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Grassroots Government Affairs

Grassroots Government Activities Committee (GGAC) exists to support cooperation with like-minded organizations and to work with community policymakers to promote ASHRAE members’ technical expertise – as well as the use of ASHRAE standards – and to advance ASHRAE’s public policy aims.

GGAC November Update

Arizona Corporation Commission Reviews Efficiency Programs

ASHRAE Grassroots Government Activities Committee (GGAC) Update

David Palty, GGAC Chairman, ASHRAE Tucson Chapter


Arizona Corporation Commission’s Review of Energy Efficiency Programs


A review of energy-efficiency programs, in which the Arizona Corporation Commission staff has suggested cutting the state requirements for utilities to conserve of their projected electricity sales 22 percent by 2020. Docket No. E-00000XX-13-0214.



In the United States, residential and commercial buildings account for approximately 40 percent of the total primary energy use -- more than either transportation or industry. Specifically, heating, ventilation, air conditioning, and refrigeration (HVAC&R), and water heating are responsible for about 75 percent of residential and 54 percent of commercial building site energy use. They are responsible for 72 percent of the electricity consumption and 39 percent of the total U.S. CO2 emissions.


States are encouraged to adopt legislation that improves building energy efficiency through equipment standards and performance-oriented building codes. Code-adopted standards can save more energy than any other policy tool, and consensus standards (e.g., ANSI/ASHRAE/IES Standard 90.1) help ensure technical and economic feasibility.  It is important that policies related to energy efficiency support innovation, reduce market barriers, include full environmental considerations, and ensure that government leads by the example of outstanding design, construction, and operation of its own buildings, whether owned or leased.  Making new technologies and practices mainstream is the key to win-win-win strategies for the owners, the economy and the environment. Improving building energy efficiency reduces greenhouse gas (GHG) emissions and saves water.


Cost effective energy efficiency is critical for the economy, the environment and energy security.



In recent weeks, the Arizona Corporation Commission has added the capability to submit comments about a particular matter. The web site has a new link on the right side to "Submit a Public Comment for a Utility."


The online submission form asks which utility "docket" a customer would like to address. Submitting comments to a specific docket ensures the comments will become a part of the official record for that matter and be available to all of the parties to the case.  Additional details for commenting on page 2.  Comments should be submitted as individuals working in the building industry, not as representatives of ASHRAE (though membership in ASHRAE can be cited). 


I ask all of you to carefully consider the matter and let the AZCC know what you think. The link below takes you directly to the comments page in question. The docket number is E-00000XX-13-0214



Read the ACC’s Proposal:


Summary of existing programs (source: Database of State Incentives for Renewables and Efficiency (DSIRE)


Southwest Energy Efficiency Project (SWEEP) has posted or linked several items on their website:


Arizona Governor's Office of Energy Policy


EmPOWER Arizona (2014) - Governor's Office of Energy


Never Heard of EmPOWER Arizona? 

From the Executive Summary

·         “Because energy production, generation, transmission, and conservation are vital to Arizona’s future, Governor Janice K. Brewer formed a Master Energy Plan Task Force in 2013”

From the Conclusion

·         “When we assess our state’s lands and resources, our logical conclusion is that our surest investment in Arizona’s energy-generation future is to reduce energy consumption and therefore not have to build a new generation facility. Efficiencies level future demand and help the state preserve its natural resources of water and land. Arizona can be a leader in implementing energy-efficient technologies and procuring those technologies for its property.”


·         “As a result of the work completed on emPOWER ARIZONA, the Governor's Office of Energy Policy was recognized as an Honoree at the 2014 Best of the Capitol awards presented on June 24th, in the Grassroots Effort category.”



Taking off the ASHRAE GGAC HAT – that means this does NOT officially represent Society’s position.


Public comment provides the potential for independent vigorous free thought and dialogue.  So, in order to have a full range of skepticism and replication applied to all ACC decisions, it is helpful to have active thinking people passionately on both sides of a proposition.

This is an opportunity for you to be involved in the decision-making process of the Arizona Corporation Commission (ACC) and to offer your thoughts on the ACC’s utility driven energy efficiency programs in Arizona, what the ACC is currently is proposing, and to offer your comments on ACC’s future plans for utility driven energy efficiency in Arizona.

In my personal opinion, cost effective energy efficiency is critical for the economy, the environment and energy security.  My active personal participation with energy efficiency and utility DSM programs makes it easy for me to conclude that energy efficiency is proven to save money, emissions and water.

Additionally, in my opinion, I think that active thinkers should consider the review of emissions and water when developing and evaluating long term energy efficiency plans that are cost effective for Arizona.

With the proposed EPA 111(d) rules that would reduce climate change-related carbon dioxide emissions, in which the EPA determined the best system of emission reduction (BSER) to be a combination of measures that can be grouped into four categories, or “building blocks” –1) power plant efficiency improvements, 2) redispatch (i.e., meeting demand with natural gas combined cycle  plants instead of coal-fired plants), 3) nuclear and renewable energy generation, and 4) demand-side energy efficiency.  

And as for water conservation, I will always remember the following factoid from a National Renewable Energy Laboratory (NREL) Technical Report that “in Arizona, for example, 7.85 gallons of water are lost to evaporation per kWh consumed.” 

However in water reuse, I also think it is very positive that at the Palo Verde Nuclear Generating Station, water treated at Arizona's largest wastewater sewage plant is piped 36 miles to a treatment plant and then into on-site reservoirs. From there, it feeds the plant's tertiary cooling loop that runs through condensers under the turbogenerator, through cooling towers, and back again, until it is super-concentrated and diverted to evaporation ponds.

In summary, I believe that energy efficiency should be part of the societal solution because it is adequately demonstrated, cost-effective, imposes minimal environmental costs, and reduces overall energy requirements.  Moreover, emission reductions from energy efficiency can be enforceable, permanent, surplus, and quantifiable as those terms are defined by EPA.  The ACC can draw on long-standing state, private sector, and federal methodologies for measuring and verifying emission reductions from end-use EE.  And finally, it saves water.

Why should you check out www.ashrae.og?   ASHRAE continuously advances the HVAC&R field by performing research and developing guides and standards for designing systems.  The purpose of these documents is to provide objective, authoritative background information to persons interested in issues within ASHRAE’s expertise, particularly in areas where such information will be helpful in drafting sound public policy.

So do your own research and provide your own comments to the ACC by November 18th.

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