Oak Ridge National Laboratory shows that aggressive retrofitting of all single-family homes across the country with GHPs would avoid the need to build up to 48% of new electric generation capacity that is projected nationwide by 2030. Such a deployment of GHPs would save $38 billion annually on consumer utility bills, and slash projected CO2 emissions by 45%. The Oak Ridge research found that one ton of GHP capacity over a 20-year operating cycle avoids CO2 emissions of 21 metric tonnes. A thousand homes retrofitted with GHPs would therefore reduce carbon emissions by 63,000 metric tonnes over 20 years.

States are Recognizing GHPs

Twenty-nine states and the District of Columbia have enforceable Renewable Portfolio Standards that mandate a certain minimum share of electricity offered by utilities come from specified renewable resources.16 GEO is actively involved at the State level, advocating common-sense changes to statute and regulations that endorse Renewable Energy Credits (RECs) for megawatts of electricity avoided by end-use thermal energy technologies including GHPs.

A simple conversion factor (1 kWh = 3,412 Btu) allows for easy translation of thermal output into REC programs. GHPs lend themselves to easy thermal production measurements in real time with readily available and inexpensive metering devices and software.

To date, three states—Maryland, New Hampshire, and most recently Massachusetts—have legislated provisions that offer RECs for thermal energy load avoided by several technologies, including GHPs. Many other states are considering recognition of renewable thermal energy ability to offset power generation and carbon emissions. These include Arizona, California, Connecticut, Michigan, Nevada, New Mexico, New York, and Vermont.


GEO and the GHP industry want to partner with EPA and its counterparts in the States 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 waiting to be used, and it’s proven to be the most energy efficient means to satisfy the thermal loads of buildings. Efficient use of geothermal energy for heating and cooling produces Negawatts, the cheapest units of energy produced and consumed.        

Homeowners, business, government and industry spend the majority of their non-transportation energy costs to heat, cool, and produce hot water. And they use huge amounts of fossil fuels and electricity to do so. Promoting GHPs as a logical offset to generation and emissions can significantly cut energy (electricity) costs, yielding more disposable income. At the same time, such programs would cut carbon emissions, create jobs and foster an additional measure of energy security for the nation.               

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.

In prepared remarks before the LEAD Conference at Georgetown University on October 24 of this year, EPA Administrator McCarthy stated in part, “The key to making EPA’s Clean Power Plan ambitious and achievable is flexibility. Flexibility means states can choose the low-carbon path that makes sense to them. Flexibility means more choices, and more ways to invest. That sends a powerful market signal that unleashes innovation and creates jobs. And that innovation leads to even more affordable clean power. It’s a positive cycle that we should do everything we can to encourage.”17

We could not agree more with this sentiment. If EPA makes an unmistakable statement in favor of thermal energy savings like those offered by GHPs, the agency will be striking a note in favor of the enhanced flexibility and powerful market signals that Ms. McCarthy says lie at the heart of the proposed rule. EPA’s explicit acknowledgment of the role that thermal energy savings can play as a compliance strategy for the 111(d) rule will encourage states to enhance programs favoring these important technologies. Such recognition will also create powerful incentives for utilities to build upon creative efforts such as rebates and other market enhancement mechanisms. And those efforts will reduce barriers to further market entry for GHPs, a technology at the frontline of renewable energy, energy efficiency, and effective reductions in carbon emissions.

GEO thanks the EPA for the opportunity to comment on its Proposed Clean Power Rulemaking for Existing Power Facilities. We hope you will seriously consider the benefits of energy efficiency offsets for generation avoided by thermal energy technologies, and especially GHPs. If you have any questions, please contact me.

Respectfully Submitted,


Douglas A. Dougherty

President and CEO

GEO – The Geothermal Exchange Organization

312 South 4th Street

Springfield, IL 62701      

Phone   (217) 414-0341        

Email   doug@geoexchange.org