The Geothermal Exchange Organization (GEO) is seeking a partnership with the U.S. Environmental Protection Agency (EPA) to cut pollution that degrades our health and contributes to climate change. On Nov. 4, GEO submitted comments to EPA urging that renewable thermal energy and geothermal heat pumps 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.
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.
In building our case for GHPs as a logical tool that could be used to help offset carbon emissions from power plants, 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 Doughertyin the six-page document.
“GEO asks that another, logical step be taken by EPA and State clean air regulators,” Dougherty said. “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.”
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 percent of primary energy use in 2010.The buildings sector consumes approximately one third more energy than either the industrial or the transportation sectors.Some 60 percent 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.
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.
GHPs are today’s most efficient “green” alternative to traditional heating and air conditioning equipment, offering significant environmental, economic and societal benefits. GHPs are widely recognized by experts and agencies as the most efficient technology for heating and cooling homes, businesses and commercial/ institutional buildings. Indeed, EPA’s own Energy Star appliance website says: “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 percent more energy efficient than standard options.”
“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,” Dougherty continued, “the cheapest units of energy produced and consumed.”
It is extremely important for energy efficiency offsets to be implemented under EPA’s carbon reduction rulemaking. What’s more, said Dougherty, “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, Dougherty said that the “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.”
GHPs can be flexibly incorporated into utility, state and multi-state carbon emission reduction programs, making them an appropriate tool to help reduce consumer energy costs and cut greenhouse gas emissions. GEO believes that the next step is a simple one: “EPA’s Final 111(d) Rulemaking (should) specifically include renewable thermal energy technologies—including GHPs—as a utility compliance option for the states,” Dougherty concluded.
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.
Lead image: Navajo Coal Generation Station, Page, AZ. Credit: Ted Clutter, GEO