SPRINGFIELD, Ill. — The Geothermal Exchange Organization (GEO) submitted comments to the U.S. Environmental Protection Agency (EPA) urging 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 impact the technology’s efficiency can have on the EPA’s expected mandates and benefits of more widespread use by reducing fossil-fuel consumption, leveling utility loads, and cutting carbon emissions from existing power plants across the U.S.

“The encouragement of GHP technology is one of the few policy initiatives that can simultaneously and cost-effectively help states and the 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 Doug Dougherty, CEO and president, GEO. “GEO asks that another logical step be taken by the 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 U.S., 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,” he continued.

“It’s of paramount importance for energy-efficiency offsets to be implemented under the EPA’s carbon reduction rulemaking,” Dougherty said. “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.

“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.”

A complete copy of GEO’s comments urging the EPA to consider thermal energy and GHPs as a renewable energy and efficiency offset under its proposed Section 111(d) rulemaking are available online at www.geoexchange.org.

Publication date: 12/15/2014 

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