vvERO.
             United States
             Environmental Protection
             Agency
             Office of Environmental
             Engineering and Technology
             Washington DC 20460
EPA-600/9-82-009b
May 1^82
             Research and Development
Federal  Energy
Conservation Programs

Perspectives from the
Public and Private
Sectors: Volume II
  Do not remove. This document
  should be retained in the EPA
  Region 5 Library Collection.

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                     Public  Law 93-577
                  93rd  Congress,  S. 1283
                    December  31, 1974
                           an
To establish a national program for research and development in nonnuclear
                          energy sources.

  Be it enacted by the Senate and House of Iteptesentatices of the
United States of America in Congress assembled,

                          SHORT TITLE

  SECTION 1. This Act may be cited as the ''Federal Xoiumclear Energy
Research and Development Act of 1974".
FtJeral Non-
nuclear Energy
Research and
Development
Act  of 1974.
42 USC 5901
note.
88 STAT. 1878
                   ENVIRONMENTAL EVALUATION'

  SEC. 11.  (a) The Council on Environmental Quality is authorized
and directed to carry out a continuing analysis of the effect of appli-
cation of nonnuclear energy technologies to evaluate—
       (1) the, adequacy of attention to energy conservation methods;
    and
       (2) the adequacy of  attention to environmental protection and
    the environmental  consequences  of the application  of energy
    technologies.
  (b)  The Council on  Environmental Quality, in carrying out the
provisions of this section, may employ consultants or contractors and
may by fund transfer employ the services of other Federal  agencies
for the conduct of studies and investigations.
  (c) The Council on Environmental Quality shall hold annual public
hearings on the conduct of energy research and development and the
probable environmental consequences of trends in  the  development
and application of energy technologies. The transcript of the  hearings
shall  be published and  made available to the public.
  (d) The Council on Environmental  Quality shall make such reports
to the President, the Administrator, and the Congress as  it deems
appropriate, concerning the  conduct of energy research and  develop-
ment.  The President as a part of the annual Environmental  Policy
Report required by section 201 of the  National Environmental  Policy
Act of 1909 (42 U.'S.C. 4:U1) shall set forth the findings of the Council
on  Environmental Quality concerning the probable environmental
consequences of trends in the development and application of energy
technologies.
42 USC 5910.
Hearings.
Transcript,
availability.
Report to
President,
Administra-
tor,  and
Congress.

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                                                              EPA-600/9-82-009b
                                                                     May 1982
•\         Federal Energy Conservation Programs
s
          Perspectives from the Public and Private Sectors
j1                                  Volume II

J
t                                  Public Hearing
J,                                July  14 and 15, 1981
                                  Washington, D.C.
                                    Program Manager
                                     Gregory Ondich
                         Office of Environmental Engineering and Technology
                              Office of Research and Development
                             U.S. Environmental Protection Agency
                                  Washington, D.C. 20460
                                      Prepared by
                                   REAP Associates, Inc.
                                    Washington, D.C.
                            Subcontract under Prime Contract 68-02-3669
                               Office of Research and Development
                               U.S. Environmental Protection Agency
                                  Washington, D.C. 20460
                                U.S. Environmental Protection Agency
                                Region 5, Library (PL-12J)
                                77 West Jackson Boutevacd. 12th Floor
                                Chicago, IL  60604-3590       "*

-------
                                 DISCLAIMER
     This report has been reviewed by the Office of Research and Development, U.S.
Environmental Protection Agency, and approved for publication.  Approval does not
signify that the contents necessarily reflect the views and policies of the U.S.
Environmental Protection Agency, nor does mention of trade names or commercial
products constitute endorsement or recommendation for use.

-------
                                  FOREWORD
     Section 11 of the Federal Research and Development Act (Public Law 93-577)
permits an  annual  public  hearing  "...on the  adequacy  of attention  to  energy
conservation methods and environmental consequences of the application of energy
technologies."   Since  1978  the Environmental Protection  Agency's  Office  of
Environmental Engineering and Technology has been responsible for conducting this
Hearing.

     The  results of the  1981  Section  11  hearing on  Federal  Energy Conservation
Programs are contained in two Volumes: Volume I, the Hearing Summary and Volume
II, the Hearing Transcript.

     This report,  Volume II, presents  the transcript of  the  hearing and written
testimony from those  who  could  not attend.   Forty witnesses  submitted  oral
testimony and forty-seven individuals and organizations submitted written testimony.
The Section 11 hearing was held July 14 and  15, 1981 in Washington, D.C., at  the
Office of Personnel Management Auditorium.
                                                  Herbert  L. Wiser
                                                   Acting Director
                                               Office of Environmental
                                              Engineering and Technology
                                       ill

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                        TABLE OF CONTENTS








FOREWORD                                                      iii




ORAL TESTIMONY                                                 v




     JULY 1*, 1981, MORNING SESSION                               1




     JULY 14, 1981, AFTERNOON SESSION                            95




     JULY 15, 1981, MORNING SESSION                             199




     JULY 15, 1981, AFTERNOON SESSION                           269






WRITTEN TESTIMONY
                                 IV

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                             ORAL TESTIMONY


JULY 1*, 1981


MORNING SESSION


HEARING PANEL

   Kurt Riegel               Acting Director, Office of
                            Environmental Engineering and Technology
                            Environmental Protection Agency

   3. Michael Power          Director, Policy, Planning and Evaluation
                            Office of Conservation and Renewable Energy
                            Department of Energy

   Andrew Glassberg         Professional Staff
                            House Energy and Commerce Committee

   John Pfeiffer             Budget Examiner
                            Office of Management and Budget


PROCEEDINGS                                                       Page

   Opening Statement, Kurt Riegel                                        2

   Charles Guinn, New York State Energy Office                             4
   3ohn Armstrong, Minnesota State Energy Agency                          8

   Questions and Discussion                                               14

   Alan Miller, Natural Resources Defense Council                          19
   Mark Cooper, Consumer Energy Council of America                       30
   Shirley Sutton, Americans for Energy Independence                        34

   Questions and Discussion                                               39

   Ned Helme, National Governors' Association                              49
   Martin Klepper, Lane and Edson, P.C.                                    57

   Questions and Discussion                                               62

   David Moulton, Energy Conservation Coalition                            66
   Lewis Perelman, Private Citizen                                        86

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AFTERNOON SESSION
HEARING PANEL

   Kurt Riegel               Acting Director, Office of
                            Environmental Engineering and Technology
                            Environmental Protection Agency

   3. Michael Power          Director, Policy, Planning and Evaluation
                            Office of Conservation and Renewable Energy
                            Department of Energy

   Andrew Glassberg         Professional Staff
                            House Energy and Commerce Committee

   John Pfeiffer             Budget Examiner
                            Office of Management and Budget
PROCEEDINGS                                                        Page

   Opening Statement, Kurt Riegel                                        96

   Robert Pauls, City of Carbondale, Illinois                                96
   W. Kim Boas, Private Citizen                                         101
   Randi Triant, New York State Alliance of Community
      Action Agencies                                                  103

   Questions and Discussion                                              107

   Betty Kahl, Rhode Island Jobs in Energy                                110
   Paul Danels, New York City Energy Office                              113
   Mart Kask, Puget Sound Council of Governments                        117

   Questions and Discussion                                              122

   Floyd Ciruli, Colorado State Office of Energy Conservation               126
   Betty Desper, Total Action Against Poverty                             136
   Charles Lawrence, New Jersey Energy Research Institute                140

   Questions and Discussion

   Joseph Prano, Community Improvement Program
   Howard Brown, Middletown, Connecticut, Energy Advisor                153
   Richard Kline, S.C. Appalachian Regional Council of Governments        157

   Questions and Discussion                                              172

   Anthony Maggiore, Milwaukee County Community Action Agency         175
   Peter Robinson, Maynard Community Development Office                186
   Keith Dorsey, National Black Caucus of State Legislators                189

                                     vi

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    Questions and Discussion

    Neal Gale, Private Citizen                                             197


JULY 15, 1981


MORNING SESSION


HEARING PANEL

    Kurt Riegel              Acting Director, Office of
                             Environmental Engineering and Technology
                             Environmental Protection Agency

    Eugene Frankel           Professional Staff
                             House Science and Technology Committee

    Ted Kapus                Deputy Director
                             Buildings and Community Systems
                             Office of Conservation and Renewable Energy
                             Department of Energy

    Gregory Ondich           Section 1 1 Program Manager
                             Environmental Protection Agency


PROCEEDINGS                                                         Page


    Opening Statement, Kurt Riegel                                        200

    Carroll Benson, Dallas Power and Light Company                         201
    David Davia, Public Service Company of Colorado                        208
    John Russell, Edison Electric Institute
    Questions and Answers                                                226

    Sheldon Cady, Mineral Insulation Manufacturers' Association              237
    Karen Anderson, American Public Power Association                    2*1
    Robert Naismith, Potomac Energy Group                               2*5

    Questions and Discussion                                              2*8

    Robert Manahan, Thermal Insulation Manufacturers Association           25*
    Richard Esteves, General Public Utilities Corporation                    258

    Questions and Discussion                                              263
                                     VII

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AFTERNOON SESSION


HEARING PANEL


   Gregory Ondich           Section 11 Program Manager
                            Environmental Protection Agency

   John Millhone             Director
                            Buildings and Community Systems
                            Office of Conservation and Renewable Energy
                            Department of Energy


PROCEEDINGS                                                        Page


   Opening Statement, Gregory Ondich                                    270

   Randall Vosbeck, American Institute of Architects                       270

   Questions and Discussion                                              275

   Alan Rimer, Management Improvement Corporation                     276
   John Harkins, Mechanical Contractors Association
     of America                                                        281

   Questions and Discussion                                              285

   Carol Allen, N.J. Community Action Program                           290
      Executive Directors Association
   William Chandler, Environmental Policy Center                         293
   Katherine Ellett, League of Women Voters of Maryland                   298

   Questions and Discussion                                              305

   Stanley Ezrol, Fusion Energy Foundation                                314

   Questions and Discussion                                              319

   Closing Remarks, Gregory Ondich                                      321
                                    vin

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                            WRITTEN TESTIMONY
                                Page

V. 3. Adduci, Motor Vehicle        324
Manufacturers Association
   of the United States, Inc.

American Consulting              326
   Engineers Council

Fred Armstrong                   329
Portland Cement Association
Joseph A. Belanger                330
Office of Policy and Management
State of  Connecticut

Eleanor Bell                      334
Unitarian Universalist Service
   Committee of Kansas

Glenn L. Bellamy                 337
Heery Energy
   Consultants, Inc.

John J. Benson                    339
Construction Industry
   Manufacturers Association

Roy Bishop                       341
Office of Energy Conservation
Boston, Massachusetts

Robert F. Blanke                 344
Orange and Rockland
   Utilities, Inc.

Barbara Brown                    345
Solar Times
U. K. Correspondent

Art Cantrall                      347
Economic Opportunity Division
State of Washington

Clifford P. Case, III               349
National  Recycling
   Coalition, Inc.
                               Page

Edith Chase                    351
Energy Chair
League of Women Voters of Ohio

Albert B. Csonka               362
Micro-Carburetor Corporation

Mike Dekalb                   363
Energy Planner
Lincoln, Nebraska

Mary Durham                  364
Rockland County Energy
    Resources Coordinator

John V. Fashing                365
Dept. of Water and Power
Los Angeles, California

Marian S. Feeney               370
Energy/Resource Development
University of Rhode Island

Kelly Finn                      372
Kansas City Citizen/Labor
   Energy Coalition

Margaret P. Garland             374
Energy Office
State of Vermont

Governor J. Joseph Garrahy      377
State of Rhode Island
Michael German                381
American Gas Association
Sara Hamric                   383
American Paper Institute, Inc.
Ralph B. Hirsch                 385
League of American Wheelmen
                                     IX

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Mari L. Hoffman
Private Citizen
Yakima, Washington

Avis E. Holmes
Detroit Energy Corporation
   Consortium
Bill Home
Office of the Governor
State of South Carolina

J. A. Hunter
San Diego Gas and Electric
Wayne Johnson
Southern Gas and Electric
Susan Keller
The Community Network for
   Appropriate Technologies

Patricia Kelly
Private Citizen
Pueblo, Colorado

William C. Kinard, P.E.
Private Citizen
Portland, Oregon

Thomas H. D. Mahoney
Department of Elder Affairs
State of Massachusetts
Montana Power Company
Chris Palmer
National Audubon Society

Patricia B. Pelkofer
Group Against Smog
   and Pollution
Page

  388



  388
  400
  401
  402
  404
  405
  406
  408
  411
  417


  419
Gerald Roccapriore
Solar Power Institute, Inc.
Arthur H. Rosenfeld
Jeffrey P. Harris
Energy Efficient Buildings Program
Lawrence Berkeley Laboratory

Richard O. Silva
Energy Detectives, Inc.
Peter M. Stern
Northeast Utilities
Service Company

Elmer N. Stuetzer
Private Citizen
St. Louis, Missouri

Amy Timmer
Michigan Energy Administration
State of Michigan

Margaret Walker
Energy Office
State of Arizona

Jeter M. Watson
Conservation Council of Virginia
June Williams
Department of Energy and
   Transportation
State of Mississippi

Ralph R. Willmer
Somerville, Cambridge
Economic Opportunity
   Committee,  Inc.

Harry Wuertenbaecher, Jr.
Union Electric Company
Page

421



423
430
433
435
439
444
448
451
452
455

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                                                        PROCEEDINGS
                                                        JULY 14, 1981
                                                        MORNING SESSION
HEARING PANEL

   Kurt Riegel



   3. Michael Power



   Andrew Glassberg


   John Pfeiffer



WITNESSES


   Charles Guinn

   John Armstrong

   Alan Miller

   Mark Cooper

   Shirley Sutton

   Ned Helme

   Martin Klepper

   David Moulton

   Lewis Perelman
Acting Director, Office of
Environmental Engineering and Technology
Environmental Protection Agency

Director, Policy, Planning and Evaluation
Office of Conservation and Renewable Energy
Department of Energy

Professional Staff
House Energy and Commerce Committee

Budget Examiner
Office of Management and Budget
New York State Energy Office

Minnesota State Energy Agency

Natural Resources Defense Council

Consumer Energy Council of America

Americans for Energy Independence

National Governors' Association

Lane and Edson, P.C.

Energy Conservation Coalition

Private Citizen

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DR. RIEGEL:     Good morning.  I'd like to convene this Section 11 Hearing,
            with a welcome to  you,  to the panelists and  to  the witnesses.

                This activity, which  we  are  conducting  for the  next  two
            days, has its origins in the Federal Nonnudear Energy Research
            and Development  Act   of  1974.   That  act  requires  an  annual
            review of  the  Federal  government's adequacy  of attention  to
            both conservation  and  environment  in  its  energy research  and
            development programs.   The  review  responsibility  originally
            rested with the Council on Environmental Quality hut was passed
            to the Environmental  Protection  Agency in an  Executive  Branch
            reorganization in  1977.   This meeting  today  represents  EPA's
            fourth annual public  hearing to review the Department of Energy
            research and development programs.

                From year to  year  we have shifted the focus  of our exami-
            nation of  the  DOE programs.   For the past  two  years  we  have
            elected to look  particularly  closely at the  conservation  com-
            ponent of those programs.

               I think it's  a  particularly appropriate  choice this year in
            view of the  fact that the  Administration  has proposed and  is
            in the process   of  implementing  a  number  of  changes in  the
            government's conservation   programs.   Changes  have  included,
            for example, a  de-emphasis  of  some  of  the  kinds   of  Federal
            activities that  we have  seen  in the  Department  of  Energy  in
            the past.    I think  one  of  the   challenges  to the  panel  this
            morning,  and to  the  witnesses  who  appear,  will  be  to  examine
            those changes with a  view toward helping us to work together to
            make them as constructive as we can,   so  that both  the Federal
            and private  sector  components of   the  national  conservation
            effort are  made  as  effective  as  possible.    In  addition,  we
            hope that  private  activities  can  be assisted  and  catalyzed
            toward more   effective  results    for  the  nation   at  large.

               In the last two years we have seen a rather striking indica-
            tion of the  successes that  conservation  implemented nationwide
            can have   for the  country.   Oil  imports declined  strikingly.
            One thing that  we earnestly hope  for  is  that  the  signals  deli-
            vered through higher  prices,  together with  a  greater  public
            awareness  of conservation opportunities, will  allow us indivi-
            dually and  in  organizations  to  realize   the  cost-effective
            conservation opportunities  that  remain  open  to  us,  not  only
            for the short-term but the long-term as well.

                In the  next  two   days,  we  expect to  hear  from about  45
            witnesses, with  additional  written  statements  to be  sumitted
            for the record.   This  activity takes on a particularly impor-
            tant role in our Section  11 proceedings this  year,  because  we
            have been  unable  for various  reasons to  precede this  formal
            public hearing phase  with  workshops  as we  have  in  the  past.

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    I hope  we will  be  able  to  pursue  three  major  areas of
questioning.  First, with declining  Federal  investment in  con-
servation activities for the  coming  years, I think it's impor-
tant that we examine the priorities for utilizing these smaller
Federal resources so that  they will have the greatest possible
impact for our conservation objectives.

    The issue  is  especially  important  in the  state  and local
area because  the  Senate  and  the House  both  are  considering
energy block grant legislation to supplant existing categorical
programs.  The  question is  how  this  kind  of  change  can be
made most effective.

    Secondly, we  are   interested  in  learning  about  private
sector programs that  are likely  to  have  a  significant  impact
and to  take up  where  the  Federal  government  has  left   off.
Thirdly, we  come  to a  perennial  question of  how we  can  best
determine the  effects   of Federal efforts in  the conservation
arena, how  we  can  best  monitor  those  effects and evaluate
them.

    I'd like  to  introduce  today's panelists.   To  my   immediate
left is John Pfeiffer,  from  the Office of  Management and Budget.
He is the budget  examiner  for the Department of Energy,  speci-
fically that part of the program dealing  with conservation, and
we're very  happy  to  have  his  presence  this  morning  and his
expert view of the DOE  budgetary situation.

    To his  left  is  Andrew  Glassberg,  a  House  Energy and  Com-
merce Committee staff member who is concerned with conservation
and renewable  activities  for  that  committee.    Finally,  to my
far left  is  Mike  Power, the  Director  of the  Office  of Policy
Planning and  Evaluation in the  Department  of  Energy's  Office
of Conservation and  Renewable  Energy.  He  has the responsibility
for a number  of the  analytical,  oversight and evaluation acti-
vities, particularly in line  with the last  points  that  I  men-
tioned for  evaluating the effectiveness  of the Federal invest-
ment and  for keeping a  handle on the effectiveness  of the  pri-
vate sector activities  as well.

    Well, I  think with  no  further  ado we will go immediately
to the witnesses.   I am going to adopt the procedure  of taking
the witnesses two or three at a time, and if the next witnesses
will prepare  to  come after the  question and  answer  period to
replace the departing witnesses, we can cycle through  the entire
list during the morning.

    Our first two witnesses are Charles  Guinn  of  the New  York
State Energy Office, and John Armstrong of the Minnesota Energy
Agency, both of whom  can bring a state  perspective  on some of
the programs that we're highlighting today.

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                What I'd  like  you  to  do,   is  to  summarize  any  prepared
            statements that you have,  then add any remarks that you feel are
            appropriate.  After each  of you has spoken, we  will then turn
            the proceedings over  to the  panel  to  discuss  your  remarks  at
            greater length.  So, Mr. Guinn,  if you will start.

MR. GUINN:      Thank you for providing the  New York  State Energy  Office
            with the opportunity to express  its concerns about the new di-
            rections of Federal energy  policy  and  its impact  on state and
            local governments.  This hearing comes at  a  very critical time
            for state energy programs  because  their  continuation is large-
            ly dependent upon future Federal funding.

                Congress' actions on the 1982 Federal budget will determine
            whether many state energy  offices survive and whether government
            maintains its successful role in fostering energy conservation.

                The Administration's dramatic shift away  from any meaningful
            role for the Federal government  in  energy conservation is most
            unsettling since it represents a giant step  backwards for both
            New York and the nation.

                Energy supply  and  demand,  development  of   alternate  fuel
            sources and  expediting  conservation  actions  need  a  national
            focus and a strong federal, state and local government partner-
            ship.  The Administration's decision to leave the energy conser-
            vation field will destroy  the  healthy partnership among the Fed-
            eral, state and local governments in implementing energy conser-
            vation and renewable resource  programs  directed  to  an overriding
            national goal.

                We appear  to   be  returning  to  the  energy  policies  prior
            to the 1973-1974  Arab  Oil Embargo,  a time when  the  nation was
            unprepared and completely vulnerable.  We saw the United States
            — the most  powerful and  technologically  advanced  country  In
            the free  world —  brought  to its  knees by  a   small  group  of
            nations, a fraction of our size.

                Since that  time,  it   has  become   only   too  apparent  how
            inextricably our  economy  and  livelihood  are  tied  to  oil-
            producing countries.  This  sudden and  continuing energy aware-
            ness caused  by the embargo is  a healthy  and  useful reaction,
            as long as  we  respond  to  this awareness in a productive manner
            focused on weaning us from OPEC oil.

                The Administration's  energy  policy,  to  the extent  it can
            be categorized  as  a coherent  set   of  actions  and intended ac-
            tions, has moved  in the direction  of  eliminating what it per-
            ceives as  constraints   on  the  production and  use  of  energy.

                The policy  apparently holds that  such  actions  are neces-
            sary to  let  the  energy  marketplace  function  naturally  and

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increase domestic  energy production.   Certainly,  no  one  can
argue against an emphasis on increasing domestic energy produc-
tion to  decrease  our  dependence  upon OPEC  oil,  help ensure
future energy  supplies  and  contribute  to  domestic  economic
development.  But, where does energy  conservation  — the  best
short term  solution  to  our OPEC  dependency  —  fit  into  this
production-oriented energy policy?

    Energy conservation  is   at  best   a  tangential  occurrence
emanating from this  policy.   The  theory is that as the market-
place functions naturally, the rising energy prices — a direct
result of the marketplace at work strategy —  will be a chief
impetus for energy conservation.

    The government need not be involved in energy conservation,
this thinking holds,  because  consumers of all  types will react
accordingly and  quite  naturally to the rising  prices by saving
energy.  I fully  recognize  that rising energy prices alone can
work satisfactorily  in many  instances as the  prime  means for
promoting and  bringing  about energy   conservation.    What  we
must be  concerned  about,  however,  are   those  situations  in
which rising energy  prices  alone  will not bring  about energy
conservation, at  least  not  in an orderly  manner  or without
having a damaging impact.

    What are these situations?   There are  at least  three  of
them.  The  first  situation  can  be  characterized  as  a market
imperfection.  It  is  when  financing   of  conservation  improve-
ments for a  consumer  is  not available at reasonable  interest
rates or  the  consumer  simply cannot  afford  the  cost  for the
improvement at virtually any borrowing rate.

    Under such  circumstances,  which  apply  in  many  instances
to small  businesses,  schools  or  homeowners,  among  others,
rising energy costs  will not result in maximum energy  savings.
The rising  costs will  induce the  consumer to  take action, but
the consumer will not have the financial wherewithal to respond
fully.  Loans at lower  than  market  interest rates,  grants  or
tax credits  represent  forms of government assistance that are
necessary to enable  consumers to  convert  the  inducement caused
by higher energy costs into conservation actions.

    The second  situation in  which higher energy prices alone
will not necessarily result  in  energy  conservation also can be
called a marketplace imperfection.  It is when a consumer does
not have  sufficient  objective  information on  which  to decide
what conservation  actions to  take.  Under these circumstances,
a consumer  may  respond  to  higher energy cost improperly,  in
the sense of putting his  money  into other than the most energy
conserving actions, or not take action at  all.

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    In New York  State,  a case In point is the small industrial
sector.  Professional  energy auditors,  consisting  largely  of
consulting engineering  firms,  generally do  not  market  their
services to this sector because it has not proven to be profit-
able.  We have been told that  small  industrial  firms cannot or
will not pay a consultant  the  fee that is necessary to provide
energy audits of their plants.

    Consequently, these  firms,  which  have  little,  if  any,
in-house energy  conservation expertise,  do  not  benefit  from
outside expertise.  In  many  instances, their sources of infor-
mation consist of  representatives  of  equipment  manufacturers
who are not very often sufficiently objective.

    For such  situations,  which  are  just  as  applicable  to
homeowners and small retailers as they are to small industries,
government-generated programs  that  provide  sound  information
to consumers  are  essential.   For  these  consumers, a  policy
that relies  exclusively  on  higher   energy  costs  to  achieve
energy conservation will only partially accomplish its purpose.

    The third  and  final  situation  in  which  higher  energy
prices alone will  fail  to  achieve energy conservation is where
institutional or  marketplace  barriers  actually  prevent  the
higher prices  from working.   Examples  of  this  situation  are
apartment and office buildings.   The  owners  of either building
type are typically not  induced  to save energy  by rising energy
prices because their rental practices  allow them to pass through
increased energy costs to building tenants.

    As long  as  the availability  of  rental  space  is  limited,
tenants have  little  choice  but  to pay  increased costs.  This
problem is especially  acute in  New  York  State.  In  New York
there are 2.25 million multi-family dwelling units representing
approximately 40 percent  of  the  state's total  housing  stock.
Energy costs now account  for as much as 40 percent of a multi-
family dwelling's operating costs, compared to under 10 percent
less than 10 years ago.

    There are, of  course,  individual  building  owners  who will
make conservation  improvements  to enhance  the  viability  of  a
property or  for  other  reasons.   Nevertheless,  the fact remains
that the  existing  practices of  the  rental marketplace  sub-
stantially ruin  the  clean, theoretical  cause  and effect rela-
tionship between higher energy prices  and  conservation  that
the Reagan policy seems to be relying upon.

    In this  situation,  necessary  additional  actions to achieve
conservation should  entail  mandatory efficiency  standards  or
conservation measures  that  have  the  effect  of  stepping  over
current practices  of the marketplace that otherwise  are effec-
tive barriers to energy conservation.

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    New York  State,  and virtually  every  other  state  in the
country as  well,  has  heen combining  Federal  assistance  from
such sources as the Energy Extension Service, the Energy Policy
and Conservation  Act,  and the   Schools  and  Hospitals  grant
program with state funds to provide programs that address these
situations in which  rising energy prices alone  will not bring
about energy conservation.

    There are  many  examples  of  substantial,  cost-effective
successes in the use of these funds.

    Recently, my  office  completed  energy   savings  evaluation
reports on four  of our programs:   the  Energy Advisory Service
to Industry Program; the Boiler Efficiency  Improvement Program;
the Oil Heat Efficiency Program;  and,  a portion of the Schools
and Hospitals Grant Program.

    These four programs  alone  have saved New  York  State resi-
dents the equivalent  of  approximately  6  1/2 half  million bar-
els of  oil  per  year  valued  at over  $220 million.   The evalu-
ation reports indicate  that  these programs  resulted  in energy
savings which were  valued  at  between 11 and 798 times the cost
of administering the programs.

    I stress that these evaluations address only three programs
and a portion of another.   I am sure that  the evaluation reports
now being done  for our  other programs will  add significantly
to the energy savings already calculated.

    Notwithstanding the positive,  practical uses of these Fed-
eral funds,  all  of the Federal assistance  programs  for states
mentioned above, and  others as  well, are proposed for elimina-
tion in  the  Federal  1982 budget,  with  the  exception  of  the
Schools and  Hospitals grant  program  for  which a  relatively
small amount of funds has  been  proposed by the Administration.

    Should Congress  not  alter  the  Administration's  intent,
the New York State Energy  Office  could  be forced to reduce its
programming and staffing  levels  by 50  percent.   The situation
would be worse in  many  states.   To assume that state and local
governments will provide replacement funds for the lost Federal
assistance is to  ignore  fiscal  realities.   Already  overpres-
sured state  and  local  budgets   simply  cannot  be  regarded  as
the substitute  source  of  funds  for  these  programs,  particu-
larly because the Federal  government  is also eliminating fund-
ing for many other programs.

     The specific impact of the Administration's energy conser-
vation policy  will  be   to forego  enormous  opportunities  to
save additional energy.   The  policy will also result  in  many
energy consumers — homeowners,  businesses, and  institutions
— not having the objective information and financing necessary

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            for them  to  take proper  energy  conservation actions  and meet
            the rising energy costs.

                The more general  impact  of the Federal policy is a backing
            away from what  must  be an all-out effort to minimize the coun-
            try's dependence on foreign sources of energy.

DR. RIEGEL:     All right, thank you.   Before going to  questions from the
            panel, we'll have testimony from John Armstrong.

MR. ARMSTRONG:  I appreciate the  opportunity  to  testify  on how the "ade-
            quacy of attention to  conservation"  can be assured,  given the
            new directions  in  Federal energy policy.   I  believe  this sub-
            ject is  of  critical   importance  to   this  country  and  applaud
            your efforts to investigate it more thoroughly.

                There are  two   important   conclusions   I have  reached  in
            analyzing this question which  I  believe  ought to frame govern-
            ment policy toward energy conservation:

            1)  Energy  conservation  can  be   of  major  economic,  military,
                environmental,  geo-political,  and  social value to the Uni-
                ted States, and;

            2)  Government has a  necessary and essential role in achieving
                the nation's energy  conservation  potential.   The corollary
                to this last point,  which answers the  basic thrust of the
                Issue Paper, is  that  reduced  government  action  in  conser-
                vation will lead to reduction in the overall effort nation-
                ally.

                In discussing these  points,  I will  try  to  answer specifi-
            cally the questions posed in the Issue Paper.

                First, it  is my  strong belief that  both the  country as a
            whole and the current Federal Administration has greatly under-
            estimated the  value  of energy conservation.  I believe  it is
            fair to summarize numerous studies which have compared the full
            range of  U.S.  energy  options  to say that  improvements  in the
            efficiency of  energy  use will provide  more energy  at  a lower
            cost and  more  quickly than any  other option  for  at  least the
            next 20 years.  To quote just  one such study:  "The United States
            can use 30 or  40 percent  less  energy  than  it does,  with virtu-
            ally no penalty for  the  way  Americans live."!/ (Editor's Note:
            References follow Mr. Armstrong's testimony.)

                The Minnesota  Energy  Agency  has  estimated  that  the  net
            economic effect  in  the  state of  a  $1  purchase  of  petroleum
            products is  $.55  compared with  $2.21 for home  energy  conser-
            vation..?/

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    In a  similar  analysis,  Stobaugh  and Yergin estimated that
the true  cost  of imported  oil  to the U.S. was  actualy 2.3 to
5.6 times  its  posted  price owing  to  the  negative  economic
impacts of  losing  U.  S.   dollars  to   foreign  countries.  ±.'

    Other studies  have  shown  that   an  investment  in  energy
conservation will  create  more  jobs than an equivalent invest-
ment in  energy production.   Indeed,   "Emerging Consensus,"  a
recent study estimated  that two-thirds  of the  growth in demand
for energy services between  1973 and 1978 was met by efficiency
improvements..£/  Less  studied  and  more  difficult  to  quantify
are the substantial  strategic and geo-political benefits to be
gained from reduced oil imports.

    The net result of all of  these factors is that the benefits
of energy conservation  are  greatly undervalued  or,  conversely,
the costs of  energy  use  are greatly underestimated.   It  is a
basic tenet  of the  new Federal  energy  policy  that if prices
are deregulated, the  market  will  bring  about the optimal allo-
cation of  energy  investments.    However,  even  at  deregulated
prices, many  of the  opportunity  costs   of  conservation (i.e.,
the true  social costs of  energy use)  are not internalized into
the market  price  of  energy, not to mention  the practice  of
pricing energy  to  the  consumer  at  its  average  rather  than
replacement cost, thus  keeping  the market price  of  energy far
below its true cost.

    The distance between the  experienced market price of energy
and its true social  cost defines  an area where the  market  will
not allocate energy investments optimally, and I believe, where
governments action is necessary and appropriate.

    Government conservation  expenditures  in areas  where  the
market is not  functioning  should  not  be  viewed as  subsidies,
but as the  economic purchase of  energy at below its  true re-
placement cost.

    In addition to the  conclusion that there is  a  sound econo-
mic basis  for  government   action where market  imperfections
exist, the role of  government must also be examined  where such
imperfections supposedly do not exist.   The Energy Productivity
Center at  the  Carnegie-Mellon   Institute demonstrated^/  that
consumers could  have reduced fuel consumption  by  25 percent
and costs by   17  percent   given actual  energy  prices  between
1973 and  1978,  had  they been truly minimizing  long-run energy
costs.

    In Minnesota,  a  survey  of  90,000  utility customers  in
1979 found that 55  percent  of the homes  had  less than  6 inches
of insulation  and  12  percent  had  none  at  all  (recommended
level is  12-15 inches).   Of these  customers,  45 percent did
not turn  their  thermostats  down at night  and  9 percent turned

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them up, even  though  night-time  setback  costs  nothing and can
save more than half as much as attic insulation.

    Many  studies  have   documented  the  substantial   barriers
                                                           S f\ I
which exist to implementing  price-responsive  conservation.J>0/
Our own studies     '  and  those conducted by DOE and others (see
references) also indicate  that most  conservation programs have
been very  cost  effective.   For  example,  an evaluation  of our
boiler efficiency  workshops  showed a payback  on  all  workshop-
associated costs of four months.i£/

    The average payback on all costs associated with the Insti-
tutional Buildings  Grants  Program  in  Minnesota  has   been 3.2
years, with an annual  savings to the state's  taxpayers  of $16
million.lZ/

    An evaluation  of  our energy hotline  found  that 17 percent
of callers  were  influenced  to  take conservation  action-:/ and
that 50 percent of those using regional  information  centers were
influenced to take conservation actions ..Lr/

    The central  question  these hearings  address,  however,  is
what impact withdrawal  of Federal  funds  will have on the na-
tion's conservation effort?

    First, it must be recognized that the  cut  in Federal  funds
is falling, in many cases,  on to-p of substantial state and  local
cuts.  The Minnesota Energy Agency has  experienced a 61 percent
cut from FY  '81  to FY '82 in total  funding.   State appropria-
tions to the MEA's Conservation Division dropped from $11,966,-
100 for the FY '80-'81  biennium  to $1,180,322  for the biennium
which began July 1,  1981  —  a  90 percent  reduction.   Rescis-
sions and  discontinued   appropriations  in  state   and  Federal
funds amounted to  over  $10 million for the  Conservation  Divi-
sions last  fiscal  year alone  and  almost  90  percent   of   these
funds were grants  to local units of government.

    Although no data exist on the  immediate  impact on the pri-
vate sector, discussions with local  engineering firms indicate
that business  has  slowed  not  only  from  loss  of  Federal and
state funds,  but  from  disinterest,  economic  recession,  and
high interest  rates  as  well.   The  American  Hotel and   Motel
Association, for example,  is  discontinuing its 10-year conser-
vation program and many managers  have  simply  decided  to pass
costs on.

    The exceedingly low  profile  on energy conservation  by the
Reagan Administration is  even affecting  the level  of interest
where grant  funds  are available.  The  number  of technical as-
sistance grant  applications   from   institutional  buildings  in
Minnesota dropped  from  2,000 in Cycle  II to only  67  in  Cycle
III, even though funding levels were similar.

                        10

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     State  and  local  governments are responding in a variety  of
ways  to  the withdrawal of  funds.   One  important change has  been
that  conservation  funding has  shifted  "off  budget;"  that  is,
from  general tax revenue to private  investment through bonding.
In Minnesota,  $11.25 million  in direct conservation  grants  were
discontinued,  while  $27.5  million was approved by the legisla-
ture  for municipal bonds  for residential conservation and  $50
million  in bonding for district  heating.

     Second, many  groups are  increasing  their efforts  to  act
cooperatively  or to  broaden their  funding base by forming  joint
public/private partnerships.

    The  Minnesota  Energy  Agency (MEA) has accelerated the  rate
of transfer of its conservation  programs  to other institutions.
In fact, we have initiated a "foster parent" strategy of finding
or creating  groups to carry  on programs  the MEA may  have  to
drop.  For example,  we are currently trying to establish a Min-
nesota Chapter of  the  Conference  of  Local  Energy Officials
(CLEO) to  continue some of our  community  outreach and technical
assistance functions.  We  are  discussing the establishment  of
a statewide public/private  energy education  funding consortium
to assume  some  of  the  substantial  energy  education  efforts
which have been  carried  out  by  the  Minnesota  Department  of
Education  and  the MEA.

    The  process  of  "institutionalizing"  conservation  programs
by establishing them in  groups  outside  government  is  not new.
Indeed,  it is  an explicit goal  of  the  Energy  Extension Service.
Although a benefit  of the  change in Federal policy has been  to
accelerate this process,  it  remains to  be   seen whether   such
efforts will be successful.

    The  process  of building  energy  capabilities at the  local
level takes time.   Direct  technical  assistance  is usually re-
quired for a  substantial  period of  time;  funding sources must
be found and information-sharing networks established.   One  of
the considerable and  often-overlooked benefits  of  the  Federal
conservation programs has  been  this  institutionalization  pro-
cess.  The sudden  curtailment  of  Federal funds  will  not  only
stop most  current  efforts,   it threatens  years of work  the
states have put in, which is not yet complete.

    As in  Minnesota,  I  believe   most  state  and  local  govern-
ments will not be able to continue functions  formerly performed
with Federal funds.   Conservation programs are likely  to  be a
low priority,  and information/education programs in  particular;
again because  of lack of understanding of the benefits  of  con-
servation  and  because of  the prevailing  sentiment for  supply-
side solutions.
                        11

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    Even in Minnesota,  where  conservation is  clearly our best
near-terra option and  has widespread  support,  funding  for the
development of alternative  energy  sources  was  increased  from
$294,700 to $705,000,  this  year  over  last,  whereas  funds for
information dissemination were cut 29 percent.

    The loss of Federal and state conservation funds, I expect,
will have  a  slowing  on the  nation's  conservation  efforts  in
general.  Information is essential if individuals and businesses
are to  make the  appropriate response  to  higher  energy prices.
Such information has been an important  contribution of the state
energy office and  is  essential in a period of  rapidly changing
prices and technology.

    Training and education  efforts  will  also  diminish,  resul-
ting in a less "energy-skilled" work force. Those institutional,
legal, and many  economic barriers  which  remain are  likely to
be removed more  slowly  because   their  removal  often  requires
informed governmental action.

    The Federal  role  during  this critical period  must  be  to
give the states  greater  flexibility and  discretion in order to
adapt to local conditions and needs.   Rules  should be perform-
ance oriented  and place greater emphasis on evaluation of effec-
tiveness and  technical assistance.   The   formation  of  infor-
mation-sharing networks,  such  as  CLEO,   the  Association  of
State Energy Professionals,  or the Energy Engineers Association
should be encouraged and assisted, particularly if the regional
DOE offices are discontinued.

    Finally,  studies  ought  to   be   initiated  to  monitor  and
evaluate the impact of  the  change in Federal energy policy and
determine if  the  results truly  are in the  national interest.
Such studies  could  include  case   studies  of  individual states,
monitoring of  efficiency  improvements  in  major  appliances,
transportation and industry, monitoring of investments in ener-
gy conservation and comparisons  of theoretical price-responsive
conservation with that actually  taking place.

    As a society  and a  government,  I believe we  have danger-
ously underestimated  the  value  of  energy  conservation.   The
true social cost of  energy may,  in   fact,  be many  times its
market price.   If this is the  case,  the nation's energy problems
will not be solved  primarily  by  the American people, as stated
in the Third National Energy Plan, but will be solved by forces
unperceived and often beyond their control.

    To the extent  that the market  is not  and  cannot  resolve
our energy  problem,   governmental action  is  a  necessary and
legitimate means  of  achieving  the  broad,  national  interest.
                        12

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                 REFERENCES FOR MR. ARMSTRONG'S  TESTIMONY

 1.  R. Stobaugh and D. Yergin, Energy  Future, Report  of  the  Energy Project
     at the Harvard Business  School,  Random House,  1979.
 2.  1980 Energy Policy and Conservation  Biennial Report,  Minnesota  Energy
     Agency, 1980.
 3.  Joint  Economic  Committee,  Energy Conservation;   Emerging  Consensus,
     Diverging Commitment, U.S. Congress,  December,  1980.
 4.  R.W.   Sant,  Least-Cost Energy  Strategies, Minimizing Consumer Costs
     Through Competition, Energy Productivity  Center,  1979.
 5.  Eric  Hirst,  et  al. , Improving  Energy Efficiency:   The  Effectiveness
     of Government Action, Oak Ridge  National  Laboratory,  1981.
 6.  Energy Efficient Building Program  Needs Assessment,   Minnesota  Energy
     Agency, 1981.
 7.  An  Evaluation Study of  Community  Energy  Awareness   Committees,  Volume
     1^, prepared  for  the Minnesota  Energy Agency by  the  University  of
     Minnesota Center for Social Research,  1979.
 8.  Energy  Hotline   Evaluation:    Effects   of Two  Energy  Conservation
     Telephon e Information Services  on  Their Client  Populations  in Minne-
     sota, prepared  for  the  Minnesota  Energy  Agency  by  the  University  of
     Minnesota Center for Social Research,  1979.
 9.  Evaluation  of the  Energy Review,   Minnesota  Energy   Agency  1981.
10.  Evaluation of Austin Home Audit  Program,  Minnesota Energy Agency,1981.
11.  Evaluation of November 1978 Minneapolis Energy  Saver's Show,  Minnesota
     Energy Agency, 1979.
12.  Minnesota Regional Information Centers :	Evaluation of Services  to
     Client Populations, Minnesota Energy Agency, 1981.
13.  The Solar Home Campaign:  An Evaluation,  prepared  for  the  Minnesota
     Energy Agency by  the University of Minnesota  Center for  Social  Re-
     search, 1981.
14.  The  Potential  for  Utility  Conservation  Investments   in  Minnesota,
     Minnesota Energy  Agency, 1981,  order establishing  programs  by  the
     Minnesota Public Utilities Commission.
15.  Effectiveness of State - Sponsored Seminars in  Stimulating  Conserva-
     tion Actions by  Private Businesses,  Minnesota Energy  Agency,  1981.
16.  Evaluation of Boiler Operator Workshops in Minnesota, Minnesota  Energy
     Agency, 1979.
17.  Unpublished  data  supplied  by Kevin Halbach  on  June   25,  1981,  MFA
     Activity Manager of Institutional  Buildings Grants Program.
                                   13

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DR. RIEGEL:     Thank you very much.  To open the questioning,  I would like
            to start with one of my own, to Mr.  Guinn.

                Both of you  have  suggested that there was some danger that
            state energy  office  activities may he  in  jeopardy as  a result
            of Federal  budgetary decisions.   I would  like  to ask  you  if
            this is the case in New York?  If your  office has  been success-
            ful and has  developed a  constituency  in  the state,  has that
            constituency resulted  in  increased  budgetary  support  for your
            programs at the state level?

MR. GUINN:      The  New York  State Energy  Office was created nearly five
            years ago, during the late  '70s a time  when sunset  law activity
            was at its height in  New  York  State.   The energy office became
            the first New York  State  agency to have  a sunset provision  in
            its enabling legislation.    I think DOE  has a similar provision.

                We have  just completed our  sunset  hearing  process.    We
            emerged unblemished  on  the  hearing record  since there were  no
            negative comments, and considerable  praise  regarding the wonder-
            ful activities carried  out.  However,  our budget  in  New York
            State will  go  before the legislature  on April  1.  How  we get
            from today to 1982 may  somewhat  difficult.  The  second concern
            is that energy conservation funds, a few million dollars, could
            he lost between  the  cracks  as the legislature  deals  with the
            many programs, most  such  as health, education and welfare that
            are  much  larger,  that   have  been   reduced  substantially.

                There is a  certain threshold in the  budget  process of the
            number of concerns that one can deal with at one point in time.
            The New York  State budget process  and  in particular the legis-
            lative side of  that  budget  process will  have  to  deal  with  a
            great deal of items.

                I hope  and   I  feel that  we should emerge  with  increased
            state fundings from  all of  this,  but  there's  no  doubt  in   my
            mind that our programs will be reduced  somewhat.  I'm not sure
            in what  areas.   The  degree  to  which   whatever  minor  Federal
            money does  occur is  more  flexible  than what  we've had in the
            past would  help.   The  degree  to which the  state legislature
            provides the money in a flexible form will also help.

                Just one aside; in New  York  we have reached the  concensus
            that conservation is  something that  we can  do  for ourselves.
            We view the rapidly  rising  energy  costs, if nothing else, to a
            certain degree an  attack  upon  the  Northeast  and  the  Midwest.
            We have  industries   that  unless  they  conserve  energy  better
            than they have,  they may not be around.   So to some degree that
            energy conservation may become an element of an economic devel-
            opment strategy  in some  of  the  older  and  colder  parts  of the
            country.


                                    14

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              A concern we  all should  have  is the  final HEAP program and
          the weatherization program funding levels. I've heard a statistic
          from New  Jersey  that the average  utility bill  in  Newark is two
          months behind.  I  don't  know what a  corresponding  figure in New
          York is,  but  there are  many problems that  seem to  be developing
          in the payment  of  bills from the  past  winter, which  was a mild
          winter.   I'm  concerned  about  what  will happen  in the years ahead
          and how we can cope with the related problems.

              These concerns are  just  for New York.   Now for other states
          I believe there  are  some  23  states where  the legislature meets
          every other year and this is the other year.

MR. POWER:    Chuck, if I may ask, in your testimony you mention the  eval-
          uation of four  programs  that  you've been  conducting and just to
          clarify the  remarks,  is this  a correct  interpretation  that you
          have saved,  based  on these estimates,  $220 million  a year from
          these efforts?  And  in  terms  of their  continuation,  are they to
          be continued as far as you know, and if not, why not?

MR. GUINN:    Right.  One of the things we found in  New  York is   that the
          marketplace must work fairly well  in the auto  transportation sec-
          tor, convincing people  to  buy more efficient  cars.  And if they
          don't have  enough  money, they  don't  drive.   So demand declines;
          but in the building sector  the market forces  just  don't work well.

              In New  York,   where  we heat predominantly with  oil,  as op-
          posed to  most of  the  country which  heats  with gas,  our prices
          have been in  a  sense decontrolled for  a  long time.  The differ-
          ence of  oil  decontrol  versus  non-decontrol,  especially  when our
          residual  oil  is  90 percent imported,  wasn't  all that much.  So
          we've been living  in a world of world price energy  for some time.

              We found  in  the  building sector  that the marketplace does't
          work all  that well and it  needs some help.   Help was found to be
          useful to  small  industry, commerical  buildings   at  almost any
          size, public  housing, apartment buildings and  other large buil-
          dings.  We  have  an  Energy Advisory  Service  to  Industry (EASI)
          program,  consisting  of  a  number   of  retired engineers  who  work
          for the  state or actually for  regional groups across the state,
          paid for  by  Federal funds.   These engineers  go  through a small
          industry  day audit and say here's  what  the  firm can do to reduce
          the demand  for  energy in  its  factory.   This  program,  you would
          think, based  on  the  kind of  philosophy of  the free marketplace,
          would be  opposed violently by the  professional engineering soci-
          eties of  New York.   It was not.

              It was  supported and  pushed  hard by  these societies,  who
          felt that  if  the  EASI  engineers   can  convince John  J.  Jones  of
          Acme Machine  Company that  he really  needs a  heat  recovery sys-
          em or  whatever  change  in  the  process  system, we'll  design it,
          but somebody's  got convince him.   When the  vendor  for a product

                                    15

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            goes walking through and says you need to buy one of my devices
            in order to  save considerable energy, John  J.  Jones Jones nay
            say: "Yeah, and you tried to sell me something else last week."
            So the  "EASI"  program  has  worked well in a  fairly narrow, but
            very important sector to New York's economy.

                The boiler program  we  refer  saving  800 times  its  invest-
            ment in a  year is  one  which  I think a  lot  of  states have.  A
            southern university I think it was Auburn or Mississippi State,
            developed an excellent program whereby if you can get the  right
            people in  a  room and convince  them that they  should  do   some-
            thing about  improving  their boiler  systems,  they  will  do it.
            The difficulty has always been  getting the  right people  in the
            room.

                The market forces  may  say  that you are  literally wasting
            millions of  dollars   in your   institution  or  your  apartment
            building or  whatever,  but unless   the  person  operating the
            boiler knows how to fix  it, nothing is  going to happen,  unless
            you fire him and/ or bring somebody  who  can operate the boiler
            efficiently.  This program works  because state and local  gov-
            ernments can  put a  fair amount  of  pressure  upon hospitals,
            schools, public housing, commercial buildings through the  local
            realty boards, and others  to  send their boiler operators  to a
            class to learn to  operate  the boilers  efficiently.  You can
            bring the  right people.  They will  listen to  what  can be  done,
            they have  a  hands  on  learning  experience where they actually
            do what is necessary.

                In the follow-up surveys which DOE makes us do  in consider-
            able detail, we  found  an incredible change  in  the consumption
            patterns.  Now, I think a free market buff  could argue  some of
            the improvements would  have happened anyhow, but  it  certainly
            didn't happen  before  we demonstrated' what  could   be  done and
            improvements did happen after  the classes.

                The third  point  I'd like  to  make,   I  think this  has  been
            proven by  at least 20 studies,  that if  you  can convince   some-
            body through an  energy audit,  be it a  homeowner,  a  shopping
            center owner,  that  they're wasting  money,  they will  do   some-
            thing to reduce  their  energy  use.  Often because  of front-end
            cost limitations  they  won't  do  as  much   as   they  should,but
            they will  at  least  do the  items  that  are  fairly  low  cost and
            also tend to have high payoff.

MR. POWER:      I guess I'm still left   wondering if  this program  is that
            cost effective, would you — would the state continue to do it?

MR. GUINN:      We will find out in April.   We will submit to our legisla-
            ture funding requests to continue those  programs that we  think
            are very cost  effective.   We  also will  continue a hotline pro-
            gram that  basically  answers  citizens'   energy  questions.   We

                                    16

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            receive 5,000 or  6,000 calls  a month, usually  concerned with
            what can  I  do  to  save  energy.   I've always  thought  that such
            programs were very useful in the times of rapidly rising energy
            costs, to be a  shock absorber  for  the people  who are searching
            what steps  to take  and how to  do them.   This  is a program that
            New York certainly would  want  to continue.   Whether it will or
            not will depend upon the budget processes.

DR. RIEGEL:     I'd like to ask John Armstrong a question. John, you argued
            persuasively that conservation represents a very valuable ener-
            gy resource to  the  nation and  pointed  out  that this  is  being
            pursued with some success in Minnesota.

                On the  other  hand,  you have pointed  out  that a  number  of
            state-sponsored conservation  activities  and,  in  one  case  at
            least, a  private  sector  activity  by  the  American  Hotel  and
            Motel Association may  be discontinued.   Can  you give  us your
            perspective on  the  extent  to  which  these  programs  are  being
            discontinued because there's a perception that they have large-
            ly achieved the intended  results.   Also to what  extent do you
            feel that these discontinuances are  taking place  with a large
            unrealized opportunity likely to be foregone?

MR. ARMSTRONG:  In the  case of  the Hotels  and Motels, I think it is a com-
            bination of things.  They have been  at it  for  10 years. They
            have achieved some  results.   On the other hand I think there's
            a great deal more  that can be  done.  So I think there are some
            fairly large foregone  results  there;  but it's a combination of
            the mood of the times,  lack of interest in energy conservation.
            For the moment  there is  a lull in price rises so that  the eco-
            nomic pressure  is not  there  and the fact that energy conserva-
            tion, as  for  most  businesses,  is  not their  primary  concern.
            Their primary concern  is  doing what  it is  they  feel they make
            a profit at.  One of the very useful  functions of many  of these
            conservation programs has been to explain the benefit of reduc-
            ing energy  expenditures in  terms  that  the  individuals under-
            stand.  If it's a profit making business, in terms of an equiv-
            alent amount  of business  they  would have  to do  to  generate
            that amount of profit.

                That was one  of the  ways  the Hotel  and  Motel Association
            originally got  into  it and  I don't  think  this  is  necessarily
            going to be the case across all  sectors.

                I still see quite  a  bit of activity in the industrial sec-
            tor.  There always has  been and I think there will continue to
            be, particularly in  large  industry.  I would  agree  with Chuck
            that small  industry  is quite  a different  case.   But  in large
            industry, they  have the  capability  to  analyze their energy
            consumption, to look at the  cost benefits of various modifica-
            tions; although our  general  experience is that they will apply
            a much more  stringent  requirement  on conservation investments

                                    17

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than they  would  in their  own  business area.   For  example,  we
see a six  months  to  one year payback demanded for conservation
investment, whereas  in  the  normal  course of  business they'll
look at a  20 to 30 percent rate of return (3-5 year payback) as
being pretty acceptable  for a general  business  investment;  so
there's a  bias, even  when they have all  the  data before them,
against conservation.

    I think in the residential  sector,  if certain programs are
cut, there will similarly be a decline  in activity.   The pri-
vate sector won't  move  in  and  I  think an important  point  to
realize is that the Federal  conservation programs which supply
information and  programs  like  the  RCS  provide a  basis  for
private sector action.

    I've heard the banking community refer to  the  RCS program
as a transaction cost.   They see  the  whole  system of analyzing
a home, providing a uniform  system of analysis and giving that
information to the homeowner, showing him contractors and where
to get loans,  all as things which  take place in order  to get
the homeowner into the bank to get a loan.

    These kinds of programs  provide  a  very  important  basis for
private sector action and  for local action.   For example, the
$27 million in  residential municipal bonds that I  referred to
would not  have  taken place  without the  RCS  program  being  in
place.  Those  programs   specifically  depend  upon  an  audit,  a
uniform audit,  a  trained  cadre  of individuals performing those
audits, consumer  protection  mechanisms  and  that whole  system
being in place which  any individual  city and  most states would
have a very difficult time developing on their own.

    That system is now in place.  All the protections and guar-
antees are there  that  need  to be  there for  both  cities and
other lending  institutions  to  be comfortable  in lending money
on that basis.

    Even the IBG program, which  provides its own  funding source,
in a way  has  an  important  spillover effect  in  that  the tools
generated for  the program,  the  energy  audit   materials,  the
training courses  and  so on  again provide a uniform  basis for
building analysis  and for providing  financing  to institutions
and even commercial buildings.  There's  an  important  spillover
effect in the commercial sector from the institutional building
grants program.

    Those kinds of  effects  of  these programs are  very unana-
lyzed.  Most of the  attention by the Department of  Energy has
been directed towards  the  immediate payback of  a very circum-
scribed area of impact of these programs.  They want to see the
actual BTU  savings  of  persons  attending  a  boiler  efficiency
                        18

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            workshop, and those are  usually  done  within a period of a year
            after attending a workshop.

                There are much  broader institutionalizing kinds of effects
            that I alluded to which are a very important 'benefit from these
            programs and  I  think will  be  lost  if  they're  taken  away.

DR. RIEGEL:     Well,as usual, we are suffering time pressure.  I would like
            to thank our  first  two witnesses for appearing and invite Alan
            Miller and  Mark  Cooper,  if they  are here,  to  step  forward.

                We find that discussion has a tendency  to go on longer than
            we allow time  for on  the schedule.   So,  to the extent that it
            is practical  for  you  to  summarize  your  statements,  it  would be
            very helpful.   If Shirley Sutton  could  come forward  as  well,
            we will  add her  to  the  group.  Let's  begin with  Alan Miller
            from the Natural Resources Defense Council.

MR. MILLER:     Thank you for inviting our  participation.  As  most of you
            know, the Council is  a national  nonprofit conservation organi-
            zation with approximately 40,000 members concerned with protec-
            tion of the environment  and  conservation of resources. Towards
            those objectives,  we have been  extremely  active   in  working
            towards legislation  and   grass  roots  activity  in   support  of
            energy conservation   and  renewable  energy  technologies.   My
            comments will be brief, thanks in part to the creation of a new
            organization, the Energy Conservation Coalition.  The Coalition
            was created to  address one of  the problems  that  we thought to
            be among  the  greatest obstacles  to  conservation,  the  lack of
            an organized  constituency in  support of  energy conservation.
            The Energy  Conservation  Coalition will  be  represented,  I be-
            lieve later this  morning,  by David Moulton.  His  comments are
            far more detailed than mine.

                My testimony  is directed briefly toward  two  basic issues.
            One, the question of  "market  forces" and their relationship to
            the achievement  of  energy  conservation  objectives,  and  the
            other to the impact of budget  cuts on state and local programs
            and from our  experience  as an environmental group,  what we see
            as the  impact  to date of  the  changes in  Federal  strategy.  I
            might note  at the  outset  that  there is  a distinct difference
            between the interest at the national level  in achieving conser-
            vation objectives and the  interest at the state level.  I think
            that some of  the  comments made by the previous panel  and some
            concerns reflected  in your questions about  differences in state
            programs and state priorities are due to differences in the na-
            tional interest  in  conservation,  the national  security costs,
            and the national  environmental costs, which are not as clearly
            responsibilities at the state level.

                I think it's  important since there  are many program decis-
            ions still  to  be made,  however, to  focus  at least briefly on

                                   19

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the specific obstacles  to  capturing all  of  the cost-effective
conservation opportunities.  I think  this will set  the  frame-
work.

    First, there is the continuing  impact of the disparity be-
tween Federal support for  fossil  and  nuclear fuels in contrast
with support  for conservation.   It is  important  to  note not
only the  quantitative  significance  of  such  subsidies  in the
past, which as  frequently  noted  exceed  at  least  $200 billion,
but the continuing  effect  of  such  subsidies.  From a current
standpoint, that is more  important  than the  simple quantifica-
tion of past subsidies.

    Unfortunately, there are few  such studies of the continuing
effect of past  subsidies.   One that I  did  discover, by Thomas
Sparrow, a  professor  of  economics  at  Purdue  University, has
attempted to do  so  and  suggests  that  past  subsidies represent
roughly 7 percent of the  cost  of nuclear power, three  percent
of the cost of coal, 27 percent of the cost of oil, and 13 per-
cent of the cost of gas.  These are current and continuing sub-
sidies which will  not  be  addressed merely  by  the elimination
of current Federal subsidies.

    Insofar as the current  budget increases  funding to various
aspects of  nuclear  energy, of  course,  this  disparity  will  be
maintained.  Therefore,   one cannot  say  that  completing  fuels
will be priced on a free market basis.

    Second, we see continuing problems because of  state control
of electricity  pricing,  which for  the most  part  continues to
reflect average  imbedded cost-pricing  principles and  therefore
will not  reflect the current  realities  of  future electricity
costs.  Because  of this, the Ford Foundation  study,  The Next 20
Years, noted customers are discouraged from investing in energy
conservation or non-utility substitute fuels which  may  be cheap-
er than the cost of new supplies.

    The third  factor  is that  the end users  are  often not the
ones who are making the investments in the capital which deter-
mines energy  operating  costs.    In particular,  most  buildings
are not  owner-designed  and the builder's incentive  is to keep
down first  costs and minimize his risks.

    The buyer  can add some,  but  not all, conservation features
later date  and only at a much higher cost.  We've  had  some very
dramatic data  in the last  few months  indicating the signifi-
cance of  this  trend even within  the  past year.   This data was
collected by  the Air Conditioning  and Refrigeration  Institute
and made  available  to  the Department  of Energy by  the  Carrier
Corporation.   This  data indicates  that,  excluding  California,
where mandatory  appliance  standards  are in effect, the energy
efficiency  of  central air  conditioners shipped during the last

                        20

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two years  has  actually  declined  nationwide.   It  is  therefore
clear that  even  in a  period of  rising  electricity prices the
incentive for builders to install more efficient air condition-
ers has simply not been adequate.

    This problem  is,  of  course,  also  true among landlords and
renters.  The problem  requires government  solution.  Finally,
in preparation  for  this,   I  made  some  effort  to  survey new
homes in the local  area.  This information  doesn't  seem to be
available very easily, exactly what is happening in the build-
ing marketplace.  If one  simply goes out on a few weekends and
looks at buildings, you'111  find  the following.

    First of all,  out  of  14  randomly   selected  developments
(I make no  claim  that  this  was scientifically selected), I saw
only one  developer  who  had  labels on  the  appliances  in his
houses.  In the other  cases when I asked about the  labels, the
people selling  the  buildings  simply claimed ignorance  of the
requirement that  labels be  shown.

    Second, I found only in the most expensive  houses, those
in the  range  of  $150,000  or more,  any use  of  overhangs  or
attention to solar  gain.   When I asked about this, the  sellers
indicated no knowledge  of   the  impact  of  solar   gain.  They
sought to turn my direction  toward  other features of the houses
more commonly asked by those  looking at their houses.

    Finally, any  effort  to ask  about  the  likely  comparative
energy operating  costs of  buildings (which  after  all  is the
ultimate issue),  encountered  a  completely  negative  response.
There's simply no basis  for people  selling  houses  to  tell you
anything more  than   specific  features  about  the   furnaces  or
water heaters or  type  of windows that have  been  installed.   I
think what  was most  distressing was the  first point, that even
those items which are no cost or extremely low-cost items, such
as overhangs and proper siding to take advantage of  solar gain,
are simply not  being adopted  in the marketplace.

    This may reflect what  I refer  to as  our fourth point, and
that is the difficulty of finding credible information concern-
ing energy  costs  both  at the residential level and at  the com-
mercial and business level.

    Evaluating claims  of  conservation is  a  time-consuming and
technical task,  not  only for  residential  consumers looking at
houses, but equally so for  small  businesses  and to some extent
even  medium and  larger  businesses.   One need  only  review  a
few issues  of  the Energy User News  and  attempt to assess the
competing claims  of energy  conservation  companies to  under-
stand very  quickly   the  difficulty of  making  some  informed
judgement about  the  value  of energy conservation technology.
                        21

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    The Department of  Energy has  had several  programs  to ad-
dress the need  for credible  information.  But  in  general, the
Administration's policy has  been  clearly that such information
should be supplied by  the marketplace, not by  the government.

    We believe that the merit and need  for  these  programs has
been amply demonstrated by several success stories, particular-
ly the energy  analysis and  diagnostic  centers  which provided
basic audit  information  for  small businesses.   More than  50
percent of  the  time  industrial  users took  the advice  of the
auditors and the  savings  were  10 times  greater than the  cost
of the program.

    Fifth, there is the problem of  capital shortage  in energy-
intensive industries.   We note that beyond simple housekeeping-
type improvements, which have been predominant in the past five
years, conservation improvements require substantial additional
expenditure in return for even greater future savings.  Knowing
this fact,  however,  is of  little benefit for  those  consumers
who lack the necessary funds  and  cannot  obtain the credit. The
question is where such funds are going to come from.

    The solar  bank was  an  attempt   to  correct this problem.
Again, the  Administration's  position  has  been  that  such  pro-
grams are not necessary,  that tax credits will achieve the same
objectives.   We believe  that tax  programs do  not  address the
problems of many low and  moderate-income consumers and the IRS
returns bear this  out.   This point is addressed in the  testi-
mony of the Conservation Coalition.

    Six, we  point  to  institutional  and   regulatory  barriers.
We note  that  conservation  — even when  conservation measures
are cost-effective and financing  is available— state and  Fed-
eral regulation often  get  in the  way.  We support the emphasis
of the Administration on eliminating regulatory obstacles inso-
far as they  obstruct  energy  conservation  efforts,  although  we
haven't seen much  evidence  of specific  programs   designed  to
achieve that end.

    I think it was a  paper of Mr. Power,  in  fact, which notes
that only  further  carefully  conceived  and  sharply  focused
government regulatory  reform can  mitigate  these  bottlenecks.

    Finally, we would  point to those  national  benefits, envi-
ronmental, social and national  security,  which are not reflec-
ted in  the  marketplace.    Insofar  as  these truly  are national
benefits, I think  it  is asking  a  great deal  of state and local
governments to be as conscious of the need to develop state and
local programs  to  substitute for  those  at  the Federal level.

    The second area I  want to address briefly is the impact  of
Federal budget cuts on state  and local conservation activities.

                        22

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The implication  of  the Administration's  approach  and,  to some
extent your  questions,  is that  perhaps  if  these  programs are
necessary that they  will be  picked  up by  the  state and  local
governments.

    We think there  is  substantial evidence  that  there  will at
least be a  serious  gap  between the end of Federal programs and
state programs,  significant  disruption  in  the  continuity  of
programs, layoffs  of  experts,  termination  of programs  which
have developed expertise and  public acceptance.

    Given the range of Federal cuts and fiscal pressures facing
most state  and local  governments across the entire array  of
social policy issues,  it's  extremely unlikely that most states
will be  able to  so  quickly pick up programs terminated in such
abrupt fashion by the Federal government.

    For evidence of  this,  I want  to point  to one program with
which I  have  some  direct  working familiarity  in  the District
of Columbia.  The success  of  the  energy office programs in the
District of  Columbia,  which  have been virtually  100  percent
funded through Federal activities, has  been proven by an energy
audit which  indicated  that   these  federally funded  programs
saved the city  more than  23  percent in  the  city government's
energy bills, or about $19 million.

    Yet, the  energy  office   in  the  current  D.  C.  Government
budget process has  so  far been  very  unsuccessful  in  finding
substitute  sources  for Federal  cutbacks.   In  the  absence  of
Federal funding, even the  administration  of the  Residential
Conservation Service,  which   was  likely to  require  only about
1 1/2 man-years, is very questionable.

    The D.C. energy  office has  become so  desperate  for funds
to administer the energy audit requirements  that  it has asked
the local utility  companies,  Pepco  and  Washington  Gas  Light,
to roll  in  the  costs of  administering  the program in their
utility rate  base.    That petition  has  been  opposed   by the
utilities.  It  is   currently  pending  before  the  District  of
Columbia Public Service Commission.  There are some legal ques-
tions about whether  the  Commission  could order it  even if  it
made good policy to do so. But  it does indicate the short-term
difficulties in maintaining some continuity.

    Even if  this program  is  to  be  picked  up  later,  I think
there would be  a substantial  cost in  disruption  and  in time,
if the people  who have  developed the  program  leave the  city
government,  if the program is  interrupted for some substantial
period of time.  Regardless of  what  happens two  or three years
from now, there  will he  a substantial cost  to the  nation  in
having this disruption imposed  on programs  across the country.
                        23

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    The B.C. experience  indicates  another general problem: The
allocation of remaining  funds  among likely activities is going
to reflect continuing mandates and legal responsibilities, many
of which remain on the books at the Federal level.  Despite the
broad policy  concern of  the  Administration  to  eliminate such
requirements, these  changes  in federal  statutes  may gradually
go into  effect  over a  two  or three  year  period.  During that
time we're going  to find that state  and local  governments are
going to be forced to put their remaining funds into compliance
with Federal activities.   These  governments  remain  liable for
compliance with Federal programs like the  RCS and it is there-
fore those legal requirements, rather than  any  rational estab-
lishment of priorities, which  will determine  the allocation of
funds.  The most discretionary programs, such as telephone hot-
lines and  information  services  and long-range  planning,  will
almost certainly be  the first  to go,  something that  we've also
seen occur in the Federal government.

    Federal efforts  should  continue  to  focus   on  information
transfer, particularly the transfer of ideas concerning program
financing which are now more than ever crucial at the state and
local level.   Transition difficulties would be needlessly exac-
erbated if the  Federal  government  simply withdraws,  leaving
state and local governments with the problems.

    Thank you.
FOLLOWING IS MR. MILLER'S FORMAL STATEMENT

    Thank you  for inviting  the participation  of  the  Natural
Resources Defense Council.  NRDC is a national,  nonprofit orga-
nization with  more  than  40,000  members devoted  to protection
of the  environmental  and  the  conservation  of  resources.   In
furtherance of  these  objectives,  NRDC  has  actively  promoted
both governmental and private efforts to accelerate energy con-
servation and the utilization of renewable energy technologies.
We have lobbied  in  support of several  of  the energy conserva-
tion programs at issue in these hearings, and we have carefully
monitored their implementation and impact.   Because  of  our be-
lief that  these  issues   have  not  been  receiving  sufficient
attention nationally,  we  also  played  an  active  role  in  the
creation of  a  new  coalition of  organizations  concerned  with
promoting energy  conservation,  the Energy  Conservation  Coali-
tion.  A representative of the Coalition will  also be presenting
testimony at these hearings.

    My testimony will focus on two basic issues, the assumption
that "market forces" are  basically adequate to induce businesses
and homeowners to adopt  energy  conservation measures,  and the
impact of  the  budget  cuts  on state  and local programs.   Our

                       24

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point is not that energy conservation programs should necessar-
ily be immune from budget  cuts.   Rather we question the philo-
sophical assumptions  underlying  the  allocation  of  funds  made
available for energy programs.

I.  "Market Forces" Will Not Bring About Sufficient Energy Con-
    servation to Meet National Objectives	

    Despite the substantial amount  of  energy conservation activ-
ity in  the  last  five years,  enormous opportunities  are  going
uncaptured because of at least seven factors:

1.  Subsidies to Fossil and Nuclear Fuels. A four-year study by
the Battelle Memorial  Institute  concluded  that  federal energy
incentives for  oil,  gas,  coal,  hydroelectricity,  and  nuclear
power amount to  more than  $217  billion  (see  attached table).
Merely eliminating current subsidies will not redress the effect
of these  sunk  subsidies.   An analysis of  the  Battelle  data by
Thomas Sparrow,a professor of economics and industrial engineer-
ing at Purdue University,  estimates  that  past  subsidies repre-
sent 7%, 3%, 27%  and  13% of the cost of nuclear  power, coal, oil,
and gas.   Since  the  Administration's budget  increases  funding
to nuclear  energy,  this  disparity in treatment  of alternative
energy sources is maintained.

2.  Average,  Embedded  Cost  Pricing  of  Electricity.    Most
electricity rates,  and  virtually  all  residential  rates,  are
based on an average of old, relatively low-cost powerplants and
much more costly  new ones.   The  utility,  but not the customer,
sees the  true  cost  of  additional units  of  electricity.   The
result,  according to the  Ford  Foundation  study,  Energy:   The
Next Twenty Years, is  that   "[Cjustomers  are  discouraged  from
investing in  energy  conservation  or  non-utility  substitute
fuels which may  be  cheaper  than the costs  of new  supplies  a
utility is  adding."   The  importance of  this  underpricing  is
illustrated by a study of  differences  in electricity  use re-
ported in  the  Wall Street Journal of  February 5,  1981.   Some
of the highest electricity bills were in cities with the lowest
electricity rates.  The low rates caused people to use electri-
city "like  there's  no tomorrow,"  according to the  authors  of
the study.

3.  Builders Don't Pay Operating Costs.   Most buildings are not
ownerdesigned.   The  builder's  incentive  is to keep  down  first
cost and minimize his risk.   Since energy conservation is  only
one of  many features  of  interest to prospective  buyers,  the
demand for conservation is not clearly expressed in the market.
The buyer  can  add some,  but not all, conservation features  at
a later date, and Only  at  a much higher  cost.   Similarly,  most
appliances are bought  by  builders for  whom first  cost  is the
primary consideration.
                      25

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    The problem  is  dramatically illustrated  by data collected
by the Air  Conditioning and Refrigeration Institute concerning
the efficiency  of  central  air  conditioners.  Eliminating data
obtained from California, where mandatory standards are already
in effect,  the  energy  efficiency  of  central  air conditioners
shipped during the  last two years  actually  declined.   Central
air conditioners  are  almost  always  purchased by  the  builder
rather than by the ultimate consumer.

    Buildings occupied  by renters are a  similar problem.  the
renter has a disincentive to make improvements which will bene-
fit the  landlord,  while  the  owner  can  simply pass  on higher
energy costs.  As a  result  of  these problems,  the Ford Founda-
tion study  concluded  that  "the  housing  market  is  almost  a
classic case in  which  intelligently conceived regulation has a
place."

4.  Credible  Information  Is Not  Readily  Available.   Indus-
trial  and  residential consumers face  a bewildering  array  of
claims concerning the  economics  and performance of alternative
conservation investments.  Evaluating these claims requires time
and technical expertise,  both of  which can be significant bur-
dens.  To make  a rational  decision concerning  the  efficiency
of a new home requires knowledge of its energy use, current and
future energy cost,  the likely  rate  of inflation, the effective-
ness of conservation measures,  and other technical issues.  The
Department of Energy has  several  programs to address the prob-
lem, but the Administration sees no  need  for any of them.  The
merit and need for these programs is illustrated by the success
of the DDE-funded Energy Analysis and Diagnostic Centers, which
provide free energy  audits  for  small firms.   More  than 50% of
the time, industrial users  take the  advice  of the auditors and
the savings to the firms  are equally impressive:   a 99.4% rate
of return on the total investment.

5.  Capital  Shortages in  Energy  Intensive  Industries.  Once
simple housekeeping-type  improvements are  made,  conservation
improvements require some additional  expenditure  in  return for
substantial future savings.  Knowing this, however, is of little
benefit for consumers who lack  the necessary funds and who can-
not obtain credit.  This is a problem for low and middle-income
consumers as  well   as  many  industries.   As  noted  in  a  1980
working paper issued by the  House Committee on Science and Tech-
nology, many companies  who  would  like  to  invest in energy con-
servation have either already exceeded  their borrowing capacity,
are unable to borrow  at reasonable  rates, or  are  reluctant  to
increase their debt  in proportion  to  their  equity  because  of
the possible adverse effect on  their bond rating.  Conservation
investments are also  considered  "risky by many  of  the  sources
of debt capital,  such as pension funds."
                      26

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 6.   Institutional  and  Regulatory  Barriers.    Even where  con-
 servation measures  are  cost-effective  and  financing is avail-
 able,  state and  federal regulation may  get  in  the way.  Building
 codes  are a classic example; in many parts of the country build-
 ing  codes  make it difficult  or unnecessarily expensive to  in-
 stall  a  solar  water  heater.  Summarizing this issue, a Depart-
 ment of Energy strategy paper concludes  that "[ijronically,  only
 further  carefully conceived and sharply focused government regu-
 latory reform  can mitigate  these bottlenecks."

 7.  Environmental  and Social   Benefits of  Conservation Are  Not
 Reflected in Market Prices. In  relation to  supply alternatives,
 conservation measures are clean and create more jobs.  They  also
 reduce risks from future supply cutoffs, and increase the over-
 all reliability of our energy distribution system. Some  of these
 benefits, such as protecting  a wilderness  area, have no market
 price.   Others simply are not well accounted for.  For  example,
 the Harvard  Business  School  Report,  Energy Future,  notes  that
 the cost of electricity from coal neglects many "externalities."
 "In the  mining  and  transportation   stage,  the  costs   include
 acid drainage  from mines  and the disruption of life in Western
 communities by noisy  trains hauling  coal.   The  costs   are  even
 greater when  coal is  burned,  for  it releases  sulfur  dioxide
 and a  host of other pollutants.  The  cost include smoggy skies,
 emphysema,and the (unknown) consequences for future generations
 of increasing  the temperature  of  the  atmosphere  by producing
 carbon dioxide."

 II. Federal Budget Cuts Will Seriously Set  Back  State and Local
    Conservation Activities	

    Because of past  subsidies, the federal role in supporting
 state  and  local  energy conservation  activities has been  sub-
 stantial.  The vast majority  of state energy offices,  as noted
 in the Issue  Paper prepared  for  these hearings,  receive  more
 than 50% of  their funding from the federal government, and in
many states essentially all  of the funding for  energy  program
 staffs comes from federal  sources.    To expect  that  states  and
 local governments will  immediately  fill the breach  created by
 federal cuts is  simply  incredible,  given  the  range of  federal
 cuts and fiscal  pressures  facing  most state and local  govern-
ments.  Thus, there is almost  sure  to be serious disruption in
 state programs.  Programs will  end, experts will leave  govern-
ment or move into  other  fields, and  the last  six years of  in-
vestment in  program  development  and  expertise  will be lost.

    One need look no  further than the District  of  Columbia to
illustrate the  likely  impact  of  federal  cutbacks.    Energy
programs carried out  by the District  of Columbia Energy Office
with federal funding have  saved the   city more than  23% on its
energy bills,  or $19 million.   Yet  the  Energy  Office is  so
strapped for funds  that,   in  the absence  of federal  funding,


                      27

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its only hope  for sufficient  monies  to  administer  the energy
audit requirements of  the  Residential  Conservation  Service is
to require these  costs to  be borne by  the affected utilities.
The prospects  for this  approach,  apart  from its  merits,  are
poor.  Ironically, energy  costs  are partly responsible for the
financial difficulties which have made  it  so  hard  for the City
to provide the needed monies.

    The B.C. experience  also  illustrates  another likely aspect
of the budget  cuts.   The  allocation  of remaining  funds  among
activities is likely  to  reflect continuing mandates and legal
responsibilities rather  than  a  rational  rethinking  of priori-
ties.   The most  discretionary  programs,  like information
services and  long-range  planning,  will   almost  certainly  be
eliminated first regardless of their merits.

    Federal efforts to continue  information transfer—particu-
larly the transfer of ideas  concerning program  financing—are
now more important than  ever.   Transition difficulties will be
needlessly exacerbated if  the  federal  government  simply with-
draws, leaving  state  and local governments with the problems.
                       28

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TABLE 1.  An Estimate of the Cost of Incentives Used to Stimulate Energy
          Production in Billions of 1977 Dollars

               Nuclear   Hydro   Coal   Oil      Gas    Electricity   Total

Taxation

Disbursements

Requirements

Traditional
  Services

Nontraditional  15.1

Market Activity  1.8

Totals          18.0     15.33   9.71    101.3  16.50    56.58       217.42
   Source:  Battelle Memorial Institute, Pacific Northwest Laboratory,
            "Incentives to Stimulate Solar Energy Use" (1980)


1.1

15.1
1.8
1.8 4.03
1.1
0.03 0.67
2.31
2.68
13.5 0.02
50.4 16.04 31.37

41.9 0.06
6.0 0.48
1.5 0.3
0.4 0.1 24.73
103.64
1.10
43.76
8.79
19.58
40.55
                                     29

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DR. RIEGEL:     Thank you very much.   I think we will go through all three
            witnesses before we open the floor for questions.  Next is Mark
            Cooper from the Consumer Energy Council of America.

MR. COOPER:     Thank you, Mr. Chairman, and members of the panel.  My name
            is Mark Cooper. I am Director of Research of the Consumer Ener-
            gy Council of  America (CECA),  CECA  is  a  broad-based coalition
            of major  national  consumer, labor,  farm,  public  power,  rural
            electric cooperative,  senior  citizen,  urban  and  low-income
            organizations.  I  appreciate your giving  CECA  the opportunity
            to contribute  to  the Environmental  Protection  Agency's review
            of Federal energy conservation programs.

                CECA has been  actively involved in conducting research on
            many of the  issues that you open for comment  in  your review.
            In fact,  we  have  recently completed a major  study entitled  A
            Comprehensive Analysis of the Costs and Benefits of  Low-Income
            Weatherization  and Its  Potential  Relationship to  Low-Income
            Energy Assistance.  I respectfully  submit  a  copy of the report
            for the record.  (This report was reviewed, but not included in
            the Transcript due to its length).

                In my remarks  today, I  will highlight  the key  points of
            the study and  show how  they relate to the  broader  context in
            which the review panel  is  working.   The  review panel has iden-
            tified four  major  policy goals embraced  by  the Administration
            and related  them  to  specific energy policy  issues.   The  goals
            are economic revitalization, enhanced  national  sec-'^'1'*-y, main-
            tenance of the  social safety net and  fiscal restra    .  Given
            these goals, policy-makers  have  a number  of  different options
            available as a means  to those  ends.  One  of  the energy policy
            options, conservation,  can  work toward maximum fulfillment of
            these national policy goals.  Let us take  each  of the  goals in
            turn and  see  how  conservation,  in  general,   and  low-income
            weatherization, in particular,  relates to it.

            ECONOMIC REVITALIZATION

                We believe  that  there  are  three economic  principles  upon
            which an  effective  revitalization  of  the  national  economy
            should be based:

                Anti-inflationary impact:  i.e.,  least  cost  per   unit  of
                                           energy

                Job creation:  i.e.,  most  labor intensive  per dollar  of
                                           output

                Balanced growth:  i.e.,  stimulating economic  activity  in
                                        all regions  and  industries,  while
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                            utilizing a  wide  range  of  labor
                            skills

    A careful  review of  the  economic  characteristics  of  the
various energy policy  options shows that  conservation  is cer-
tainly a  basis on  which to  build a  rational energy/economic
policy.  In the CECA study,  we found that weatherization deliv-
ers energy  at  a  cost  between $15  and  $40  per  barrel  of  oil
equivalent. This makes  it a  cheaper way to expand the nation's
energy resources than any of  the production options.

    In addition,  the  energy  efficiency  option  exhibits  an
extremely high labor  intensity,  perhaps twice that  of  conven-
tional fossil  fuel  production.   Moreover,  with  the  moderate
skill levels  that  are  required  by  energy  conservation,  the
conservation option  has a  tremendous  potential   for  reaching
those who are most in need of employment.

    Additionally,  energy  efficiency  improvements  create  geo-
graphically widespread  patterns  of  economic  activity  because
they are decentralized  and  do  not rely  on  specific regional
natural resources.   Therefore, they avoid  massive transfers of
wealth from energy-consuming to energy-producing regions.  Low-
income weatherization,  in  particular,  creates jobs  and  keeps
resources where they are needed most, in the poorest communities
of the nation.

ENHANCED NATIONAL SECURITY

    With respect to  enhancing  national  security,  it has become
clear over  the last  decade  that  a  sound energy  policy  must be
a cornerstone  of  a strong defense  policy.   We must  reduce our
vulnerability to  foreign  or domestic manipulations  of  supply,
to conventional or nuclear attack,  to  regional  conflicts,  or
to terrorist activities.

    The development  of  alternatives  to  conventional  sources
of supply,   such  as  increased energy  efficiency,  would  serve
this goal best.   Conservation is  domestic  in origin, varied in
source and  inherently  decentralized.   In  the short-term,  in-
creased energy efficiency represents  the  single  most promising
means of expanding  available  energy  resources.    In  the  long-
term, the potential  contribution  of  energy efficiency  to  the
nation's energy needs can be  substantial indeed.   The National
Academy of  Sciences  estimated  that  between  one-quarter  and
one-half of  our  energy  needs could  be supplied  by increased
efficiency.  Recent studies by the Solar Energy Research Insti-
tute, the Oak  Ridge National Laboratory and  the  Congressional
Budget Office reaffirm this conclusion.

    CECA's study,   compiling  data  on  the  weatherization  of
over 6,000 homes,  suggests  that  these prior, theoretical esti-

                        31

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mates have  not  been  gross  overestimates,  by  any  means.   We
find that energy  consumption can be reduced by  almost 30 per-
cent with basic  conservation measures and more  extensive wea-
therizations can  achieve  cost-effective  reductions  in  energy
consumption of almost  70 percent.   Energy  efficiency improve-
ments can make a  massive  contribution  to  secxiring the nation's
energy future  and  thereby   enhancing  our  national  security.
That contribution can  reach its  potential  just  as  quickly as
we desire,  by  devoting increased  resources  to  weatherization.
There are millions  and millions  of buildings that  can  make a
contribution to  the  nation's energy  supply;  they  are waiting
to be weatherized.

MAINTAINING THE SOCIAL SAFETY NET

    From the point  of view of  maintaining  the  social  safety
net, there  is absolutely  no doubt  that  conservation must play
a crucial role.   Energy  is  a basic  subsistence  commodity, and
low-income households have been forced to devote a debilitating
share of  their  incomes  —  as  much  as  one-third  — to this
single commodity alone.  As  energy costs rise higher and higher,
there is a  serious  danger that  the economic  viability of those
American households which live  near to the poverty level will
be undermined.  Energy policy must prevent more and more Ameri-
cans from being  rendered  poor  by perpetually  escalating energy
costs, while  it   relieves the   burden  that  high  energy  prices
place on the poor.

    In the  long run,  if  we  are  to break the dependence of low-
income households  on  the  safety net  and  to prevent  more and
more Americans from being  forced into a dependence on public
assistance, programs such as low-income  weatherization and the
Solar and  Conservation Bank,  which permanently  reduce  energy
consumption and cut energy costs, must be maintained and expan-
ded.  Programs such  as these  permit households  to direct re-
sources away from necessities,  such as energy,  toward building
a firmer  economic base within  the household and  investing in
human capital to  enhance  the earning capacity of the household.

     Our study  shows  that   low-income  weatherization makes  a
significant contribution  to  alleviating  the  burden that energy
costs place  on  the poor  and near-poor.   On average, weatheri-
zation constitutes  an  addition  to  income  of almost 5 percent
for the  average   low-income  household.   That  contribution will
increase over time as real energy prices rise.

     If the  goal is  to   maintain  the  social safety net which
protects low-income energy  consumers,  an approach  which  throws
low-income  weatherization into  a  non-specific   block  grant is
unacceptable.  Such  an  approach  would   prove   disastrous  for
low-income  energy consumers.   Under the  Administration's ap-
proach, it  is  possible  that weatherization would  not be per-

                        32

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formed at  all,  since there  are  no requirements  that  funds be
spent for  weatherization.    At  the very  least,  weatherization
would slow  down considerably.   Rural areas,  where  40 percent
of the poor reside, would certainly be underserved.

    Thus, for the  low-income energy consumer, folding weather-
ization into a non-specific  block  grant could mean an increased
and perpetual dependence on  other means of Federal assistance,
such as energy assistance payments for fuel bills.  Furthermore,
we have  accumulated  too  much  expertise   in  the  current  low-
income weatherization program to  abandon  it.   Folding weather-
ization into  a  non-specific  block grant  would  eliminate  many
of the tremendous  benefits  achieved  by  the  current Department
of Energy program.

FISCAL RESTRAINT

    It is obvious  that  conservation must be accorded the high-
est priority  in energy  policy.    However,  in times  of  fiscal
restraint, policymakers must carefully analyze whether someone
other than government can,  or will,  get the job done.  Here we
disagree totally with the  Administration's point  of  view. The
Administration deems  that only  high-cost,  high-risk,  long-term
projects are  within it  purview.   This view  overlooks the  many
sectors of our  society  which are forced to struggle to survive
in the short-term.

    From the  corporate  headquarters  of  the  oil  companies,  a
$2000 weatherization  and  the industry  required  to  deliver it
may look  insignificant.   But,   in the  reality  of  the  snail
business sector and the low  and  moderate-income  households of
our nation, faced  with  oppressive interest rates and a massive
overflow of  resources  to   the   energy  industry,  the  problem
appears insurmountable.   The poor and  near-poor  don't  contem-
plate the high-risk,  high-technology, long-term  future;  their
risks, which  are  very high  indeed,  are in  surviving the  next
winter.

    Thus, rising  energy prices  pose  a  dilemma  for  those  who
would rely on the  market  to  solve the energy problem.   At the
very same  time  that  rising  prices  increase  the  incentive to
invest in energy efficiency,  they  rob households and businesses
of the capital  to  do so.    The  oil  companies are  swimming in
cash and engaging  in  an orgy of  corporate takeovers, buy-outs
and mergers,  while the  poor and  near-poor  struggle  to  scrape
together the finances for a  simple weatherization.

    The evidence on this point,  as contained  in the Department
of Energy's  Residential Consumption  Survey,  is  quite  clear.
The poor are just as likely  as the non-poor to  undertake no-cost
conservation measures,  but   only  one-third as  likely  to  take
costly conservation measures.   In fact,  between 1979 and 1980,

                       33

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            the poor reduced  their average  investment  in  conservation by
            16 percent, while the  non-poor  increased  their  average invest-
            ment by about  2 percent.   Capital  is the  critical constraint
            in the market.

                If one expects  the market process to  work, one  cannot so
            skew the distribution  of  resources  at the outset as  to  make a
            mockery of the  very concept  of  a market  and a misery  of the
            lives of those  who  do not possess resources.   We  believe that
            the role of  the Federal  government  is to  assist  those  alter-
            natives and  those  individuals that are  directly disadvantaged
            by rising  energy  prices.   It must  balance the  scales,   so to
            speak, so  that the  balanced pattern of   energy  development,
            which is clearly in  the the  nation's  interest can be achieved,
            and so  that  the very  lives  of   the poor  can be  protected and
            preserved.

                CECA makes  these  observations and  arguments on  the  basis
            of the  single  largest  review conducted to  date  on  the results
            of actual  weatherizations.    Our data  base  covers  over 6000
            houses in 25 states and includes data  on about one out of every
            500 homes weatherized  in  the Department  of Energy's low-income
            weatherization program.  We have  applied  rigorous  cost accoun-
            ting procedures and  stiff  economic  criteria to  the available
            data.  We  conclude  that  low-income  weatherization  should not
            only be maintained as  a separate program,  but that  it would be
            wise to expand it as quickly as'possible.

                Beyond that  specific  recommendation,  the  implications  of
            our analysis for  the  work of the review panel are  clear.  We
            urge you to take your  own stated goals to heart, to apply your
            own criteria on a rigorous  basis,  to examine  the  evidence in
            an objective  fashion and,  above al], to  have  the  courage to
            change your minds.   Have  the courage  to take a  close and fair
            look at these  programs which you Intended to defund or disman-
            tle.  Have the  courage to find  that  they are  of  much greater
            value than you originally thought.   Have  the  courage to con-
            clude that  they deserve  a  more  extensive Federal commitment
            and demand   more  Federal   resources  than  you   anticipated.

                If you do  so,  you will do a  tremendous service to the na-
            tion as a  whole and to the  specific  groups which benefit from
            these programs, the nation's  low  and moderate-income households.
            households.

DR. RIEGEL:     Thank you very much. Before  turning to  questions, we  have a
            final contribution  from  Shirley  Sutton  from  the Americans for
            Energy  Independence.

MS. SUTTON:     Mr. Chairman, members of  the  panel.  I am   Shirley   Sutton,
            Director of Community  Programs for Americans for Energy  Indepe-
            dence (AFEI),  a Washington-based nonprofit public  interest or-

                                  34

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ganizatton representing  the business,  labor,  academic,  reli-
gious and public interest communities.  AFEI is  privately funded
by business and labor.

    A major AFEI  purpose is to  provide  public  energy informa-
tion programs encouraging the development  of  a  strong national
energy policy of  rapid development of our national energy re-
sources and capabilities, including  conservation.   My comments
are based on  experiences I  have gained as,we have worked with
many diverse  groups and a  variety  of programs  that involved
both the public and private sectors.

    As AFEI Director of  Community  Programs,  I have coordinated
energy education programs with business,  labor,  and other citi-
zen groups  in local communities across  the  country; directed
an AFEI three-year  community energy  conservation and education
program in  Pittsburgh,  Pennsylvania,  including  fund-raising
efforts, and managed two DOE conservation grants.  In addition,
I served on the DOE Consumer Affairs Advisory Committee for two
years and chaired a task force that evaluated DOE public infor-
mation programs.

    It is from  this perspective  that  I wish to  address how the
"adequacy of  attention  to  conservation  can  be assured  given
the new direction of   Federal  energy policy."   I  will confine
my remarks  to the  impact  of changes  on public  energy  infor-
mation programs and residential  conservation  efforts, particu-
larly those for low and  fixed-income persons.

    1 would like  to comment  on two  of  your suggested  topics
for general discussion that are derived from the  Public Energy
Discussion Package for the Third Year National Energy Plan (NEP
III), and  on  the  general questions you  raise,  regarding the
role of private firms  and organizations  and  Federal, state and
local governments in the new Federal energy policy.

    The DOE assumption in the  NEP III discussion package that
"public spending  should  not  be used  to  subsidize  domestic
energy production and  conservation  since  this  buys  us  little
additional security and  diverts capital,  workers and initiative
from more  productive   uses  elsewhere  in  the economy" is  not
shared by AFEI.

    AFEI believes  that  conservation  will continue  to play  a
vital national role in directing the country to  a more  secure
energy future.   Conservation,   in   the  broadest  sense,  means
using our resources wisely, efficiently  and  productively.   In
that respect,  it  becomes a  vast domestic energy resource help-
ing to lessen our dependence on imported oil  and  saving  sub-
stantial sums of  money.   The role  that  conservation will play
as an  important  energy   source  is  acknowledged  by  so  many
                       35

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respected sources that  its  importance  to  the national interest
cannot he questioned.   Just a  few  of many diverse sources that
confirm the  vital  role  that   conservation  can  play  includes:
Resources for  the   Future  (Energy:  The  Next   Twenty  Years);
Consumer Energy  Council  of America  (Analysis of the  Costs and
Benefits of  Low-Income  Weatherization);  Mellon  Institute Pro-
ductivity Center (Least Cost Energy  Strategy);  U. S.  League of
Savings Associations  (Energy  Saving Ideas  in Home  Building);
DOE Assistant  Secretary for Policy  and  Control  (Reducing Oil
Vulnerability—1980 Report); various studies by Edison Electric
Institute, American Petroleum Institute, Gas Research Institute,
Solar Energy Research Institute.

    The important question  that  remains  is  whether it  will be
the public or private sector that  will ensure the continuation
of conservation  efforts.   Throughout the  recent  budget cutting
process, Administration  spokesmen  have said that  they  expect
private volunteers and the marketplace  to  replace many curtailed
government programs.  This  philosophy  also  appears in  the NEP
III discussion package.   It states  that "individuals  and  firms
in the private  sector have incentives  to produce and  conserve
energy efficiently."

    It may be  that the  commercial  sector  will  find  there is
no need  for  incentives  or  other  government-sponsored programs
to bring  about  massive  conservation efforts.   I leave that to
others who  are  more  knowledgeable in   that  area.   However,
residential consumers,  and  particularly   fixed-income  residen-
tial consumers,  do  not have  sufficient   incentives,  financial
resources or  information  to   make  meaningful   investments  of
time or money.   Not  only  do they not have  incentives,  but our
experience in working with  the public  has shown  us that people
still are not  even  aware  of the full range  of  options open to
them to  save energy  and  money.   For the most  part,  people do
not know  of  help  available to  them from  utilities,  existing
governmental programs,  social  service  agencies  and other pri-
vate sources.

    Half of  our 67 million homes are  without attic insulation
or storm windows.  Reports from the Energy Forum  in New England
show that  impressive inroads  have  been  made in New England,
where in  Connecticut  alone  37,000 energy  audits  were  requested
and 23,000  were completed  in  a  program  supported  by private
and public efforts.   But  audits  are  just  the first step.  There
are many  roadblocks  from start  to  finish  in  the process of
weatherizing homes.   People don't know where to  get  the best
materials, whom  to  hire,  how  to perform  the  work,  or where to
get the  money  to do  the  work  necessary.   Despite  the success
of the  audit program,  the New  England  Forum tells us that many
citizens will  not  receive these services or others.   Tenants,
elderly and  low-income persons  are now installing weatherization
measures at  a  rate  of  5% annually, only half  as  fast  as the

                       36

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national average.  Moderate and upper-income homeowners reques-
ted the audit,  while poorer and older  homeowners  did not. Ad-
ditional help  is  necessary to  encourage these  persons  to use
the services offered.

    Who will take on this responsibility?  As mentioned, a num-
ber of utilities have  good programs.   Others  have programs in
the planning  stages.   We  hope  that they  will  continue  even
though they are no longer required to do so.  Some major energy
companies support programs of public interest  groups.  But can
utilities, energy  companies,   the   labor community,  nonprofit
groups, or  local  governments  take  on   this  much  needed  role
without public funds or incentives?

    I would  like  to  bring to  your  attention  one  government
program that has  been  able to  bring together all  segments  of
the community.   It  is  the  Community  Energy  Project of ACTION.
Although seed  money  is provided through  government funds, the
project involves  community  volunteers  and  private investment.
Because of  this,  it  is an  extremely  cost-effective program.
The CEP project  is  designed  to launch  a community on a "self-
help" program that uses all of its resources to provide conser-
vation help to  everyone.   However,  it  places  special emphasis
on low to moderate-income  persons.  Not  only  do these persons
receive kits  of  low-cost,no-cost  materials and  training  to  go
with them, but volunteers  are  trained to do the  work for those
who are unable to help themselves.

    CEP programs have  been demonstrably  successful.   During  a
nine-week program, one  small Massachusetts  community mobilized
and 1,728 households saved  14% on  their energy  bills.  ACTION
extended the  CEP program  to  more  than 18  communities  in the
State of  Massachusetts in  1980 and  expanded to  30  in  other
parts of the  country during  1981-1982.   However, the program's
base funding  came  to  ACTION  from DOE.   That  funding will  no
doubt be  cut.   Who  will  pick  it  up?   Will  communities  "self
start?"  Our experience shows  that they do not.

    Our own  community   involvement  project  is  an example  of
how a  private  program can  work.   AFEI's  Pittsburgh  energy
education program  was  privately  funded  by  the  corporate  and
labor communities.  It  organized  all sectors  of the community
to work  together  to help  the Allegheny  County   area  become
energy efficient.  The  program was highly successful in involv-
ing hundreds  of  organizations  and through  them,  thousands  of
individuals.  However,  at the  end  of three years,  funding was
dropped due to the press of other commitments and new interests.
To date,   we have  been unsuccessful in  locating  funding  for
more programs of this sort in other cities.

    As a  nonprofit  organization  dependent  upon  contributions
for survival,   we  understand how much  time,  effort - and  very

                        37

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hard work -  is necessary  to  persuade contributors  to  support
the activities of  such  an organization.   Fund  raising  becomes
a major time-consuming element  of staff operations.  I  do not
believe it will  be possible  for many nonprofit  organizations
to mount  the  necessary  effort  that  will enable them to  carry
out programs  that can substitute fully for the Federal programs
that will be  cut.   Not  only  will they not  have  the ability to
staff an ongoing fund-raising effort for conservation programs,
the money isn't even there.

    A recent   New York Times  article quotes  an  Urban Institute
study estimating Federal  budget  reductions of  $128.2  billion
for social welfare,  health,   arts,  housing and  food programs.
Currently corporate  contributions  to  nonprofit  groups  only
total $2.55 billion.  This is a gap that is impossible to fill,
even though  some  corporations  are  increasing  their level  of
giving.  In fact, many corporate leaders are chagrined at hear-
ing continued statements  that the private  sector  can close the
funding gap.

    AFEI does not  believe  that  the  private  sector  or  the mar-
ketplace can   currently  provide  sufficient  help or incentives
to enable enough residential  consumers  to  participate  fully in
much needed conservation programs.

    We do not  believe that state and  local governments  will be
able to take  up the  slack because  their  funding  and  program
delivery systems are also  undergoing radical change.  In effect,
we do not  know,  nor do we  believe  that anyone knows  just what is
going to happen to many of our residential consumers who have to
choose, in many cases, between heat, food, clothing and shelter.

    We believe the Federal government must carefully weigh the
decisions to  cut programs that have shown they are helping peo-
ple to  help  themselves  conserve  energy  and money  when there
does not seem to be a chance  they can be replaced.

    AFEI has  long been critical of excessive government regula-
tion and involvement in energy affairs.   We agree that too much
public money has been spent  on  programs  that were not properly
conceived and  administered.   However,  we do  believe there are
some roles the  government must play where  it  is  unlikelv that
the private sector will step in.

    We would  like  to  suggest that  the  Administration  and Con-
gress monitor the  effects  of  their  current budget  decisions in
terms of  the social and  financial  impact  on  the   residential
consumer.  To  help in the evaluation process and  to  plan for
the future,  we  suggest  a partnership   of  government,  private
and public interest sectors,  to help residential consumers con-
serve energy,  which is  consistent  with  the national interest.
                        38

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DR. RIEGEL:     Thank you.   I will open the floor for discussion now.

MR. PFEIFFER:   Mr. Cooper,  I was curious as to  what activities you expect
            your member organizations to be concentrating on in this envir-
            onment of  reduced  funding at the  Federal  level,  for conserva-
            tion programs?

MR. COOPER:     Well, two  activities.  One is to continue to do  research,
            such as this report, and to monitor conservation activity. This
            was done  almost  entirely  from  internal  resources and  since
            we've released the report I've gotten another 500 or 600 houses
            from a number of states.

                The second activity  which  we're actively engaged in now is
            developing a nonprofit public  interest  energy service company,
            which will try and  go  into  local  communities and see if it can
            raise resources  to fill the gaps we have identified in deliver-
            ing weatherization to low-income households.  We will certainly
            do the best  we  can  in  responding to the  reduction in Federal
            funding.

MR. GLASSBERG:  I'd like to  ask the  witnesses what evidence they have seen
            that would attribute  conservation on the  part  of  consumers or
            businesses in the  market directly to  Federal involvement.  In
            the case of the weatherization program you can say that materi-
            als were  put  into  a  house  and you  compare  the  cost— energy
            consumed before  and  after  the  weatherization took  place.  But
            how about for  other state and  local conservation programs. Can
            you draw that causal relationship?

MS. SUTTON:     I can't quote — give you figures right now.  But I can say
            that in the Pittsburgh area when we were involved in a program,
            we worked with  school districts.  The  school districts became
            aware and involved,  not   only  because  of  our program,  but  of
            other kinds of  things  that  were happening.   There  are numerous
            school districts  in the  Pennsylvania  area  and all  over  the
            country, as there  are  hospitals  and  other public  institutions
            that can  quote   you  exact  figures  of  savings  that have  been
            realized through programs that  they have been  involved in.   A
            number of those were programs that were done with some Federal,
            some DOE monies.  ' These   schools,  hospitals  programs—  and  if
            they're not available  or you don't  have  them,  I'd be  glad  to
            gather some of those and provide them for you.

                That's one sector.  Of course the industrial community also
            has some marvelous  stories  to  tell  of energy savings that they
            have experienced.  These are programs that have been done  for
            the most  part  with their  own  finances, however, they  too are
            interested in incentives and programs to help them  but  as far
            as schools  and   hospitals,  there   are  some  very good  figures
            available in connection with that.
                                   39

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MR. GLASSBERG:  Well,  that  is also sort  of  a construction program similar
            to the weatherization program?

MS. SUTTON:     A construction program?

MR. GLASSBERG:  Yes, in other words you put building materials or conserva-
            tion measures into  a  building and can  measure energy consump-
            tion before and afterward.

MS. SUTTON:     That's correct.

MR. GLASSBERG:  Okay.  Do you have any other—

MR. COOPER:     I  think  that you've  certainly hit a  difficult  point in
            terms of how you  do cost  benefit analysis on information  pro-
            grams or  education  programs,  and  it  would probably  only  be a
            decade or  two from  now when we go back and  reconstruct aggre-
            gates and  sort  of take apart every piece of  information that
            was generated in the interim.

                Some historian  will make  some  kind of  factual historical
            economic argument and say: "Well, yup, that's where the turning
            point was."  I think  a  similar problem exists in every program
            where the benefit is not easily calculable. I mean, what is the
            benefit of the  next  battleship?  Do  we measure it?   Would  we
            have peace without it and so forth? What happens in these kinds
            of situations is  that you proceed with a general concept and a
            general thrust,  you observe general results and then much later
            on you can go back and say: "My God,  if we hadn't had that bat-
            tleship or that  fleet or that conservation program things would
            have been much worse."

                You reach conclusions, but  to demand precision from infor-
            mation programs  and  other types  of  general  programs is  very
            difficult.

                The other point  should  also be stated.  Where  you can get
            precision, you should demand it. In weatherization programs,  in
            schools and hospitals programs, when  you clearly and certainly
            can identify a  shift  in  policy, and  measure its  impact,  you
            should be  on-ground today monitoring  things.   Within a year  or
            two or three you can know  very precisely whether or not the cost
            and benefits have turned, whether benefits have  been increased
            or not.

MR. GLASSBERG:  But you agree that  cost-benefit  analysis  cannot be applied
            across the board  for  conservation programs with any precision.

MR. COOPER:     Certainly not in the short  term.  In the  slightly  longer
            term I think you start to construct the  possibility of doing so.
            For instance, suppose next year we institute a building labeling
            program, which is a remote possibility;  but  suppose it were  to

                                   40

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            happen.  You  might well look  at the behavior  of the building
            industry over a  decade  or  observe that  within a  short time lag
            there was  an  increase  in  the  energy efficiency of  buildings.
            You will have to have constructed a five-year data base before-
            hand and a couple  years after  so  that this  type  of precise cost
            benefit, profit and loss calculation can be  conducted.  It still
            can be difficult for non-specific objectives.

MR. POWER:      I hate to  promise anything;  but partly in  response to en-
            couragement from last year's  review we  have increased  efforts
            to evaluate our programs and we've also instituted an effort to
            strengthen the measurement  of what  we're  calling conservation
            indicators.  And so hopefully within the next several months we
            will have much more refined  insights into what is actually going
            on in the  marketplace and  I hope that  that will be a helpful
            piece of information.

                Have you  any thoughts   about  possible tradeoffs  within the
            low-income energy assistance payments program that is run by the
            Health and Human Services Department?

MR. COOPER:     Well,  in the  study we  spent a  lot of time  developing a
            theoretical model for how to make the tradeoff,  and I do so with
            a certain  trepidation,  because  I don't think you simply throw
            the thing into a block grant and  let decisions work  out.  There
            must be a careful process of fabricating  the program.  However,
            there is no doubt  that  Federal dollars  are  better spent buying
            weatherization than paying  fuel  bills.   There may be  some  who
            will say that if you  don't  pay fuel bills,  then energy suppli-
            ers will be hurt and there is a recycling on  that production
            side.  However,  I think it's clear enough that the benefits are
            there.

                Second, I  think  it is  possible to  manage   the  program  so
            that you do not have to stop delivering  energy  services  in the
            short term while you  start  increasing  weatherization services.
            We point out  that  a series of sequential purchases  of smaller
            packages of weatherization  services is  one  way to sort of bal-
            ance cost and benefits for  the low-income population.

                One of the problems,  and I frankly  admit it, is that this
            could be an administrative nightmare.  We're talking about three
            or four trips  back  to  households and program administrators tell
            me that  that's   impossible.   You  may  run   the  administrative
            costs out  of  sight.   In that  case, what you need  to do  is to
            have a bigger  base to  spread  the management of assistance in
            weatherization around.  What that argues for is  less  of a narrow
            local approach and  more of a  broader  approach,  where you  can
            balance off more weatherization with more assistance.

MR. GLASSBERG:  I have one  question  for  Alan  Miller.   In  your testimony,
            you ran through a  number of market  forces that  will not induce

                                    41

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            conservation to the proper  level,  such as past  and continuing
            subsidies and  state  control of  electricity  prices,  etc.,  and
            you address these comments primarily focused as a justification
            not to cut the budget for the next year's program.

                How do your comments  fit in  with the present program, with
            the past  program?   Have  past  conservation programs  addressed
            these needs adequately  and if you had  your  way, how  could we
            reconfigure those programs in a  greater  or lesser budget situ-
            ation?

MR. MILLER:     That would probably be another set of testimony. I wouldn't
            — I'd  certainly  be  the last to  claim  that  the  programs  as
            they've evolved have  been  the  best  way of  doing things.   I
            think I  just  don't  have a real  crisp answer to  that  in a few
            sentences.

MR. GLASSBERG:  Is  it  okay if  he could  provide  information  for the record
            on that?

DR. RIEGEL:     Yes.

MR. MILLER:     I'd be happy to do that.

                      ************
        SUPPLEMENTAL INFORMATION SUPPLIED BY MR.  ALAN MILLER

                At the July 14th  hearing,  Mr.  Glassberg asked  for comment
            on the  extent to which existing programs  were  responsive to
            NRDC's concerns and  how  we  would reconfigure programs within
            the reduced  funding  levels.   NRDC  prepared  an  alternative
            budget for the environment  in  conjunction  with  several other
            conservation groups.   (See attachment).   Our  budget would have
            achieved the  President's  fiscal  objectives  but  would  have
            allocated funds in a  substantially different  fashion.   Specif-
            ically, by cutting the Department of Energy nuclear and synthe-
            tic fuels  programs,  we  would  save  sufficient funds  to reduce
            the necessary  cuts   in   solar  and  conservation.   Details  are
            provided in the excerpt attached to these comments.

                Given the  cutbacks  that have  been made,  we  believe more
            emphasis is  necessary  on assisting  with the   development  of
            state and  local  energy  conservation  programs.   Both  technical
            and financial  assistance is  needed.   The  elimination  of  the
            Presidential Clearinghouse on  Community  Energy  Efficiency will
            save very  little money  and was a  serious mistake.   Low-income
            assistance, including  the  Conservation  and  Solar  Bank,  is
            also a  high  priority.   Regulatory programs, particularly  the
            RCS and  appliance  standards,  will  return  substantial energy
            savings for a  small  Federal expenditure.   Research  programs,
            by contrast,   offer  some  opportunity  for  cuts because  many of
            the firms  being  funded  do  not  need  financial  assistance.

                                    42

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         ALTERNATIVE BUDGET PROPOSALS FOR THE ENVIRONMENT
                  FISCAL YEARS 1981 & 1982

Proposed by: Environmental Defense Fund, Environmental Policy Center,
             Friends of the Earth, National Audubon Society, National
             Parks and Conservation Association, National Wildlife
             Federation, Natural Resources Defense Council, Sierra
             Club, Wilderness Society — March 18,1981

             Solar Energy Research & Development

                 The DOE  solar  program  is comprised of a  variety  of compo-
             nent research  and  demonstration  projects.    Included  in  the
             original $800 million  funding were  programs  to promote  wind,
             photovoltaics, biomass, and  active and passive  solar systems.
             These programs have  suffered  a  cumulative  reduction  of  some
             77 percent, to $193 million for FY 82.

             DOE Nuclear Programs

                 The DOE  nuclear  budget  contains  funds  for a  variety  of
             programs, ranging from  cost-sharing  reserach  with  the  nuclear
             industry to  the  development  of third-generation technology  of
             only speculative impact on national  energy security.   Many  of
             these programs should be cut  in  line with the Administration's
             stated desire to  end  unnecessary  Federal  involvement  in  the
             energy marketplace.   Despite  the  overriding  need  to  restrain
             Federal spending,  DOE's civilian nuclear  programs (fission  and
             fusion budgets)  have  received  substantial  increases  in  the
             latest budget revisions.

                 Based on  a   program-by-program  analysis   of the  nuclear
             budget, we  recommend  significant  cuts  which  include:  zero-
             budgeting the Advanced Nuclear Systems program and  elimination
             of the Clinch River  Breeder and water cooled  breeder  programs,
             neither of which will have  any significant impact on the devel-
             opment of world breeder technology,   even  if  they  were  unsuc-
             cessfully completed.

                 Additionally,  an equitable program of budget  cuts  within
             the DOE  budget  requires  additional   cuts in  Magnetic   Fusion
             R&D.   Even with  full funding  of magnetic  fusion, no assessment
             of the technology's  potential impact on  commercial electric
             generation is expected  to be  available prior  to 1995.

                 Although we  have  not  included  recommendations  for  DOE's
             Defense Activities  and  Uranium Enrichment  programs,  significant
             savings are  also  obtainable  in  these  areas.  For  example,
             stretching out the design  and construction  of the Portsmouth
             Gaseous Centrifuge  Enrichment  facility by one third would save
             $200+  million.   Such  a stretch-out   is  justified  by the fact
             that  the  construction schedule for the plant calls  for  instal-

                                    43

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lation of centrifuge equipment which DOE  itself  claims will be
made obsolete  on Portsmouth's  projected  opening  day (1988),
by an  ongoing Oak  Ridge  project which  is intended  to demon-
strate a process which is 50% more efficient.

Additionally, the enrichment  capacity  of  Portsmouth GCEF, pro-
jected to cover  over  $8 billion,  will  not be  needed until well
after the scheduled completion date.

DOE Synthetic Fuels Program

    There are  two  primary  sources  of  Federal   funding  which
are supporting the  development  of a synthetic  fuels  industry.
The "Energy  Security  Reserve" makes available  $17.522 billion
for the development  of  a  commercial synthetic  fuels  industry.
This money is to be administered by the Synthetic Fuels Corpor-
ation.  However, until  a  chairman  and board of  directors  are
selected for  the  Corporation, part of this money ($5 billion)
is being administered by  the Department of Energy's "Alternative
Fuels Program."   The  Reagan  Administration  has  recommended
that $.3  billion,  originally  designated  for feasibility stu-
dies and  cooperative  agreements,  be  rescinded,  and  that  the
remaining $5.3  billion  be  transferred to the  Synthetic Fuels
Corporation,  leaving it with a sum of  $17.212 billion.

    In addition,  the  Department  of  Energy's   Fossil  Energy
Program is  subsidizing  five  large-scale  synfuel demonstration
programs:  Solvent  Refined  Coal  I  (SRC  I) in Newman, KY;  SRC
II in Morgantown, WV; a Medium Btu Gasification  plant in Noble
County OH, and Perry County,  II.

    The Administration  now plans  to   rescind  FY 81   funds  for
all of the DOE line-item synfuels demonstration projects except
SRC II  which will  continue to be funded  for FY  81 because of
existing "international  agreements."   The Administration  has
also proposed that  no  money  be  appropriated  for  any  of  the
projects in  FY  82.   The  Carter  Administration  had   requested
$802 million  for FY 82.   We  support  the Administration's  re-
quests for these cuts.   Additionally,  we encourage the rescis-
sion of  FY  81 funds for the  SRC  II project.   If accepted, the
SRC II cut could yield savings of  $162  million in  FY 81 outlays.

Energy Conservation Programs

    The Administration's  proposed  budget  recommendations  for
DOE's energy  conservation  programs  represent a  77%  reduction
from levels   appropriated  for  FY 81.     Such reductions  would
effectively  cancel  major  portions of the national energy stra-
tegy enacted  by  Congress over the last four years.

    The  proposed cuts in programs  which are vital to the na-
tion's  energy security  future are  not   cost-effective.  These

                        44

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programs, unlike many of DOF.'s long-term R&D efforts, offer an
immediate return in terms of energy saved, and of millions of
barrels of oil freed for other uses in the economy.  Promoting
such efficiencies need  not,  and does  not, involve curtailing
the end  uses  to which  energy  is put,  but  it  does  require a
constructive Federal  role  in  increasing  the  efficiency  of
energy use throughout American society.

    The conservation budget of $700 million which we now pro-
pose would trim 20%  from the  Carter  Administration's request
for FY82.  This would allow for the continuation of essential
and highly successful federal energy conservation efforts,such
as the low-income weatherization program,schools and hospitals
program, state  conservation  planning  grants,  appliance effi-
ciency standards, and industrial, building and community sys-
tems, and transportation research and development.

Solar and Energy Conservation Bank

    This program, authorized  by Congress only last year, has
been eliminated in  the  Administration's  revised  budget,  and
regulations will not be  issued.   FY 81 funding of $121 million
for the Bank is proposed for rescission as well.  Intended to
promote residential, commercial, and agricultural energy con-
servation and  solar  energy  investments,  the Bank  would have
subsidized loans for  such installations to people  who could
not take advantage  of energy tax credits on their income tax
because of insufficient  income.   Only 8% of  the nation's home-
owners with annual incomes under $21,000 have taken tax cred-
its, according to IRS figures.  The bank is thus an essential
complement to  the energy tax credits if  energy  conservation
and solar development  are  to  be pursued in a comprehensive
national effort.
                       45

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           FY  1982  ENERGY FUNCTION
            Cons.
       Fossil \ 6t
        14%
                                               Conservation
                                                   20%
PRESIDENT'S BUDGET
ENVIRONMENTAL ALTERNATIVE

-------
QJ
    f


    J


    I


    i


    0


   -/
   -*

   -,

   -6

   -f

  -10
          FY 1982  ENERGY  FUNCTION
 Budget Authority
   (IN MILLIONS)
                                           President's
                                           Budget
                                           Environmental
                                           Alternative
-7*7
              Conservation    Solar
                        Nuclear
HUD Bank

-------
Energy Budget Comparison
(in millions)
Carter
Budget
Solar Energy Research & Development
FY 81 Budget Authority 585
Outlay 589
FY 82 Budget Authority 583
Outlay 589
DOE Nuclear Programs
FY 81 Budget Authority 1,396
Outlay 1,529
FY 82 Budget Authority 1,465
Outlay 1,847
Energy Conservation Programs
FY 81 Budget Authority 817
Outlay 735
FY 82 Budget Authority 922
Outlay 990
Solar and Energy Conservation Bank
FY 81 Budget Authority 121
Outlay 47
FY 82 Budget Authority 132
Outlay 149

President's
Revision
507
510
193
224
1,549
1,679
1,767
1,875
558
663
195
489
0
0
0
0

Environmental
Alternative
583
510
435
435
1,347
1,479
1,227
1,335
700
700
740
789
100
40
100
125
    ************
                48

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DE. RIEGEL:     Before asking Ned Helme and  Martin Klepper to come forward
            I'd like to ask you a question, Alan, as well.   It's irresistible
            to use  your  example of  $19 million saving  in the  District of
            Columbia Energy Office operation to ask this:   If  that operation
            is, in  fact, providing so large and so tangible and so valuable
            a return,  how  could  such  an  operation  be  discontinued   ?

MR. MILLER:     I think the answer to that is  the  same answer that the  Ad-
            ministration is  giving  in many hearings  on  the  Hill right now
            and that is  that  there  are  other  economic objectives to which
            city and state governments are responsive and  political object-
            ives that are often overriding, even when programs appear to be
            cost-effective and publicly desirable.

                My  point  for  the purposes  of  this hearing is  that  in the
            short term those pressures  are  going  to  make it very difficult
            to replace, program by program, all of the services which would
            be eliminated if  all  of these people  are let  go, and I've par-
            ticipated in some of those hearings at the local level. And the
            situation is that there are  many,  many programs  that are being
            explained and defended  and  justified in  the  same way,  much as
            there are at  the  Federal level.   These  are  different times at
            the state and local level  just  as  the Administration is saying
            at the  Federal  level  and therefore there are  going  to  be some
            short-term dislocations and disruptions  that the  city is going
            to endure.

                I think  over  the long  term that  they're  going  to  realize
            that these programs  ought  to  be   picked  up.  But in  the  short
            term, there's just  no  means of suddenly increasing local bud-
            gets without  major  changes  in  tax policies.  The case  of the
            the District  of  Columbia,  as  we   all know,  is  unfortunately
            complicated by  the  need  to  obtain  congressional  approval.   So
            it's not that simple to  say just  because a rational analytical
            cost-benefit analysis proves that  the program  is justified that
            politically the program is going to be retained.

                It  doesn't work that  way at the local  level  any more than
            it does at the Federal level.

DR. RIEGEL:     Thank you. Now I'd like to ask Ned Helme and Martin Klepper
            to step forward, please.  Ned Helme represents  the National Gov-
            ernors' Association and Martin  Klepper is from Lane and Edson.
            Mr. Helme, would you begin?
MR. HELME:      Thank you very much.  I think what I'll do rather than read
            my formal testimony,  which  will be in the  record,  I assume to
            be kept with  the permanent  file  and  so  forth,  I'll just sum-
            marize the major  points I was going  to  make  and have a  little
            more time for interchange in the time you've got.
                                    49

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    I'd start by  saying that, as you  know,  the Governors have
been very  supportive  of the  Administration's  budget  cuts.  At
the winter  meeting in  February here  in  Washington,  that was
the main  source  of discussion, the main  subject.   We came out
strongly in  favor of  the  budget  cuts and  in favor  of  block
grants, but we  indicated several  areas,  and not  very many,  I
think less than five  areas in the  entire  Federal  budget,  where
we felt that the Administration's proposals were not proper and
reflective of the needs that we see for the country.

    And the only  one within  the energy-environment area where
we indicated that was  a problem was  the state energy conserva-
tion grant programs.   We came out strongly  feeling that  those
programs should  not  be eliminated.    We would   support  some
cuts.  We  favor a  cut; we were willing  to  support up to one-
third budget  reduction  for   the   weatherization,   schools and
hospitals and the  core  programs,  with the  understanding that
we'd move  toward  a flexible  block grant  that would  give the
states a  great  deal  more  flexibility  to   implement  measures
that were  appropriate  to  that  particular   state's needs and
resources and climate and so forth.

    Given that,  we've  been testifying  regularly on the Hill on
both appropriations and on the block grant legislation, pushing
very hard  for the  continuation of these  programs  in the  short
run and their consolidation phasing into a block grant proposal
in the longer term.

    There's basically  four  reasons why I think  the Governors
identify these programs as so critical and  singled them out as
a program they'd push  for, in contrast to many other programs.

    First, I  think there's  a  feeling that  as your  previous
speakers indicated, there are a number of areas that the market
simply does not encourage  conservation and  our feeling is that
the state  programs in  providing  technical  assistance  and  in
providing information  on the  various  types  of  measures  and so
on and the savings that  can  be achieved with various measures,
those kinds  of  things  were   a  real  necessity  out  there.  It
wasn't enough to  simply say;  "Well, energy  prices are rising.
So therefore we can  count  on that  to  take care of  conservation
and we don't need these programs anymore."
                       50

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      There's  a  strong  feeling  on  the  Governors'  part  that  there
were  definite  sectors  of  the  economy that did  not respond  in
terms of  conservation  to market incentives.

      Secondly,  we  felt that  these programs  are  significantly
cost  effective.  I know Andy asked some  questions  of  the earli-
er witnesses  about whether you can show any real  results.   Sure,
the brick and mortar programs  can show results, but  what  about
the other programs and I think the fact is  that  they can.   There
are certainly some programs that  you  cannot measure effectively
in a  cost benefit sense.  But by the same token there are numbers
such  as  the  audits  for industrial  boilers,  small  industrial
boiler operators,  where  we can  show  a  significant result  and
we've got,  you  know,  the  Price,  Waterhouse.   I'm sure John's
familiar  with  these.   They're studies that  show  up  to $5  per
$1 invested at  the governmental  level.   So  we  think there's  a
significant cost effectiveness to these programs.  They're  not
just  paper  pushing kind of programs as some people  have charac-
terized them.

      Thirdly, it's our feeling that  they're  programs that deal
with  the  low  income  groups and that was addressed  very effect-
ively by  your earlier  panel.   Our  feeling is that that sector
or that  group  of  the  economy faces  the  most  severe  impacts
from  fast rising energy prices and  decontrol.

      The  Governors have always been in favor of decontrol,  but
with  the  understanding that  you take  care  of the  needs of  the
low income  and  our feeling is that the  state energy conserva-
tion  programs  have  moved   in  the direction  of  coupling  the
audits that are done under RCS and  they're done under individu-
al state  programs  with  the   delivery  of weatherization  and
things like that so  that  we see  a real  connection there  and  a
need  for  the energy office to  carry out that sort  of function.

      Finally, though we're not faced currently with  any  kind
of oil shortage because  of the  oil  glut  that  we're  all  aware
of, our feeling is that the states have the capacity and that's
been  demonstrated  in a number of GAO studies  that have   shown
that  the states  have  been the key  force when it comes to dealing
with  the  natural gas shortage, with the earlier coal strike  in
'77,  and with the '79 gasoline  lines and so forth.   And we think
it's  critical that you  maintain that basic  capacity  at the state
level to  deal with those  shortages.  The Administration's pro-
posal to  wipe  out these  programs  would  in  essence,  wipe  out
many  of the state emergency efforts and I think that's a criti-
cal need  that  while we  may  not   need it  this  year or  next,
we'll need it down the road and we shouldn't throw it away now
in a  rush of budget cutting kind of frenzy.

      Beyond that I'd like  to   give  you a little background  on
the survey  we did.   It's  alluded  to  in  your  background paper.

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This winter we  surveyed all  50  energy offices  to  get an idea
of what effect the proposed cutbacks would have on those energy
offices.  Twenty-nine  of  the states  are 80  percent  or  more
Federally funded.  So you can see right off the bat we're talk-
ing about two-thirds  — or 60 percent of the  states roughly,
would be close to  being shut  down by  the proposed  budget cut-
backs .

    Twelve of the  states fall in the  category of from 50 to 80
percent Federally  funded.   The  affect  there would  be  not  as
great but again  fairly  significant.  Only nine  states have up
to 50  percent  of  the  money  provided  by  the  state  government
itself.  So it  gives you  an  idea of  these  programs that have
been heavily  Federally  reliant.   Now,   I'm  talking  strictly
about the money  that supports energy office  staffing and the
SECP and EES.   I'm  not  talking   about  brick and mortar money
for bond programs  and  weatherizing buildings and that sort of
thing.  There  are  a  number  of  states that  have programs  of
that sort, but  it's a  lot  easier as you  know,  from political
prospective, to get  support in the  state  legislature for brick
and mortar  programs.   Much   more  difficult   to  get  something
that  deals  with  information,  and  staffing  and  so  forth.

     In addition,  it's  sort  of  the picture  of  how  states will
fare with this cutoff  in Federal funds.  I'd have to be direct
and say that  states  are trying  to find ways  to  bring out, you
know, to get  a little  more  support from their  state legisla-
tures.  However, given  the timing  of these   budget  cuts, it's
very tough to  see  any real  —   I  really can't see  any real
prospect of  any significant  number  of  states  being  able  to
replace these funds  in  any timely fashion.   We're  sure to see
a major hiatus  in terms of  lost  capacity,  lost staff,  if we
were to  go  ahead  with  the   budget  reductions   in  '82  as  are
proposed.

     There are  several  reasons  for this.  First,  there are 21
states that have biennial  budgets.   That  means they've already
put together budget  for a  two-year period.  Unless  you can get
a special  legislative  session   to  go  back  in  and   make  some
changes, it's  very difficult to change  that  and  usually that
follows the revenue  estimates so that you don't have an extra
surplus in the  second year that you  can draw  on  if you're in
the second year of a biennium.

    The problem  with special sessions  I've  alluded  to is that
it can  be  difficult  to  get  the   states to go back  in special
session.  Most  legislatures  have completed  their   '82  budget
considerations.
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    Thirdly, to understand  the  effect of  these  budget  cuts on
the states, you've  got to  look  at  this  within  the  context of
the whole Federal budget.  We're talking NGA's estimate is  that
across the whole range of  domestic assistance  the Federal budget
cuts will reduce Federal  aid to  states by  37  percent.  So  when
we say well, yes, the states can take over the energy conserva-
tion program,  we've  got to remember  that  there  are many other
programs competing at the state level for the same scarce state
resources, and  while you do have  some  energy rich  states  who
may well be able to pick up some things, the bulk of the states
are in fiscal  difficulty  at the moment,  particularly Northeast
and Midwest.   They  are in  very severe  economic difficulties.
So you're  seeing  significant   cuts  even  without  the  Federal
cuts.  So that  to think that well,  yeah,  the  state should  take
it over and  it will  happen, I  think  that's a real fallacy and
we can't really expect to see that.

    The final  part  of our  survey  that  I  want  to  allude to is
we did ask the states what  their priorities were.  If they  face
these kind  of  cuts,  which areas  within  their  programs would
they emphasize and interestingly there's a tremendous variation
across the  board.   You  couldn't pick  one single  program and
say, everybody  wants to do this.   It was — it really varied
with the climate, with the situation, the particular resources
those states had.

    Personally, we  felt  was  a  real strong  argument  for  the
block grant because it points up the  fact that in the Northeast
the weatherization  program is  clearly the  key  issue  because
you've got heavy dependence on oil,  high  and low income popu-
lation, rough winters.

    In the  Southeast and  the  Southwest  you've  got  a position
where they're looking more  at the agricultural sectors as being
the place  where they can  make  tremendous  savings in conserva-
tion, more  cost effective.  They probably  put  more money  into
that area.   So  we  did not  find  any single area that you could
pencil in and  say all right,  this  is the  one thing the Federal
government should  continue to  support  because  that will  cut
across all the states.

    Our clear  finding was that, in fact, making the money  more
flexible and  letting states target  it  made  much  more sense.

    I guess  the final  point  I'd like  to  make  to  you  is  that
these programs have  been  around  roughly  I  guess  six years  now.
The states have  done a lot of  planning under the programs and
a lot  of  assessment   of where  the   needs are  for conservation,
that sort  of  thing.   It's  our  feeling that  this  would be the
wrong time to  be cutting  off  these programs,  that we're now at
the point where  we don't  need  to do as  much planning.  We  know
                       53

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where the sectors are that  we  can make the real savings and it
would be a shame to cut it off at this point when you're really
getting down to  implementation,  getting  involved  in the local
governments and  the  program,  that sort  of thing.    So  I guess
that concludes my presentation — I  didn't mean to be quite so
long-winded, but that summarizes my remarks.
FOLLOWING IS MR. HELME'S FORMAL STATEMENT:

    My Name  is  Ned  Helme  and  I  am Director  of  the  National
Governors' Association Energy and Environment Program.  I appre-
ciate the  opportunity to  testify  before  you  this  morning on
behalf of the National Governors'  Association.

    Before addressing  the  specific  questions  posed  in  the
Issue Paper  issued  in June  for this hearing,  I  would like to
present the  general   position  of   the  Governors  regarding the
proposed changes  to   the  state conservation  grant  programs.

    The Governors  met  in  Washington  in  late  February  for
their winter meeting.  The focus of  this  year's  meeting  was on
the Administration's proposed budget cuts.   In a major resolu-
tion, the  Governors  supported  budget  reductions  and  block
grants.

    At the  same  time, they  set forth  certain priority  budget
items where  they differed  with  the Administration's proposals.
In energy and environmental  programs,  the Governors identified
the state conservation  grant programs  as the  only  area  where
they opposed  Administration  proposals to  eliminate  most  of
these programs.   NGA has  suggested instead   consolidation of
the existing programs into an energy block  grant with 1/3 less
funding then  was  available  in  FY  81.  An  energy  block  grant
would allow  states  to  direct  dollars to  the  measures  which
would be most cost-effective in that specific area.

The Continued Need for the State Conservation Program

     The Governors have  selected  the  continued  funding  of the
state energy  conservation  grant programs as  our  top  priority
for the following reasons:

o First, in  a world  of  rapidly  rising  energy prices, state and
local governments have served as the primary delivery mechanism
for information and technical assistance necessary to consumers
in taking  energy  savings  actions.   Although  rising  energy
prices have  increasingly motivated  companies  and  individuals
to seek energy  conserving  methods, many  consumers  do  not have
either the  front-end funds  or accurate  information necessary
to undertake  cost-effective  energy  savings actions.   States,

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through the  State Energy  Conservation Program  (SECP)  and the
Energy Extension  Service   (EES)  have  been responding  to these
needs.  Over time,  these  same programs have  been drawn upon to
provide support for  additional  federal initiatives such as the
Residential Conservation  Service Program and  the  Energy Emer-
gency Conservation Program.

o Second, these programs have proven themselves cost-effective.
Numerous studies have  shown five  fold or greater  returns for
every governmental  dollar  invested   in  the  state  programs.

o Third, state-administered programs  have  targeted assistance
to low-income  individuals  who  feel  more intensely the burden
of rapidly  rising  energy  costs.    States  are  now moving  to
couple home  energy audits  under the  Residential   Conservation
Service Program with the delivery of low-income weatherization.

o Fourth, the  states have  acted as  the  first line of defense
in responding  to  fuel  shortages.  It  is  crucial  to the health
and safety  of  the people  of  this  nation that the  capacity at
the state level  to deal with  major  oil  supply  disruptions  be
further developed and maintained.

    A further  description  of  the  state grant  programs  and
examples of  state  efforts  are  included in the  fact  sheet at-
tached to my testimony.

Impact on the  States

    I would  now  like  to  describe  to you  the results   of  a
recent NGA  survey  on the impact of  the proposed energy budget
cuts on the states.  NGA  conducted a survey  this winter of the
impact of proposed federal budget cuts  on state energy programs.
The survey results indicate that the total withdrawal of feder-
al support for FY 82 as proposed in the Administration's budget
will severely  impact the states' ability to carry out conserva-
tion and emergency programs.

    As noted in  the EPA  Issue  Paper,  the  majority of states
indicated that their energy offices  were 80% or more federally
funded, with the  bulk  of federal  funding coming  from  the SECP
and EES programs.   Twelve  state offices  were between  50% and
80% federally  supported,  and  nine states  indicated the energy
office was  50%  or  more   state  supported.   As  these  figures
indicate, there is  a strong likelihood  that  many  state energy
offices could  be  closed if federal funds are  eliminated in FY
82.  Functions may, in  some cases, be picked up by other state
agencies.  In  many  cases  the   functions  will  be  eliminated
altogether.

    In response to  potential  cuts, many  states  are attempting
to rally support for state funding for continuation of priority

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conservation activities.  It appears  unlikely that many states
will he able  to provide  any  significant support  in FY  82 to
replace federal dollars for the state energy office activities.
In our survey,  states  cited major problems with  the  timing of
the withdrawal of  federal  funds.   Most state legislatures have
already completed  consideration  of FY  82  budgets.  Even  if a
state had  sufficient  revenue  to  take over  financing of   the
programs,  it would be  unable  to  do so  unless  a  special legis-
lative session  were   called.   In  addition,  twenty-one states
have biennial budgets.   These  states  would have  even  greater
difficulty in obtaining state support to replace federal funds.
States are  constitutionally required   to  maintain a  balanced
budget and  a number  face  limitations  on  annual  increases in
spending.   Finally,  states  are  being asked to absorb  signifi-
cant federal cuts  across  the  board (estimated to  total 37% of
FY 81  federal  appropriations  to  states)  including  major  cuts
in social services and  transportation  and,  in  some cases,  face
their own severe fiscal difficulties.

State Priorities
    The NGA  survey  questioned  the  states on  their priorities
given the proposed  federal cuts.   Most states  indicated  that
they are currently assessing  their  priorities  and reevaluating
the programs.  Final  decisions  on priorities  will  depend  upon
the final  level   of   federal  support.   Responses also  showed
that when these  priorities are  finally chosen they  will  vary
a great deal among  states.  Priorities  mentioned included low-
income weatherization,  general  conservation activities,  resi-
dential conservation   programs,  transportation  conservation,
schools and hospitals, renewable resources activities, emergen-
cy preparedness,  and assistance to local government.

Current State Conservation Efforts
    The EPA  Issue  Paper  requested  additional information  on
state and local  conservation  activities.   In  the  past  the NGA
has published a number of reports on state conservation activi-
ties.  Our most recent  published  report is "Ensuring our Energy
Future: State Initiatives for the 80's" which  I am  submitting
with my testimony.   (This report was  reviewed  but  not included
in the Transcript due to its length).  In January of this year,
we began to  assemble  an information bank on  state energy pro-
grams collecting summaries prepared  by  states  of their activi-
ties and other relevant  reports and  documents.  We are currently
working on  compiling  this information  into a useful  fashion.
Examples of  these  state measures are included in  the  attached
fact sheet on "Energy Conservation in the States."

    Once again,  I  want  to thank  you  for  the  opportunity to
testify this morning.   I  will be happy to respond to any ques-
tions you might have.

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DR. RIEGEL:     All right.  Thank you.  Mr. Klepper.

MR. KLEPPER:    Thank you very much, Dr. Riegel. My name is Martin Klepper.
            I appreciate the opportunity to testify today.

                I am an  attorney  with the Washington,  D.  C.  law  firm of
            Lane & Edson, and have  been  working for the last four years in
            the field of energy conservation.   I've  been working on behalf
            of both public and private sector clients.

                We've been working with some major national underwriters in
            developing tax exempt bond programs to finance energy conserva-
            tion.  We've been working  with leasing companies and companies
            that are  called  equity  syndicators  that  are  interested  in
            raising capital for energy conservation purposes.

                We've been working with a variety of state and local govern-
            ments in the public sector.  We  recently completed a study for
            HUD in cooperation with the  New York City Energy Office, look-
            ing at  financing  opportunities  for  small and  medium  sized
            industry in  New  York  City  that  wanted  to undertake  energy
            conservation measures.

                We've done work  with the  State  of Massachusetts,  with the
            National Association  of Counties, the  National  Association of
            State Legislatures, primarily  in  the  area of assisting them in
            identifying financing  mechanisms  for  energy conservation pro-
            gram.

                I've had  a  unique  opportunity  as   well,  by   serving  as
            chairman of an Energy Law Committee of the American Bar Associ-
            ation in the  Section  of Real  Property,  Probate  and  trust law,
            to talk with attorneys throughout the  country who  are dealing
            with the same issues,  and while I'm appearing here today in my
            personal capacity and  not as  a  representative of any client,
            the comments  that  I'm  going to make  and the suggestions  are
            the kinds of  suggestions  that  I  think  would be of extreme help
            and assistance to the variety  of both public and private sector
            groups that we've been working with.

                I've tried to  give these  clients  a message  and  that's the
            message that private  sector  financing can  work.   I'm  going to
            be talking today  only about the  financing  of  energy conserva-
            tion.

                It can work,  but  there's  a lot  of assistance that's needed
            and it's a  long  road  to go  before we're  going to have very
            active involvement of  the private  sector  in  financing energy
            conservation.

                I'm going  to  suggest  for  your  consideration  six  very
            specific types of  legislative  changes that  I  think  would make

                                   57

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it an awful lot easier and that would facilitate private sector
financing for energy conservation.

    These deal  with  leasing,  tax exempt  financing,  the estab-
lishment of  energy  service  companies,  assistance  in  utility
involvement in financing energy conservation.

    There's a willingness  that we  found  on the part  of local
government to solve  the  energy  conservation  problem.   I think
that state and  local government  is  probably  far  ahead  of the
public, both private  and  business sectors, within the  country
in terms of  recognizing  the  savings potential,  recognizing the
benefit to their  community from energy conservation.   It's  a
little bit of government  pull  rather than demand push in terms
of government  willing  to take   some  steps  to encourage  the
private sector activity in energy conservation.

    We found that  local  government  generally doesn't  have the
expertise in the  financing  area.   Those  individuals who  are
responsible for energy  planning  at  the  city,  county  or state
level often are not well versed and well schooled in the mecha-
nics of tax  exempt  financing or  government municipal finance.
They don't have the resources to  retain the kinds  of financial
consultants that  they might  be  able  to   afford  if  they  were
financing a  $100  million  nuclear  facility.   They  don't  have
the support  either from  Federal funds  or from  state  funds.
Finally, there's really  no direct  working  relationship that's
been established between the energy offices, between the people
who are  responsible  for  energy  planning  at  the  local  level,
and the  financial  institutions  in  the  community,  the  banks,
the insurance companies,  the underwriters,  even the utilities.

    In some  communities,  they're  starting  to develop  those
relationships.   The energy offices  are  going  out and trying to
talk with  the  financial  community, but  that  is  a  very long,
slow process.

    Business, for its part,  is  really not  interested now  on a
relative basis   in  involving  themselves in  energy  conservation
on the local level.  When  I  say local,  I'm talking about loans
or providing financing for $2,000 or $2,500  worth of retrofit
for thousands of single family homes in the city or for dealing
with the problems  of  multi-family buildings or a  large number
of nonprofit buildings  within  a community.   If  they  have an
alternative,  private  financing  firms will  use  their time,  ef-
fort and resources to finance a $50 million gasohol facility or
a $30 million hydroelectric plants.

    In terms of  the  return on  investment,  on their investment
in those projects, private firms are  much more interested in
the larger projects than  the smaller ones.  So that even though
on an economic  basis you  can  look  at any  energy  conservation

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investment and  determine that  it's  extremely  cost effective,
that it has  a  very high  rate of  return,  that  it's a rational
economic investment,  it's  unlikely that that alone is going  to
be enough  to entice  the financial  community to  actively and
aggressively pursue the  energy conservation market.

    In working  with some of these companies, we've come across
problems, if  you  will,  in  Federal legislation  that  make  it
very difficult  even  for those  companies  that are interested
and willing  to  take fairly significant  risk in trying to devel-
op financing in the energy  conservation area.  The suggestions
that I'm going  to make  -  I think are  all  consistent  with the
Reagan Administration's  approach,  which is  to  let the private
sector provide  the financing.   But  I think  there's  a  need  to
assist local and  state  governments,  loosen some of the tax law
provisions, for  example, so  that local  and  state government
have the tools  where  they  show the interest and the initiative
to act  on   their  own  to   create   financing  opportunities.

    For example,  in  the  leasing  area  there are  a number  of
restrictions on  the use  of leasing that prevent a  company  that
wants to lease  energy  conservation equipment  for a  building
from obtaining  the tax credits that  would  otherwise be availa-
ble.  There's a limitation,  for  example,  that the lease term
cannot be more  than  one-half  of the useful  life  of the equip-
ment.  Well, it  is  very difficult for  a  company  that's buying
a boiler with a 15  year life  to lease  that boiler on an econo-
mic basis to a  property  owner if the lease cannot exceed seven
and one-half years.   If the  lease is   for more than  seven and
one-half years,   the   owner  loses  the   tax  credit   and  the tax
credit will  probably  be an  important   inducement  to  that type
of activity in the first place.

    So that  even  though the tax  credit   exists,  because   of
the restrictions  on leasing,  those tax  credits cannot  be used
by private  financial  institutions to provide the  capital that
the property owner might not have.

    For a  property owner  who  doesn't  have  the   capital,  the
tax credit is meaningless.   He cannot  obtain the  credit  if he
doesn't have the capital to buy the equipment.

    There's a provision  called  the  at  risk limitation  that
the Administration is proposing  to impose  on leasing.   That,  I
think would  further delay,  if not prevent,  the implementation
of leasing  for  energy  conservation because  it  would  make  it
that much  more  difficult  to  raise  capital  from  the  private
sector to  be  used for  leasing energy  conservation equipment.

    With regard   to  tax  credits,  one  area  that  our firm has
spent a lot  of   time  looking  at   is the  area  of  multi-family
housing.  There   is  virtually no  Federal   incentive  available

                      59

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for energy*  conservation  in  the  multi-family housing  sector.
A bill has  recently  been introduced in the  House  by Represen-
tative Schneider  from Rhode  Island that  would  provide  a  20
percent tax credit  for multi-family property  owners.   I think
that would  be  a  very important  incentive  in giving  them the
first step, the step that they need to encourage energy conser-
vation investment.

    I think it's  important  that  the existing  tax  credits have
their termination dates  extended.  That's  probably not high on
anybody's agenda right now.  But  in terms of business planning,
in terms of enticing  private  financial institutions into ener-
gy conservation,  if   they look  at  tax credits that  expire in
1982 or 1985,  and that's an important incentive  for their in-
vestment, and  they  expect it to  take  a year  or   a  year and  a
half before their program is  established  and on its feet, it's
unlikely they're  going to want to  make  that investment if the
tax credit  is  going  to  terminate in  another  two  years and if
they don't have some  assurance it will continue.

    Tax exempt  bonds  are one  of  the  most  attractive  means of
financing energy  conservation  because they  can  provide much
lower interest rate loans to property  owners over  a much longer
term than  is  available from  bank financing or  from any  other
alternative source.

    In trying  to  structure tax exempt  bond programs  I'm talking
now about  a revenue  bond,  not   a  general  obligation  bond,  a
bond program that would not rely on  the  full faith and  credit
of the  city but  would  rely  solely on the  security that  would
be behind  the  bonds.   There  are  a   number of  problems  that
have been  raised  primarily  by  the  Mortgage  Subsidy Bond Act,
also known  as  the Ullman Bill.   That  law,  among  other things,
permits energy conservation  bonds  to  be  issued  for   loans to
single family  homeowners  for energy purposes, but  it  restricts
those bonds  in a  number of  respects.  The restrictions were
really intended  to be  restrictions on  single family  mortgage
revenue bonds  not  on energy  conservation  bonds.  But  energy
conservation bonds  are included  under the definition  of  a home
improvement loan.  Therefore,  the  Mortgage  Subsidy  Bond  Act
limits the  amount of bonds that a  city, that a state  or that  a
county can  issue.   On  policy  grounds, even at  the   time  the
legislation was  enacted, I don't think  that it was the  intent
of  Congress  to  restrict a  city's  ability  to use tax  exempt
bonds  for  energy  purposes.

     The  limits in the Mortgage  Subsidy Bond Act  that  ought  to
be  changed  include  the  overall  state limit  on  the amount  of
bonds  that can be issued.   It  seems  to me  that  any bonds that
are  issued for energy  conservation purposes are  in the  public
interest,  particularly if  they  are saving  energy, or  if they
                        60

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are conservation  measures  that  result  from  recommended  RCS
measures.

    There's a limit  on  the  issuance of multi-family bonds that
requires that  the bond proceeds  only be  used  for apartment
buildings that have  20  percent low income tenants.  Well, that
might be  a  rational limitation  when  you're  dealing  with  a
mortgage revenue,  bond,  but  when  you're dealing  with energy
conservation, if  it's in the national  interest  to save energy
in a  low  income  building,  it's also  in  our  interest  to save
energy in an upper income building.

    Finally, there's  a   prohibition on taking tax  credits  if
you use the  proceeds of revenue bonds.   That might again have
made sense in  connection with  certain  types  of energy invest-
ments, but I don't think it  makes  sense in connection with the
energy conservation  investments.

    And in the  industrial sector,  industrial development reve-
nue bonds can be used to finance energy conservation for indus-
try, but  the problem  is that  there's  a  limit —  called  the
small issue exemption — which makes  it very hard to structure
a bond issue with a  lot  of $50,000 or $100,000 energy conserva-
tion items.  The size of the bond issue is too small to warrant
or justify the interest of  the financial  institutions.   If the
law were  simply  changed to permit  an  aggregation of 20  or  30
specific projects in one bond issue, then you would have under-
writers interested in providing the capital,  raising the funds
for these types of loans.

    In the multi-family sector, Congress  required HUD to adopt
an insurance program, a loan insurance program.   HUD came  out
with regulations  called the  Section  241  program  last  August,
but they have not  issued guidelines to their regional  offices
so that that Federal insurance program  for multi-family build-
ings is not effective and cannot be used.

    We have a  couple of clients who are  interested in  setting
up energy  service companies.   One of  the problems  that  they
face is the  possibility of being  regulated  as  a  utility.   If
they go into the  business  of  providing  the heat, light  and
electricity in a  building and  they're  willing  to pay  all  the
costs of  installing  energy  conservation  measures  and  they're
willing to take the  risk that their measures will  be effective,
they still may  not  be  able  to  do  that  in some  states  because
they'd be deemed  to  be  utilities and they'd  be regulated  as a
utility.

    I think that  the Federal government  can  help support some
of what I call long term research and development  in developing
some of these financing techniques.  We now have  all the tech-
nological answers that  we  need for  energy  conservation.   We
                       61

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            already acknowledge  that  energy conservation  is a  relatively
            riskless investment,  that  the  technology  exists  and yet  the
            infra-structure,  the  technical advice,  the  models for financing
            some of these investments  do not  exist  and that  ought to  be
            just as much within  the category  of research  and  development
            in terms of use of DOE  funds  as designing  the  answer to energy
            conservation in  buildings 10  years down the road  when  no  one
            has the mechanism, the means  of .paying for  those measures  that
            were designed or  invented 10 years  ago.

                Finally, in  terms of  a  broader  Federal  role,  I'd  like  to
            suggest that there's  a need  for a corporation like the National
            Corporation for   Housing  Partnerships  which  was  created  by
            Congress back in  1970  to  provide  a mechanism,  a  model,  for
            financing low income housing  production.   That  same  model  can
            be used to  create a  national corporation for  energy conserva-
            tion, a  separate  nonprofit  corporation.   It  would  only  need
            Federal funding  to get  on its  feet  and  to get  started.  That
            corporation would have   the   flexibility  and  the  ability  to
            raise private capital   through  a  stock  issue,  or   through  an
            issue of  limited  partnership  interests.    It  would  go  about
            creating the mechanism,  creating the models and demonstrating
            to the financial  community that energy  conservation is a viable
            valid investment  of  their time and  resources.

                The National   Corporation  for  Housing  Partnerships  is  now
            a completely independent, very successful  corporation.   There
            are literally hundreds,  if not thousands  of real estate limited
            partnerships that are  used  to  finance low  income  housing  in
            the country, all  modeled on work initiated  by NHP.

                The second alternative  for  a  broader   Federal  role  is  to
            create a  regional  corporation  for energy  conservation,  some-
            thing like  TVA  or BPA,  in those  areas  of  the  country where
            they don't  necessarily  have  the same  need  for  the  supply  of
            energy or  the  control  of  energy  that  TVA  and  BPA  have,  but
            where they  have   similar needs  in  terms   of  utilizing their
            resources to save  energy,  to  upgrade  the efficiency of their
            plant, of their  equipment and of their  buildings.

                New England  is  a  prime  example of  an  area that  I think
            needs that kind of regional  cooperation and  support that could
            involve both public  and private  sector financial  assistance.

                Thank you.

DR. RIEGEL:     Thank you very much.  Questions and discussion?

MR. POWER:      Just to  comment and ask  a question of Martin Klepper.  We
            have been working on the financial implications  of conservation
            more in recent years.  We've  I think finally gotten some recog-
            nition that the size of investment,  if you will, is much great-
                                   62

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            er in  energy  conservation that  it  is  in  energy production in
            the U.  S.   If  you  consider  items,  such as  consumer durable
            goods which produce  a  stream  of services like an automobile or
            refrigerator, as  an  investment  —  and I  think  this  is  a new
            look, a new way of approaching conservation — it gives a dif-
            ferent perspective and I think that your comments are very well
            received.  I'd  really  enjoy  a chance  to  chat  more about that.
            I think that  the  question  being how  we  can  examine  some  of
            these specific  changes and DOE  is looking  at  some  of these.

                I think in the context  of  current Administration philosophy,
            we are looking  at ways, new  institutional  ideas.   So  specific
            suggestions would be very, very much appreciated.

                I think  that  in terms of  where  we go,  we're  trying  to
            create specific  investment  calculations  in  our procedures  so
            that decision makers will have  a better  idea of what can be
            achieved by  conservation.   From  your  experience,  do  you have
            any specifics as  to  why some  of the conservation measures that
            look so  good  in  terms  of   the  engineering  analysis  or  the
            financial analysis,  aren't undertaken  by the private sector?
            I assume that  you're  saying  it's not  just  the  fact  that  the
            investments need  to  look better, it's — there's also something
            beyond that that's holding things up.

MR. KLEPPER:    There  are  a range of  reasons  that people  don't install
            energy conservation  measures, and  it  depends,  I  mean there are
            different reasons  for  different  sectors.   I will  be  happy to
            submit for the  record  the  report that  we  did  for  HUD in which
            we identified the barriers to energy conservation in the indus-
            trial sector and  they  ranged  from little  things  like the fact
            that the plant  manager who's  responsible  for  energy conserva-
            tion, looks bad if  he  can  recommend a million  dollar savings
            because the question is why  didn't  he recommend  it  last year
            or, why is  there that much waste in the  plant.   Yet he's the
            person with the technical  knowledge  who's probably going to be
            approached by  the person  selling the  equipment and  he's  the
            one who understands  the potential  savings.   (This  report  was
            reviewed, but not included  in  the Transcript  due to its  length).

                There's a lack  of  incentive in the industrial  area on the
            part of  the  corporation  because  there are  competing demands
            for capital.  The  employee  who wants to  expand  his  shoe sales
            department by  adding three new people  or  by  building  a  new
            wing to the  office  building  to  support  his expansion doesn't
            have any greater empire if  there's energy  conservation,  even
            if conservation  produces dollar  savings which drop immediately
            to the bottom line profit.

                There are a whole range  of  similar  reasons  that apply to
            the multi-family  area  and  the single  family area.  If you talk
            to the people in  Oregon  where they have the  zero interest loan

                                  63

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            program they  tell  you  that they  only  had  60  percent —  or
            something like a  60  percent —  response rate.  They went  out
            and performed 100 audits  and  said: "Here's the  energy  savings
            that we  recommend.   We'll  install  this  basically  for  free.
            We'll only ask you to  repay the  principal  at  the time  you  sell
            the house, no interest."  And only 60  out  of  100 people signed
            up.  They couldn't believe  it.   It reminds me  of the statement
            that if you  stand on  42nd Street and  5th  Avenue,  and  hand  out
            $1 bills, a  lot  of  people  are  going  to walk  by  and  not  take
            one.  There  are  a lot  of hassles involved  in applying for  a
            loan, finding the right  person  to give you the  loan,  meeting
            the different credit  requirements of   different  institutions.
            The loan  is  only one  part  of  it.  Letting  somebody you don't
            know come into your house and  spend  two days  drilling  holes  in
            your walls or up  in  your attic,  et  cetera,  is another hassle.
            We need to overcome  a lot of those barriers and economic incen-
            tives is  one way to  do  it  without  forcing  people  to  do  it,
            without  mandating  conservation   by  the  Portland  approach.

DR. RIEGEL:     I  have a  question   for Ned  Helme about the provision for
            emergency response or   crisis  management  events  that  we  have
            had to  contend  with in the past  and  that I  think all of  us
            realize could recur  if conditions were right.

                Many of  the  states, of course, did  go through very severe
            energy emergencies.   Is it your  feeling  that  this  experience
            is somehow insufficient to motivate the states to act unilater-
            ally to provide for  contingency arrangements?

MR. HELME:      I think  the problem is a problem of  timing in terms of the
            funding and  that's  why  I alluded to  the difficulties  in  the
            phasing of this  decision.  I  think,  in  fact,  that many states
            would rate the  emergency preparedness  part of their operation
            high on the  list  of  something  they'd want  to preserve.   But as
            a good example,  when the Administration in March repealed the
            existing allocation  rules  and   repealed the  state  set aside
            program which  gave   the  states  five  percent  of  the  fuel  to
            allocate and  so  on,  a number  of  states lost their allocation
            officers, immediately   lost  the   authority  and  people  left.
            There was a  real morale  problem for the states  in a number of
            programs, not just  this  program.   Where  there's  a  perception
            that this is  all going  to go away  and  nobody thinks  it's impor-
            tant anymore, you start  to  lose the  top  people  and something
            like that, dealing  with  emergencies  is a function  of  a small
            group of people who really know  the business, know the  industry
            contracts, can  get  the  fuel  where they need  to get  it in an
            emergency, understand  the coal industry in the  case of a coal
            strike, that sort of thing.  So it's  really staff,  it's people
            that you're  talking about  and  there's a  problem  in   keeping
            them when the money dries up essentially.
                                    64

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                It's not  a great  cost,  I'm not  going  to  say  it's  $100
            million to  do  that job  but it  is  difficult to  maintain  that
            funding and  just  as you  know how complex  it  is  here in terms
            of the  Federal budget,  when  once  the  cuts  go  through,  it's
            very hard to turn that around.   It's  the same situation at the
            state level  or the  state legislature.   Once  they act  on  the
            budget it's  very  hard to turn  it around,  if  they assume that
            they're going  to  have Federal  money  to  pay for  those people
            and in many cases they do.

DR. RIEGEL:     Thank you very much.

MR. GLASSBERG:  Just a minute, I want to ask  another question.
DR. RIEGEL:
    Oh, yes.  Go ahead.
MR. GLASSBERG   This is for Ned again.  You mentioned  that the state grant
            programs have been around  for  about  six years now.  Originally
            they were intended  to  serve very  specific purposes.   It seems
            that those purposes have  either been served  or  there's  been a
            move away from those directions.   Could you comment on how the
            directions in which the program has  moved  in — have they been
            good directions, do they  need  to  move in  other directions that
            they haven't moved in, could they —
MR. HELME:
    I think  they have been good  directions  and you're right,
they have  moved.   There  are  some  programs  that  added things
like procurement and  right  turn on red,  all  those things that
have been  done  essentially.  As  I said  earlier, it  laid the
groundwork, the planning.   They went  out  and  they  looked  at
all the  sectors  where  they could  make  conservation improve-
ments and I think what you find now is that states are focusing
their attention on  pieces of  that that have the best payoff,
the most cost-effective payoff.
                Beyond that  I  think  the  renewables
            only been  addressed by  a small  number
                                         area  is one
                                         of  states.
that has
It's not
            really part of  SECP  and EES currently and  that's  an area that
            I think there's a lot of potential.  And if we saw a shift from
            the more stringent mandatory requirements to a broader mandate,
            I think you'd see  a  lot more initiative in that  area than you
            have to date.  So I think there are some new areas that haven't
            been touched  and  it  would  help  if  legislation  allowed  that
            sort of activity to be pursued.
DR. RIEGEL:
    Okay.  Thank you.  David Moulton and Lewis Perelman are next
            up.
                These will be the  final  two  morning witnesses.  The agenda
            calls for us to recess at  noon  for lunch and we will reconvene
            again at 1:00 o'clock.
                                   65

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                David Moulton  is  from  the  Energy  Conservation  Coalition.
            Lewis Perelman from the  Jet Propulsion Laboratory and  we  will
            begin with Mr. Moulton.

MR. MOULTON:    Thank you.   I am a Policy Director of the Energy Conserva-
            tion Coalition  which  is  an umbrella  nonpartisan,  nonprofit
            alliance of public interest organizations,  formed to publicize
            and promote energy conservation.   The  organizations  serving on
            its Board represent over six million members, making the coali-
            tion the  nation's largest  organization  dedicated  solely  to
            increasing energy efficiency.

                The members include  the  Federation  of American Scientists,
            the Environmental  Policy  Institute,  the  National  Consumers
            League, the National Wildlife Federation,  the Union of Concerned
            Scientists, the Environmental  Defense  Fund  and  National  Con-
            sumer Law Center and Natural Resources Defense Council, National
            Audubon Society, Friends  of the Earth, Solar Lobby, Conservation
            Foundation, League of  Women Voters,  Conservation Foundation of
            New England and the Sierra Club.

                The Energy Conservation Coalition (ECC) appreciates  this op-
            portunity to address  this nation's  "adequacy of attention to en-
            ergy conservation methods" in accordance with Section 11 of the
            Federal Nonnuclear Energy Research and Development Act of 1974.
            The Coalition believes that this  subject is critical not only to
            our energy future, but also to the economic  well-being and na-
            tional security of our country.  Few issues rival energy in its
            fundamental relevance to the success  or  failure of both domestic
            and foreign policy.   And  few  solutions to our  current energy
            problem are as promising as energy conservation.

                Since the Arab oil embargo of 1973, great strides have been
            made toward recognizing  the  special  role  that  efficient energy
            use can play in our society.  A  series  of comprehensive analy-
            ses of national energy demand has  been  made,  which almost uni-
            formly emphasize  that reducing  energy waste  offers  the  best
            near-term option for  achieving a reduction in oil imports at a
            reasonable cost, a reasonable  speed, and with  reasonable  cer-
            tainty in  this  decade .J.'   Moreover,  energy  conservation  will
            remain a  critical  energy  "source  for  the foreseeable future.

                For purposes  of   this  hearing,  we  have  assumed  that  the
            value of energy conservation is undisputed.  We are asking whe-
            ther we as a nation are taking adequate steps to achieve energy
            conservation.

                Tlie Energy Conservation Coalition believes that current at-
            tention to energy conservation methods is woefully  inadequate.

                The Administration has  severely reduced federal energy con-
            servation programs on the premise that rising energy costs will

                                   66

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encourage all the conservation we need.  This reflects a danger-
ous and unjustified complacency with the status quo.

    Our foreign oil imports averaged around six million barrels
per day for the first  five months of 1981.   It is true that this
is the lowest level of imports since  1975,  and represents a con-
siderable achievement relative to the most  recent past. But more
importantly,it is the same level that we were importing in 1973
when the Arab  oil embargo hit our economy like a shock-wave,
causing double-digit  inflation and the  worst  recession  since
World War II.  A recent report of the  Senate Energy Committee on
world oil politics concluded  that  "(a)  major  oil  supply inter-
ruption appears  to be  inevitable within  the  next decade."—'

    This fact alone dictates  a strong  federal  interest  in the
pace of energy conservation in this country.

    Instead, the Administration  rejects any responsibility for
the level  of oil  imports  or the pace  of  energy  conservation.
It appears to be sleeping on  the so-called "glut"  — the tempo-
rary condition  of oversupply  that  has prevented  rapid  energy
inflation during the  Iran-Iraq war.  This  "glut" is due in part
to the  strong  national commitment to  energy  conservation that
previous administrations have  espoused.  But it can be wiped out
in a matter of weeks  by a single  member of OPEC —  Saudi Arabia.

    The Energy  Conservation   Coalition  believes that  at  least
three steps  must  be  taken before the  federal  energy conserva-
tion program can be considered "adequate".

    RECOMMENDATION  #1: SET  MEANINGFUL  GOALS  AND  PRIORITIES

    First, the Administration  must develop meaningful goals and
priorities for energy conservation before  decisions can be made
on a rational and consistent  basis.

    Even the previous  Administration  failed to take that step.
Last year,  for example,  the  Office  of Technology Assessment
harshly criticized  the  conservation  program  for  lacking  any
meaningful goals or priorities. ~J  Similar criticisms have been
voiced repeatedly  by  the General Accounting  Office.   Most re-
cently, in a June 17 letter to  the energy committees of Congress,
GAO wrote that "major decisions on the Federal Government's role
in fostering energy conservation continue to  be made without a
clear understanding  of energy, conservation's  contribution  in
resolving national  energy  problems  in   a  timely  manner. "Z.'

    The basis  of  these criticisms is  fundamental:  unless the
government sets meaningful goals  and  priorities, it has no means
for determining the  relative value of  alternative energy con-
servation methods.  Programs  will  be  stopped,  started and sty-
                        67

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mied haphazardly, without regard to  need.   Tax dollars  will be
misallocated and  wasted  for  lack  of  focus  and  direction.

    To its  credit,   the  previous  Administration   responded  to
the past criticism by initiating a hroad analysis  of the poten-
tial for energy  conservation by the year  2000.   Begun  in July
1979, under the direction of DOE and the  Solar Energy Research
Institute (SERI), this  18-month  study  reviewed each  sector of
energy end use and  attempted to quantify the  amount  of energy
that could be saved  by  the year 2000 using strict economic prin-
ciples and  assuming a  strong growth-oriented full-employment
economy.

    The SERI  report concluded  that  we  could  actually reduce
current energy consumption by over 20  percent by the year 2000
without sacrificing  other  national  goals.   End use  demand in
that year would  be  33 percent less  than  under current  policy.
The potential for each sector is  shown  on the Table 1 on the
following page.

    As the  report  indicates,  these are goals, not forecasts.
But as  indicators  of  the  potential  for energy  conservation
that is  realistically  achievable,  these  goals can serve  as  a
benchmark against which to measure progress in energy conserva-
tion.  When one considers  that renewable energy sources,  accord-
ing to the  report,  could  contribute another  12 to 22 quads by
the year 2000,  it  is clear that an enormous opportunity exists
to gain control over our energy future.

    The Reagan  Administration took  office  as this  study was
completed.  Unfortunately, the new Administration has failed to
adopt meaningful  goals and  priorities.  This  is  true  not only
of its  energy conservation program, but  of  its  entire energy
program.  Officially,  its policy  is to shun  setting any  goals
or targets,  and  to  reject  any  federal involvement  in  leading
the nation  towards  more efficient  energy use._'   Moreover, it
suggests that decisions about energy conservation will be made
outside a comprehensive framework and without  serious analysis.

    The goals  laid  out in the  SERI report  were  not accepted,
and no  attempt  has  been  made to  replace  them.   This  reaction
to the  most thorough  review of energy  conservation potential
to date does not augur well  for energy conservation.

    RECOMMENDATION  #2:  ADDRESS MARKET BARRIERS

    Second,  the Administration must  devote attention to identi-
fying the limits of market forces  to encourage energy conserva-
tion.  Without a thorough understanding of the barriers  to  ener-
gy conservation, the Administration  is not in  a position to de-
cide whether  existing  programs are properly focussed to address
real problems.

                         68

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                                      END-USE ENERGY DEMAND POTENTIALS
ON
                                                                         Yfear 2000
Residential Buildings
Commercial Buildings
Industry
Agriculture
Personal Transportation
Freight Transportation
TOTAL
-^Without 50C gas tax
Source: Report on Building A
1977
(QUADS)
16.2
10.4
29.1
1.6
15.1
4.3
76.7
Sustainable
Baseline
(QUADS)
21.95
13.30
39.70
2.18
13.26
7.2 - 8.7
97.59-99.09
Future, prepared by
Economic Potential v.
Potential Baseline
(QUADS) (PERCENT)
11.06 -50
7.26 -45
29.40 -26
1.7 -22
7.6 - 11.4-/ -14 -
5.7 - 6.0 -17 -
61.91 -66.01 -32 -
the Solar Energy Research




-42
-34
-38

                Institute, reprinted by Committee on Energy and Commerce, U.S. House of Representatives,
                Committee Print 97-K, April,  1981, pp. xxvii, 3, 81, 124.
                                                      Table 1

-------
    Consumers and  businesses  require  extremely high  rates  of
return on  energy efficiency  investments  —  much  higher than
seems rational  to  an economist.   In a  recent   review  done  by
Robert Williams of Princeton".' the evidence revealed:

    —In an analysis done  by the  National Association of Home-
      builders, homeowners applied discount  rates  from 20 per-
      cent to  150 percent  on  energy  efficiency  investments.

    —In an  analysis  done  by Oak  Ridge  National Laboratory,
      median households  applied  a 47 percent discount  rate  on
      energy efficiency investments.

    —In an  analysis  done on  room air  conditioners,  the dis-
      count rate averaged  from 15 to  25 percent,  and  rose  to
      89 percent for poor households.

    —Volkswagen will  only  make   fuel  efficiency  investments
      for new  cars  that  correspond  to  a 52 percent discount
      rate for the owner.

    —Data from the SERI report indicates  that commercial build-
      ing owners apply a discount rate of 65 percent or more to
      energy efficiency investments.

    —Industrial investment  standards  imply  discount  rates  of
      40-110 percent.

    If the market were working "properly", these discount rates
would be much lower and economic waste would  be  avoided.  If we
pursue policies that do not  address  this  problem,  we are miss-
ing enormous cost-effective  opportunities to bring  our energy
future under control.

    Other evidence of the  degree  to  which the real world falls
short of the perfect market can be gleaned from tax data on the
residential energy credit.   Despite  sharply  rising oil and gas
prices from 1977-1979,  the data shows a decline  of 8 percent  in
investment in energy conservation per capita.Z/

    Similarly,  recent data prepared  by  the  Carrier Corporation
indicates that from  1979-1980, despite  rapidly  rising electri-
city prices, the efficiency  of central  air-conditioners actu-
ally declined nationally  after eliminating data on  California
sales (where  mandatory   state standards  have  been  adopted).
Central air-conditioners are  purchased  with  little regard with
little regard for  the  preference  of individual consumers  be-
cause they  are  usually  "contractor-installed"  before  the con-
sumer buys a house.  The dominating  factor  is the  contractor's
desire to minimize  first  cost, not  to  minimize the life-cycle
cost.
                         70

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    A useful  summary  of  these  imperfections with  respect  to
appliances was given in 1977 by former  Congressman David  Stock-
man (now  Director  of the Office  of Management  and  Budget)  in
his additional views to the House report on  the  National  Energy
Act:

    There is some reason  to doubt that  market  forces alone will
    bring about the needed  shift  to more efficient appliances.
    Numerous witnesses appearing before the  subcommittee  testi-
    fied that  the  average  consumer looks  for  a  payback from
    higher purchase prices  within  3 years.   In  the  case of  an
    appliance with a useful life of  10 years, this  short pay-
    back horizon severely limits  the amount  of  higher purchase
    price the consumer will accept  in choosing a more efficient
    product over a  cheaper, less efficient  product.   A  second
    reason to doubt  the  efficacy of  higher  electric prices  in
    changing consumer  appliance  buying  habits  is the  lack  of
    information that would  enable  consumers  to  judge the rela-
    tive efficiency  of competing products,  as well  as a wide-
    spread lack  of  understanding  of  the   little  information
    that is  available.   A  third  reason  that would  support a
    regulatory approach is  that the appliances in many new re-
    sidential units are not purchased by the user, but are pur-
    chased by the builder, who will continue to  seek appliances
    with the lowest  initial cost without  regard to increasing
    electric rates.

        In the  face  of these  factors  inhibiting the operation
    of market forces in the  consumer appliance  sector, a regu-
    latory program designed  to impose  life-cycle cost purchas-
    ing on the consumer appears justified..-/

    Some of  these  imperfections  are  institutional,   some  are
informational, and some are  economic.   The  Energy Conservation
Coalition believes that all these imperfections  are part of the
energy market, and  result in  significantly  less investment  in
energy efficiency than economic theory would predict.  A recent
DOE report calculated that the American economy  is $100 billion
behind what  economic  models  predict  should have occurred   in
energy efficiency investment in buildings through 1979.2.'  Pro-
fessor Arthur  Rosenfeld  of Lawrence  Berkeley  Laboratory  has
translated this sluggish  conservation  of 6  to 17 years in gas-
heated houses and 14 to 25 years in electrically heated houses.
(See following pages,  Tables  2 and 3)  Paul  MacAvoy  made the
same point on a broader scale in a recent New York Times article
when he wrote:

    "The demand side  of  the world  oil market is  dominated  by
    conditions that  stubbornly  refuse  to   surrender  to  the
    conservation ethic, or to  the urgings for new energy-effi-
    cient technology.    Increases  in price  reduce demand,  but
                        71

-------
                                     ZL
                        Energy use for space conditioning in an average

                        new U.S. house  (gas heating) (mm Btu/yr)
                                                        03
                                                        0
                                                O
                                                0
                      ta
                      -* I—
                      «3
                      ^j
                      o
             z
Ol
cr
ro
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I  S.

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                                   cz.
cr
oo
          II
          £  2.

          •  3
          2.  3
          2  S
          >  Q
§
u

8
          i
          i
          s
          9
§
3*
•

f
5-

3
   i
   3


   I
                     Energy use for space conditioning in an average

                     new U.S. house  (electric resistance heating)
                     (thousand kWh/yr)
                          ro
                          I
                                    o
                                     I
                                      ro
                                       I
                                             a>
                                             i
                    (0
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                    ~J
                    03
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                    CD

-------
     only with  a  five-to-ten-year  lag,  and  only  by  30  percent
     as  much  as  any  percentage  price  increase..127

     In  addition to  these  market  imperfections,  an adequate  en-
 ergy conservation  policy  must  explicitly  address   two  other
 problems which  bear on  the ability of the  market  to  realize  our
 conservation potential  —  social equity  and  basic  research.

 Equity;   Energy is  a  necessity.   Its use  can be curtailed only
 so  far   before  cutbacks threaten the  health of  consumers  and
 businesses.  Much of  the potential for energy conservation will
 never be captured unless consumers possess  the  means  and knowl-
 edge to  invest  in additional efficiency once outright  waste  has
 been curtailed.   This requires capital and  reliable  information
 which individuals and small  businesses  often lack.   Low-income
 families are particularly incapable of  responding  to  higher
 prices by investing in energy  efficiency.  Their  only  choice
 is  to reduce their standard of  living unless programs  are avail-
 able to  make energy efficiency  investment financially  practical.
 I think  Marty Klepper very adequately addressed  the  issue of  the
 kinds of barriers that  prevent what  appear to  be very economic
 investments  from  actually   occurring   in  the  marketplace.

 Research;  Basic  research in  the  field of energy conservation is
 a particularly  peculiar problem,  especially in buildings.   The
 building industry is highly decentralized and fragmented  and has
 little ability  to support  research  and  development.    It  is un-
 likely that  Federally sponsored research aimed at understanding
 the  flow of  energy  through a building or quantifying  and miti-
 gating problems of  indoor air pollution will ever be undertaken
 by private companies when funds are  cut by  this Administration.
 Yet,  unless we have a thorough understanding of those  problems,
 much  investment  in    energy   conservation  will  be   wasted.

     The  Energy  Conservation  Coalition believes  that  to be ade-
 quate, the energy conservation  program  must recognize that the
 free market  contains  these imperfections  and that decisions to
 eliminate or expand existing programs  should be made, in part,
 according to whether  they increase  or  reduce  these  imperfec-
 tions.

 RECOMMENDATION #3:  ACKNOWLEDGE NATIONAL INTEREST IN ACHIEVING
                    CONSERVATION BEYOND MARKET LEVEL

    Third, the Administration's energy conservation program in-
 adequately accounts for the value to the nation of reducing oil
 imports.

    The  impact  of  embargos,  or  threats  of  embargos,  on  our
national security justifies national energy conservation goals
 that exceed  what is  economically  -justifiable   for  the  indivi-
dual consumer.   This issue was explored  in last year's  Section

                        74

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11 hearings  and  report.  The  concept  is as  valid  today as it
was a year ago.  Implicit in this recommendation is the premise
that despite the  oil import reductions  we  have experienced in
1980-81, 6.0 million barrels of oil per day (over a third of it
from the Middle East)  is a dangerous and undesirable  level of
imports and should not be tolerated.

    The recommendations above are offered as the necessary pre-
requisites of rational  decision-making  in  energy conservation.
To summarize, they include:

    1)  setting meaningful goals and priorities;

    2)  identifying   market   imperfections  and   inequities;

    3)  recognizing the  value  of oil  import  reductions beyond
        what the market can accomplish alone.

    Current energy  conservation policy  has  been made  without
reference to this  fundamental  framework.  The President's bud-
get eliminates, almost without comment:

    —Residential Conservation Service

    —Commercial and Apartment Conservation Service

    —Building Energy Performance Standards (both mandatory and
      voluntary)

    —Residential Energy  Efficiency Program  (demonstration  of
      innovative delivery systems)

    —Appliance Efficiency Standards

    —Small Business program

    —Consumer Products program

    —Analysis and Technical Transfer

    —Emergency Building Temperature Restrictions

    —Industrial Efficiency Program

    —Transportation Systems Utilization

    —Appropriate Technology

    —State and Local Programs, including

      *Schools and  Hospitals  (originally  cut  by  50  percent,
       later in Reconciliation, by 100 percent)

                        75

-------
      *State energy offices

      *Weatherization

      *Emergency planning

      *Energy Extension Service

    —The Solar and Energy Conservation Bank

    The federal energy conservation budget  would  be cut by the
Administration from $999 million to $199 million—80 percent.il/

    Other then to assert  generally  that  tax credits and higher
energy prices will pick up where  these programs are eliminated,
the Administration has  not offered  even the  most rudimentary
cost-benefit analysis of these radical cuts.

    With regard to the  residnetial tax  credit,  the Energy Con-
servation Coalition believes that this is an  important but in-
sufficient stimulus  to  increased energy conservation.   It is
insufficient because as a  practical matter, the  credit is use-
ful to  too  narrow a  segment   of  the  American  public.   Recent
tax data show  that  the wealthiest 25 percent  of  America's in-
dividual taxpayers claimed over 65 percent of the total claimed
in both  1978  and  1979.il/  Eighty  million owners  and tenants
are eligible and yet  only 4.9 million taxpayers  used  the cre-
dit last year.  It is not an attractive program unless the tax-
payer 1) is a  homeowner,  not  a renter;   2) can  afford the en-
tire up-front  capital investment;   3)  can afford  to wait for a
period of months to  claim  the  benefit  of the  credit;  4) is in
an income  bracket  high  enough to  create  tax liability;  and
5) has information on the availability of the credit.

    An adequate energy conservation  progran  must  make energy
efficiency investment a  realistic  opportunity for  all Ameri-
cans.  Programs designed  to  supplement the tax  credit include
the low-income  weatherization program  at  DOE and the  Solar
Energy and  Energy  Conservation  Bank  at  HUD.   These  programs
have been specifically designed to reach  the  majority  of Amer-
icans who have not been  able  to  take  advantage of the tax cre-
dit.  The  weatherization  program  appears  to be  particularly
cost-effective, saving an  average  of  26 percent  of the energy
in each  weatherized  house  at a  cost  far  below  the  cost  of
heating fuel.lJLL  I believe Mark Cooper earlier today addressed
the findings of his  study from which my  data was taken.  Yet,
the Administration has  proposed  eliminating  funding  for  both
programs.

    Internal DOE documents provide evidence  that many other pro-
grams slated for elimination may be cost-effective.  In a March
3, 1981 DOE memorandum assessing the cost-effectiveness of pro-

                        76

-------
grams within the jurisdiction of Buildings and Community Systems
at DOE,  it was estimated  that  the  cost per  barrel  of  energy
saved from 1980-2000 was as follows:

    Voluntary BEPS                $  5
    Buildings Conservation (RCS)  $17
    Appliance Standards           $  3
    Consumer Products             $  4
    Analysis & Tech Transfer      $  3
    Community Systems             $16
    Small  Business                $  6

    If these programs were maintained,  cumulative energy savings
would reach 53  quads  by the year  2000,  at an average cost of
less than  $10  per  barrel.   (See on the  following page, the DOE
memorandum dated March 3, 1981,  "Effects of Rescission and Bud-
get Cuts on the BCS Portfolio.")

    Similarly, careful analysis of  DOE's  industrial  conserva-
tion program shows that eliminating  that  program would eliminate
an estimated annual savings of  9 quads.   (See Tables 4, 5 and 6)

    There  is no evidence  that  decision-makers at  DOE  have made
any attempt to  refute these  documents,  or  to incorporate them
into their decisions.

    These  documents are exactly the kind of  analysis  that the
Energy Conservation Coalition  would expect  to be  undertaken in
a rational decision process.   But they apparently are not being
used.   Nowhere has this Administration explained  why  achieving
these savings  at  such  bargain  prices  is undesirable for the
nation.

    Finally, the Administration has made no  attempt  to  target
its energy budget cuts on those programs which the market could
conceivably absorb.   For  example,  one of  the healthiest,  most
prosperous sectors of today's economy is  the oil and gas sector.
In an era  of fiscal austerity,  subsidies and incentives to that
industry could be eliminated with the least  adverse  impact  on
national goals.  Yet  the  Administration  has left  virtually un-
touched an  estimated  $5  billion in oil  and  gas tax  subsidies
which alone account for half  the $10  billion  in energy  supply
expenditures in the  federal  budget.   (See  Table  7).   In  con-
trast,  the  Administration  is  cutting  energy  conservation pro-
grams  which were designed  specifically to address the problems
that the market does not adequately address.
                        77

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              UNITED STATES DEPARTMENT OF ENERGY



DATE:     March 3, 1981

SUBJECT:  Effects  of Rescission  and  Budget  Cuts  on the  BCS Portfolio

Energy savings estimates and the cost  of  saving  one harrel of oil equiv-
alent have been estimated for BCS program elements.  These estimates have
been made under the assumption of 100% funding, 50% reduction in funding,
and 100%  reduction  of  funding.  These estimates were derived  using the
ORNL and  Threshold  Models  and  divisional  inputs  on  project  priorities
under budget reduction scenarios.

Compared with the ORNL's  models  used last year,  the models have been im-
proved by  1) modifying  the  manner  in which the  efficiency  of  new build-
ings is  calculated,  2)  the  appliances are retired,  and 3)  by updating
most cost efficiency  curves.   The  model  still assumes,  however,  that if
a level of efficient products/structures are demanded, industry will sup-
ply what  is demanded.   Last year,  no models were  used directly to esti-
mate the  energy demand  reduction resulting from Community  Systems acti-
vities.  This year the  potential for  savings was  identified  through the
BNL Reference Energy  Systems  model and the Systems  Analysis  Branch case
analysis.  BNL District Heating  model inputs  and  Community  Systems per-
sonnel inputs were also used this year to estimate energy savings for the
division.  Of course,  a new and higher  set of  energy price  projections
were used in all model runs.

The results show  significant differences  between the 1980 and 1981 esti-
mates of  energy   savings  and associated   costs  per  barrel  of  savings.
Cumulative energy  savings  are  lower  for  three programs, while  they are
augmented in the  remaining  four.   In  general,  the  cost  per barrel  of
energy savings is  substantially  lower than indicated  by last  year's es-
timates.

The reduction In  the dollars per barrel  reflects the improvements in the
models.  These improvements, coupled with  the higher energy price streams,
have resulted in lower energy demand in the base case.  This has made the
change in energy demand smaller  and  at the same  time has made the change
in private investment proportionately smaller.

The table below shows last year's estimates in savings and $/BBL compared
with the  full funding case of this year.
                                  78

-------
United States Department of Energy
March 3, 1981 Memorandum (continued)
1980
ESTIMATES
PROGRAM ELEMENTS
Quads
$/BBL
1981
ESTIMATES
Quads
$/BBL
    Building Systems               41.6      7.40            14.8        3.75

    Buildings Conservation          7.8     24.25            10.2       17.20
      Services

    Appliance Standards            16.2      9.62            10.9        2.67

    Technology and Consumer         7.4      1.88             4.3        3.78
      Products

    Analysis and Technology        12.6      6.09            15.0        3.06
      Transfer

    Community Systems               6.3      7.48            10.0       15.93

    Small Business                  1.4     10.38             5.5        5.50
    Attached are  Tables  4,  5 and 6  showing  levels  of funding and the energy
    saving estimates  (based on  normalized  Threshold Runs)  for the projects
    deleted for  a 50% reduction.   Note also  that  some  energy  savings  will
    occur due to  past and current BCS activities even if  BCS  is  "zeroed" out.

          SPECIFIC  IMPACTS OF FY 1981  RESCISSION AND ZERO BUDGET IN FY 1982
                         Industrial Energy Conservation

    The Reagan budget  of $43  million in FY  1981 and  $0 in FY 1982 prompted a
    recent detailed analysis and replanning  of  the Industrial Program in both
    years.  The analysis was based strictly  on  the assumption that $43.0 mil-
    lion is the  only  future funding for the program  with FY 1982 and subse-
    quent years without  additional authority.

    As required by prudency, some efforts previously  planned  for FY  1981 were
    not begun in  order to  fund  efforts  through completion.   Costs were esti-
    mated for  close  out  of  projects also.   These  costs  would  be within  the
    $43.0 million of FY  1981 funding.

    The specific  project impacts have been  listed  in two categories:  those
    which will be closed out after  significant  investment but  prior to com-
    pletion of all  objectives,  and  those identified opportunities which will
    not be started.  The following tables summarize the projects in  these  two
    categories.
                                      79

-------
            03/02/11
                          ENEIUf 3AVING3  rHOJECTlONJ FOI UUII DlttOS AND COHHUMITI  8T3TEHS

                          •I riOCtAH ILEMENTl B131C BUDGET
COST
(blllloni of 1910 I
TOT
no r«ii iirtu
Diilldlnf ay«t«i( 0.2}) 9.3) 9.56
(IDErs)
Dulldlni &r>t>«l .2)) 7.5 |.l
U« .09] 21.2 27. «
&»11 Gualn<» .OU9 5.11 5.19
iom BCS o.9» at. 92 n.r>t
196)
Q Mill HHBOC
O.II «.I2 »5.«
.09 2.57 >S.i
O.JJ J.J« (0.2
0.0] 1.0 5.2
0.12 5.«5 20.6
0.12 ».» 20.6
0.0 0.0 0.0
0.21 2.6 M.2
0.67 20.16 1*9-7
1990
Q HH« HMOOC
0.31 T.«2 6]. 6
0.2] 2.57 39.6
0.$ l«.) (6.0
0.) 6.) Jl. 6
0.12 5.65 20.6
0.) 10.2 91.6
.13 IDS 56.76
0.26 2.6 *(.2
l.tt «5.59 ))6.«6
1S95
i
Q MHB HHBOt
0.»5 IO.M 77. «
0.27 ].a« 16. «
0.5 l».5 16.0
o.<] a.« 7«.o
O.I 5.61 17.2
O.M H.6 75.7
.31 11.35 56.7
0.21 2.6 11.2
2.0« SO. 21 350.96
2000
q HUB HHBOC
O.S7 ll.l* 91.04
0.35 «.07 60.2
O.S !«.$ 16.0
0.47 1.9« 10. 1
O.I S.ll IT. 2
0.56 19.1 96.1
.33 11.35 S6.7
0.21 2.6 «1.2
2.20 52.1* 371.3%
CUMULATIVE TOTAL
1910 - 2000 t/i
TOT ACTUAL OIL
QUADS OIL CQUIV
*
M.I 110.6 2515.6 J.75
9.0 17.0 15H.O S.OO
10.2 364.] 1751.4 IT. 2
10.9 1*1.9 117«.l 2.67
4.J ITJ.T 739.6 J.7B
t!>.0 421.4 2510.0 ].06
1 10.00 25S.O 1720.0 15.9)
5.5 104.4 946.0 5.5
S3.S 1133.0 9210.6 9.54
00
o
                                                                               Table  4

-------
                           PROJECTS CLOSED CUT PRIOR TO COMPLETION


WASTE EK23GY REDUCTION
Reradiant Recuperator
Air Fuel Ratio Controller
Oxygen Eariciraent
Large Passage Ceraaic Recuperator
Water-Ta-Warer Heat Puap
2iCOP Heat Puap
Waste Oil Utilization
Waste Fired Brielc **"!.•»
Liquid Fuel Pros Waste Rasearcn
Enrrgy ?roa Waste Water
(5000)
INVESTMENT
TO DATE
5 2,322
766
845
835
AOO
3,325
3,500
797
671
461

COST TO
COMPLETE
S 700
300
100
1,400
3,000
340
1,000
1,000
500
1,500
 SUBTOTAL - WASTE ENERC7  REDUCTION
513,932
5 9,840
   ESTDiATED
    ANOTAL
SAVINGS (QUASS),

      .15
      .12
      .20
      .12
      .10
      .30
      .16
      .50
      .50
      .07

     2.22
        INDUSTRIAL PROCESS  ETTICTZNCT
Coal In Aluainua Reaelt
Glass Pellet Preheat
Direct Reduction Of Aluoima
Inert Anode
AlumintSE Cathode >
Hot Inspection/ Steel
Freeze Concentration
7oaa Processing
Chemical Separation - Critical Tluid
Sensor Development
Energy Recovery - Dryers
Cutting Tool Coatings
5 3,740
600
4,155
S20
2,400
2,563
876
658
981
675
270
31
5 3,000
2,750
7,500
4,000
1,500
1,072
5,000
860
3,000
1,025
736
83
.03
.06
.70
.20
.20
.30
.05
.05
.40
.15
.06
.01
SUBTOTAL - INDUSTRIAL PROCESS E7TTCIENCT
517,574
$30,526
                                                                                 2.21
               COGENERATTON
Single Stage ORC
Coal Fired Brayton Cycle
Sceaa Diesel
Sobanaospheric Bray tuu

SUBTOTAL - CCGEERATIOS
TOTAL - PROJECTS STOPPED 3E?ORE COHHJTIOH
              5   300
                8,000
               30,000
                2,000
                   .25
                   .60
                                 .85


                                5.28
                                  Table  5
                                           81

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                      PROJECTS WHICH WILL KOT BE STARTED
                      ~~~ESTIMATED
                                                                  POTENTIAL
                                                                   ANNUAL
	WASTE ENERC7 REDUCTION	           SAVINGS (QUADS)

Tluidic Teaperamre Sensor                                           -03
District Heating Recuperator                                         -20
Biphase Concentrator                                                 -06
Slagging Burner                                                      -20
Cheaical Heat Puap                                                   -10
Wood "ired Luaber Dryer                                              -03
Mobile Tire Pyrolysis                                                -04
Coaainution And Blasting                                             .02
Liquid Fuel Troa Waste Pilot                                         -07
Tluidized Bed Waste Heat Boiler (1 Project)                          .20
High Teaperature Burner Duct Recuperator (1 Project)                 -30,-
  SUBTOTAL - WASTE ENERGT REDUCTION                                 1•23

            INDUSTRIAL PROCESS ETTICIENC?	
Cement Particle Size Control                                         -10
Coke Pellet Process                                                  —
Toracoke Process                                                     —
Advanced Copper Sneltiug                                             -01
Hydropyrolvsis - Cheaical Burning                                    -20
Efficient Motor 3evelopment                                          -20
Computer Controls - Hanuf acmring                                    -1-5
Advanced Catalytic Reactor                                           ••50
Methane Transport                                                    -50
Dessicant Lunber I>rying                                              -01
Bav Pulp Process         .                                            -os
Energy Integrated ?ar=s  (3 Projects)                                 -01
Citrus Process Development                                           -0^
Mechanical Vapor Recompression                                       -O6
Energy Conservation Meat Aad Dairy                                   -03
Crop Drying Systea Deaonscration                                     -03
Vegetable Oil Continuous Process                                     -°3
   SUBTOTAL - INDUSTRIAL PRCCZSS ETICTiNCT                          1-95

^ _ COGINZRATIOK __ ,

Brayton Topping Systea  (2 Projects)                                  -25
Large Bottoeing Cycle                                                -01
Theraionic Topping                                                   '°°
   SUBTOTAL - COGiNiRAIIOH                                            -35
                           AND DSPT-OTMS
 ZADC  (10 Universities).                                                -0*
 Industrial Workshops                                                   -OI
 Technology lapleaeatation Prograas                                     ~
   SUBTOTAL - Ei?L2SNTAIION  AND DEPLJEEST                             -02


 TOTAL - PROJECTS  WHICH WILL  SCT BE  STARTED                            3.57
                       Table 6

                                      G2

-------
                 COMPARATIVE TABLE OF

        TAX EXPENDITURES AND BUDGET OUTLAYS

                        IN THE

                FEDERAL ENERGY BUDGET
baavom
Energy.
Consavatoon:
Ta trowditure (outlay equivalent) 	 	 	
Outlays 	 	
Total
Ta expenditures as a percsit of total —
Suopty;
Ta CTpoKfetuTts (wifiay equivalent) ,.._.,..._._..
ftrttoyj
Tits'
Ta expenditures as a permit of total 	
Totafc
Ta tipHKfiturs (outtjy Kjuivalwt) ,._.»_,,,. .
rvrtia^
To*?'
Ta expenditure as a percsit of total —
fesMlf*
13«
	 1
720
570
U90
55.9
7,715
*,575
r 12^90
613
3,435
5,140
13,575
62.1
1JJ1 | 190
325
750
1,575
513
9.520
5.725
15.245
52.4
10.345
6,480
16,825
51.5
895
1.065
1,950
45.7
10,375
5.235
17,110
53.6
11.770
7,300
19.070
51.7
   mHa or ce. a tSxxOB On tot «ne!
  t Due «a» « «M » BOB 
-------
The severe market distortions condoned by our government reflect a deeply-
rooted system of subsidies and  tax  advantages that contine to work against
energy conservation.

Similarly, the  Administration's  budget  favors  nuclear power,  an energy
source which has  only a marginal  impact  on our basic  problem — liquid
fuels.  The  Administration  has proposed  increasing the  nuclear fission
budget by  $337  million in  FY  82  —  40  percent higher than  the Carter
budget.  Clearly,  as  long  as   the Administration  continues  to protect
supply options  from  the  marketplace,  it  cannot  cut  the   conservation
budget on  the  grounds  that  the  marketplace  should  control  demand.
                                FOOTNOTES

\J.  See, e.g., Solar Energy Research Institute, A New Prosperity: Building
~~   A Sustainable Future, (Andover Mass.:  Brick  House Publishing,  1981);
    John H.  Gibbons and William  V.   Chandler,  Energy—The Conservation
    Revolution  (New York: Plenum Press, 1981);  Marc H.  Ross  and  Robert
    H. Williams, Our Energy:  Regaining  Control  (New York:  McGraw-Hill,
    1981);  Henry  Kendall  and  Steven  Nadis,  Eds.,  Energy Strategies:
    Toward a Solar Future, (Cambridge,  Mass.:  Ballinger:  1980);  Hans  H.
    Landsberg, Chairman,  et  al. , Energy:  The Next Twenty Years,   Report
    by a  study group  sponsored  by the  Ford  Foundation and administered
    by Resources  for the Future  (Cambridge, Mass.:  Ballinger Publishing
    Company, 1979);    National  Research Council,  Energy in Transition:
    1985-2010, Final Report  of the  Committee  on  Nuclear  and Alternative
    Energy Systems,  National Academy  of Sciences (San  Francisco:  W.  H.
    Freeman and  Co.,  1979);   Robert  Stobaugh and Daniel Yergin, Eds.,
    Energy Future,  Report  of the Energy Project  at  the Harvard  Business
    School (New York:  Random House,  1979);  Roger Sant  et al., The Least
    Cost Energy Strategy, The  Energy Productivity Center, Mellon  Insti-
    tute(Pittsburgh:Carnegie-Mellon  University  Press, 1979);  Domes-
    tic Policy  Review  Panel, The Domestic  Policy Review of Solar Energy,
    A Response  Memorandum to  the President of  the  United States  (U.S.
    Department of  Energy, February 1979) TID-22834.

2/  The Geopolitics  of Oil,  United  States  Senate,   Committee  on  Energy
~~  and Natural Resources,  Publication No. 96-119, December 1980,  p.  71.

3/  U.S.   Congress,  Office  of  Technology  Assessment,  Conservation and
~  Solar  Energy  Programs of the  Department of Energy,"1980.

4/  United States  General Accounting Office, Views on Energy Conservation
~  and the  Federal Government's  Role." EMD-81-82,  June  17,  1982,  p.l.
    See   also,  The Federal   Government Should  Establish  and  Meet  Energy
    Conservation  Goals, EMD  78-32,  June  30,  1978.

 5/   See,  e.g., Executive  Communication from  the  Acting  General  Counsel
~~  of  DOE to the President  of Senate,  as  reprinted  in  Senate  Report No.
    97081, p.  19.
                                  84

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 6/  Letter from Dr.  Robert Williams  to  Senator Mark Hatfield,  June 19,
 ~   1981, pp. 5-7.

 TJ  "Congressional Study of Tax  Credit Highlights:  Barriers to Conserva-
     tion Investment"  in Energy  Conservation  Bulletin,   Vol.   1,  No.  1,
     June/July 1981, p. 5.

 8/  "Additional views of Representative  Dave  Stockman",  Report of the Ad
 ~~   Hoc Committee on  Energy on H.R. 8444, House Report  No.  95-543,  Vol.
     II, p. 604.

 9_/  Reducing Oil Vulnerability,   U.S.  Department  of Energy,  November 10,
     1980, p. 23.

10/  New York Times, Sunday, 11/23/80, "To  OPEC,   With  Many Thanks",  by
     Paul W. MacAvoy.

ll/  This includes HUD's  Solar and Energy  Conservation  Bank  with DOE  con-
     servation budget,  but excludes Energy Impact Assistance which appears
     in DOE's energy conservation budget  but  which is not an energy  con-
     servation program.

12/  See  Congressional Research  Service,  Residential Energy Tax Credits,
     by Salvatore Lazzari, March 12, 1981.

13/  See, e.g., A Comprehensive Analysis  of the Costs and Benefits of  Low-
     Income Weatherization and its   Potential  Relationship to Low-Income
     Energy Assistance, prepared by the Consumer Energy Council of America
     Research Foundation, June 2,  1981.
                                   85

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DR. RIEGEL:     All right.  Thank you very much.   Lewis  Perelman, from the
            Jet Propulsion Laboratory will  speak  now and then we'll  go  to
            questions.

DR. PERELMAN:   Thank you.  Let me begin with a disclaimer that my comments
            here today are  purely personal  and do  not  represent official
            views of either the  Jet  Propulsion Laboratory,  Cal Tech,  NASA,
            DOE or anybody else that I'm aware of.

                Last year, in  its  Section 11 review,  the EPA paid particu-
            lar attention to the problem  of  the evaluation  of  conservation
            and solar  energy  programs  carried out  by  the Department  of
            Energy.  I  was  one  of  the  people  who  participated in  that
            review; I  thought  it  would  be  useful  to  follow up on  that
            investigation and report some of the  things that have happened
            in the year since and what's going on  now.

                By way of background, I should mention that EPA's interest
            in evaluation of these programs  was consistent with the concern
            expressed by  other  Federal  agencies  such  as  the  Office  of
            Technology Assessment, the General Accounting Office and Office
            of Management and  Budget,  that a  number  of  programs in  the
            Department of Energy, including conservation and solar programs,
            had not been  producing information sufficient  to evaluate  or
            judge the  performance  and  productivity  of  those  programs.

                Also, of  course,  part  of  the law  which  established  the
            Department of Energy included a  title,  Title X,  the so-called
            "sunset" provision  which required  a  comprehensive   review  of
            all Department of  Energy  programs to  be  performed,  leading  to
            a report from the President to the Congress  on  January 15th  of
            1982.  Therefore,   this  year  the  process  of  developing  that
            report has been implemented.

                My own involvement in this area was  initiated approximately
            three and  a  half  years  ago  when  I  was  on  the  staff of  the
            Solar Energy  Research  Institute, where I had responsibilities
            in the  Program  Evaluation  Branch  for  developing  methods  to
            evaluate solar  energy  programs  for  the  Federal  Government.

                Later, I  went  to the Jet Propulsion  Laboratory  where I've
            been working on several  solar energy  and  conservation programs
            for the Department of  Energy.  Last year  I  was asked to parti-
            cipate in the EPA  review as an  expert of  sorts on evaluation.
            Partly as a  result  of  that  review, Mike  Power's office  at  DOE
            initiated some efforts  to  plan  more systematic evaluations  of
            these programs.    I  was  asked as  a  representative  of JPL  to
            work for the Office  of  what was then  called Solar Applications
            for Buildings, within  the  Conservataion and  Solar Division  of
            DOE, to help them  in cooperation with Mike's office to develop
            specific plans for an evaluation process.


                                     86

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    I've been  working  in  DOE  headquarters  since  January  of
this year on  this  problem.   Along the line in the last several
months, our  efforts  in  planning  overall  evaluation  rather
quickly turned  to  the  immediate  problem of develolping  a re-
sponse for  the  sunset provision  of  the DOE Act,  and this has
occupied most  of  our  attention  for  the last  several months.

    I want  to  talk today —  evidently rather briefly — both
about what  has  been  going  on in  the  development  of the sunset
response, and more generally about what we've been doing on pro-
gram evaluation, based  on  my personal view of those processes.

    The sunset  provisions  were   added as  Title  X of the DOE
Organization Act almost as  an afterthought.  A  bill  to estab-
lish a Federal  government-wide  sunset review process  was pend-
ing in  the  Congress  at the  same  time that  the  DOE  Act  was
passed.  The provisions of that sunset bill — which was called
S-2 in the  95th Congress — were  taken essentially intact and
added to the DOE Act.

    The key to  the  sunset  concept,  as it was  developed ini-
tially in the  State  of  Colorado  (where I  worked  in  the  state
governments) and later  in other state governments, was to make
major government departments,  regulatory agencies,  etc.,  sub-
ject to  a  periodic  legislative  review,  to  see  whether  they
needed to continue to  exist.   The  concept of doing  a sunset
review was  that  it should  lead to a  "go or no-go" decision by
the legislature: whether to  reauthorize  the existence of the
agency, or  to abolish it, or  to change its mission or level of
funding in  some dramatic  way.   That  decisive  provision  was
included originally   in Title  X  of  the DOE  Act,  but  in the
conference committee it was removed.  The procedures for carry-
ing out  the  sunset  assessment  work  were  retained,   but  the
ultimate decision  — the  go  no-go   decision  — was  removed.
So there's  no  contingency  that  anything  has to  happen  as  a
result of this sunset study being performed.

    That's where this sunset task came from.  It's significant,
perhaps, that the  Senate ultimately  decided not  to pass S-2 —
perhaps to  some extent  because expert  witnesses  who  testified
indicated that  the procedures called  for  could  not  really be
implemented in  an  effective  way.   Nevertheless,  the Department
of Energy has  this requirement  to meet and  we've  been working
on satisfying it.

    There are numerous problems  in doing  this.  Overall, there's
a confused mandate from the  Congress about exactly what  it is
they want us  to do.   As  I've mentioned, there is  no specific
decision or outcome  which is  contingent upon the  performance
of this sunset report.
                       87

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    The ordering  of the  questions  in  the  law itself  is  very
confusing and arbitrary.  Specific questions are very ambiguous
and difficult to interpret.  There's no request for environmen-
tal impact assessment  though  we assume that  that  was intended
and we're doing  it  anyway.   One of the questions  asks  for the
impact for increases,  decreases,  or termination of  funding of
major programs,  and  yet,  with  the  reorientation  of  budget
priorities of  the  new  Administration,  it's  been  virtually
impossible to answer that question  in any  concrete way without
further guidance from  the Congress  about what they really want
to know.

    And several  questions ask for assessment  of  the economic,
health and other kinds of program impacts, but it's  not clear
whether they  want  to  know  impacts that  have happened  in the
past or impacts  that  would  happen in  the  future  if  programs
were continued under different scenarios.

    So it's very difficult to answer these  questions  even with
information which already exists.

    Also,  I  should  note  that  there's  no  requirement   in the
law for public  participation  in this  sunset review  process.
It seems kind of  strange  that the Congress should  not  want to
know how  the  Department  of  Energy,  which has  spent tens  of
billions of dollars, has affected the public.

    The implied  intent of Title  X  was  to  evaluate the  overall
performance of  the  Department  of  Energy  over the last  four
years, yet the law never required any actual evaluation process
to be  implemented  during  that  time  which would have  produced
the information to be  reported  in this  review.  It's  virtually
impossible at this stage to go  back and retrospectively create
that evaluation.

    Also,  as   I've  indicated  but will  emphasize   again,  there
is no  real  demand  for the  results of this  study.   The  key
decisions  about  the  future   direction  of  the  Department  of
Energy are now  being made,  to  some  extent  by OMB  through its
budget planning processes, and  to some extent by  the  Congress
itself through its  response  to  the President's budget  request
and its own deliberations  on the budget.    Significant  changes
in the direction,  character,  levels  of effort, and  so  forth
of the Department  of  Energy  are  now   being  made  without any
information provided by the  so-called sunset review.

    It seems   avident  that  by  the  time the  sunset  report  is
available, many  of  the critical energy program decisions  will
have become history.   Also,  the  President  — or  at  least the
Administration through  the  Department  of   Energy's  office  in
charge of  this  study  —  has  made it  clear  that the  sunset
report will  not  be  used  as  an input to the  President's deci-

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sions on  either the abolition  of  the Department  or  any reor-
ganization that he  may  choose  to  implement.   So again, there's
no contingency  to which this study is important.

    The prospects  for  where  this  sunset  review  is  likely to
lead don't  seem to be terribly exciting.   I think the Admini-
stration has been honest in attempting to meet the requirements
of the law.   The  staff that I've  worked within the Department
of Energy have  been making,  I think,  a quite earnest effort to
try to provide accurate and informative answers  to  the questions
that have been  posed,  given the great confusion about what we
really are supposed  to do.

    But the  Administration  does  not  seem  to  look   at   this
sunset review as  an urgent input to any  of  its own decisions;
rather, it  is  simply  trying  to  carry   out  a  legal   mandate.

    Congress, on  the other hand,  also  does  not  seem  to have
any great  requirements  that  they're  expecting  to  be  met by
this assessment.  As I  said before, it's not likely that there's
going to  be much  real  evaluation of DOE's  performance as  a
result of this  study,   because in the  past  there  hasn't been
much evaluation performed  that  would  provide that information.
So most  of  the  information in  this  report  is likely  to  be,
more or less, off-the-shelf  information  that has been  reported
through hearings, program  plans,  and  other documents,   and that
has been seen before.

    To a  large  extent,  therefore, the  sunset  document  will,
if anything,  rationalize  decisions   which  have  already  been
made, and  simply describe what  those decisions were,  without
providing the  sense of  real  alternatives  that  the   Congress
presumably was  looking for.

    On the  plus side,   I  think  there  has  been  some conscious-
ness-raising as a  result  of  this process.   I  think  many  DOE
program managers have become aware of the paucity of evaluation
that has  existed  over  the last several  years, and have been
confronted with their  own inabil-ity at  this  point to  document
what they have  really  accomplished,  or  what the  problems  of
their programs have  been,  in any thorough way.

    Yet, on the other hand, the very  vacuousness of the sunset
exercise, and the  confusing aspects  of  it,   to  a  large extent
have reduced morale and undermined enthusiasm for doing evalua-
tion in the future.

    Overall, I  would say  this  constitutes a lost opportunity
both for the  executive  branch and  for the  Congress.   A large
number of person-years  of effort  and  a large  amount  of money
are being  invested  in  producing  this   sunset  document.   It
could be  used  to  inform  the  decisions  that the  Congress  is

                        89

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making, it could be used to help the President in his delibera-
tions about  what  the future  of  the Department should  be,  and
yet it isn't being applied in that manner.

    In regard  to  program  evaluation in  general,   our  efforts
on evaluation  planning  have  been  curtailed by   the  intense
effort that's had to go into  the sunset  review.   Starting with
last year's  EPA review, the  most  significant progress  in the
four years  that I've been involved in  the DOE  solar  program
has been made,  under  the  direction  of Mike Power's office, to
begin planning actual evaluation of DOE programs.

    In my  testimony  that  I  submitted to  EPA in  writing last
year, I listed a number  of  barriers to making evaluation happen.
I'll simply  say that all  those barriers  still exist.   Some of
them have  been intensified  by the  change  in  Administration.
Among the current barriers to any future development of evalua-
tion of energy  programs is  the  fact  that the budget  process
has taken  on a very  different  character  from  the way  it  has
been practiced  in the  past.  This  has   made  the   real  appli-
cation of  evaluation  information   even  less  likely  to  occur
than in the past,  when it was virtually unknown.

    Second,  as I've  said the Title X process to  some  extent
has discouraged program managers  from  thinking   that  anybody
really wants  to see  evaluative  information.   And  third,  the
ultimate and most  important   observation  is that  the  Congress
itself is not  showing  a genuine commitment to having  programs
evaluated in an objective way,  and to using  that information
in its own decision making.

    Also,  for  evaluation  to  take place,  the  same  requirements
that I  indicated  last  year  still  exist,  and they are  three.
One is that  somebody at a  high level,  meaning on the executive
side or the Congressional side or both, has to make an explicit
commitment that evaluation not  only will  be done  but  will be
used by decision  makers  in   making  decisions.   Second,  there
has to  be  organizational  responsibility  assigned  to  somebody
to carry out  evaluation on a full-time  continuing basis.  And
third, the  resources  necessary  to  do  evaluation  thoroughly
have to be provided.  None of those  requirements  yet have been
or now are being satisfied.

    Some recommendations  I would  make  are,  first of all  and
perhaps.primarily, that the  Congress needs to take the  lead in
this situation. Evaluation can be  a valuable tool.  It  can be
a valuable part  of  creating a  more coherent, effective,  and
efficient national energy  program,  if the  Congress will actually
use the information that is  produced.  So far the  Congress has
not shown a real interest in doing that.
                       90

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     Second,  the   Title X  sunset  review process  is  not  irre-
trievably  lost at  this point.  I  think  it  still could be  sal-
vaged as  a useful  activity if certain  things  were done.   One
of these  is that it  would probably be  necessary to defer  the
reporting  date of January  15,  1982 to  some  later time.  There's
not  enough time  now  to  do  the  kind  of  thorough or trenchant
job  that would  contribute interesting information  to decisions
that the  Congress  and the  President  want  to   make  about  the
Department of Energy.

     The Congress  is going to  have to  clarify its guidance,  to
indicate exactly how  this  review  is to  be  carried  out.    What
do the questions  really  mean?  What does  the Congress want  to
know? There's too much ambiguity and  uncertainty  in the exist-
ing  guidance, and that really can't be  resolved on the executive
side because  we  don't know what  the  Congress'  wants  to  hear.

     Also,  if there's going to  be more  than  simply off-the-shelf
information provided,  there's  going  to  have   to be  funding
allocated  to perform  some  fairly thorough analysis and evalua-
tion of  both future  options  and  past  performance.   Some  re-
sources beyond what have  already  been  allocated will  have  to
be invested to carry out those studies.

    And finally,  it will  have to be  demonstrated  that  some-
thing is contingent on the  performance  of  the  sunset  review,
that some  decision  will rest on the outcome  of  the information
which is provided,  if  the review  is not going  to be  simply a
hollow paper exercise.

     I want  to  add  a  conclusion   to  respond  to  the  overall
function of  the  EPA hearing.  The  more  decentralized  approach
to energy  programs  which  the  hearing  document  describes   and
which the  current  Administration  foresees  not  only  in   the
conservation area   but  perhaps  also  in renewable  and  other
energy programs,  is demonstrated,  for  example,  in the  call  for
a block-grant approach to  funding.  I personally think that  in
many ways  this  is  a  promising  alternative  and  a potentially
useful way  to  proceed.   But  evaluation would  be the key  to
making that  strategy   a  successful  one.  If one is  going  to
have a large  number of state  and  local programs carrying  out
what in  the past has  been  more  highly centralized and  more
focused at  the  Federal   level,  it's  critical  to have  good,
reliable evaluation  of  those  activities,   for  two  reasons.

    One is  that,  if   there's   Federal  funding   involved,   the
Federal government  has a  right to know  what  is  being  done  and
what's being accomplished with the money that it  is dispensing.
Evaluation will  be  necessary  to   produce   that  information.

    Second, and  perhaps  even  more  important,  a  large  number
of diversified  state   and  local   programs  —  50, 100,  1000,

                       o -i
                       ? I

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            whatever — are in effect 50 or 100 or 1000 program experiments
            on how to achieve certain kinds  of national energy objectives.
            The value  of  that diversity is best  captured  by measuring and
            documenting the  experience  of  those  programs,  so  that  state
            and local  agencies can  learn  from each other's experience, and
            so that  the  Federal  government  can  understand  how different
            program strategies actually can  be  used  to achieve  the most
            cost-effective results.

                Evaluation is  the  key  to  making  that kind  of  stragegy
            successful, and  for   the  reasons  I've  indicated  earlier,  we
            are not now making any substantial progress toward establishing
            a real energy program evaluation capacity.

DR. RIEGEL:     Thank you.  Questions and discussion?

MR. POWER:      Maybe I  could ask  David to elaborate  a little bit on the
            image that you  have   of  a  national  conservation  plan.   Could
            you elaborate  on  what  that would  look  like  if you had  one,
            what elements would  it  contain and to what  level  of depth and
            specificity it would  go?

MR. MOULTON:    Well,  the criticism  that I have  voiced in  the testimony
            is based not  so much  on  any  particular  plan  that we  have  in
            mind but  on   our  concern  that  some   effort  be undertaken  to
            decide where  we want  to go.

                Many of the decisions that are  currently being made appear
            to have no relationship to  the  overall effort  that in the past
            has been  a  national  commitment   to   energy  conservation.   I
            don't think the Administration's position is  that energy conser-
            vation is no  longer important.   Secretary Edwards has frequently
            said that he  thinks  it is important.

                Rut we're trying  to get some  kind of a handle on what that
            means in terms of where the  Department thinks our nation should
            be heading,  whether   there's   some relationship  between  that
            concern and our energy imports, whether there is some relation-
            ship between  that concern and the overall  effort  to  hold down
            energy inflation.  The purpose  of goal  setting  is not  to  set
            up some  sort  of national energy  plan but  simply  to  have  some
            idea of where we're  going so  that as  time goes  by and  evalua-
            tions take place, we have   some  sense of  whether  we're making
            progress.  If we don't know where we  want to go, we don't know
            whether we're  getting any  closer  from day  to  day.   I  know
            there is evaluation  going on  at  the Department  of  Energy.   But
            in public  statements  there  is   no  relationship  between  the
            results of those  evaluations  and  what actually is  decided  in
            national policy.  The  National   Energy  Plan,   NEP  3  that  is
            about to  be   released  by  the  Administration   is  an  example.
            What I've seen of it  so far  in draft form appears to be written
            in a closed  room somewhere without  making any  attempt  to  tie


                                    92

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            in all the  evidence  that is available and  that  could make the
            decision appear more rational.

                As it  is,  it kind  of  floats  free and  everyone questions
            whether it has any  relationship  to any kind  of  goals.   That's
            the problem.  There's just a perception that there is no direc-
            tion.

DR. RIEGEL:     We are overtime, unfortunately, so I think we will conclude
            with our thanks.   We will reconvene again at 1:00 for the after-
            noon session.

            (Whereupon, at 12:13 p.m.,  the  hearing adjourned for  the  noon
            recess).
                                   93

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94

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                                                     PROCEEDINGS
                                                     3ULY 14, 1981
                                                     AFTERNOON SESSION
HEARING PANEL

   Kurt Riegel



   J. Michael Power



   Andrew Glassberg


   John Pfeiffer


WITNESSES

   Robert Pauls

   W. Kim Boas

   Randi Triant

   Betty Kahl

   Paul Danels

   Mart Kask

   Floyd Ciruli

   Betty Desper

   Charles Lawrence

   Joseph Prano

   Howard Brown

   Richard Kline

   Anthony Maggiore

   Peter Robinson

   Keith Dorsey

   Neal Gale
Acting Director, Office of
Environmental Engineering and Technology
Environmental Protection Agency

Director, Policy, Planning and Evaluation
Office of Conservation and Renewable Energy
Department of Energy

Professional Staff
House Energy and Commerce Committee

Budget Examiner
Office of Management and Budget
City of Carbondale, Illinois

Private Citizen

New York State Alliance of Community Action Agencies

Rhode Island Jobs in Energy

New York City Energy Office

Puget Sound Council of Governments

Colorado State Office of Energy Conservation

Total Action Against Poverty

New Jersey Energy Research Institute

Community Improvement Program

Middletown, Connecticut, Energy Advisor

S.C. Appalachian Regional Council of Governments

Milwaukee County Community Action Agency

Maynard Community Development Office

National Black Caucus of State Legislators

Private Citizen
                95

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DR. RIEGEL:     I'd  like to  welcome the  next  three  witnesses here this
            afternoon.  Randi Triant,  from the  New York  Community Action
            Program;  Kim Boas from the City of Dayton in Ohio;  and Robert
            Pauls, the City of Carbondale in Illinois.

                We have  a  very  long  witness  list  this afternoon  and I'd
            like to  ask  the participants to  keep  their remarks  short.   I
            will remind you  again  that  prepared statements  will be looked
            at very  carefully as  a  part of  the record  in  compiling our
            report.  To  the  extent   that  you  can  simply   summarize  the
            prepared statement,  it might expedite the discussion to follow.

                So let's start  with  Robert Pauls from  the  City of Carbon-
            dale.

MR. PAULS:      Hi.   My name is Robert Pauls.  I am the Energy Coordinator
            for the  City of Carbondale, Illinois.  It's nice to  see some
            of you   again,  back again  this  year.   When I  decided  to come
            here, I  debated  several  strategies for a  presentation  to make
            to this  group.   My  initial tendency was  to,  at the  risk  of
            offending my born-again  solar/ conservation  advocate friends,
            toe the  company  line and  preach the heavenly glory of  the in-
            surmountable  opportunities  of   the  Reagan  Administration's
            supply side economics.

                You know what  I mean  by supply  side  economics:  "Strength
            through exhaustion,   burn  America first, no one  ever conserved
            their way to greatness,  and you  can't  waste energy you  can't
            afford."

                Well, I decided I just  couldn't do that.  I couldn't preach
            what I've come  to call punk energy  policy  which rewrites his-
            tory's great one liners  to be  amended now  to  read,  "What's
            that you say, the poor have no  bread,  well, let them eat block
            grants  —   the  low regulation  brand  with  25  percent   fewer
            kilocalories."

                In foregoing  the first  strategy,   I  thought that  maybe I
            could go  to  Washington  D.   C.,  this  time instead  of  cup  in
            hand, begging  for administrative  mercy,  for  fiscal reprieve,
            bare my  solar  soul  and confess  to  others'  past mismanagement,
            fraud and  abuse  of taxpayer  dollars  for hackneyed,  Federal
            energy conservation  programs and  solar  demonstration programs,
            L.I.E.A.P. largesse  in income  transfer payments  to  the  util-
            ities in  the  guise  of welfare  for the  truly  needy,  and the
            near invisible,  like the  so-called  stealth  bomber, emergency
            energy contingency plans.
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    After much  thought  and  procrastination,   I  decided  that
come hellish war  over Mideast  oil or  high  prices at  home,  I
just couldn't  do  that.  I  must in  all conscience  fight  back
what I  consider to  be,  in agreement  with Dennis  Hayes,  "the
open war on  solar  energy"  and conservation by  the Secretary of
Energy - Edwards and the President.  I  cannot  stand by and see
America's best  energy  hopes methodically  destroyed  by fission
and fusion fussbudgets and oil oligarchies.

    The Administration's  attack on  communities,   their social
and economic fabric,  will  be  fought on the homefront,  in the
homes, businesses,  cities  and counties, and the  fourth estate
of this country to counteract this new trend.

    The war  will   be  won  in  municipalities,  such as  ray  own,
Carbondale, where  from one perspective  we seem  to  be playing
right into  the hands  of  the new  Administration  by  doing our
own thing, doing  what  the feds couldn't do, make a transition
to a conservation  and  renewables  based economy — one based on
our design,  our own money,  and our own  vision  of a  safe and
sane future.

    In Carbondale, we are preparing quite  possibly in Ayatollah
style, to sever the  hand  that has quite frankly  fed  us in the
past, that has  given us lots  of money, the hand that has  given
us the so-called Federal free lunch.

    A feasibility report on the creation  of  what  we believe to
be a truly  comprehensive  municipal  solar  utility (or MSU) for
Carbondale has just been completed, some 280 pages of an energy
menu, and  we  are  about to partake of it.   It   is  presently
undergoing a fast  - track  internal review.   (This  report was
reviewed, but not  included  in  the Transcript due to its length).

    Our MSU  model  was  created by  the  Shawnee  Solar Project,
which is a non-for-profit corporation in the City of Carbondale
and with  it,  we are  proposing a  Community  Energy Development
Fund comprising an innovative energy  consumption tax,  of all
things, and direct but not necessarily essential,  contributions
from the  local investor-owned  utility  (IOU).   They  will  be
likely the prime sources in the short run, but we are anticipa-
ting a  complex merging of  other  creative  financing mechanisms
to meet the marketing needs of our community.
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    With this capital  pool,  our  MSU proposes  to  provide  four
intertwined program measures:  1) an  energy audit  and  quality
assurance program, not so new;  2) an expanded energy education
program, something we've  been doing  for  five,  six  years;   3>
an MSU  conservation loan  fund;  and 4) a  renewable energy pro-
duction capacity  characterized  by dispersed solar,  hydro,  and
cogeneration facilities.

    If the federal menu  of possible  energy  funds  makes it out
of the  Reagan  kitchen,   Carbondale  will  cautiously  approach
these new  greenbacks,  this lunch,  knowing  full  well that they
have more of  a  similarity to hors  d 'oeuvres than  a full lunch
— finger  sandwiches,  if  you will,  that tend to  reach  out and
grasp communities  and  specify  their destiny which may  be  in
conflict  with  what  is   really needed  in   that  community.

    The separate  program  measures  we have for  the MSU  are not
all that  unique  in  America.   The  different  elements   are  in
existence in  different  communities  in  different  forms.   We
think ours is going to  be a  little  bit different.   Our  skilled
energy auditors and combination  "loan-a-ranger" will prescribe
like a  house  doctor   and sell  conservation  like  a   new  car
salesman.  Other  staff will  make loans like your Uncle  Fay and
educate you like  Mr. Wizard.   Others will make this all possi-
ble, but mostly our own citizens.

    We propose to do this  all  in a  municipality of some 27,000
people situated  in  the heart of  high sulfur coal country and
what I  term  nuclear madness.  We  shall  force  our own future.

    It has been said that  if  the  only  tool you have  is a hammer,
you perceive  all  of  your problems  as  nails.    Well,  that was
maybe the  occasion  in Carbondale.  We drove  our first  nail on
our city  vehicle  fleet gasoline  allocations back in  '74, and
things have changed considerably since then.  We've  used Feder-
al monies, state  monies,  where  we  can, but we've  done  an awful
lot on  our own too.   Our new tool  chest has  swollen  to where
we are  no longer referred to  as the Davis,  California of the
Midwest.   The  recent   comment,   this  week,   in  fact, was that
we're becoming the  Wall  Street  in conservation and  solar  crea-
tivity.  We now  wield  hammers,  pliers,  wrenches, levers and an
array of  acronyms:   HUD, CDBG,  IBOP,  SECP,  F,ES,  RCS,   INR,
CIPS, ICC,  SIUC,  STC, SERI,  DOE,   EPA,  MASEC,  GERPDC,  NACT,
SRAP SCATGP,  NSHCIC and others too numerous to  mention.   Least
of all we  use DOE and  most of all we  use S.E.L.F..

    The  Carbondale  Energy Division  which has been  in existence
about a  year  and a half  was created without  outside   funds in
mid-fiscal year,  response which is   absolutely  unique for our
town.   We  did it in to   unmitigated  problems  that  either the
Federal  or the  state  government could not handle  or the  market
place wouldn't approach.

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    As I  said,  energy  initiatives began  in  '74.   Since that
time, I  could  characterize  energy in  Carbondale as  one long
evolutionary energy education project interspersed, interrupted
by 300 brief public pauses to catch our breath.

    There have been  that  many workshops in  Carbondale,  300 in
the last  four  years.   Other communities  are now considering
entry into the energy  conservation and  survival  game are going
to have a much harder  time  at it than we have.  They have some
of us to  look  for examples, but they are  also faced with some
rather large problems.

    In Carbondale, we've  got things  sort  of,  you know,  gentle
and nice  already.   We have an  Appropriate Technology Resource
Center run by  that  same not-for-profit  group.  We've done the
whole array  of  projects   that   everybody  talks  about:    from
infrared thermography  to  promoting bicycling,  recycling, gar-
dening, solar  greenhousing,  energy  auditing, alcohol  fuels,
solar this,  solar that,  low  cost/no   cost  conservation, wind
power, cogeneration  and  energy  impact  assessments,  the  works.

    Carbondale has  adopted a  comprehensive  energy  plan,  gone
out and really tried to make right the concept of public parti-
pation and make  sure that what we do  is  truly our mandate and
not something  falsely  touted  by  others,  such  as   occurs  in
this town.

    Many groups  in  Carbondale  and especially the government,
now educate  on energy, cajole, plead,  beg,  borrow, and  as  a
measure of last resort, mandate.   Carbondale  now has an energy
efficiency building  code  in a state without  one.  City govern-
ment enters  the  court to  argue  for utility  reform,  to  assist
other local  units  of government to ask at no  charge to  answer
the myriad of  phone  calls from  cold,  freezing widows and out-
raged students, a whole list of things.

    Carbondale is  really   where  it's at  now  because  of  the
interest by  its  citizens  as  early as  '74,  some  federal money
and unfailing  support  by  its  City  Council  on  every   single
energy measure that  we have  brought  before  it,  and probably
it's been  most assisted  by  the  non-existent or inconsistent
state and Federal energy policy.

    My intent  in  all  this  rambling has not  been to act  as  a
head of  tourism  for  Carbondale and  say,  come  on  out  there,
it's all  great.   I've  just been trying  to say that  we've come
a long  way   because  we've  had  a  long time  to  do  it.   Other
communities are not  in the  same boat.  The demise of conserva-
tion and  solar funds on the Federal scene, I  think,  are disas-
trous.
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                Other  communities  cannot  do what  we  have  done,  even  if
            they wanted  to.   We can't progress  that  much farther if we're
            continuously facing  increasing   escalating  fuel   prices,   and
            accelerated  natural  gas  deregulation.  On  that  subject  alone,
            we're  expecting,  if deregulation is accelerated,  our  current
            $25  million   capital  export  that we  currently  lose  now   for
            energy payments  is  going to,  quadruple, $100  million a  year
            from a town  of  27,000.   Removal  of  the  alleged  regulatory
            burden referred  to  in  the  National  Energy  Plan,  and  this
            possible four fold increase  in gas costs  are  going  to devastate
            our  economy.

                It's going to do  more than  that.   It's going to cloud  a
            myriad of  social  issues,  stifle  freedom, threaten  our internal
            security and make  reality the  essential question  — shall  I
            heat or eat?

                President Reagan's  war  policy  on conservation and solar
            really must  crease.   We  must stop driving  petropigs and  living
            in sieves.  Price  signals  will  work so poorly  and make  much
            greater problems  than  exist  under the threat  of  overregulation.
            Coordinated  efforts  by all levels (and even  we  admitting that,
            yes, we sometimes  need the  Feds,) will  be necessary.

                Without  being  too  over  dramatic  and this may  sound so,  I
            say  given  the choice,  having made the most of my energy  career
            and  the resources we have available  to us,  I choose as my  last
            lament, which I hope fervently the President shares,  to  not be
            that from  Anthony and Cleopatra, where   Anthony  utters  upon
            assessing  his own  bloody incompetence,  "Not dead?" We don't
            need that  alternative.

                The energy future  is  of  our own making.  The  death  throes
            need not  begin now.  We  have the potential  in  the hinterlands
            to make the  changes with  or without  the Federal government,
            but  it would sure  help if we had them with us.

                I  have tried to make my  remarks  brief.  I could  go  on for
            six hours  on municipal   solar  utility.   I don't  think  that's
            necessary  unless  you have questions.

DR. RIEGEL:     Thank  you very much.    Before turning to Kim Boas, I'd  like
            to take advantage of  a note I wrote myself  this morning.   The
            first  point   is that at the morning session many  of the witnes-
            ses and panelists  were   very  effective  in making  arguments
            respecting conservation   and  its value  and desirability  now
            and for the future.
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                To the  extent  that  it's  possible  to  step  beyond points
            relating to conservation  alone to  the  appropriate Federal role
            and actions in  pursuing  the wisest  course,  we would certainly
            appreciate those  kinds of  suggestions during  these hearings.

                The second  point,   mostly  for  the  benefit  of  the future
            speakers this afternoon,  is that  my arithmetic  tells  me that
            we have an average  of  seven minutes per speaker, and with that,
            we'll move on to Kim Boas from Dayton.

MR. BOAS:       Although  I am  employed by the City of  Dayton,   I cannot
            officially represent the  City   Government.  My  opinions are my
            own and do not  reflect the  City of Dayton's position in regard
            to Federal  conservation  programs.   I  can  speak  only  of  my
            experiences in working with the City of Dayton.

                For the past  four  years   I have been  employed  as Energy
            Analyst for the City of Dayton, Ohio.   I like to say that I am
            the City's  Energy  Program  for  I  have  worked with community
            energy planning,  community  involvement  and  internal  energy
            management.  My testimony concerns  these  three areas  and  the
            Federal government's role in these efforts.

                Since 1978  the  City  of Dayton  has been  involved  in  the
            Comprehensive Community Energy  Management Program, a Department
            of Energy program to provide  local governments with the means
            to develop  energy  plans  to deal  with  local  energy concerns.
            It was this program which brought  the  City to  hire  me from its
            General Fund -  not  the grant.   So it  can  be said that without
            a Federal  involvement  in  local  energy   conservation  that  a
            position such as  mine  with the City of Dayton would not have
            been created.

                This would  have been  a detriment  to  the  City's  internal
            energy effort,  which  through   implementation  of  energy  audit
            recommendations will save over  $100,000 this  year  in  five of
            the City's major  facilities.   Three  of  these buildings' energy
            audits are  currently  being  considered for Federal  matching
            grants under  the  Title III  program.   Although Title III does
            not offer much  incentive for  local  government  involvement,  I
            felt that  recouping any  amount  of  Federal  grant  money,  no
            matter how  small,  will help induce  more  interest  on the part
            of Department  Directors  and  Division   Superintendents  to have
            their facilities audited.

                One concern  I  have  with  Title  III,  besides the  lack  of
            Federal funds for local government energy conservation measures
            implementation, is the  poor  timing  in the notification of parti-
            pants.  Notice  of  impending deadlines  always  seems  to appear
            at the last minute, which constrains participation  on my part.
            Most local energy offices have small  staffs  and have other  job
            commitments in  addition  to  filing grant  applications and  in

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many local energy offices the staff consists of, as in my posi-
tion, one person.  Other people involved in Title III are main-
tenance staff and also have  little  time  to  deal with short dead-
lines.  A consistently timed Title III Program would be valuable
to all participants.

    In addition to Title III and the CCEM Program, for the past
year, I have  been  assisting in the development  of  a community
involvement weatherization program with the local Community Ac-
tion Agency.  This program,  known  as  Project  CASE or Community
Action Saves  Energy, was   created through  the  Department  of
and developed in the ACTION Agency.  It is a  small-scale pro-
gram in Federal terms, but the local impact promises to be very
significant.  Initial funding  is  from ACTION with  additional
funds available through  the Department  of  Energy's Weatheriza-
tion Assistance Program.  These  Federal dollars will  not only
launch the  program  but  purchase  weatherization kits  for the
low-income and elderly participants.   Because  of the community
involvement aspect  of this program,  not only will  volunteers
provide staffing and training,  but the local business community
will be involved by  supplying  training materials and materials
for additional weatherization kits.

    It is  probably  true that  the   small amount  of  money this
program needed  from  the  Federal  government might  have  been
raised locally, but  again I believe  it was the  commitment  of
the Federal government  to  its  conservation program  which made
the very concept possible.  A  great disservice  will be done if
that visible commitment  is removed.

    I have  addressed by  viewpoint from the  local  level with
Federal conservation  programs  I  have  been  involved  with di-
rectly.  I would like to combine my  comments  on the other con-
servation programs with the general  questions  addressed in the
Section 11 issue paper.

    The Ohio  state government's Department  of  Energy is depen-
dent upon  Federal  funds in  addition to state  monies  for its
operation.  The new  austerity  budget  at the  state level has  no
funds for the Ohio Department of Energy and it is expected that
ODOE will  be  dismantled  within a  year.  So  in  addressing the
first question on assuming new responsibilities,  it can be seen
that the state is  not interested in  this new  burden.   Nor can
local governments  such  as  the  City  of Dayton  assume a  role
even approximating the Federal  or  state role  in conservation.
The activities  of  private  and  public  organizations  getting
priority pertain to  increasing revenue.  As  a consequence, all
energy using  sectors will be at a  disadvantage  simply because
increasing revenue will  not  equal the  rise  of  operating costs
due to rising energy prices.
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                The situation  (the  Federal  shift in  conservation policy)
            has not  really congealed  adequately  for  new  initiatives and
            opportunities  to  be  noticed in  the  marketplace.   It  might be
            that the  Federal  government's role  in this  transition period
            should be to  act  as  an information  source  on potential oppor-
            tunities opening  in  the  marketplace  for  conservation-related
            businesses to  develop.

                In the evaluation  of  the  Federal government's  new energy
            policies and  programs, it  might  be wise to  prove  its  point of
            conservation as a  function of the marketplace.   This  might be
            done by  comparing past  programs,  the level of  conservation
            achieved and  program  costs with  the new  programs and   their
            conservation and cost levels.

                I would  like  to  thank  the Environmental Protection Agency
            for its  invitation  to  participate  in the  Section 11 Public
            Hearings.  I  appreciate  their  interest  in  my  efforts and my
            opinions on energy conservation.

DR. RIEGEL:     Thank you.   Our last   witness before  turning to questions
            and discussion is Randi Triant.

MS. TRIANT:     Good afternoon,  my name is  Randi Triant.   I am the  para-
            legal for the  New York State Alliance of Community Action  Agen-
            cies.  We are  the  statewide communicating  and coordinating arm
            of the  49 local  CAA's  throughout New York  State.   I welcome
            this opportunity  to  provide recommendations  on the adequacy of
            the Federal conservation program.

                The anti-poverty mandate of CAA's, and our years of experi-
            ence in  energy conservation establishes  a  record  of   advocacy
            on behalf of  some three  million  low-income energy consumers in
            New York State.  I would therefore like to very briefly present
            two policy areas  which must  be  addressed  if  our conservation
            endeavors are  to  continue  to be  successful in the coming  years
            of budgetary  austerity  and energy scarcity.  These two policy
            areas are the  New  York  State Weatherization Assistance Program
            and the  New  York  State  Home   Insulation  Energy Conservation
            Program.

                Though the beginning years of the Weatherization Assistance
            Program were riddled with problems of CETA labor allocation and
            strict   administrative  regulations,  the  80's  began  a   new
            efficient management plan designed to  result  in  an increase in
            completed projects and a more productive overall program.  This
            management plan has  proved successful.  During  1980, the  Divi-
            sion of  Economic  Opportunity  began  to monitor  production and
            vouchering very  closely.    Monthly  training  sessions   for new
            subgrantee Weatherization  and  fiscal staff members in  addition
            to other  regular  training  sessions  held  for  subgrantee   staff
            were  practiced.  These  sessions were   developed  to  provide
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training of  all uniform  statewide weatherization  procedures.
In addition, DEO began  to require on-site audits  of  each com-
pleted project  by local agency  personnel  who were not involved
in the work performed at that site. Thus, workmanship and allo-
cation of weatherization materials were to be checked thorough-
ly.  Finally, DEO recommended placement of fiscal  staff in the
field offices  to  provide  bookkeeping  services and  answer any
question regarding the  financial  aspect  of  the  weatherization
project.

    We realize  that  the  present  Administration's  budget  cuts
will severely impact the availability of CETA labor.  We recog-
nize that we will be forced to look to private industry to pro-
vide the labor  needed to  continue the program.   However,  our
relationship with private  construction  firms has  been success-
full in the  past and  it will continue to be so  in the future.

    The involvement DEO  and  CAA's  have  had  in  weatherization
has insured a  steady  expenditure  of program  funds  to meet the
clearly identified need  of elderly people.   Originally funded
for 2 million dollars in  FY 77, FY 81 appropriations increased
to 18 million  dollars  with an additional 9  million dollars to
be appropriated   if   funds  are   available  and  production  is
maintained.

    The program has  shown marked  improvement in the  number of
units completed.  While in 1978 only 4,000  homes  were weathe-
rized in New York State,  17,054 units were  completed in FY 79,
and 22,000 in  FY  1980.   Clearly,  the  program is  highly produc-
tive in helping the  poor  and the elderly cope with the energy
crisis.  In fact, New York was  the top  producer  in weatheriza-
tion in the  country  through August 1980.  However, the program
can only continue  this production  rate  as  long as  the  funds
are provided.

    According  to  the   Division   of   Economic   Opportunity's
Weatherization Assistance  Program Management  Plan,  which  was
submitted to the U. S.  Department  of Energy in December 1980,
2,748,222,  or  15.5%  of the total  New  York  State  population,
live at  or  below  the  standard  125%  of  poverty  level.   The
elderly comprise approximately  1/5  of  this figure.   Without
adequate resources, this population is unable to pay for rising
fuel bills  or  improvements designed  to  increase  energy  effi-
ciency, insure lower bills in the future and thus, lower energy
assistance expenditures by government in the future.  To simply
receive case assistance is  not  enough.   The homes  of the poor
must be weatherized in  order  to insure  optimum warmth.  A full
oil tank cannot keep the house warm  if there is  little  or no
insulation, no storm windows and drafty doorways.

    Despite the success  of the program and  continued need for
it, the  Administration  has  proposed  transferring  the  current

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Federal Weatherization  Program into  the  Community Development
Block Grant with no additional funding of  its own.  As a result,
it will be  forced  to compete  with  sewer  and highway projects,
projects which have  long  been a community priority.   Secretary
Schweiker's Energy  and  Emergency  Block  Grant  Program has  no
provision that would limit  administrative costs.   No follow-up
report would  be  required  on  population  served  or  benefits
paid.  No deadline for  processing applications  would be stipu-
lated.  No  priority  for   the  would-be   handicapped  would  be
given.  And  10%  of the funds could  be transferred  to  another
Health and Human Services  block grant at the discretion of the
state.  The quintessence  of this proposal is the repeal provi-
sion, which  would  allow  the  legislation authorizing  all the
different categorical programs to  be eliminated in  the  event
the block  grant  approach  does not  work.  Not only  would the
Weatherization Assistance  Program  have to  first  compete  with
other Human  Services programs,  but should  the  proposed  block
grants fail,  we  will be  forced to  go  back and  introduce new
legislation authorizing this  much needed  program.

    The Weatherization Assistance Program was intended to enable
low-income families to  save money on home heating costs through
adding improvements to their houses such as  insulation, weather-
stripping and  storm  windows.   That  such  improvements decrease
heating costs  is indisputable.   CAA's can and  will continue to
weatherize thousands of homes a year only  as  long  as the pro-
gram is supported administratively and financially.  Most indi-
vidual states are not able  to  appropriate enough funds to main-
tain the program as it  is today.

    We have finally started to solve  the problems which hindered
Weatherization programs throughout  New York State.   We  cannot
now in the  face  of considerable success  begin  an entirely new
program and believe that success will continue.

    A second  issue of importance in consideration is the acces-
sibility of energy audits and  improvements to the aging housing
stock of the  Northeast.  The Federal program charged with this
responsibility is  the   Residential  Conservation  Service  (RCS)
and within  New  York  State,  it operates in  conjunction  with
the Home Insulation  and Energy Conservation Act  in  HIECA.   I
would like  to talk about  the  status  of  HIECA and improvements
in this area  for improved home  conservation.

    HIECA includes  three   types of  audits; the  "A" audit  on
which a utility  inspects  a home and provides a pay-back analy-
sis for $10;  a "B" audit  in which a utility provides a text of
instructions  for site  inspection by  the  homeowner and  a pay-
back analysis  for  $3; and a  "C" audit  in which a utility pro-
vides audit workbooks for a customer to do both site inspection
and the payback  analysis.   This last  class  of audit  is  free.
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    Once the  audit  is  conducted,   the  utility  provides  the
customer with a list of contractors  in the area who can install
the energy  conservation measures.   In addition,  each  utility
has made arrangements  with at least  two  hanks in  its  area to
offer loans  for  these  improvements.   The  interest  rate  is
generally between 9% and 11%.

    The minimum allowable  amount that can be  loaned  is $200.
The maximum  amount  loaned  is  $2,500  for  a  one-family  house;
$3,500 for a two-family house; $4,000 for a three-family house;
$4,500 for a  four-family house.  These  loans can  be  extended
up to seven years.

    Solar and wind  construction  loans  have  a  maximum of $1,500
higher than the above  scale and  can be extended  up to fifteen
years.

    In practice, this  sensible  framework has  been inadequate.
After more than two years,  less than  2% of  eligible 1-3 family
households have received  audits.  Less  than  one tenth  of  one
percent of eligible  households  have  received  HIFCA loans.   In
fact, only  6% of  households that  completed  audits  have  also
completed suggested improvments with HIECA financing.

    There are  generally  four  areas  conspicuouslv  demanding
improvement in the  NYS  HIECA program;  improvements  which apply
equally to RCS  and  future  Federal initiatives in conservation:

    1)  Utilities have been inactive and  ineffective in perfor-
        ming community outreach and publicity for energy audits
        and improvement  loans.   Community  based  organizations
        or state energy offices  should be  given this responsi-
        bility if we  expect it  to  reach  the  truly low-income
        homeowner or energy consumer.

    2)  The fee  of  $10 or  even  $3  prohibits  otherwise curious
        and interested  consumers from  availing  themselves  of
        the program.  Energy audits should be free.

    3)  Low  estimates  of   potential  saving  from  improvements
        are provided  by  utilities  to HIECA participants.  Cal-
        culations are not  updated  frequently  enough to keep up
        with the ever-rising cost of home fuel supplies.  State
        energy offices should be charged with the responsibili-
        ty for monitoring payback analysis.

    4)  Current  procedures  for HIECA  loans result  in  a large
        number of defaults, which has disillusioned many utili-
        ty companies  and prevented  their  optimum  cooperation.
        Homeowners taking  advantage  of  HIECA should  ideally
        be able  to pay  for conservation  improvements  out  of
        the savings  of  fuel interest  free  loans  with  lower

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                    monthly payments  would be  a more sensible  alternative
                    to the present  10% interest  charge.

                Rather than decreasing interest  on  loans,  the utilities  are
            encouraging increasingly  strict terms for HIECA loans;   Roches-
            ter Electric  &  Gas wants credit  checks on each HIECA  partici-
            pant.  Needless  to say,  this  would negate  the  very intention
            of insulating low-income, older homes and diminish the  rate  of
            participation even further.

                This is  not  the  time  to  make HIECA  more  restrictive.
            Amid the many HIECA amendments in NYS recently, one  bill passed
            which extended energy audits (but not utility loans)  to  multiple
            dwellings.  The same  bill requires  utilities  to provide train-
            ing for  employees in  conducting audits  and  offers  free post
            inspection.

                The NYS  alliance  of  CAP's  encourages the EPA  to  consider
            our recommendations  on  HIECA  and  the   sense  of momentum  and
            support for the  program in the 1981  session of  the NYS Legis-
            lature.  Federal  and  state  initiatives  in RCS and HIECA should
            be compatible.   Federal  RCS  regulations  can be  improved   to
            ensure a better HIECA program  in NYS and  a  greater uniformity
            in energy  audit/conservation programs  throughout  the  country.

                As non-profit, private  organizations,  CAA's  are willing  to
            extend their  role  in  Weatherization  and  HIECA.   Continued
            participation of  CAA's  will  only be possible  through continued
            financial support  and  compatible  regulatory guidelines  from
            the Federal  government,  assuring  that  the  programs   operate
            in the best interest of low-income consumers.

                I might also  add  as a post note  that  since  the  writing  of
            this testimony,  the  $10  fee is  no  longer  allowable,  and  the
            audits are now  completely free.   That  was  recently passed   in
            the legislature.

DR. RIEGEL:     Thank you.  Questions and discussion?

MR. GLASSBERG:   Yeah,  I  have a question  for Mr.  Pauls.  Have  you  found
            that your  activities  in  Carbondale  have  ebbed  and  flowed
            with the ebb  and  flow  of  Federal  funds.   In other  words   —

MR. PAULS:      Not at all,  not one bit.

MR. GLASSBERG:   In  other  words,  the  local  initiative  has  carried  your
            program through almost  independently of how the  Federal  funds
            have flowed to your community?

MR. PAULS:      It's like the less money there is sometimes, the more  crea-
            tive and  innovative  you  can  become.  You  find the   sources,
            being the financial  or human resources, in  different   sectors.

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                We've tried  to  utilize,  and  when  I say  we,  I'm talking
            about many different  groups in town, tried to  utilize a whole
            range of  services,  and it's  worked.   It's pretty  tight some-
            times.  Staffs  of  one  agency,  for example,  swell and  shrink
            between 50 and 5, and that doesn't make for great job security,
            but it gets the job done.

MR. GLASSBERG:  If  I  could follow up on  that  for a  second,  would you feel
            that if  money  were   to  flow  to  local   governments   to  allow
            innovative projects,  such as  those  in  Carbondale, do you think
            it would  force  good  programs, if  those monies were to be on a
            competitive basis  so that  there  would  have  to  be  sufficient
            intiative at the local  level  in order to get  Federal funding?

MR. PAULS:      Well,whenever you're talking competitive program,it depends
            on who's  doing  the  evaluation and  what  your criteria are.  I
            think there will be  a great  tendency to have  some innovation,
            but there  will also  be a  tendency for  more homogeneity from
            the evaluators.

                In some sense,  the block  grant principle  is  nice in that
            it says  the  community  can  decide  its  own  solutions  according
            to its own problems.   It  just depends  on how you structure it.

MR. POWER:      Just a question about this Municipal Solar Utility.  Do you
            have a  write-up on  that,  and what  was  the plan around which
            that was  confronted?  Did  you create  your own  institutional
            framework?  You  might describe some  of   the  basic principles.

MR. PAULS:      A quick summary.  The program was a research  study.   It was
            was co-funded by the city for  $5000, and  the state kicked  in 45.

                It was a one-year project.  It  went through three  different
            phases.   It:  was looking  at  the  free  lunch  from the  Feds at
            first and  looking  into  the  conservation  bank  in  the  second
            phase, and  all  those  things just  fell  aside,   and we were
            sort of  glad,  because  it  ended up  bringing  us  all  back home
            and looking at what was possible there.

                The format  was that  we  subcontracted  it  to  a  non-profit
            group in  our  community,  and  they  did   a  hell  of  a  good  job
            researching what  is  available,  what   the   legal issues  are,
            what's possible  within  the  statutory  constitutional   limits
            within our  state for both home rule and non-home rule cities.

                I don't  know  if  I've  answered your  question   properly.

MR. POWER:       I guess   any  comment you  might  have  about  reaction of
            existing  entities,   like  utilities  and banks   and   community
            authorities, how they've reacted to the creation of this entity,
            if it's occurred yet.
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MR. PAULS:       I'll give you the reaction of four different groups.    The
            utilities when they were approached with this initially, infor-
            mally, the  first  question  was after understanding the  concept,
            have you  talked  to  any other  communities  about this,  like  oh,
            boy, we're  not ready for this.

                As for  the  community,  we  talked  to  the  citizen utility
            reform kind of groups, which we have a big one  in our area,  and
            they seemed  to  be  very  supportive  of  it.    The  homeowners
            association is supportive of it.  We think we have our Chamber of
            Commerce to  back it,  and  the reaction  of the  city administ-
            ration, which  is different  than  City Council,  is,  hey,   the
            model may not  be exactly what we're going to  do,  but it  sure
            makes sense.   It's  within  the  purview of  local government to
            help public  welfare  and  something we  ought  to  look  at,  even
            though maybe not  in  the  final form that the model talks about.

                As for  the City Council, they have not acted on  it  formally
            ordinance wise, but they're  gung ho.   They want to  go  with  it.

                One quick  comment  on  Randi's testimony.   I think she is
            outlining the problems  of  energy audits that we have  tried to
            overcome in our  structuring of this.  The  success of a program
            is very  much on  how  you  market  it  and  how  you  define  your
            clientele.  The problem there seems to be, I don't know, you've
            got a  lot  of them  there,  but we're  hoping that you  can  sell
            the program, not  simply put  it out there and  say, come get  me.

                You have to educate so that people want it.

DR. RIEGEL:     I  wonder, Randi, if you've  run across  any  perception in
            the public that the audit  is  in  any  sense perceived as unreli-
            able or  does  not provide  information  beyond   that  which  most
            homeowners already have  available  to them  before  the audit is
            conducted.  Is  that   a part  of  the  marketing  problem  aside
            from the  $10  charge that  you mentioned as a  barrier before?

MS. TRIANT:     Yes, very  much  so, especially throughout New York State I
            think we're  being confronted  with the  problem that  when   the
            utilities are  given  the  go-ahead  on  an audit,  somebody  does
            sign up  for it,  for a large  part,  they are not  doing an  ade-
            quate job in  the audit, and,  as a  result,  simply  by  word of
            mouth, people are  telling other people that the  audit really
            isn't worth their time and effort.

                What's happening is  that  the  utility   representative  will
            come in and do  a five-minute audit and  won't  thoroughly check
            the insulation, won't  get  into the  attic, won't get into   the
            basement and check the  oil  tank or whatever needs  to  be  checked.
            As a result,  the  Alliance  is going  to be  conducting  a survey
            because recent legislation has a provision, and this has passed
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            also this session, which will enable CAP's to be an entity that
            will be able to do audits.

                Something like a  subcontracting  system will be set up with
            the utilities and the CAP's.  The CAP's are doing a much better
            job, especially when  it comes  in terms  of  low-income people.
            They're more likely  to turn to  a CAP  and say, well,  we know
            them, for other  services,   and  they know  them  personally,  and
            the CAP's have  the  time  to  go  in and  thoroughly  check  the
            houses.

                As a result, it's  kind of  changing more or less toward the
            CAP dominated kind of procedure.

DR. RIEGEL:     The  next  three  scheduled  speakers are  Betty Kahl, Paul
            Danels, and Mart  Kask, if  they  are all present.  Mr.  Kask is
            with the Puget  Sound  Council  of  Governments;   Betty  Kahl is
            from Rhode Island Jobs and Energy organization,  and Paul Danels
            is with the New York City Energy Office.

                Let's start with Betty Kahl.

MS. KAHL:       Good  afternoon.  My  name   is Betty Kahl.    I am a  VISTA
            Volunteer and a  community  organizer  for a  national  community
            based organization:   Congress for  a Working America.   Congress
            for a Working America  has  organizations in Rhode Island and in
            Milwaukee,  Wisconsin.    I  work   for the  Rhode  Island  group,
            Rhode Island Jobs in Energy.

                Rhode Island Jobs  in Energy has been designated a Community
            Energy Project  by ACTION.   We have  also just been appointed to
            coordinate Rhode  Island's  participation  in the  International
            Energy Days  Competition.   Our  organization's basic goal  is to
            make ongoing human needs  and  dignity the  United  States'  first
            priority through actions  rooted in  citizen  participation,  and
            focused on those most  in  need,  by  creating  and perpetuating a
            full employment program that:

                o   continually  creates  employment  for those  who are or
                    potentially will be unemployed  and  for those  who  are
                    underemployed

                o   produces goods and services that will meet human needs,
                    improve the quality of  life,and respect  the environment

                o   and   builds  economic  security for  all  within a stable
                    peacetime economy

            We are focusing on energy because of the job creation potential
            in the  fields  of  energy   conservation and   weatherization.
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    Last January, the  Rhode Island Jobs  in Energy Project, in
conjunction with a local  Senior  agency and the City of Pawtuc-
ket, Rhode Island,  ran a low cost/no cost weatherization program
for seniors.  The money  for the  materials  came originally from
the Department of Energy as part of  the  Low Income Energy As-
sistance Program to  the  State of  Rhode Island's  Department of
Community Affairs.   The  state then purchased  low  cost/no cost
weatherization kits  and  distributed them  to  the  Department of
Elderly Affairs  and  the  state  Community  Action  Programs.  In
trying to track  down these kits,  we  found that not  very many
people knew  about  them,  and even  fewer  could  tell  us  where
they were or how to  gain access  to them.  But persistence pre-
vailed and  we  were  authorized  to distribute  500 weatheriza-
tion kits.   Through  the Pawtucket Public  Service  CETA program
we hired  and  trained  eight previously  unemployed  people to
install the  kits in senior  households.   In  February,  we con-
vinced the Blackstone Valley of Rhode Island.

    In addition,  we  conducted informational low  cost/no cost
weatherization seminars  in which we demonstrated  and explained
to hundreds  of  Rhode  Islanders   weatherization techniques  to
keep them warmer and reduce  their fuel bills.

    In talking  with  people we  find  they  are  uninformed  or
have wrong ideas about energy conservation.   Rising fuel bills
alone are not  enough to  make most people take steps  to save
energy;  this  is  especially true of   renters.    Reasons  for
failure to weatherize are many:

    o   people receive  their  fuel bills  only after they have
        consumed  the energy, so they are  less likely  to take
        preventatlve steps  to conserve

    o   folks  cannot see energy  escaping and most weatheriza-
        tion materials are not clearly visible

    o   many,  many people  are  not aware of low  cost/no cost
        weatherization  techniques  and  feel  they must  spend
        thousands  of dollars on  insulation to see  any reduction
        of their fuel bills

    o   many  of the seniors  we  worked  with  were  unable to
        install  even  the  low   cost  weatherization  materials
        themselves

    o   renters generally  assume that they need the landlord's
        permission  for  any  type  of  weatherization  measure

    o   those who do try to weatherize are often confused about
        what their homes need as  well  as what kinds  of energy-
        saving materials to buy
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    o   those people who are able to purchase materials need to
        know the proper ways to install them

    Getting information across to people is extremely effective
when done in a  small  meeting approach, preferably in someone's
home.  Large  group presentations  are  generally  boring,  more
cumbersome, and it  is much  more  difficult  to  demonstrate the
proper installation  of  weatherization materials  than  simply
have an  oral  presentation;  and  better yet  to  have  the house-
meeting participants practice caulking or weatherstripping win-
dows and doors.

    The Residential Conservation Service Program, known locally
as RISE,  Rhode  Islanders'  Saving  Energy,  provides   an  energy
audit that  identifies what  is  needed, makes  recommendations
about materials and contractors,  and perhaps most importantly,
gets people actively involved in learning about the weatheriza-
tion needs  of  their  own homes.   We  have  found  door-to-door
canvassing a very good way to convince people to have an energy
audit done  of  their home.  Another  method we  are going to do
this fall is  to have  people get  an infrared photograph (which
are provided  free   from  RISE as  well) of  the heat  loss  from
their homes.   The   photos  demonstrate  very  graphically  (thus
actually allowing folks  to  see heat escaping  from windows and
doors) the process  of infiltration.

    Many more major weatherization measures would be undertaken
by homeowners  if  affordable financing  were readily available.
Currently with  interest   rates  at approximately  18% financing
is an  enormous problem.   If  we  could  offer  people  loans  at
anywhere from  3-10%,  much  of  the weatherization  problems for
middle-class homeowners would solve  themselves.

    As we see it, two possibilities  currently exist  for middle-
class people.   The Rhode Island Mortgage and Finance  Corporation
may be  able to  offer loans  for energy  conservation  at  from
12-15% interest.    In  addition,  some  monies  from Community
Development Block   Grants  may  be  funneled  into  low-interest
weatherization  loans.  However,  as  you know,  block  grants are
to be  cut  approximately  25%  overall  in  the  coming  years.
Also, those  monies have traditionally  gone to support  housing
code enforcement and  the 312  Rehabilitation Loan Program.  So
redirecting any money  for   low-interest   weatherization  loans
will be  very difficult.

    Working class  people need  no-interest  loans  to  be able to
do major  home  weatherization.    And  even  poorer people  must
depend on subsidies to insure manageable fuel bills this  winter.

    Utility companies,  banks,  private  industry,  and/or local,
state, and  Federal  governments  must provide  the necessary
financing mentioned above.   If  they do not,   the middle-class

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            will become  even more  discontented,  poorer  people  will  face
            harder choices with fewer and fewer resources, and this country
            will continue to  deplete  its economy  by  spending $100 billion
            dollars a year on foreign oil.

                In conclusion,  I feel  that our  country has  a  choice  of
            economic priorities.  We  can either  continue  to subsidize big
            business (and big oil) or we can make a commitment to stimulate
            the economy by putting people back  to work.   I am fearful that
            most of the work  we and others have  done  this  year and others
            have done this year is  going to go  down  the  drain in light  of
            the budget  cuts.    But  I  am even more  outraged  that  in  this
            country many  people are going  to face  next  winter  having  to
            choose between heating  their homes  or  feeding  their families,
            and in the  end when all the testimony is  read  and your report
            has been written,  a lot of  people  will have  frozen to death.

DR. RIEGEL:     All right, thank you.  Next is Paul Danels.

MR. DANELS:     My name is  Paul Danels, and I am  Legislative  Counsel and
            Director of the  Utility Analysis  Unit for  the New  York  City
            Energy Office.  The Energy Office is responsible for the formu-
            lation and  coordination  of  the  City's Energy  Policy.   On be-
            half of Mayor Koch and Robert  M.  Herzog,  Director  of  the New
            York City Energy Office, I'd like to thank you for the opportu-
            nity to present the City's views on Federal energy conservation
            efforts for the  Environmental  Protection  Agency's  Section  11
            Program Review.

                The Reagan Administration  has embarked  upon a  new course
            for the nation's  energy policy,  one which places  the primary
            responsibility for  energy,  and  particularly the areas  of  con-
            servation and  renewables  squarely  in  the  marketplace.   The
            thrust of this new approach is that  a free  market functioning
            in the  absence  of  distortions  and  imperfections  is  the  best
            framework for the allocation of our energy resources.

                To spearhead  this  policy,  the President  decontrolled the
            price of  domestic  oil  as   one  of  his  first  acts  of  office.
            Beyond this  first  step, however,  little  else  has  been  done.

                If the energy marketplace could be made free of distortions
            by simply decontrolling  oil  prices, this  policy  would be  both
            acceptable and effective.  Yet decontrol alone does not consti-
            tute an effective  energy  policy.   Decontrol is  not sufficient
            to correct  marketplace  imperfections which have persisted and
            have become virtually  institutionalized over  several decades.

                On the  contrary,  it is  necessary  to  insure  that  all the
            components of a  free market  are  in  place before we  begin  to
            rely solely on its  ability to foster economically and socially
            rational decisions on energy.
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    A key  element  of  a  fully  functioning  free market  is the
availability of, and access  to,  accurate  and credible informa-
tion about various energy  options.   Currently,  the information
about these  energy  options,  especially about  conservation and
renewable options is in disarray.

    Energy consumers often have no idea as to what opportunities
are available  to  improve  the  efficiency of their  energy use
or to  utilize  less  expensive  fuel  sources.  For  example,  in
New York  City,  we have  found  that  many  homeowners  and  land-
lords are  unaware  of  even  simple,  low-cost  ways  to  improve
their energy  efficiency   and  a   result,  reduce  their  energy
costs, even  though the price of  heating oil has  risen astrono-
mically during the past few years.

    In those areas  where  information  is  available,  there are
oftentimes no established criteria by which  it can be evaluated.
Thus, consumers  are   faced  with good  and   bad  products,  but
without any means to distinguish among them.

    This produces  an enormous  uncertainty   among  energy  users
about available energy efficiency opportunities,  often result-
ing in a total lack of consumer action.

    This inactivity,   in  turn,  impedes  the  timely  development
of  the  role   of  energy    conservation  in the  marketplace.

    Although it  would  be  inappropriate  for any  governmental
agency to  endorse  one product  over  another, it  is reasonable
and appropriate for  government  to educate the  public regarding
energy alternatives.    By  providing  information which  fosters
rational decision-making in the energy marketplace, the availa-
bility of  credible   information  about  how  energy  is  used and
the opportunities which  exist  to use it more efficiently  need
to be improved, prior  to an optimal marketplace  allocation  of
energy resources.

    However, providing  better  quality  information  addresses
only one of the problems  which  unbalance the  energy marketplace.
Currently, different  energy  alternatives  have  unequal  access
to financing mechanisms.

    Thus, access to  capital rather  than  energy  efficiency  is
often the  determining  factor  in energy decision-making.   For
example, the decision of an  electric utility to expand genera-
ting capacity  cannot be   compared with that of  a  homeowner's
decision to  purchase  more  efficient air  conditioners.   Finan-
cing conditions, such as  interest rates  and terms of repayment,
are hardly  comparable for these two  options,  and  are  often
skewed favorably towards the utility, despite the  fact that  in
many cases  a more  rapid  turnover  of  appliances  such  as air
conditioners is actually  the better energy  and  economic  deci-

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sion, providing a more economically favorable result at a lower
cost and at a shorter time.

    It is  necessary  that we  as  energy planners  at  all levels
of government take the necessary actions to insure equal access
to capital  and  equal financing  conditions for  all  energy op-
tions.  Only with  these  measures  in  place can  we have confi-
dence that the market will operate most efficiently.

    Thus, rather  than allowing  us  to  operate  in  a  perfect
world as  the  Administration  had hoped,  decontrol has provided
only one piece of a larger mosaic of actions which are necessary
to promote  greater energy efficiency.  In fact,  in  absence of
all the  necessary conditions  for  the  marketplace  to  operate
efficiently, the decontrol of oil will only exacerbate the sys-
temic problems which  impede progress towards  a more efficient
economy.

    By raising the cost   of  energy even higher,  decontrol has
forced energy users  to  commit  more  of their  already  limited
budgets to  direct  energy  purchases,  making   it  increasingly
difficult for them to invest in  energy  conserving measures.
We must address  the  inequities  of  decontrol  to insure that its
benefit and burdens are distributed fairly.

    An aggressive program aimed  at improving energy efficiency
is clearly  the  best approach.   We agree  with  the  Administra-
tion's view that  energy  conservation activities  are  best  car-
ried out on a decentralized level through programs run by state
and local  governments,   as  well as  by  private organizations.

    This is particularly true of  cities,  since  by  their  very
nature, they  lend  themselves well to  efficient site-specific
applications of  technologies  such  as  district  heating  and
cogeneration.

    Thus, a  shift in  responsibility  for  these  activities to
the local  level  can,  in  fact, produce  a more  efficient imple-
mentation of energy  conservation programs  by  removing  a layer
of Federal bureaucracy.  However, without the financial resour-
ces to  carry  out  these  programs,  the  new Federal   initiatives
to restore local control will have no effect  at all.

    Simply stated, without  funding,   local energy conservation
programs will be  severely limited  and possibly curtailed alto-
gether.

    For some  time now,  New  York  City  has  been  preparing to
assume a  greater  role in  controlling its  energy future.   The
City's Energy Office has  completed a  detailed  end-use analysis
of local energy demand as well as a comparative economic analy-
sis of  local electric   generation and conservation  options.

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    We have  instituted  a  far-reaching educational  program to
better inform city  energy  users  about ways  to  achieve greater
levels of  efficiency.   We  have  also moved  ahead  with  major
projects to utilize  garbage  as  an energy source,  to study the
feasibility of district  heating   in  the City,  and  to  improve
the efficiency of  energy  use in  city-owned  buildings,  to name
just a few.

    The city will try to carry out  these  and other programs in
light of the  new budget cuts,  but,  frankly, our  efforts will
be hampered  if  the  Federal  government does indeed  choose to
abdicate their present responsibility to insure program funding.

    If Federal funding for energy conservation is severely cut,
it is likely  that  many  current  activities  will be  reduced in
scope or  eliminated altogether.   Unfortunately,  it  is  often
the big ticket  or  sexy technologies  which  get  priority,  while
the neighborhood and household scale  opportunities go unnoticed.
Yet in many cases,  these decentralized programs  such  as weather-
ization provide  the  greatest amount  of energy  savings for the
least cost.

    Furthermore, these  programs  often have  immediate and posi-
tive impacts  for  thousands  of  individual   households.   Their
elimination will result in  a  large  negative impact  on  middle
and lower income households nationwide.

    The Federal  government  can  go a long way towards promoting
increased energy efficiency without  burdening states and  cities
with excessive regulation.   Energy  block  grants should be pro-
vided to cities affording them the opportunity to create locally
appropriate programs  x^ithout  imposing  unnecessary  controls.
In addition,  research   and  development efforts  should be  ex-
panded  in  the area  of  energy  conservation,   relieving  state
and local  governments  of   this  costly,  and  risky,  burden.

    Demonstration projects  which clearly  show  the  energy and
economic benefits of conservation activity should be  established
in all  areas of the  country,  each   being  geared to meet  local
needs and problems.

    The Federal  governnent  should   work  with  state  and  local
officials to  establish  neighborhood  energy   centers.    These
centers could  be used  to distribute  information to  local  resi-
dents and  businesses about  energy  conservation  opportunities
while also  serving as  a neighborhood  energy monitoring center.

    Data on  local  energy use could then be  collected along with
information  about   local   firms   which provide energy-related
services.   This  information  could then be disseminated  to those
seeking to  use  these  services,   providing  a degree of quality
control  which   does not  currently  exist in this  market.

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                 Over  the  past several years,  we  have all learned  two  very
             important  lessons about energy.  The first is that  uncertainty
             is  pervasive  in the planning process.   Our perspectives  on the
             past have  given  us  little  knowledge  about what  to expect  in
             the future.

                 Second, there is no  single solution  to  our energy  needs.
             Different  areas  of  the country  face  dissimilar  problems  and
             opportunities.   Thus,  it  is impossible  to embark upon  a  single
             narrowly defined  national   energy  policy.   It   is   necessary,
             however, that  energy planners  recognize  this  uncertainty  and
             the diversity  of options  and provide programs which  are  suffi-
             ciently flexible to achieve those goals  which  are  consistent
             with local needs as  well as  national interests.

                 A  set  of  successful  government and private sector initia-
             tives  aimed at  improving  energy efficiency use  can  do this  at
             a lower  cost  than  any other  alternative.   Furthermore,  the
             available  evidence  indicates that  not  only is  an  energy  con-
             servation  strategy  the  least cost, most environmentally  benign
             approach,  but  that  it  is  economically  productive  in terms  of
             creating new employment opportunities.

                 Given  these  benefits,  it would  seem that the Federal  gov-
             ernment should  be  fostering the  development of  thousands  of
             local  energy  conservation programs  rather than  insuring  their
             demise through  short-sighted budget cutting.   A more efficient
             energy system is a national  priority,  and the  Federal  government
             has  an important role  to  play if  it  is  to  become  a  reality.

                 It must be  remembered that  energy is not just  a  national
             or  international  issue.   Based  on their  knowledge  of   local
             institutions, business  and  residents,  cities  are best  equipped
             to  develop energy programs  which are feasible and realistic  to
             implement  at the  local level.

                 Cities need  the  support of  a  reasonable  and   consistent
             national framework for energy policy and access to the resources
             necessary  to  achieve locally  appropriate goals.  The  Federal
             government must  recognize  these needs  and take  actions  which
             will insure  that  cities  can  make their  contribution.  Thank
             you.

DR. RIEGEL:      Thank  you. Mart  Kask is  the Executive  Director of the Puget
             Sound  Council of Governments in Seattle.
MR. KASK:       Thank you. I have given out my testimony.
            a couple of points in very short form.
I will underline
                The Council of  Governments  is an association of cities and
            counties around the Puget  Sound  Area,  the central  city being
            the City of  Seattle.  Our  organization was  formed  in 1957 to
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deal with area   wide   problems,   such  as  water   quality, air
quality, transportation, housing and now energy.

    I flew over  yesterday,  and it rained in  Seattle.   Rain in
Seattle and the  Puget   Sound  area is  energy.   We  collect the
water behind  dams  during  the  summertime  and melt  the  snow
back in the spring, we  generate hydropower.

    The dams  built on  the  Columbia  and  its  tributaries  have
reached saturation. We no longer  have  dam sites and, therefore,
we have run out of hydropower, but nevertheless, the population
in the  State  of  Washington keeps  growing.  Our  current  1980
population is about 4  1/2 million and expected to grow to about
6 million by the year  2000.    We need more electricity.

    Then we  need  to  resort  to   thermal  power,  such  as  coal
fired plants  and nuclear plants.  We  know that  the  cost  of
thermal power is  considerably more  than  hydropower.   To  give
you an  example,  the current  hydropower at  the retail  end  is
about 17 to  22 mils,   and  we  are talking  about  40 to  60 mil
nuclear power, and  also up to  80  mils  in  some  coal fired plant
situations.

    It became a question to  us in the Northwest: Who's entitled
to the  cheap  hydropower,  and.  who must pay the high price  of
thermal power?  And we  tried  to  solve that  at the local level.
However, since our  hydropower  contributes  to  the  power  supply
in four states, it became a  Federal issue.

    Congress in  the last  session enacted  the  Northwest Power
Bill which, in  essence,  does  three things.  It melts  the  low-
cost hydropower  with   the  higher  cost of  nuclear power.   It
calls for  guarantee of  purchase  of   power  by the  Bonneville
Power Administration of  any new  power plants, and also calls
for a  substantial  conservation  effort on  the  part  of local
government, states, the Federal government,  prior to commitment
to construction of nuclear or thermal power.

    This act was enacted by  Congress, and we are now implement-
ing this act.  But  prior to the passage of  the act, the Bonne-
ville Power Administration began  to  outline some  of the things
that it can do with local governments.

    They contracted with the Puget Sound Council of Governments
to develop  a  local  government  workbook.    The  workbook  is
designed to enable  local  governments  to  identify what  can  be
done in the area of conservation.   What  can  be  done by whom,
and not all actions are necessarily actions  of  local government.

    Some can  be  done by utilities, some  by local governments,
some by  individuals,   and  many  are  obviously joint  efforts.
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    The workbook is  in  a simple form.   It  identifies 20 ques-
tions that  can be  answered  yes or no, and  if the  answer is
yes, we have,  for  instance,  in the city a  zoning  and subdivi-
sion code  that  takes into  consideration energy  conservation.
Then you  go to the next question,  and it  sort  of  gradually
builds up  to  some  pretty  high-powered  questions leading to
questions of  garbage burning projects  among  cities,  counties,
and also many of our water  supply  systems,  our gravity systems
coming from  the hills,  and  we  have  discovered  that many of
them are available  to install a low-head hydro projects in there
and generate some electricity.

    So the  workbook  goes  through  this  array  of  20  questions
starting with very  simple questions and leading to very inten-
sive kinds  of  projects.   If  the  answer  is  yes,   then  it
points out in the book  what is the  next step that  can be taken
and what are the specifics one has  to  follow in order to bring
this project on line.

    There is  incentive  for doing  that because  the  Bonneville
Power Administration provides some  capital for the construction
of these  projects   and   also  buys  the  power  generated  as  a
result of  these projects  or  the  conservation  generated  by
these projects.

    The second  effort we are  carrying out  is  the application
of this workbook.   We have  received a  grant  from  BPA to apply
this in one  of  our counties.   What we will do and have done is
we go and sit down with each City Council and their administra-
tive people and go through the workbook and identify  what  they
have and  what  are  their potentials  for energy  conservation.
Once these  are  identified,  that's   where  we leave the  city or
county on their own  to  take the next  step  and prepare a speci-
fic program  for  action and work with  the utility and  the  BPA
for the implementation of the project.

    The net result  is conservation,  which is  a supply of energy.
This is  what we're doing.    I  appreciate  the opportunity to
discuss this with  you.   We  are  very  excited  about   it,  and  I
think that  the results  that  we  have  achieved will be  even
greater when  we complete  these projects  and  lead   to  imple-
mentation.  Thank you.

          *************

  FOLLOWING IS MR.  KASK'S WRITTEN STATEMENT

    The Puget  Sound Council of  Governments is  an association
of local governments  with the  primary purpose of policy devel-
opment and  regional coordination  in the planning  of  programs,
projects and activities  in  the local   government  sector.   The
Puget Sound  Council  of Governments  has  56 local  government

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members including  four  counties  and  four Indian  tribes.   The
constituency of  the  elected  officials  representing  the  56
local government  members  comprises  over  50  percent  of  the
population of the State of Washington.

    The local  government members  of  the  Puget  Sound  Council
are working, together with private  firms,  the state government
and other local agencies, to prepare to assume their new energy
management responsibilities.    A  program  to   take  a  hands-on
approach to  solving energy  management  problems  at  the  local
level has  evolved  over  the  past two  years.    A  year  ago  the
Puget Sound  Council  completed  a  workbook  for  use  by  local
general purpose  governments   as  a   guide  to  preparing  local
energy management plans.  The  content  and  format  of the three-
volume manual was  shaped by the  results  of  a PSCOG  survey of
1000 local  governments  in  the  four-state  Pacific  Northwest
Region.

    The workbook  recommends  a planning  process  built  around
a simple but comprehensive exercise — one in  which  the  local
staff gives yes and no answers  to twenty questions.  The answers
help them  select  local  energy management  actions  tailored to
the needs of their particular  community.   A  favorable response
to the workbook and  its  unique approach has  led to  the  funding
by the U.S. Department of  Energy of an energy management plan-
ning implementation pilot project.

    During the  first  phase of  the  pilot project,  each  of the
study area's local  general purpose  governments will  be guided
through the  workbook's   20-question exercise  in  two-to-three
hour meetings  with  key  local  staff  and  elected  officials.
During this same period an orientation meeting for local energy
advocacy and economic  interest  groups within  the  study  area
will be hosted.   Attendees will  be briefed  on the  scope  and
expectations of the  project  and  asked  if  and how they  might
like to participate in the formulation of the energy management
plan.  Opportunities for  participation in the project will be
offered by  a  special citizen's  advisory group made up  of ap-
pointed local representatives and other citizens.

    The Subregional  Councils  of  the  Puget Sound Council  will
become the  coordinating  bodies  for  development of the  energy
management plan.   Technical  advisory  committees  to the  Subre-
gional Councils will be  asked  to expand to include  local elec-
trical utilities'  staff  and  other  local experts  to  advise
other local experts to advise  the councils on technical issues
to be addressed in the course of the project.

    After all  eligible   local  governments  in  the  study  area
have completed  the  20-question workbook exercise,  a  report on
the findings will  be prepared and  circulated as  a first  step
toward formulating  a  regional  energy  management  plan.   The

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contents and scope of the final plan will depend on the results
of the workshops and local plans, which  will form the hasis of
the final document.   Some common themes  are already emerging:
updated building,  zoning  and subdivision codes;   a program to
audit local local  government buildings;   and contingency plans
for emergency energy curtailment.

    It is hoped  that  when specific  conservation and renewable
resource projects  are  identified, these projects  will  receive
priority from the  utilities  and the private  sector as  well as
the local  governments.    The whole  intent   of  the  program is
that by  working  through  this   process  together,  public  and
private agencies  can  agree  on  what energy  management  actions
must be  done,  how  to  to  get  them done,  and then proceed to
implement the actions cooperatively.

    The Pacific  Northwest Power Act has provided  great incen-
tives for implementing cost-effective electrical management ac-
tions.  Through this Act  BPA can fund planning activities  such
as our program,  that  lead  to  cost-effective  energy projects.
It also  overcomes  economic  inhibitors inherent  in large  scale
energy supply systems.  The  economic  inhibitors  primarily  con-
sist of the retail  cost  of conservation and renewable resource
actions being greater  than large scale  systems'  retail costs,
even though  the marginal costs  for  new  large  scale  systems
exceed the marginal costs for  conservation  and direct applica-
tion renewable  resource  activities.   The  result  is  that it
costs more for  the  consumer to implement the  most cost-effec-
tive projects  because  the  burden  of   financing   conservation
and direct source  renewable resource activities must be  borne
directly and totally  by  the consumer.   The  Pacific Northwest
Power Act allows the marginal  costs of the more cost-effec-
tive consumer oriented  activities to be melded  into the  rates
of the large regional  system,  thereby allowing the more  cost-
effective energy  to  be made available  to  the region  without
a penalty to consumers.

    The federal government can greatly assist local governments,
other energy  consumers  and  energy  suppliers by  implementing
similar legislation  to the  Pacific  Northwest Power Act  for
other energy forms.   One  bill   that  helps   to do  this is  the
state and  local  government  energy block   grant   bill.    This
bill, providing  approximately  $60  million  for   local  energy
strategies and  implementation,  would  be of great  benefit to
local governments.   An additional  incentive  that   should be
included in this bill, however,  is an incentive that encourages
local governments to  work through councils  of  governments  and
other associations of local  governments  to plan  for and imple-
ment energy management  actions.   The  economies  of  scale  for
coordinated programs  are   great,  especially  in   the  planning
period.  Our pilot project has  demonstrated  this  to the extent
that our other local government members have asked us to imple-

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            ment similar activities for  them.   One  of the main reasons for
            their request is  the  cost-effectiveness of working through the
            PSCOG.

                I very much  appreciate  this opportunity  to  share with you
            what we are  doing and heartily recommend  similar programs for
            implementation throughout  the  nation  for  all   energy  forms.
            Because of the Pacific  Northwest Power Act,  the  greatest need
            in the  Pacific  Northwest is  for legislation  to  implement for
            oil and  natural   gas  programs  similar  to those  authorized  by
            the Power Act for electrical energy.

DR. RIEGEL:     Thank you.  We are now ready for questions and discussion.

MR. POWER:      Mr. Danels,   I was curious as to why the City of Carbondale
            has a  thriving   conservation program  with  almost  no  Federal
            resources, and the City of New York asserts that  in the absence
            of Federal  resources,  it  would have  no  Federal conservation
            program at all.

MR. DANELS:     Well, for example, one problem we have is with the weather-
            ization program.   In  its  attempt  to  cut  Federal bureaucracy,
            the Department of  Energy  insists on different tests for eligi-
            bility for  Federal  program  monies  for  weatherization  than
            every other  Federal  agency,  that  is,  using  census  tracts for
            certification for eligibles.

                By using  individual  apartment  dweller   eligibility,  that
            is, going  into   the  ghetto  and  certifying  families in  each
            dwelling unit, when there  are maybe 18,  20,  25,  50,  150 dwel-
            ling units  that   have  to  be  certified all  together before  a
            building can  be  done,  it  makes it  virtually  impossible for
            the program to operate.

                That's one example of  how if DOE were  to come around with
            HUD and all  the  other Federal agencies to  certify eligibility
            for programs, it  would  make the implementation  of the program
            much better.

                Now our  conservation efforts  also  hinge on a different set
            of circumstances  energy-wise  in New York  City.  I really don't
            know the  energy   situation  in Carbondale.   In New  York  City,
            we don't  heat  with  electricity.   We  heat  with heating  oil,
            delivered by trucks to homes  and apartments,  and mainly multi-
            family dwellings.

                Teaching an  electrical   utility about insulation  of  homes
            when they're not  going to  save a kilowatt,  and in  any  case,
            have a  50 percent over capacity in the  system  as well  and  a
            shrinking demand in the system or a very small growth in demand,
            makes it  very difficult to  get  utilities  in the  area, particu-
            larly our  major   utility,  Con  Edison,  to  aggressively  pursue
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            conservation in New York City when the  demand  is very flat in
            the first place.

                So we have  to  look  for alternatives other than the market-
            place to  stimulate conservation  if  we're going  to  reduce our
            oil dependence.   It's  very  difficult  to  convince  a utility
            that sells electricity to get homeowners and apartment dwellers
            to conserve  oil,   which  is not  their thing.   They  don't heat
            homes.  Con  Edison  doesn't  heat our  homes.   We  don't have
            electrical heat.

                They had  it upstate where  it's  a  half  cent  a  kilowatt
            hour, but we're now paying 17 cents  a kilowatt hour for elec-
            tricity.

MR. POWER:      I had two questions  for Betty Kahl.   One was  a  remark in
            your presentation  where you  said you  felt  that  if  you could
            offer people low interest loans that  that would be very attrac-
            tive, and the  other,  I  guess,  issue  was where  you  said you'd
            like to provide no interest support for lower income households.

                Have you  done   any  analysis  looking  at the  LIEAP program
            just to see what kind of trade-offs exist in terms of providing
            — it seems  to  imply that  you  would suggest that people just
            have to  depend upon  the   assistance payments,  but have  you
            looked at  any  economic trade-offs   between  weatherizing  and
            just paying lump sum payments?

MS. KAHL:       Well, I guess  I would not recommend reducing the LIEAP pro-
            gram and  giving that  payment  to people  to weatherize  their
            homes, because  I don't think  they would  do  it,  because at that
            level, I don't  think people  generally  are aware  enough about
            what to do, how to do it,  and  I'm afraid the  resources  would
            not be readily available for  them to  do so.

                Plus, their main  concern at  that  point when  that  money
            comes through is paying  last  month's  oil  bill.   It's  not like
            they have money that's   just  saved  away  so  that  they  can get
            some weatherization.  The  money  is  going to pay  last month's
            oil bill, and  the  contractor, the oil  man is  calling them up
            right then and  saying,  hey,  we're going to cut  your  oil off,
            or the  gas  company  is   going to  cut the  gas  off  unless last
            month's bill is paid.

                People are continually  behind in  their payments  because it
            is so expensive, and  because  they live  in  substandard housing
            in which the energy efficiency is very, very low.

                I can see requiring  some low interest  weatherization pro-
            grams be tied into the LIEAP program,  but  only  if  you're not
            going to take away  money from the LIEAP program to pay for the
            low interest weatherization,  because  when you  do that, there's
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            going to be  a time  lag,  I think  ,  in the time  it's  going to
            take to get people's homes  weatherized,  and in that difference
            of time, people  are going  to have  some  real  problems heating
            their houses.

MR. POWER:      Do you attempt  to identify weatherization candidates based
            on the LIEAP program?

MS. KAHL:       That's what our program was.  All the weatherization candi-
            dates were LIEAP recipients.

DR. RIEGEL:     A number of witnesses today have pointed  out the rationale
            for continued  Federal  involvement in  conservation  activities.
            They cite  market  imperfections,  the  inability  of  the  market
            to reflect certain  forces  in pricing and investment decisions,
            and others.   Paul,  you were one  of those witnesses,  and you
            pointed out that information plays a critical role in assisting
            a consumer or investor who may have  a chance to come out better
            for an investment than by foregoing  it.

                Are there  any  particular  Federal   information  activities
            that you see  as being  meritorious  and  that the  Department of
            Energy ought to keep  in mind as it looks toward the future and
            its changed priorities?

MR. DANELS:     Well, first in  the area of  information, to give you a good
            example that we've encountered, we encouraged the Public Devel-
            opment Corporation, which is an industrial development corpora-
            tion to  develop  industrial parks  in the city, to  embark upon
            an audit  program.   They  could not  give  away  free  audits to
            firms in  the  city  when  they  first started  until we  became
            involved with them.

                We began  to just  knock on doors, and  then  we got the con-
            tractors to offer a guarantee, along with their audit, that if
            they were  to  institute these measures,  they would have certain
            energy savings.  Otherwise,  the firm would make up the differ-
            ence.  That the businessmen understood.

                So it's  that  information.   I mean  these  are  businessmen
            who we  were  talking to, not  homeowners.   These  are people who
            are looking at  their  bottom line.   But then again,  when energy
            is maybe  3 to  5  percent  of a business'  operating  cost, and
            you're reducing it to 2 1/2 percent,  you'd have a  lot of talking
            to do.   And  these   are  business  people  with  sound  business
            experience, and they're interested not just  in  net, but in net
            net.  The  auditing  firm could go  in and demonstrate on a cost
            basis, less  than  a  five-year payback.   Often under the Type A
            audits we  offered,  there  was  less than a  one-year payback on
            some of the measures.
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    They still  couldn't  sell  it until  they got  in there  and
did a hard sell on the  companies.  These are not  just the engi-
neers, but the mechanical people.

    Now in the  other area, there's  a  terrific  opportunity  for
what I think  is  a very low cost  program,  and that  is  the loan
guarantee program  for looking into  the  new urban  technologies
for resource  recovery,  district  heating,  cogeneration on  de-
centralized systems,  and  energy  cells.   These  are  things that
every city in the country can take advantage of.

    We see terrific  potential for  cogenerating district heat-
ing.  But these  resource  recovery plants  are  extremely specu-
lative, if you think  of what  Monsanto tried to do in Baltimore
a few years ago  and  the colossal failure  of  their effort.   It
was tried again  up  in New England with  some  more success,  but
to ask a municipality,  which  has its  back up  against  the wall
because of  the  Federal laws  against  landfills,  and  no  more
ocean dumping  and  with  good  reason,  because  of  the  leachate
problems and other environmental problems, we understand.  We'd
love to burn  garbage,  but  nobody really  knows  how  to do  it,
and the  European  experience  isn't   necessarily   transferable
given the mixture of  the  garbage we have  to  deal with.  These
are problems  that  the  cities  across  the  country  are  facing.

    We think it's an  appropriate role for the  Federal  govern-
ment to  provide  loan  guarantees,   if not  the  direct loans.
Give the  loan guarantees  so  that  we  can go  to  the  private
sector and have access  to the market,  because  these are consi-
dered by bankers  to  be  exotic technologies in  the  same way as
the conservation technologies.

    Talk to the  bankers.   We  go  and we talk to  our banks  all
the time.   We're  part  of  the  Office  of  Fconomic Development.
When you talk  to them  about  conservation, it's  still  exotic.
It still has  not  yet reached the levels  of  the man  who  gives
the loan to even  Helmsley Speer to  do work  in  their apartment
buildings,  and to say  the  least, the  owners of  19 unit build-
ings built in  1895 that  are  leaking  like  hell,  and we  can't
get them fixed up, because  they can't get a  loan at less than
21 percent interest,  and  that  shoots  the payback  period  when
you hit that  kind of  interest  rate.   So we  must  get to   the
banking community and  get them  to  understand that  there  is a
reasonable payback,  that  we're  not  talking  about exotic  tech-
nologies.   We're beginning  to  do that  through  our  office,   but
it would help  a  lot  if we  had  some sound information  coming.
Instead of negative  information  about  conservation,   positive
information about the value of conservation and its cost-effec-
tiveness and the value  of  it  as  a tool for economic efficiency
in our system.
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                Then I  think  in the  financial community,  as
            business community, things would improve.
                                               well  as  the
DR. RIEGEL:     Thanks very much.  We'll  go on now  to the next three wit-
            nesses:  Floyd  Ciruli,  Betty  Desper,  and  Charles  Lawrence.
            Floyd Ciruli is  from the Colorado Energy  Conservation Office.
            Betty Desper is  from the Total Action Against  Poverty organi-
            zation, and  Charles  Lawrence  is  from  the  New  Jersey Energy
            Research Institute.
MR. CIRULI:
Thank you,  gentlemen.  It's a pleasure  to be  here  today
            and discuss  with you
            the potential impacts
                  the  new direction  of energy  policy and
                  of  the significant Federal  budget cuts.
                I represent  the   State  Office  of  Energy  Conservation  in
            Colorado.  We were formed in  1977  on the basis of an executive
            order from  our  Governor.   The  Office  is  still  authorized  by
            executive order,  not  as a  reflection  of  the type  or quality
            of work that's  done,  because we do,  in fact,  administer many
            successful programs,   but rather as  a reflection of the ongoing
            lack of a  concensus   as  to  how long energy  conservation  is a
            vital need in the State of Colorado,  even though the evidence
            points out that conservation  is the  best way to go in terms of
            our import and fuel pricing problems.

                The Office is active in five major areas of energy conser-
            vation:  The Office plans,  monitors and evaluates energy acti-
            vities for  the   state and  local   governments, this  including
            developing the  State  Energy  Conservation  Plan;    the  Office
            informs state  and local government  and the public  on energy
            conservation problems and activities;  the Office prepares  for
            energy emergencies;   the  Office  coordinates  all  state   and
            local government  energy  conservation  problems  and activities;
            and the  Office  manages  energy  programs  such  as  the  Energy
            Extension Service,  the  Residential  Conservation Service   and
            the Institutional Building Grants Program.

                Energy emergency  planning is  one  of my  jobs, and Colorado
            will continue to  be active  on that even though there have been
            rescissions of much of the Federal  budget in  emergency planning.

                Our Office is mandated to coordinate state and local energy
            conservation programs,  including  LIEAP,  Weatherization,   and
            EES.  I'm here  today  to  discuss with you  our Office's efforts
            at coordination.   Because   we realized  that  conservation  and
            assistance programs were probably  in  some  trouble in terms of
            Federal support  last  January, OEC  began a study  to  see how we
            could best survive and  keep some  of  these programs alive;   how
            to pick those that are  best and most needed, how to coordinate
            them between  state agencies and how  to  fund them.  That study
            is being introduced  into  the testimony today. (This  report  was
            reviewed,but not  included in  the Transcript  due to its length.)

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    I would  also  like to  introduce  a  statement  from Governor
Lamm and  from  Mr.   Joe  Zettell,  the  Acting  Director  of  the
Colorado Office of  Energy  Conservation.  Both statements point
out that conservation in Colorado has worked, that the programs
have by and  large met their objectives and that  Colorado is on
the forefront  in terms of  solar and  other conservation activi-
ties.

    We have a  large weatherization program.  It allocated about
$5 million.   We  have a  LIFAP program under our  Department of
Social Services that distributed about $25 million this winter.

    It was a very,  very  mild  winter.   That was the main reason
we were able to meet  the   identified  public  assistance needs.
Our program directors feel  there will be probably substantially
less funds  next year, even in  the  face  of  increased prices.

    The "Management  and  Coordination"  study outlines  in  some
detail potential options for  improving the delivery systems in
Weatherization, LIEAP and energy conservation.

    The study has 35 overall recommendations largely discussing
the way current  programs  are  operating and  can  be  improved.
For example, the idea of one-stop shopping is introduced where
an individual  who is on LIEAP can get  weatherization,  can get
an audit,   can move  right   through  the assistance-conservation
system.

    One clear  problem the  study  identifies is  that LIEAP has a
tendency to fund chronic energy assistance households in need,
but never get  them  off  that continuum.  It  is not able to re-
duce their vulnerability by getting them  some  weatherization,
by getting their home audited, because by and large the programs
are fragmented in different departments.

    They are delivered by different systems and any coordination
that went  on was going  on  out in the field and was largely hit
and miss.

    The study concludes  that the new fiscal environment requires
the Governor, state  planners and program administrators prepare
for two possible eventualities:

(1) unless state and local money make up  the  difference,  FY82
    funds  for  energy  assistance/conservation programs will  be
    substantially reduced  from  the   recent  past  —  over  $1
    million less in  conservation funds,  and  potentially  $8
    million less in  energy  assistance;
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(2) if block grants are adopted,  the states will rapidly become
    the focal point for  a  massive battle  between  programs  and
    their support groups:  administrators,  legislators,  consul-
    tants,  and clients.   Unless  that  struggle  is  anticipated
    by state  government  and  accommodated  by   some  structure,
    final program decisions could be the  outcome of  a  survival
    of the  best-connected  or  most  vocal,  as  opposed  to  any
    rational planning   criteria.    But  the  federal  government
    must recognize the increased  state burdens  in administra-
    tive costs and continuing public needs.

    I haven't  followed  what's  going  on  in Washington during
the last weeks, and I  know it changes almost daily  in  some of
these House  and  Senate  committees  as  to  what will  be  in  a
block grant, what  won't  be in a  block grant or if  there will
be block grants at all,  or  just more categorical programs with
some flexibility or no funding at all.

    But, as  I pointed out,  if  the block  grants  are  adopted
here in  Washington, then there is  going  to be  a  major battle
in Denver between  current  administrative   group,  client groups
and their  representatives,  consultants and legislators,  sort
of our  own  iron  triangle will then make planning and coordina-
tion really  difficult.   This  makes it  imperative,   given  the
fact there's  going to be  less money,  that these  programs be
sorted out  in  a  rational and intelligent  fashion to the extent
possible.

    There is,  of  course,  significant  legal and  programmatic
momentum to  continue  current policies and  bureaucracies.  But
a window  of opportunity is  opening during the  next two  years
that may provide Colorado an  occasion to pick its best programs,
create  some  new  structures,  and deliver  needed   services in
the least bureaucratic and most cost-effective manner possible.

    We're prepared to adapt to the budget  cuts and Governor Lamm
and the  National Governors' Association are working  in  that di-
rection.

    It  is  premature to conment upon the  level  of support  that
can be  expected  from  the Colorado State Legislature for  energy
assistance  and  conservation  programs  because  of  the  current
lack of  information  on  exactly  what  Federal  support  that  can
be expected in FY82.   However,  the Legislature is  prepared to
go back into  session  later this  summer or fall to consider the
issue  once  the  Federal  budget and  program authorizations are
more firmly established.

    It  should  be pointed out that the  Office of Energy Conser-
vation,  which  is  over  90%  federally  funded,   has  reduced its
staff  50 percent  since January of 1981 and could  be terminated
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in January of  1982 unless  Federal  or state funds are provided.
Currently there is no state funding for DEC.

    The "Management  and  Coordination"  study  outlines  in some
detail potential  options  improving  the   delivery   systems  in
Weatherization, LIEAP  and  energy  conservation  and I  am pre-
pared to address  any questions that this  committee might have.

    In conclusion,  Colorado's  energy assistance  and conserva-
tion programs  have  heen  successful  in   meeting   real  needs.
The problems  of  increased  energy  costs and  oil  import depen-
dence continues.   And  although we  are  prepared to  accept our
share of budget reductions, the federal government must realize
that the state will have  a difficult  transition period during
program and  funding  changes  and should provide maximum support
for our efforts.

    The idea  of  my  testimony today,  at   least  partially,  was
to help  sensitize  the policy  leaders to  the  fact  that  we are
going to have  significantly increased burdens  in administrative
costs and  that,  although  flexibility  is   something  we  desire,
it brings  with it a lot of  responsibility  in terms of making
these programs work  at the local  level,  and  and we could use
policy support at  this  level  to  help  do  that.  I think that
will be  enough opening  statement  and I'll  be happy to answer
questions when you get back to me.
STATEMENT OF GOVERNOR RICHARD LAMM

    Given the facts  of  diminishing  supply and escalating cost,
the conservation of energy will  continue  to be a major challenge
facing this  country  over  the next  few  decades.   Colorado has
made much progress in this  regard.   We can hold our heads high
in relation  to  many  other  states.   But while  we have  made
significant strides, the  facts  of  supply and cost will require
new initiatives in Colorado homes and businesses.

    I would like to review the progress we have made  in Colorado
and the  distance   we  still  must travel  in  ad lusting  to  new
energy realities.

    Projected energy consumption in  Colorado decreased  by 5.2
percent in 1979, and by 7.7 percent in 1980.  The 1980 savings
is the equivalent  of the  current  natural gas  and electricity
needs of  the  City of   Grand  Junction for  the  next  20 years.
Residential energy  use,  which  accounts  for  1°  percent  of
total energy use in  Colorado, was  5  percent less  than projec-
tions in 1980.
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    In November  of 1980,  one  million Coloradans  received Low
Cost/No Cost  booklets outlining  14  energy  saving  tips  which
could be  taken  in the  home  at  minimal  cost.   Through  this
program, large numbers  of Coloradans  caulked,  weatherstripped
and insulated  their homes  and  businesses;  turned down thermo-
stats; turned  off  unnecessary  lights;  and  installed a  water
flow restrictor  in their  shower heads which  cuts hot water use
by 25 percent.

    Studies show that people who  invest $500  in energy conser-
vation measures  such  as  weatherstripping,  insulation and  storm
windows will  be  making money back in four years  or  less.   For
example, a  Colorado homeowner  using natural gas  could cut his
heating bill  from  $3,551  to  $2,644  over  a four-year  period
from 1981 to  1985.   This  savings  of $887  would  result in  a net
of $387 after subtracting the $500 investment.

    The number of  solar  systems  installed throughout Colorado
in the past two years appears to have doubled from the previous
two years,  to a  total  of  3000  systems.   These   3000  solar
systems saved  309  billion Btu's in 1979-80,  or enough natural
gas to heat 2700 homes for a year.

    These individual  efforts have been given impetus by actions
of the  Colorado  Legislature.   On  this issue,  the  legislative
and executive branches have worked  together most constructively,
making Colorado a  leader  in  conservation, solar  and renewable
energy issues.

    Colorado taxpayers can take advantage of  some of the high-
est tax credits  in the  country for installing  solar and  other
renewable energy systems  and for upgrading the energy efficien-
cy of existing homes  and  buildings.

    Under Colorado's  model code for energy efficient buildings,
more than  100,000  energy  efficient   homes  and   buildings  have
been constructed.  This   model code  has   been   adopted  by  87
percent of the local  jurisdictions in Colorado.

    Colorado has been especially  cognizant  of  the needs  of
low-income and elderly  citizens,   living  on  fixed incomes  and
facing skyrocketing energy costs.   The State Legislature provi-
ded $12 million in  utility relief  for the  elderly and disabled,
which was later  supplemented by  $28  million in  federal  funds
to help pay utility bills for low-income  families.  Additional-
ly the State administers  a  $5.2 million federal  program for wea-
therization.  Through  this  program,   the  number  of  low-income
homes weatherized each month has  risen a spectacular 115  per-
cent,  from 196 homes to 423.  We must expand the  State's weather-
ization programs to insulate the homes of  over  400,000 Colora-
dans living on $12,000 per year or less.
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    Schools, hospitals and local governments throughout Colora-
do reduced  energy consumption dramatically  under  the Institu-
tional Building  Grants  Program,   coordinated  by  the Colorado
Office of  Energy  Conservation.   More  than  550  institutions
have participated  in this program,  saving  1.6  trillion Btu's
— an amount  equal to the energy  contained  in 300,000 barrels
of crude  oil,  or enough energy to  operate  250 schools for one
year.  State government itself has invested significant dollars
in improving  the  energy  efficiency of  State  buildings.

    In the  area  of  transportation,  gasoline  consumption  was
down 3 percent in  1979 and nearly 5 percent in 1980.   One-third
of the  individuals  employed  in  the  Denver metropolitan  area
used public transportation,  carpools,  vanpools, or  rode bicy-
cles or walked to  get to work in 1980.

    Coloradans have  recognized  that conservation is the cheap-
est, safest  and  most productive  alternative  to  increasingly
expensive conventional  fuels,  and  the  most   effective  way to
combat the  crisis  of energy  costs.  And we  have  accomplished
this without sacrificing comfort or economic growth.

    But while we can be justifiably proud of  what we've done,
we cannot be  complacent.   Despite  the  fact  that we,  as Colora-
dans, are using  less energy, we  continue to  pay  more for it.
Natural gas rates  have  been  rising 20 to 30 percent per year;
electricity has  been ascending an average of 10 percent annual-
ly.  A  study  by the  Colorado Energy  Research  Institute (CERI)
reports that natural gas bills for a typical Colorado homeowner
will rise by  63  percent  over the  next year alone if the coming
winter is a normal one.   Natural  gas bills  could  rise as  much
as 137 percent  next year  if the  winter is an  unusually  cold
one.

    The progress  we  have  made  in the  field  of  conservation
and renewable energy  resources  is but a small step  on  a  long
road.

    Coloradans have  taken  the  low  cost/no  cost steps to  save
energy.  They now  face  major investments required  for alterna-
tive sources of  energy,  such  as  solar,  to further  reduce their
consumption of  fossil fuels  and  stem  the  tide of  increasing
prices.  These investments face  them  just as their discretion-
ary incomes are   being  devoured  by the  very price  increases
they are trying  to avoid.

    We must make  nore  financing   available  to homeowners  who
wish to make their homes  more energy efficient.   We  must  take
measures such  as  the  establishment  of  bonding  authorities
which would make  low interest  conservation  loans;   or  the
extension of  corporate  tax   credits   to lending  institutions
which offer  reasonable  loans  for  conservation  investments;

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or the extension  of  tax credits  for  conservation of renewable
energy measures to taxpayers regardless of their tax liability.

    Colorado has  indeed come  a  long way,  further  than  many
other states.  But there is no time to gloat.  Energy conserva-
tion is certainly an  idea whose time has arrived.  Non-renewable
resources are, by  definition,  finite.   The  law of  supply and
demand tells  us  that  finite  resources  will escalate  in  cost
as the supply dwindles.   Without minimizing the  importance  of
new exploration  and  development,  it  is  becoming increasingly
clear that  conservation is  the  cheapest  and most  efficient
form of  energy development.   Insulated  attics  and  walls can
be energy  sources every  bit  as  valuable  as  new  and  deeper
wells.
STATEMENT OF JOSEPH H. ZETTEL

    Like most  Americans,  we  applaud   the  Administration  and
    Congress' efforts to  reduce  budgets; however, we  are  con-
    cerned that energy  funds are not  fairly  allocated between
    energy resources.

    1.0 Real  world  of  energy problems  resides  in  the  States

        1.1 This  is  where  energy  is  produced   with  all  its
            impacts.

        1.2 This is where energy is used with all its benefits,
            problems, and costs.

        1.3 The  Administration's  efforts  to  abandon  funding
            for energy conservation imposes a  major problem on
            Coloradans who are being clobbered by rising natur-
            al gas prices.  Present phased de-control schedules
            already approved  by Congress  mean that next  win-
            ter's home heating natural  gas  bills will  be  24%
            higher than  this  year's,  if we have  a  normal  win-
            ter; and  46% higher if we have an  unusually  cold
            winter.  Total  decontrol  of  natural  gas advocated
            in some  quarters, would   result  in   an  unbearable
            burden on  our  citizens  far  exceeding  the  above
            projects.  Total  de-control  at  this  time is  not
            warranted.

        1.4 The  free market  approach  proposed by  the Admini-
            s'tration advances  the   theory that  rising natural
            gas costs  will  reduce  use.   The  validity of  this
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        theory is questionable because  there  are limits as
        to how  low  indoor  temperature  can  be  maintained
        in the  winter  without  health   problems  arising.
        Furthermore,  trying to  heat even  cold  homes  that
        are heat sieves is very costly.

    1.5 The only hope  for  the  homeowner/occupant to  reduce
        the impact on  the  wallet lies  in home  weatheriza-
        tion.   Improving  the   thermal  characteristics  of
        millions of homes  in America  is a horrendous task.
        The ultimate  in cooperative effort between federal,
        state, and private sectors is required.   The build-
        iung materials infrastructure can play an important
        role in  getting the  job done.    State   offices  of
        energy conservation can  continue  to provide a  ma-
        jor public role in conservation.  It is ironic that
        funding for state energy offices has been curtailed
        for FY 81 and may be canceled for FY 82.

2.0 Role of State Energy Conservation Offices.

    2.1 Maintain Energy Extension Service Offices throughout
        the state.

    2.2 Provide  complete  package  of  energy  conservation
        information about ways  to reduce natural  gas  con-
        sumption through  weatherization  and  conservation
        in every day  living.

    2.3 Participate in  energy  audit program for residences
        - work  with   utilities,  Residential  Conservation
        Service.

    2.4 Participate in  establishing financing packages for
        weatherization of  residences at  low-interest rates
        and easy terms.

    2.5 Promote  energy  conservation  assistance  for  the
        poor and aged   on  fixed  incomes.   Senator  Hart's
        "Retrofit Voucher" idea has merit.

    2.6 Promote  education  in  energy conservation  at  all
        ages and levels of society.

    2.7 Assist businesses combat rising  energy prices which
        impact their  costs and profits.

3.0 Role of Federal Government.

    3.1 Federal  government should  begin  to  withdraw  its
        support of state  energy conservation by providing
        block grants  to  the states to be used  for states'

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        energy  conservation  programs   speciftc  to  that
        state's  requirements.

    3.2 These block grants should continue until the  states
        are ready to provide funding independent of federal
        aid.  Possibly one to two years.

    3.3 Past errors in over-control by the  federal govern-
        ment of  energy  prices  have contributed to today's
        problems.

4.0 The  states  are  targets  of  energy  problems  such  as
    rising energy costs and the  perils of  petroleum  short-
    ages due  to  international  problems  beyond  the states'
    control.

    4.1 Temporarily, the  federal  government  must share the
        states'  energy  problems   even  though  the  federal
        government is  a  long  way  from  the  firing  line.
        State government,   citizens,  takes  all  the  heat
        from irate  constituencies  when  problems  of  cost
        and supply arise.

5.0 Balanced approach to energy survival.

    5.1 Nation  needs  bridge to  energy future  -  carry  us
        from gas and oil  era to  future era  of  solar photo-
        voltaics and other high  technologiy  energy systems
        such as  safe nuclear options.

    5.2 Bridge consists of many planks such as:

        5.21 Energy  conservation - quickest and least ex-
             pensive.

        5.22 Dwindling oil and gas reserves.

        5.23 Coal - most  abundant  fossil resource.

        5.24 Nuclear  fission  -  electric  power  generation.

        5.25 Solar,  thermal,  space and hot  water heating.

        5.26 Synfuels  from oil  shale and  coal resources.

6.0 All  energy  planks  need  continued  activity  whether
    that activity be research, demonstration and/or commer-
    cialization.

    6.1 Too  many eggs  in  too  few baskets  can be disastrous
        if  the baskets break.
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 7.0 Overexpenditure  on nuclear  power  at  the  expense  of
     solar,  energy conservation, and other  important  planks
     of the  energy hridge is wrong.

 7.1 We  strongly  urge  that your  national  energy  plan  #3
     contain a  balanced approach  through  judicious  allo-
     cation  of limited federal  energy funds.

 8.0 Average  Coloradan  cannot  play  an  important  role  in
     production of the  oil, gas, and/or  nuclear planks  of
     the bridge.

 9.0 But the  average person can make  a  major  contribution
     toward  energy independence  through  efforts  in  energy
     conservation and use  of solar technology, thereby  re-
     ducing  the rate  of  depletion  of our valued  fossil  en-
     ergy resources  and  at  the  same  time  reducing  the
     financial burden  of  millions   of  Americans  to  save
     energy  will provide 20-25%  reduction  in energy  use  at
     very low cost to consumers and  government.

10.0 Energy  conservation has already  shown  remarkable  suc-
     cess.

    10.1 Total  energy  consumption  in  Colorado was  reduced
         by  8% in 1980 below normal  expectancies.

    10.2 Nationally,   the  rate  of annual  increase  in  elec-
         trical consumption  was  less  than  2%,  in  contrast
         with about 7% in the earlier 1970's.

    10.3 Motor  fuel   consumption  in  1980  was  reduced  by
         about 15% below normal expectancies.

    10.4 This   success  story is  worthy  of   recognition  and
         continued support.

11.0 Emergency planning for motor fuel  shortages.

    11.1 Dependence  on  Mid-East oil  can  result  in  severe
         shortages through  war,  Russian  intervention,   or
         political chicanery.

    11.2 States need contingency plans  to handle  motor  fuel
         shortages -  also  completely developed  implementa-
         tion and  management plans.

    11.3 Federal government  cannot  create  crises in  energy
         supply and  then  not  share  with  the  states  the
         burden of coping   with  petroleum  shortages.   Our
         policies  in the Middle  East,  regardless of  valid-
         ity,  can  cause states  serious  problems.

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                   11.4 Block grants to states  can  keep emergency planning
                        alive until   the    states  assume   this  function.

               12.0 Recommendations.

                   12.1 Established balanced  approach  to  important  energy
                        systems.

                        12.11  Don't over-expend on  nuclear  at the expense
                               of other  important  energy  resources.

                        12.12  Support states' efforts  in:

                               12.121  Energy conservation -  both residen-
                                       tial  and   business   conservation.

                               12.122  Energy Extension   Service  activity.

                               12.123  Emergency planning  for major  liquid
                                       petroleum shortages.

                       12.13 Provide transition period  for states to assume
                             fiscal responsibilities for  energy  conserva-
                             tion and solar programs.

                       12.14 Achieve the above  within  budget  cut funds by
                             directing some of  the  nuclear funds to  other
                             important options  such  as  energy conservation
                             and solar.

DR. RIEGEL:     Thank you.

MS. DESPER:     I am Betty Desper,  Director  of  Housing  for Total Action
            Against Poverty.  I  have  operated a weatherization  program at
            TAP since  1975  and  we were one of the  first  community  action
            agencies in the nation to weatherize homes  of  low income  fami-
            lies.  As  of  June  30,  1981 TAP has  weatherized 1,400 houses in
            our service area.   This area  includes  5 counties  and 6  cities
            in southwestern  Virginia  and   geographically  is   mostly  rural
            in nature and encompasses 2,243 square miles.

                The  Virginia   Association   of  Community  Action  Agencies
            (VACAA) is the state level operator for the program.

                At present  there  are  29 agencies that  operate weatheriza-
            tion programs throughout the  state.  Of these agencies  15 are
            community action  agencies,  6  are  area  agencies  on  aging,  4
            local government and 4 single-purpose agencies.

                The Virginia  Winterization Program  has  been  in  operation
            since 1976, and  presently  covers about  85% of the  state.   It
            is funded  by  a grant  from the Department  of Energy (DOE) to

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the State Department  of  Welfare.  Welfare  contracts  the funds
to operate the program to VACAA.

    As of the  end  of 1980,  Virginia  ranked 12th in  numher of
homes weatherized nationwide  under DOE funding, hut  only 19th
in total funding allocations during the same period.  (Virginia
had weatherized  2.76% of all  homes  done nationwide  under DOE
funding, yet  received only  1.6% of total  funding  allocations
during the same period.)

    21,313 homes had  been weatherized  across  the   state  as of
February 28,  1981.   15,665  of these  were weatherized under DOE
funds.  (The rest were weatherized under funds from the Commun-
ity Services Administration, which sponsored the program before
DOE took it over in 1978.)

    In Virginia, homes  show an average 31%  per  year  fuel sav-
ings after they have been weatherized by the program.

    The program has  saved the equivalent of about  5.5 million
barrels of  oil since  its inception.   Of  the total  number of
homes weatherized to date:

    About 83% have been owner-occupied units.

    About 17% have been owner-occupied rental units.

    About 75% have been in rural areas.

    About 25% have been in urban areas.

    Virginia will receive about $3  million from DOE  for wea-
therization for  FY   1981.   The  FY  1980 grant  was about $3.2
million.

    In Virginia, according to  1975 figures:

    245,000 households have  income below  125%  of  the  poverty
        level

    734,000 individuals comprise these households.

    113,000of these households have elderly residents.

     30,000 of  these  households  have  handicapped  residents.

        53% of  these  households live  in  their own  housing.

        47%of these households livein rented housing.

        54% of these households live in rural areas.
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        46% of these households live in urban areas.

    Based on  DOE  allocation   and  production  figures  through
1980, Virginia is  spending  an average $840 per home (including
materials and  local  and state  level  operational costs)  to do
weatherization.  Comparing this figure with our current average
materials cost per  home ($511) shows  that  we are  putting 61%
of our  funds  into  weatherization materials  which  benefit low-
income people for many years.

    In response  to the  question on  the Administration's energy
conservation policy I would first  like to address the possibil-
ity of  the  weatherization  program  being transferred  from DOE
to HUD to be included in their CDBG program.

    I believe  that   it  would  be   an  administrative  disaster.
For example, HUD has no previous experience, no trained person-
nel and no mechanism in place to continue the effective admini-
stration of the program.

    Additional Federal dollars would be required to effectively
monitor and evaluate  the  program,  not taking  into  account the
length of time involved  for  the  transistion which would literal-
ly stop production  of  weatherization  activities and  decrease
service to low-income families.

    Secondly many  rural localities  do  not  receive  CDBG  set
aside grants.  Qualified families  in these areas would not be
able to receive these services.

    According to the  proposed  regulations,  each locality would
determine what programs had  priority  in  their  jurisdiction.
Localities that receive these funds have already made long term
commitments to their citizens  for  high  cost   structural  and
infrastructural improvements.

    Let us not kid  ourselves about  continued  funding  for wea-
therization through  the  block  grant  approach.  When  programs
and/or agencies  are  in competition   for  a  Imited amount  of
funds the needs  of  poor people are often  overlooked.   It will
then become a  matter of who  can write  the best  proposal and
who has the most clout with elected officials.

    I understand that Congress  is  considering several alterna-
tives pertaining to the weatherization program.

    The most  logical and cost-effective  solution   would  be to
maintain the  program in DOE  as  a  categorical  grant  with the
reduced level of funding.

    DOE has  successfully managed  and implemented  the program
since 1978.   The mechanisms  are  already  established and  in

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operation for  quality  control, monitoring  and evaluation, and
cost-effectiveness.  Trained  and  experienced  personnel  have
established communication with all state agencies to effective-
ly work  out  all  administrative   procedures   and  regulations.

    To even  consider  combining weatherization with other pro-
grams would  seriously  jeopardize the  effective  continuation
of the program.

    Another important  issue  affecting   the  operation of  the
weatherization program  is  the  proposed  elimination  of  the
Community Services  Administration (CSA).  To  my  knowledge the
majority of  agencies  that operate weatherization  programs are
funded by  CSA.   Few other agencies have  the  experience to ef-
fectively administer  the  program  without  decreasing  services
and increasing administrative costs.

    I believe  it will  be  necessary  to  take a  good  look  at
weatherization services.  The  weatherization   of houses  is not
a program that  can be implemented like  other federally funded
programs.  In my agency alone we maintain a  fleet of 8 vehicles,
retain warehouses in 5 locations,  supervise a crew of 43 work-
ers.  Inventory  of  all tools,  equipment  and   materials  with  a
yearly budget  of  $180,000.   Business  and   accounting  proce-
dures had to be  established and utilized  for  successful opera-
tion.  Our inventory  control system  was  so  effective that  it
was adopted  by the state.   Safety rules and  regulations  must
be enforced.    Quality  control  measures have to  be  initiated
and last  but  not  least   Federal,  state and  local  regulations
have to  be  adhered to.   Any agency  that  operates a  weather-
ization program  is  running  a top  notch business  that requires
all the  skills that are  necessary to  succeed in  the private
sector.

    For these reasons, before any new regulations are passed,  I
would recommend that Congress get  input from  experienced field
personnel who have  actually administered  a  successful program.

    In my opinion and  from  my own experience  I do  not believe
that there are  any  agencies that   could  successfully  and cost-
effectively operate this  program  as  well as  community action
agencies with DOE as the funding source.

    Why change  sponsors  when CAA's have six  years  of valuable
and very successful experience?

    In response  to  the  elimination of  the  CETA program,  which
has provided approximately  80% of all  labor   for  the program,
Virginia has  adopted   labor  waiver   procedures,  which  allows
agencies who produce to hire production crews  which will enable
the program to continue at a reduced level.
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               Also the  federal  regs have been changed to allow for  other
           supportive measures.

               As  to  the possible  limited  amount of  allowable funds  per
           house ($1,000-$2,000)  or  ($200.00-$300.00),  it  has been  our
           experience that  it is better  to provide complete weatherization
           of a  house   as   opposed  to  minimum  infiltration  measures.

               Complete  weatherization of houses would decrease  the number
           of units weatherized but  it is my belief that band-aid measures
           are never adequate or cost-effective.

               The weatherization   program   is  cost-effective   (cutting
           energy  consumption  from 20%-50%),  helps  to ease pressure upon
           the government  in the  long  run  as energy prices  continue  to
           rise, provides jobs, stimulates growth of conservation, weather-
           ization businesses,  provides  a  measure  of  self-reliance  for
           low-income, assists the  national  policy of  reducing consumption
           of fossil  fuels, and  is the  only  means  to  help  minimize  the
           need  and size of energy  assistance.

               In  order  to  help  the poor  better help themselves, weatheri-
           zation/conservation assistance should  be  a  higher priority.
           Study after   study  has  found  that  conservation is  the  least
           cost  and fastest method  of energy production,  is  cost-effective
           and becomes even more  so with each  energy price  hike.

               The energy   problems  of  the  poor  will  only  worsen  if  a
           concerted weatherization/conservation  effort  does  not   occur
           immediately.

                I would   sincerely   hope  that  the panel  and  all  persons
           involved in   the  critical   decisions  affecting  this   program
           seriously  consider all  information  received at   this  hearing
           for  the successful  continued operation  of the  weatherization
           assistance  program.

                I would  like to  thank you for inviting me  to  this  hearing
           and  giving me the opportunity to  speak today.

DR. RIEGEL:     Thank   you.   The   last  witness  for  this  group is Charles
            Lawrence.

DR. LAWRENCE:   Mr. Chairman and  members of  the panel,  for  the record,  my
            name  is Charles Lawrence,  and  I'm the  Executive Director  of
            the New Jersey  Energy  Research  Institute in Parsippany,  New
            Jersey.  I am pleased to have the opportunity to testify before
            you on behalf of my Board of Trustees.

                We  believe  the  Energy  Institute  is unique in  the  United
            States.  It   was initiated by the  private  sector  in 1977,  not
            to conduct research,  but to  act  as a catalyst  in stimulating

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projects with  near  term results  in  energy  conservation  and
energy production.   It  is a management organization  hacked hy
the technical  resources and brain  power  of  the  most diversi-
fied membership  of  any  such  organization  in  the  country.

    Furthermore, our  charter  mandates  the  use  of  existing
facilities and  expertise among  its industrial  and  university
members rather  than  by  the  expansion  of  the staff  of  the  New
Jersey Energy Research  Institute.

    Among the members are Johnson and Johnson, Prudential Insur-
ance Company  of America, EXXON  Research  and  Engineering,  RCA
Laboratories, Public  Service  Electric  and Gas  Company,  Jersey
Central Power and Light Company,  the Port Authority of New York
and New Jersey.  We have three universities sitting on the board
as well,  namely Princeton  University,  New Jersey  Institute of
Technology, Stevens  Institute  of Technology.   We  have Tishman
Realty and Construction Company,  the Lummus  Company, Englehard
Industries Division,  Widmer and Ernst,  E.    R.  Squibb and we
do have input from the  State  of  New Jersey  Government as  well,
namely the New Jersey  Department of  Environmental Protection.
Commissioner English  sits  on  our  board  and  our  Governor,
Brendan Byrne is on our board as well.

    As you see, many  of the companies  are  national in business
activitity and several,  in fact, are international, and they co-
ver a wide spectrum of  forms of business.

    I believe this distinguished  panel  will be especially inter-
ested in knowing that the Energy Institute has benefited from a
close working relationship  with  the U.S.  Department  of Energy,
but has sought relatively little in the way of federal monetarv
support.

    The bulk of our operating  funds come from  the private sector
with modest amounts of federal  money for initial study and plan-
ning purposes.

    We believe  it  is this  relationship  and  stimulus  that  has
been responsible for  many of  our achievements.   Before descri-
bing some of  them, let  me explain  that our most effective  role
has been  in  the area  of addressing institutional  constraints
that often prevent  or  delay  otherwise technically  sound  pro-
jects from succeeding.

    Technical considerations are often less  important than the
non-technical factors present in trying to implement proposals.
I would like to now report on  the major projects that the Insti-
tute has  undertaken  since its  inception and  then  on what might
be termed  conservation, but I would more  accurately call  them
projects  in energy system planning.
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    They are private  sector  projects,  that is,  they  have  been
built or will be built with the bulk of  the funding from private
capital.

    In each case,  however, as I've mentioned before, there have
been federal funds  made  available from the U.S.  Department  of
Energy and  the  Argonne National  Laboratory for  initial  study
and planning purposes.

    The first project  I'd  like to discuss,  I  think it's gained
quite a bit  of prominence  over the  years,  is  the City of Tren-
ton Integrated Community Energy  System, what  we call the ICFS.

    This has been  studied now for  four years,  and is  a  study
that will  result  in  the  construction of  the  nation's  first
urban cogeneration  facility  at a cost  of  about  $22 million in
our capital  city of Trenton.  It will produce high temperature
hot water for space heating and cooling as its primary product,
and as a  byproduct,  electricity.  In  other words,  this is the
reverse of the common total energy system.

    Four million square  feet of  office, residential and hospi-
tal space will be  served in  the  downtown  urban renewal area of
Trenton.  Incidentally, Trenton  State  Prison  will be  served as
well.  It will have an overall  efficiency  of  some 65 percent,
which is  about  double that  of-  our utility's net  power plant
average, and the system  will be  operated  only when there  is a
need for heating or cooling  in the buildings.

    The electricity  produced will  be   delivered to  the  local
utility grid, and  all customers   in  the Trenton  area  will con-
tinue to  receive electricity from this local  utility.  We will
not in any  way disturb the conventional means of selling elec-
tricity.  That remains the purview, the prerogative,  the busi-
ness of PSE&G.  I  might  add  that about 70 percent of the floor
space that we will  heat  and  air  condition will be  State of New
Jersey buildings.

    The total project cost in the testimony I've  submitted pre-
viously indicated $20 million dollars.  Well,  you know how bad
inflation is,  it's  now  $22  million for  the  total funding to
completion.  The project  will be finished  in,  I would say two
years.  Ground breaking  will be  September  21, 1981.  The total
research  funding  from Uncle  Sam will be  about $1.3 million.

    The next  project  I'd  like  to  talk   about  is a  26-story
office building known as Park Plaza in downtown Newark.  This
building  is  owned  by  Rockefeller Center,  Inc.,  and  leased to
PSE&G, Public Service Electric and  Gas, as their new corporate
headquarters.
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    This building  is  equipped  to  monitor  building  energy use
patterns and  to  measure  the effectiveness  of  the  various pro-
grams that we have installed and will be installing.

    It is important to  note that the  studies  will involve the
architectural and  engineering  communities  in  the  Metropolitan
New York area  as well,  within a radius,  I would say easily of
25 miles from Newark.

    The New  Jersey  Institute   of  Technology  and  the  Stevens
Institute of  Technology  will have  specific roles to  carry on
in this building.   In fact, we have convinced the two institu-
tions to  work into  their  curriculum,  data and opportunities
for their students to do  master's  and doctor's research within
the building.

    The instrumentation  built  into this  structure  will enable
it to be used  as a living  laboratory,  something,  I  hope, that
doesn't upset  Rockefeller  Center  or  PSE&G,  for  the  next  20
years.  The  information  coming out of  it  is expected to have,
with all due  respect, significant  influence on national build-
ing codes and  general energy management planning techniques in
the building community.

    But, I'd  like  to  point out  again,  I  know  that  many, many
conservation and study projects have  been  undertaken in build-
ings even  before the embargo.   In  fact,   I  was part  of this
activity when  I  was with  the  City of  New York Administration
under John Lindsay.

    Here we  have one of  the  major  builders and  investors in
the United  States, namely  RCI and  the   Tishman  Corporation,
engaged in  this  activity  which,  believe  me,   gentlemen,  will
have the very decided effect on the private building community,
not only  throughout  the  United   States,   but   worldwide.  The
total project is $80  million.   The  Federal research  funding to
completion is a shade under a million,  $950,000.  Incidentally,
I might add  that  as  we  are  collecting   data,  which will  be
coming in this spring and  summer,  a  number of manufacturers of
lighting equipment, and  fenestration, and  several  other types
of proprietary devices  have very  willingly agreed  to install
their apparatus  at  no charge  just for  the benefit  of  seeing
its performance in a real  life situation.

    The newest project  we have  is  the  redevelopment of  the
waterfront properties in  Jersey City and  Hoboken.   NJERI and
one its members,  the Port Authority of New York and New Jersey,
are working with the  Argonne National Laboratory in developing
the abandoned and  decaying areas in  New  Jersey on  the  water-
front for residential and light commercial purposes.
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    The intent is to  investigate  and determine the most energy
effective plan while  we're still  in the design stage  for the
new community.   The  projected total  project   cost  will  be  in
the order of  half a  billion,  $500 million.   The  total energy
research funding, and  I  hope  it  doesn't stop  at  this level,  I
hope to get more, is $95,000.

    We are not  totally insensitive to  the  needs   of  our young
children.  We have  been  involved  in  a program which has  been
rather successful and  promises even  greater  success known  as
the Student Exposition  on Energy  Resources,  with  the  acronym
SEER.  I don't want you to think that our only interest is with
big business.   The SEER program aims  to educate school children,
and for that  matter,  their teachers,  as to  their  obligation  as
future business and government leaders  and  workers to seek new
energy sources and more  efficient  energy utilization.  This is
done by helping the children construct  working models of their
novel ideas,   and  we hold an  exposition once a  year within the
state and now this is  being done  on  a national basis.  Now the
total project  within  New  Jersey  has been  $40,000, completely
contributed by the  private sector.   We have  never  sought  nor
will we seek Federal research subsidy for this.

    We have interest  in  coal  research.   NJERI has  assembled
and worked with  experts  in  coal  technology  of  the  leading
universities  in Pennsylvania,  Delaware and New Jersey in devel-
oping a  team  that could  address  and help  solve  problems that
are impeding the wider use of coal in the Northeast.

    We are rather concerned,  because we have very heavy depen-
dence on the  use of  oil.   Our  major  utilities  in  the  state
depend either  on  oil or  to  some  extent   on nuclear power.

    This coal  research project has $30,000 expended  thus  far.
Again, we have not sought Federal research funding.

    NJERI has   been  requested  by  and has assisted  several  of
our municipalities in  energy problem solutions and management.
NJERI provides expertise  from  our membership,  and  I  point  out
that this is  done without  charge,  that these  communities would
not otherwise be able  to obtain.

    For example,  NJERI is working with  Red Bank,  Rahway and
Jersey City at the present time in looking into the feasibility
of district heating and solid waste as fuel.

    Another major project which I hope will  be announced momen-
tarily for final  signing of papers  is the  Union  County Solid
Waste Project.   NJERI  serves  on the  Union  County  Solid Waste
Task Force and helped  the City of Rahway make  its decision  to
become the host  community for  a  2000-ton  a  day  solid  waste
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            energy facility  that  will displace the  current  use of 750,000
            barrels of oil per year.

                This facility will use the proven European method of water-
            wall incineration and will provide steam to New Jersey's second
            largest pharmaceutical company.  It will also generate electri-
            city and  it's  NJERI's desire  to help establish  within Rahway
            the district heating system.

                Incidentally, about  the  only indigenous  resource  we have,
            energy resource  other than  sun and  wind  is garbage.  We have a
            great deal  of  garbage.    We  have high population density.  Our
            state has the  highest energy density in the  union,  and we are
            looking forward  very  much to  being able to use  our major re-
            source, garbage, as fuel.

                As you  can  see,  the Energy  Institute has  a  charter  and
            operations that are consistent with the policies of the present
            Administration.  You  don't  hear  that  very  often,  do  you?

                It is the  catalyst for  carrying our research projects with
            maximum private  sector  initiative  and minimal  federal assist-
            ance.  Thank you.

DR. RIEGEL:     Thank you.  We can turn  to questions now.

MR. GLASSBERG:   Yes,  a  question for Mr.  Ciruli.   With  respect  to  more
            flexible grants to states and  localities to do energy conserva-
            tion, "'you mentioned  that in the State  of Colorado  with more
            limited funds  you  would  run into a  state  iron  triangle situa-
            tion.  Is the  panel  to  infer from  that  comment  that the claim
            for flexibility  at  the   state  and local level  for  programs  in
            order to  do more  rational  energy  conservation  programs  that
            are applicable  to  those  local areas  should be  —  is tempered
            by the political realities that these programs will be competing
            for funds  and  decisions might  be  made more  on  a political
            basis rather than on an energy conservation basis?

MR. CIRULI:     There is absolutely no doubt that in the state the Governor
            will definitely have  to  create a structure to  adapt the block
            grants to current  state  needs  and he's doing that now in terms
            of evaluating  these programs;  that's what my study was about.

                A couple  of other  factors  are  involved.   One,  if  there
            should be a  block  grant, we need to be honest  about  the fact
            that it won't  save that  much  administrative money.   So there
            will be some additional burden on the state.

                Secondly,  the grants need  to be shaped in a way in Washing-
            ton in which  a  lot  of  programs  that belong  in a  block  grant
            aren't allowed  to  lobby  their way  out  of  it,   so  that what's
            left are  a  few  minor programs.   For example,  putting energy

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            planning and EES  in a block  grant,  but leaving  out the other
            major programs,  such  as  weatherization, that  really could use
            some consolidation.   So  programs need  to  be  designed  in D.C.
            that will mediate these issues.

                For example,  if LIEAP has  some element  of weatherization
            as a part  of  it,  it definitely has  to  be  coordinated with the
            other major weatherization program.   It simply  would not make
            sense to leave  the program  fragmented, because  LIEAP  in  our
            state is administered  by  the  Department of Social Services, an
            excellent agency at  getting  a check to  a  person,  not particu-
            larly good  at   outreach  functions  or   at  referring  people  to
            conservation,  because they use new employees, temporarily hired
            for the  short  winter season, who are  inundated with paperwork
            to make sure the LIEAP checks are delivered to the right person
            on time.

                That job alone  overwhelms them  at  their  intake point  and
            undermines their  ability  to  do  all those  other  functions  in
            terms of referrals  and outreach  and moving a person along into
            energy conservation.   So  I think  that  if  a block  grant  came
            down that encouraged putting LIEAP together with weatherization
            and EES, it would be excellent.

                But there's  no  doubt  there  is  definitely going  to be  a
            political struggle, a  political  sorting out that has  to take
            place at the  state level, regardless  of what  happens  in D.C.
            To some extent, the legislature,  the current bureaucracies that
            manage these  programs,  and  of  course, the  Governor  will  be
            involved.  So at  both ends  there  is going  to be a political
            tussle to  try  and  deliver these programs  as  best  as possible
            with limited funds.

MR. GLASSBERG:   Which  programs do  you  think  will  receive  the  highest
             priority in Colorado?

MR. CIRULI:     I think that the  two programs   that  would get  the highest
            priority are  energy  assistance  i.e.,  LIEAP,   particularly  in
            the light of our natural gas price increases and weatherization,
            both programs  that have proven themselves.

                Now weatherization has a  problem  of  losing  its  delivery
            system in  terms  of  CSA.   Most  of  these  local CAP's  are  non-
            profit and maybe  can  survive by finding new sources of funds,
            but in the short term, there  is  going to  be tremendous admini-
            strative hardship.  We are beginning to shut  down  weatheriza-
            tion right now in many of our cities.

                My office  is  in  charge  of  the  Energy  Extension  Service,
            the RCS and IBGP programs, and in terms of saving wasted Btu's,
            the programs we administer are  the most  cost-effective.   But
            they are  dealing primarily  with  a  marketing  strategy to  a

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            middle class clientele, and to that extent, they would probably
            be put  on a priority list below helping people with emergency
            needs.  This  is one  reason  why our  office  got  involved with
            the coordination  study.   We feel  there's a  definite  role for
            DEC in  coordinating  these programs,  or  possibly  having one
            office to handle the  referrals and make sure that once a  LIEAP
            recipient is  identified  as having a housing unit  in  need  of
            weatherization  that the  service  would  be provided.   Currently
            no agency does  that.   It's kind  of a haphazard referral system
            between the agencies.

                One of  the  block grants had an interesting  aspect  to it,
            and that was  the  idea that for  local  governments  to get  funds
            it would have  to  do  an  energy   assessment, and then a certain
            amount of these funds,  20 percent, would  then be channeled to
            them.  It's  an excellent  idea.   Very  few  of  our  communities
            have done good  energy assessments  of what they  should be focus-
            ing on  in  terms  of  local  energy  supply,   use   and  needs.

                So that we  see it as a good strategy to  get better energy
            conservation planning at the local level.

MR. POWER:      I'd like to ask Dr. Lawrence if he could  describe what kind
            of administrative  arrangements are there between your clients,
            if you will, and the institute.

                Do you  receive compensation  or is  this done on  a voluntary
            basis?  You  know,  how confident  are  the  recipients of  this
            advice in the quality of  information  they didn't pay for  if it
            isn't paid for?

DR. LAWRENCE:   Invariably  those  involved  in the  projects,   if you look
            through them, and  I may just  refer back to them in  the order I
            gave them, the  City of Trenton,  that involved one of our  board
            members to begin with, PSE&G.

                I think  we were  essentially  asked  to  get  involved  with
            this largely at the request  of  the U.S.  Department  of Energy,
            to shepherd this  activity.  The  City  of Trenton simultaneously
            made the  request   and Park  Plaza, Tishman  again,  PSE&G,  are
            board members.

                I have  never   run into  a   question  where  our  particular
            judgment on the part  of  the board or  reports  were  ever ques-
            tioned as to validity.  That aspect has  never come  up.  You're
            the first one that's raised it.

MR. POWER:      Are the services provided free?

DR. LAWRENCE:   If a town comes to us, they  get this at no charge. In fact,
            the reason  why  we can do  so much  for so little  money  is,  of
            course, that  the   members  of  the  institute  have  assessments,

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            dues, that  they  pay in,  and  simultaneously,  they  provide  in
            kind, service with their staff.

                We call  upon  Princeton  to do studies.   The  Port Authority
            is doing  studies,  so  forth and  so  on.  This  is a  choice,  a
            determination, a  vote  on the part of  the board  members  which
            meet every other month.

MR. PFEIFFER:   Ms. Desper,  I was curious as to what the prospects are for
            the continuation of Total Action Against Poverty if the federal
            funds for  CAA's  are   cut  in  '82,  will  your organization  be
            able to continue?

MS. DESPER:     Well, in my housing component alone, we use very little CSA
            funds.  We have many  resources  — hopefully we will,  but at a
            reduced level.  I've talked with my Executive Director, Mr. Ted
            Edlich, and he's very  optimistic.  We  have  a rehab program too
            that we  operate  with  the housing  authority in the  inner city
            that we  get CD  funds  for,  so  hopefully  that will  continue.

                We have  a  housing  counselling program  that was  funded  by
            HUD up until this year, and I'm not sure what's going to happen
            with that yet, but we  do have other resources of funds and hope-
            fully could survive on a very limited basis.

MR. PFEIFFER:   Do you expect a  weatherization  effort to be able to  con-
            tinue?

MS. DESPER:     We have, at one point in  the Program — as I mentioned  in
            my report,  we  had  43  people onboard.   I  now have  nine,  and
            most of  these  were CETA people  that  I have picked  up and put
            on staff more or less  on faith.

                We've been allocated a  certain amount  of  State Department
            of Welfare  through  VACAA,  and if we produce,  we  get a certain
            amount of money  back  as program support, and hopefully  I can
            pay their salaries,  with the  change  in the  Federal  regs that
            allow you to pay for off-site personnel.

                So if we can produce, and given the fact that we can conti-
            nue to get enough funds, I would hope we could keep a weatheri-
            zation program in place until we get through the transition or
            whatever is going to happen.

                I do see us surviving.

MR. PFEIFFER:   I have one other question.     Do you really think it makes
            sense to continue with a program that does complete weatheriza-
            tion and  as a  result   serves  a very  small proportion  of the
            needy rather  than one  that  does partial or low-cost weather-
            ization  services and serves a great many more people.
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MS. DESPER:     Well,  we did both, and we  found  that actually with  trained
            personnel, we could probably do as many houses as we could with
            the low  cost/no cost program,  which  we  didn't find effective.
            We felt that it saved very little fuel to the homeowners.  For
            instance, if you insulated an attic  for  a  family,  and all the
            heat goes out  the  windows, you really haven't helped them that
            much, because there's not  enough  money really to be effective.
            That was why we decided  or we felt like it was better to fully
            weatherize a house.

DR. RIEGEL:     Just before  we take a short  break, I'd like  to thank the
            three witnesses  for appearing.   We'll reconvene at 3:10.

                (Whereupon,  a brief recess was called.)

DR. RIEGEL:     I would like to get together again now,if we could, please.
            The next  witnesses  are  Joseph Prano from  the  City  of Terre
            Haute, Indiana;   Richard  Kline  from the  Appalachian  Regional
            Commission; and  Howard  Brown,  energy advisor  for  Middletown,
            Connecticut.

            Okay.  Mr. Prano, if you could begin.

MR. PRANO:      First off,    I would like  to issue a  disclaimer before the
            City of Terre Haute.  Our  agency  just happens  to  be located in
            Terre Haute, Indiana.

                I guess that will lead into parentage  and  why I'm here.  I
            was the Director of the weatherization program for  Vigo  County
            and the county  offices in  the city of Terre Haute,  and  it was
            under the CAP program originally in  1979 when I went  aboard,
            but we had  a problem that  some of  the  CAP agencies  may have
            had.
                The weatherizatiion program  was a  very small part  of  its
            overall activities.  In fact, weatherization in Vigo County was
            only 4 percent  of the  agency's  function when  I went  aboard
            in September of '79.   In March of 1980, I had built the program
            to $2.3 million, and  it  had become 84  percent  of the agency's
            activities, and because  of that,  it  now took  on a  new focal
            point.

                Before, it was something that you  didn't worry  whether or
            not you received  funding  or  continued funding  for to  where
            everything evolved around  it,  and  because of the problems that
            it built  by growing so quick,  the  inner struggles required the
            Department of  Energy,  upon  recommendation  of   the   state,  to
            pull the  program away  from the CAP agency.

                At that time,  I  had  to  look for  a new parent,  because  I
            could not  adopt the weatherization program  for  myself, and  one
            thing we  did with  building the program is we started a  coali-

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tion of  the  union,  the  Carpenters' Local  133,  and  I  made a
suggestion to them  that  they  become  the parents for the  wea-
therlzation program, and they  submitted  a proposal  under their
not-for-profit charter, their  funds which  are their health and
welfare, and  they  were  granted  the  weatherization  program
which they delegated back to me, and we  continued weatherizing
homes.

    We averaged 250 homes a month completed, spending an average
of $525  in  materials.   We  lost our  CETA personnel  under the
CAP program on October 31 of 1979.

    We operated the program without CETA, per se, and we devel-
oped other state  employment  projects  into it.   A lot  of bypro-
duct benefits were  training,  and we  also got  people  into the
union who would have never had the opportunity to become a part
of it, and we created  job  skills through our training,  and ex-
posed them  to  the  world   of   existing   on  your   own  merits.

    So, you  know, people may  look upon CETA  as a  loss;   we
looked at it as a benefit,  because we were able to employ func-
tions that DOE  allowed us to do that  Department of  Labor would
not allow us.

    There was interagency agreement,  but all rules  and regula-
tions weren't combined to make it- work.  Okay.  We had overrid-
ing regulations.  Like,  I couldn't,  for  example, subsidize De-
partment of  Labor employees  by more  than  10 percent,  which
means that  I couldn't  effectively upgrade  them into  a union
trainee program,  because of  the  fact  that their wages would no
longer be in  line with the maximum increase,  which means that
because I was teaching  people to   be  more  independent  and  do
more and  teaching them how to  do  that,  that I  could not hire
them onto our program if  they come from CETA or  those types
of, agencies  that had  restrictions.   So  it  took  on  a whole
new outlook and naturally,  as you all are aware, weatherization
in Indiana  ceased  to  exist  on March  13 of  this  year.   The
reason for that is, we ran out of operating capital.

    Here's another  inefficiency  of  government.    If  you are
pushed to produce more, and we  were all  told by Federal Regis-
ter and  by  the  Department  of  Energy  that  we will  be funded
based upon  our  accomplishment.  The states  that  were not pro-
ducing would  be funded at a smaller level.

    The state in  turn  passed it down  to  the  individual agency.
We had 31 operational  arms of  the weatherization  program in  the
Indiana, and  every  one  of  them worked at   different  levels.
But what  happens  here,  because  we  produced  more,  we   ended
up with the biggest part of the state's  funding.
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    In fact, we were operating at 26 percent of the state's al-
location, which in my opinion is  unfair because of the fact that
we had only one county of the 92 counties that exist in Indiana
under our sponsorship.  So we were able to complete one-third of
our households, our  eligible households  in  one  calendar year,
where other agencies  were only able to  complete maybe  1  or 2
percent of their total eligible households.

    So there needs to  he  a  lot  of things turned around on that
basis.  I  have submitted a  proposal  to  the State  of  Indiana,
not knowing who the funding  source is going to be, for a state-
wide weatherization  program  sponsored  by  the   Indiana  State
Council of Carpenters, so  we  can operate the same thing but turn
around and try to be  fairer  in  our distribution of allocations
to the entire state.

    I could  go on and  on and on about  all  of  the benefits of
our project.   Some of you have probably heard about it.  If you
have any questions, I'll answer them at the end of this.  Thank
you.

(Following are specific recommendations  submitted by Mr. Prano
on the Weatherization Assistance Program (WAP)).

1.  Maintaining Weatherization.

    The maintaining of Weatherization with DOE would give every
State a  clearing  house to  transfer the needed  reports and/or
review house which  where-by  they can receive opinions or deci-
sions from as  they  relate to the allowable  activities  of WAP.
If it is  not done thru DOE  I strongly  would  support  that  the
weatherization program  be maintained  as a  categorical  funded
project, with  assurances  that this  activity be consistent with
the program objectives.

2.  Benefits of WAP to fixed income individuals.

    The benefits  of  this  type of program are very numerous not
just in the conservation  and the  logic of us all  reducing waste
but more significantly as  this relates  to those on fixed income,
who are  forced to reduce but cannot afford  to do so properly.
The WAP  project  can  be  measured in  real  dollars not  only in
savings but as it relates to each project undertaken.  When  you
consider a 40% reduction  in  consumption and a maintenance of a
more uniformly heated/cooled dwelling,  this becomes  the most
logical project we  can undertake.  The benefits of:  jobs,  job
skill development,  training  of  future  private  weatherization
employees and/or  specialists,  these are just  to  name  a few of
the by-product benefits  if  properly implemented are as equally
beneficial as  the project itself.  The next logical step is to
correlate  this with LIEAP.
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3.  Uniting WAP with Low Income Energy Assistance Program (LIE-
    AP)

    Running LIEAP with WAP can  produce many more by-product ben-
efits, one being application eligibility forms and the correla-
tion of these two good programs, plus the amount  of assistance
provided under LIEAP could be  reduced  by the  amount of reduced
consumption after weatherization,  thus  allowing WAP  funds  and
LIEAP funds to  reach  more  of  the  eligible households.  Person
power needs are somewhat  reduced by combining these similar pro-
jects and this would then directly reflect to the amount of peo-
ple serviced and  the  cost  of  administrative  overhead.   From a
business/management  point this too is very logical.

4.  Suggestion for Statewide Proposal.

    Statewide special  purpose  programs   could  be  set  up  espe-
cially with these two  projects (WAP &  LIEAP).   One suggestion is
the one proposal  we have  submitted  to  the  State  of  Indiana.
This one asks the state to select as their sub-grantee the Indi-
ana State Council of Carpenters to be designated as the service
delivery arm for  WAP  in  Indiana.   We feel this would  allow us
to come up with  a  fairer distribution  of  the State funding levels
and afford  us  a  better  way  of implementing  uniformity  to  the
states' eligible applicants.

5.  Reporting of project  activities.

    It would be  very useful to have a central  reporting  of all
the activities of WAP as  I suggest in  (1.), this will be the only
way the nation as a  whole may benefit from the exasperations of
others who have gone the  trial and  error route  and need to share
the successes to the general public so they know where their dol-
lars are  going.   In  so  doing  we are  continually  educating  the
people of the ongoing need  for conservation  and helping to de-
velop a growth  in the industry by publishing all the statisti-
cal data  that  could be   generated  from  a central clearinghouse
reporting system.  In my opinion all  projects should be report-
ed on and should  be responsive to  where the  funding source for
without reports you create an  opportunity for abuse and project
neglect that would subsequently  jeopardize all fundings  of any
kind.

6.  Future funding of  projects.

    We should know  in advance if  possible  what  our  next two-
year projections  for  funding will  be  and   what  lies  beyond
that.  The  reason for this is  so  we can develop  the strategy
as to  where do  we go from here.   We are looking towards that
area and  it  is  our  opinion  that  what we have proposed  to  the
State will  allow  us to  do  just that.   We intend to be  set up
to spin-off  into  the  private  sectors competing for the private

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DR. RIEGEL:
MR. BROWN:
dollars by demonstrating  our abilities to deliver  the  WAP ef-
fectively, cost-efficiently  and  thru a  General Contractorship
that will remain  ongoing.   Through our project we  want to de-
monstrate that  the  construction-oriented  projects  that  the
Federal Government  is  involved   in  may  be  best   served  thru
this type of mechanism.  We  do need  to have  our goals laid out
in advance and we do  need  to know the future funding levels at
least two, preferably three years ahead,  so  we  can  complete
what we start wihout opening ourselves to liabilities that can-
not perpetuate the  goodwill  we  have worked  long  and  hard  to
develop.  (See Appendix,  Volume  III for Mr.  Prano's  proposal
for the State of Indiana).

    Thank you.  Mr. Brown is next.

    I'd like  to introduce myself  first.   I am a trained city
planner who for the last 12 years has been involved in resource
management issues from  the neighborhood level  to  the  interna-
tional level, and I'm a lecturer in  resource  planning  at  Wes-
leyan University.

    I'm here in a particular capacity.  For the last two years,
I have been serving on a very part-time basis as energy advisor
to the Mayor of Middletown, Connecticut, which  is a small commu-
nity of 40,000 people in the  center  of  Connecticut, and a pro-
gram — a community which has taken part in a very unusual Fed-
eral program which  I'd  like  to discuss with you.   But I'd like
to take  a minute,  if  it's okay,  to say something  in  general
about energy  conservation programs,  and then  to  address the
community energy project  of the  Federal ACTION Agency  in that
context of  our  experience  in  Middletown  with that  program.

    As someone who  has  been involved in energy programs  for a
long time, and many,  many different  programs,  I'd like to take
this opportunity to express  my  strong support  in  the  need for
the Federal government  to remain involved  in  energy conserva-
tion and  small-scale  applications of solar and alternative en-
ergy technologies.  I feel  that  these programs are extremely
consistent with  the present  Administration's   approach  to the
marketplace and  moving the  country  towards  reliance  on the
marketplace to solve its energy problems.

    I have been doing  some research, which,  if I hadn't come here
on such short notice, I could have possibly finished to bring,
the work looks at the impact of  energy conservation and alter-
native energy technologies  on communities,  the economic impact
of these kinds of programs compared to, for example, traditional
economic development, for example,  what are the benefits  to a
community which helps its  citizens save  money, energy dollars,
compared to the  economic  benefits of bringing  in  new business
which will consume energy into a community.
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    Preliminarily, the research shows that saving energy can he
one of the most sophisticated and effective ways of stimulating
a local or state economy that exists.

    Now in defending energy conservation solar programs, I want
to make it clear that  I'm not defending or advocating all of the
particular programs which  have been  run  by  the  Department  of
Energy and other  programs,  because I feel  there  has  been very
much waste and  inefficiency  in the way that  numerous  programs
have been run.  But  I'm not here to discuss that specifically.

    I feel that the programs which should be left at the end of
the budget cutting procedures  should  be  those which neet a set
of very specific  and  useful criteria, that they  should not  be
programs that  subsidize bureaucracy, but  ones  which  minimize
overhead and  minimize  immediate  impacts.   There  should  be
programs to  encourage  conservation  at  all  levels and  at all
sectors to encourage  small-scale  solar  and  other alternative
technologies and the diversity  of  those  in the  marketplace and
to protect the marketplace in the energy field.

    Particularly I feel one  area which has been enormously omit-
ted is the area of passive solar energy,  and omitted and misun-
derstood.   But to do these kinds of programs, I think it's impor-
tant that  specific program targets be evaluated on the basis of
their ability to serve as initiators and motivators to communi-
ties, small businesses and  others to get  started on programs,
not to fund  from  beginning  to  end with  enormous Federal grants
and programs.

    The programs need to encourage  — they need to include in-
centives,  like  tax  incentives, incentives  to state and local
governments to run loan  programs.   The RCS  program, for example,
for energy audits  by  utilities,  loans  and grant  programs for
non-profit organizations, small grants can have an enormous im-
pact and an  example of  that is the  Department  of Energy Small
Grants Programs which has taken — given into the hands of peo-
ple who don't  have access  to   capital—very  small amounts  of
money.  It has a  low  operating overhead.   The  selection  of
grants is  made  by  volunteers  on a state by  state basis.  It's
locally controlled.  It's an extremely effective program that's
had an enormous  impact.  PURPA  is  a regulatory  program which
has the effect  of protecting,  not  retarding  the marketplace,
and I  think  that  regulations  need  to  be  evaluated   on  that
basis, not all thrown out.

    Now, in converting to a marketplace energy economy, I think
it's extremely important to  recognize the  need  that we have to
help the poor and the near poor who cannot afford to capitalize
the transition  to  an  energy-efficient  society,  and  there are
ways of helping those  people which can be cost-effective to them

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and to the government  and to local  economies,  and I think that
we need to look at those programs as well.

    Now, specifically,  one program which  meets  the criterion,
I think, very  effectively that  I wanted to talk about a little
bit today is  the  Community Energy Project which  is  run by the
Federal ACTION  Agency  under an  interagency  agreement  with the
Department of  Energy,  which supplies  funding  for the program.

    This particular program  began in  a pilot project in Fitch-
burg, Massachusetts about  three  years ago.  The program was de-
signed to use  the  techniques and philosophy of  DOE's  no cost/
low cost program,  but  to  do  it  by putting the  power of organi-
zation into the hands of the local community in which case Fed-
eral funding would only be used  as an incentive to help get the
program off the ground, to motivate the local  community,  and a
kind of  catalyst.    In addition,  the  ACTION agency  provides
a kind  of  ongoing  technical   support  when  it's  necessary.

    The City  of Middletown  was one  of 18  cities  selected  in
the United States  to  be  the  next  round after the  first pilot
project for  carrying  out   this  program.  The program  is  short
term.  It has  immediate  impact.  It  has  a single  objective,
reaching a lot of people very  quickly.  Its  success depends
completely  on  citizen   mobilization,  the  use  of volunteer
agencies.  It often does,  as in  the case of Middletown, utilize
volunteers and community groups  like the Girl Scouts,the Police-
men's Benevolent Association and others.

    Local businesses and banks have gotten involved, the utili-
ties.  There is virtually  no  bureaucracy.  A coordinator who was
hired on a six-month  basis for   the term of  the  program.   When
the program was over, everyone understood the coordinator would
leave.

    Because the funding is minimal, it  absolutely requires crea-
tivity and imagination  on the part of  the  communities to make
them work with the amount  of money available and in piecing to-
gether the other resources.  It  does not require a lot of tech-
nical understanding.   It's a self-help program.  Most people do
it themselves.

    People in it are  responsible for taking  their own energy fu-
ture into their own  hands.  The communities that  have done  it
have developed enormous pride in this program as being selected
as the cities  to do it, and  often they  give  it their own name.
Each program has had its own name,  its  own ground rules, its own
approach, and  it has worked  effectively in the large number  of
cases.

    Now, one other characteristic of the program is that it does
not involve the imposition of a lot of  Federal regulations on the

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community in terms of how it should be carried out.

    In Middletown, when some members of the city government be-
gan talking to  the ACTION  Agency  about making  Middletown the
site, I had just come onboard into  the  city  government and was
extremely skeptical  of  the  program  and  of  the  city jumping
quickly into a program  as  the  people from ACTION  were encour-
aging it to do.   They were  saying  that,  no, you  don't  really
need to do a  lot  of preparation.  You  really just need to get
in there and get your hands dirty and do this thing.

    I had had enough  experience  with Federal programs to  know
that usually they didn't work in communities.  The outreach as-
pect is usually a  failure,  just  as it involves  subsidizing po-
sitions, et cetera.

    We reluctantly got involved in the program.   We began to —
we started late,  in fact ACTION  actually began to  be annoyed
with us  for  sort  of  spinning  our  wheels  a little  bit  at the
beginning in  getting  started.   We  finally  brought a  coordina-
tor onboard and  began piecing  together parts  of  the program.

    We set  up an  executive board  of  community organizations
which began developing plans and  set  a  goal  of  reaching 800
households out of  10,000 in the community.

    The program was  to  run  for  six months.  We  gave it a name
called MSER, Middletowners for Saving Energy Resources.  We de-
signed workshops.   We began to  contact landlords  to overcome
some of the traditional problems of energy conservation in ten-
ant, rental housing.

    We began  to get local businesses involved.   Businesses  star-
ted contributing in-kind contributions, the printing of materi-
als and numerous other things, loaning  office supplies, all as-
pects of operations.  The local press became enthusiastic.  The
local realty  association became so  enthusiastic, they  organized
a  large energy fair to kick  off this program.

    In carrying out  the  program, we found that  it  far  surpassed
the initial goal reaching 1200 or  12 percent of  the  entire hou-
sing stock  of the  city,  and the  program was so  successful that
it was  selected  by a private foundation  as  one of  five cities
to carry on in a  second  round, and  we  intend to  go from 12 per-
cent to  25  percent of the  city's housing stock  to  reach in the
second six-month  phase of the program.

     The  local utilities, as  I said, have played  a  large role as
well.  Now  all  of this grew out of a $5000 ACTION grant  and  a
commitment  by the Department of  Energy for this program and to
make available  some of  its  weatherization  funds  through its re-
gional office to  be used for the purchase of kits.

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                 In  addition  to  the direct  impact  of  the  program,  which
             is  saving  Middletown residents thousands  and thousands  of dol-
             lars, the  program was  cut  off  at  the  end  of  six  months,  because
             that's  what  it was designed  to do,  and  the interest  in the pro-
             gram on the  part of  the community was increasing geometrically.

                 That is, the people coming to the  workshops for the training
             to  install their kits  was  increasing  so rapidly,  and  it  was
             stopped right at the peak  of its  success.

                 The program, at  least  as important as that,  kicked  off in-
             terest  in  the community in other energy  conservation programs.
             Now the City of  Middletown has considered seriously floating  a
             million dollars worth of general  bonds for the purpose of making
             low-interest loans to members  of  the  community for more  compre-
             hensive energy conservation programs.   It  has served as  a  model
             for several  legislative efforts, and the  bills  that passed the
             state legislature, and  it  has served  as  an  impetus  to  improve
             the effectiveness   of  the   local   weatherization  program.

                 Now, I want  to go  back to the whole just to conclude  for  a
             moment,  and  say  that as we  experience  this  shift of responsi-
             bility  from  the  Federal  to  the local  level  that's  going on
             under the  present  Administration,  municipalities  are increas-
             ingly being  left  with  the  responsibility of dealing  with  the
             impacts of rising energy prices and the energy crisis in gener-
             al,  and without the  resources  and the responsibilities and  the
             experience to deal  with it.   Programs need to  be designed to
             allow and  encourage  communities  to  effectively take  on  this
             problem.   People are going to  be cold.  The  Federal government
             is  not  going to  be  taking  responsibility for  keeping  people
             warm.
                State government  is  also not accepting that responsibility
            and where it  has,  it has demonstrated  itself  in most cases to
            be a miserable  failure.   So programs need to be designed, as I
            said, to help cities, and I  feel very,  very strongly that this
            community Action  program,  this  community energy  program with
            the ACTION agency is one of  several examples of extremely crea-
            tive low cost to  the  government  programs  which can have a very
            significant impact on — at  the  grass-roots levels.  Thank you.

DR. RIEGEL:     Thank you.   Next is Dr. Richard Kline who comes to us as a
            Spartanburg City  Councilman  and  Chairman  of the Energy Subcom-
            mittee of the  South  Carolina  Appalachian Regional  Council of
            Governments.

DR. KLINE:      Thank  you for the  introduction.   By way of  professional
            training, I'm also a  chemical engineer with  a  Ph.D.  Degree in
            engineering from MIT.
            neer and  am a  member
            Engineers.
I'm employed by W. R.  Grace  as  an engi-
of  the  American  Institute  of  Chemical
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    In preparing for  this  talk,  I polled the municipalities in
the six-county northwestern region of South Carolina and compa-
nies of the members of the  Chemical Engineering Society and also
got input from the League of Women Voters.  My presentation to-
day, which basically follows the  outlines of your issues prepar-
er, is a composite  of my own experience and the information that
I've gotten from these people.

    I'd like  to  say  first that  people  in  our  region  rather
strongly support the  new Administration's initiatives to allow
the free market  to handle  the energy problem.   As a practical
matter, the  rising cost  of  energy  is  the  only  reason  that
people in our  area have  any serious interest at all in conser-
vation or  generation  of energy  from other  sources.   We  take
pride in  other  considerations,   such  as  patriotism,  social
concern, et  cetera;   but  these   are  not  the  reasons that  we
make economic decisions.

    As to  the  previous  Administration's  policy,  Attachment #1
which is on the seventh  page of my paper,  lists the  12 grant ap-
plications that came through for energy conservation in our re-
gion last year.  In addition to the amount of money asked for and
the amount received,  we  have compiled a  rough  estimate  of the
cost that each organization  incurred  in asking for this monev.
The costs of applying for the  grants were on the average roughly
10 percent  of  the  amount  of money  that  the  groups  received,
and a number of  qualifying  applications  were not funded to any
extent at all.

    As to the effect of  the  new Administration's policy, I think
the first and most important thing to realize is that the local
governments in our region view ourselves primarily as providers
of traditional governmental  services:   roads,  water,  sewage,
public safety,  parks and recreation, et cetera.  We view energy
conservation as it  impacts  us, as something that we wil] do our-
selves to  make our  organizations more  efficient.   Therefore,
we will probably continue  without the  Federal  funding,  albeit
at a  reduced  level, funding  the energy  conservation measures
that we are doing.

    My second attachment is  a  three  page  list of the energy con-
servation measures  being  taken  by  the   City  of  Spartanburg.
We're probably the most active   city  in  the  region,  but  the
measures that  we're  taking are  typical  of  the  measures  that
are being taken throughout  the region.

    The industries in our region generally don't publicize their
energy plans,  but  they  are engaged in  energy  conservation for
the sane reasons  we are, economic.  And the concensus among them
is that they want  the Federal government  to  leave them alone.
They got nothing from the  grant  program.   They  expect nothing
from the new program either.

                      158

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ATTACHMENT #1
FEDERAL ENERGY GRANT APPLICATIONS FROM THE SOUTH CAROLINA APPALACHIAN REGION
                                             Amount        Amount     Application
                        Purpose              Requested
Applicant

Gaffney, Easley,
 Seneca, and Greer
 Boards of Public
 Works
                                                                                         Dollars Received
                                                           Received   Preparation Costs  per Dollar Cost
                        Alcohol Fuel Demon-  $337,500
                        stration Project
Appalachian Resource    Greenville-Spartan-    82,000
 Recovery Study Com-    burg Incinerator;
 mittee                 Resource/Energy Recovery
                        Studies
City of Seneca

City of Easley

City of Spartanburg


City of Spartanburg


City of Spartanburg



City of Greenville


City of Seneca
                         Seneca Incinerator      15,000*

                         Easley Incinerator      15,000*

                         Energy Conservation     17,014
                         at City Hall

                         Solar Energy for Swim   49,250
                         Center

                         Energy Conservation     28,125
                         at Rec. Centers
                         (4 applications total)

                         Solar Heat Reflective   17,434
                         Film

                         700 kw Low Head Hydro-  40,000**
                         electric Generator
City of South Carolina  ARC Energy Plan Update
                        for Grant Qualification
                                                            $285,000   $10,650
                                                              15,000     7,650
15,000
15,000
17,000
1,050
800
1,050
                                                                        1,050


                                                                        4,300



                                                                        1,310


                                                                        3,250


                                                                        1,500
TOTAL
*   Applications solicited by state.
**  Loan only.
*** Total for all applications.
                                              $601,323     $347,000   $32,610
$26.76
                                                                                             1.96
                                                                                            3.49**

                                                                                           18.75

                                                                                            2.66***
                                                                                            $10.64

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ATTACHMENT #2

CITY OF SPARTANBURG:  ENERGY CONSERVATION MEASURES



At City Hall:

Install a microprocessor controlled energy
 management system, using a 50/50 state
 grants.  (3 year payback)

Install a demand recorder to register demand
 for every 30 minute period of the day.
 (Duke Power, which hills on a peak demand
 load system, provided the recorder.)

Start cooking on the electric stove in the
 jail only after 5 pm. to reduce peak demand
 load.

Replace sixty 300 watt incandescent lights
 in the jail with sixty 80 watt fluorescent
 lights.

Conduct energy conservation seminars for City
 employees.

Change outside lights to high pressure sodium.*

Add one 400 watt high pressure sodium floodlight
 and turn off seventeen 150 watt lights.

Turn off loading area and garage lights.

Add R-16 insulation with new roof.

Install an air lock on front entrance.

Blend waste oil into boiler fuel oil.

Add wall insulation.

Add economizer cycles to air conditioning/
 heating units.

Add cooling tower and boiler controls.

Install an ORSAT analyzer in the boiler flue
 to improve boiler efficiency.
Net Savings:
$71,198/5 yr.
 11,418/5 yr.
  1,209/5 yr.


  2,888/5 yr.
   $.70/gal.
                                    160

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ATTACHMENT #2 (continued)
DR. RICHARD KLINE'S TESTIMONY

Set up employee carpools, if possible in as-
 sociation with the County.*

At the Recreation Centers:

Keep gym lights off when possible.

Put stage lights on separate switch.*

Install attic fans.

Install Marvair water heater that uses air
 conditioning exhaust heat (or heat pump in
 winter) in fire stateion and rec. centers.

Turn off oil burning heaters at one center.

Readjust day care center timers.

Replace propane with natural gas at one
 center.

Install solar heater in swim center.*

Add insulation at 3 rec. centers.*

Add economizers to air conditioner/heating
 units at 2 rec. centers.*

Install a microprocessor energy management
 control system at 2 rec. centers.*

Modify a boiler flue opening to retain inci-
 dental heat.*

At the City Garage:

Change car wash rate schedule.

Install a waste oil heater.*

Waste Collection and Disposal;

Construct a solid waste compactor/transfer
 station to minimize vehicular trips to the
 landfill.
Net Savings:
$22,751/10 yr.
    750/5 yr.

  4,925/5 yr.

 22,710/5 yr.


     4.6 year payback

   4-10 year paybacks

   4-5 year paybacks


   4-5 year paybacks


     4 year payback




  1,300/5 yr.

    $.70/gal.
                                    161

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ATTACHMENT #2 (continued)
DR. RICHARD KLINE'S TESTIMONY

Install a power factor controller, which
 reduces electrical use by electric motors
 constantly under varying loads, at the
 transfer station and a pumping station.*

Optimize the rate schedule at the transfer
 station.

Investigate economics of methane recovery
 from landfill.*
Net Saving:
 1,613/5 yr,
Vehicular Savings:

Purchase exclusively compact police cars, and
 sub-compacts for administrative personnel.

Purchase economy sizetf pickup trucks.

Evaluate XPCL gasoline additive as a gasoline
 mileage extender.

Evaluate Econo-mist carburetors.*

Evaluate automobile gasoline pre-heater.*

Convert all gasoline powered city cars to
 compressed natural gas.  (2 year payback)

Apply for DOE grant to test electric cars.
 (Greenville, S.C.  got the grant.)

Miscellaneous Savings:

Replace 2 meters with one at a city building,
 and 4 meters with one at another city
 building.

Install photo-cell switches on outside lights
 at city buildings.

Install photo-cell on parking garage lights.*

Replace bad 40 watt fluorescents with energy
 saving 35 watt fluorescents.
$259,652/5 yr,
   7,250/5 yr.



   1,447/5 yr.


   5,000/5 yr.

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ATTACHMENT #2 (continued)
DR. RICHARD KLINE'S TESTIMONY
                                                    Net Saving:
Install timers on hot water heaters, reduce          1,440/5 yr.
 water heater temperatures to 100 degrees,
 turn off or time ciculating hot water, and disconnect
 outdoor shower where vandals could run hot water.

Install water heater insulation jackets on 8           760/5 yr.
 units.*

Turn off building heat and air conditioning nights
 and weekends.*

Shade air conditioner.*

*Not yet implemented.
                                    163

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    The one area of energy conservation at the governmental le-
vel that will probably suffer is  joint  programs.   We have, for
example, four  cities  going  together  for  an  alcohol   fuels
program whereby 120 vehicles will be run on alcohol, which will
be generated  from  peach  and  textile  waste  producsts.   With
programs of this type, the  coordination  is  best when the  local
governmental agencies  can  get  the  money  from somewhere  else
and don't  have  to  fight  among  themselves as  to  the  funding
formula.  For this  admittedly political  reason,  programs like
this will probably be slowed under the new policy.

    The one area where there will be serious slowdown is the low-
income area.  Although the upper and middle income people in our
area are seriously going ahead with their own conservation mea-
sures, including aggressively seeking out the information  to do
them, the low-income people simply cannot afford this.  This is
the area that we feel  the Federal government will have to concen-
trate on, and I'll get into that in a few minutes.

    As a  transition  policy  consideration,  we  would recommend
that you  consider  funding  some more  of  the grant applications
throughout the  nation  in  which  the  local  governments  have
invested a great deal  of  time  and money.  Many of these appli-
cations are basically  sound applications.   They were made in a
good faith  expectation that  the Federal  policies  would  con-
tinue; and  although  we  support the  change   from  individual
grants to  block grants,  because of the  inefficiency  in the
individual grants,  we would like  some  consideration  - grand-
fathering, if you will - for the transitional period.

    In our area, the  phase-out of Federal  programs  will have a
rather mixed  effect:   We  are  getting no  energy impact assist-
ance.

    The schools and hospital conservation  program, which  the new
Administration is proposing to fund, is  ironically  the one  which
would do best if left  alone.  The counties, which run schools and
hospitals, have strong financial positions.  They  are able to
generate revenue for conservation measures,  if necessary, by the
issuing of bonds,  and  they've  consistently supported  both hospi-
tals and education.

    The weatherization program,  as   I've  said  before, probably
will not be carried out at anything approaching the scale  that it
was previously.  We might  expect  some  municipalities  to put on a
limited effort, and private agencies, under charitable auspices
such as the United Way, might continue to some  extent.  We  can't
predict the extent  at this  time.  The  State  of South Carolina
has an energy office,  which is  primarily run on Federal funds,
as the League of  Women Voters  of Greenville   (Attachment #3),
has noted.   Probably  as  these  Federal  funds  are reduced, the
state's commitment to overall energy policy will be reduced, and

                      164

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ATTACHMENT #3

ENERGY POLICY  STATEMENT  OF  THE  GREENVILLE,  S.C.  COUNTY LEAGUE  OF WOMEN
VOTERS

    It is the League  of  Women Voters' position that conservation of energy
should be the keystone  of U.S.  national energy strategy.  Conservation can
extend the use  of present nonrenewable resources and other environmentally
benign sources  and technologies.   The  League opposes  the  administration
plan to  slash over 77%  from conservation programs  and  more  than 62% from
solar.

    Administration cuts  are  based  on  the assumption  that  higher energy
costs and tax  incentives alone will  take  care of  energy conservation and
encourage the use of  solar.   Higher  prices have  had a significant effect.
But higher prices will not provide capital  to  the  vast number of individuals
and businesses who  can  use conservation and  solar.   Higher  prices and tax
incentives will not enable tenants to  control  the  design and operation of
the residences and office buildings they occupy and whose energy operating
costs they pay.   Higher prices  will not ensure that we achieve the maximum
cost-effective improvements in efficiency,  even though such improvements are
clearly in the national interest.

    The League of Women Voters  maintains that federally funded conservation
and solar programs are  needed to  expedite  market forces.  They provide the
diversity of  approaches  needed to  help break  down  institutional barriers
to use of these resources.   The Solar and  Conservation Bank, for instance,
was designed specifically to assist those who  would not be expected to bene-
fit from tax credits.  These programs can assist  citizens in the large num-
ber of small applications of solar  and  conservation  technologies.

    Proposals to axe the Solar and Conservation Bank, building and appliance
standards, utility audit  programs,  funds for state energy offices, and pub-
lic outreach programs fly in  the  face of all  recent energy studies.  More-
over, these  conservation programs,  plus  low-income  weatherization  funds,
are critical in reducing the impact  on consumers of rising  energy costs.

    The 1978 report of  the S.C. Energy Task Force Conference declared that
lack of public knowledge  is  the greatest single barrier to the development
of alternative energy sources of all kinds  in  South Carolina.  Yet many sig-
nificant conservation efforts in the state  are federally funded:  the Gover-
nor's Office on Energy,  the  energy extension services, the energy programs
of the S.C.  Appalachian  Council  of Governments, the Appalachian Regional
Commission,  and the Southern  Solar  Energy  Center.  Major state monies have
gone to fund  the state legislative committee on energy and the newly proposed
energy research center at Clemson, which will conduct industry oriented pro-
jects.  In addition, the state has provided required matching funds for the
Governor's Office  on  Energy.  Additional  state support  of this  office is
among the lowest  in  the  nation.   The  office  exists mainly  to  implement
federal programs.
                                  165

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we would hope that you will take this into account in your pro-
grams.  I note that you have some funds allocated for state plan-
ning in the new program.

    The Energy Extension Service is being supplemented now very
aggressively from many,  many  sources:  private books  that are
published, articles in Popular Science, and  symposia  put on by
the local tech schools, colleges, and universities.  In fact, I
will tell you personally that until you brought it to my atten-
tion in your  position paper,  I,  as the local regional  energy
chairman, didn't know of its existence.  So I  think we could pro-
bably do without it.

    The emergency energy conservation measures  are  being carried
on by the state.  As  I've mentioned,  they will  probably go on at
a reduced level.  There is  some emergency planning  being done at
the local county  level  by Civil  Defense  authorities,  although
this is applicable only  to particular counties and badly needs
to be supplemented by state and national plans.

    The Residential  Conservation  Service is being  carried on
aggressively by the  utilities,  especially by  our  local elec-
tric company, and  they will probably continue to do what is man-
dated and, in  some cases,  a  bit more.  I  doubt  that  the local
governments will get  into this service, although the professio-
nal home builders association may go ahead  with  programs like
this on their own as  an advertising means.

    The state  energy  office  should  be continued.  We  need an
overall energy plan  for the  State  of South Carolina  and also
an office which can concentrate resources on statewide programs,
such as a proposed Energy Research Center at Clemson University.
That's merely one example.

    The weatherization  and  low-income  assistance  program,  as
I've mentioned, is  the  one   which  is  most  likely to  suffer
seriously.  I  would  recommend the  alternate proposal  that you
set forth: That this  be put  into a  block  grant  with  the LIEAP
program and funded as a separate block grant, rather than being
put into  community development.   To be quite  honest  with you,
if you give us community development block grant money, we will
use it  for  roads,  sidewalks, extension  of  the   sewer  lines,
parks in  lower income areas,  and things  like this,  before we
would use it  for  specific programs that  benefit  specific in-
dividuals, however justified  these may be.  As to the low-income
energy assistance  program,   I  would  recommend  based  on  the
experience in our area that monies from this  program be allowed
to be transferred to  weatherization.   We've  had  very  good luck
with our local  community action  agency in the  Piedmont area in
the weatherization program.

    The same agency was given last year money to handle low-in-

                        166

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come energy assistance.   That  money went to the first thousand
qualifying recipients  out of  an estimating  30,000 who  could
use it.  In essence, a handful of coins was thrown off the bal-
cony to the peasants below.  I don't want to sound disparaging,
but that was  the  effect,  however well intentioned the program.

    In addition, we see advantages to weatherization.  Weatheri-
zation is a permanent benefit to low-income people, whereas en-
ergy assistance is  something that will have to be given to the
same people  year  after  year.   The  weatherization  programs
tend to reduce national demand for energy and benefit everybody
including the  poor  people  not  receiving  them.   Whereas  the
energy assistance  programs  provide more   dollars  to  compete
for the same  scarce  resources  and have an  inflationary effect.
Also, the  weatherization programs  can  employ presently  low-
income semi-skilled  workers  in  the   CETA  program  and  other
programs and  provide a double  benefit for  low-income  people.

    In addition to  this  program,  we'd like  to see a modifica-
tion in  the  rules  so that  the  3  percent  community  develop-
ment loan programs can be used for weatherization.  At present,
if we use  them, we are restricted  to  a  few community develop-
ment areas,  and  the houses must  be  brought  up entirely  to
code.  We'd like  to  be able  to offer this program to the upper
low-income people,  basically  the ones who  can take on  a loan
program, citywide,  and we  would like the  requirement  waived
that the houses  be  brought  up to  code,  with  the requirement
instead that they be  merely habitable  houses,  so  that  we could
impact a larger number of people.

    We feel that  the  funding  level of  this program,  a  snail
amount of  money  to  many houses  or a large  amount  to  a  few
houses, should  be on a  cost/benefit   ratio.   The  formula  will
have to vary  depending  on the part of the  country.   Obviously
New York and Maine are going to need more extensive weatheriza-
tion than South Carolina.

    We feel that the CETA and other semi-skilled low-income peo-
ple can best be hired under this  program by  private agencies and
the local contractors, if possible.  This gives them permanent
jobs as opposed to CETA jobs which will terminate in 18 months,
and it gives  them their  foot on the  ladder into  the lucrative
construction industry.  Incentives  could  be given in  terms  of
preferential consideration for qualifying  contractors  to  hire
these people.

    Finally,  on the  area  of  evaluation, the philosophy  of the
new Administration  basically   is  that the  free market  should
handle this.    Conservation  is  a local problem.   We  accept the
challenge.   But by  the  same token, since  you've  said this  is
our problem,   you  really  don't  need   the  detailed information
that you needed in the past as to how we're doing.

                         167

-------
                Now obviously you will need a detailed evaluation of how the
            grant money that you give us is being spent.   To the largest ex-
            tent possible,  I'd  recommend that  the detailed  evaluation he
            after the fact,  so  that qualifying local governments do not have
            to spend a large amount of money in advance applying for grants
            they will not get.

                In addition, detailed information should be gotten from the
            large energy producers who  can easily supply  it  at relatively
            little cost, from professional societies, from research institu-
            tions, and from sampling with brief questionnaires to the other
            groups.

                Thank you very  much  for  allowing me to make this presenta-
            tion.

(Following are additional comments submitted  by Dr.  Kline  on July 17, 1981

Attachment #4

            COMMENTS OF  THE APPALACHIAN  REGIONAL  COUNCIL OF  GOVERNMENTS
            AND ITS  ENERGY  SUBCOMMITTEE  ON THE  NATIONAL  ENERGY  PLAN AND
            ITS REGIONAL APPLICATION

OUTLINE
      I.    Conservation
     II.    Electric Power
    III.    Renewable Energy Sources
     IV.    Fossil Fuels
      V.    Nuclear Energy
     VI.    Environmental Considerations
    VII.    Economic Incentives

CONSERVATION

    The Council of Governments  supports South Carolina's emphasis on conser-
vation.  Energy conservation which avoids  waste  and provides jobs if consis-
tent with economic growth.  To  encourage  conservation,  the  Council of Gov-
ernments itself can provide information to  consumers  and other appropriate
groups.

    Housing;  Local  governments should  co-ordinate their  efforts  so as to
encourage the construction of low and moderate income housing in areas where
industry and other major sources of employment are located, so as to reduce
the cost and  fuel  expenditure  involved  in transporting  employees  to work.
The use of  solar  design  principles, especially  for the  construction of low
and moderate income housing, should be encouraged.

    The programs of public  and  private  agencies to weatherize the homes of
low income  people  should be  encouraged  and  expanded.  Durable  materials
should be used,  with priority  being  given to  homes that  are structurally
sound.  Agencies involved in weatherization should co-ordinate their efforts

                                   168

-------
with local planners  and  redevelopment  authorities to assure that buildings
to be weatherized are not targeted for early demolition.

    Transportation:  Ridesharing and vanpooling should be encouraged.  Local
governments should set up voluntary ridesharing  programs for their employees
in co-ordination with other employers in their  areas.  State and local laws
should be modified so as  to remove legal impediments  to ridesharing arrange-
ments, as recommended by  the Department of Transportation.

    The construction of a network of  pedestrian  and bicycle paths to supple-
ment motor vehicular roads should be  encouraged.  A  portion of state highway
funds equal to at least 1% of the total should be set  aside for this purpose.

    Provisions should be made for a network of  fuel  depots to keep emergen-
cy vehicles,  such as ambulances,  supplied  with fuel when on extended trips
during periods of fuel shortage.

ELECTRIC POWER

    Hydroelectric resources should be  developed, since hydroelectric power
has no pollution or  waste disposal problems  and costs,  on the average, 1/6
as much as  nuclear  power to produce.  Existing hydroelectric  sites can be
upgraded, and pumped storage capability can be added  in some cases.  Develop-
ment of low head  hydroelectric resources should be encouraged, with the aban-
doned mill dams in the Piedmont region being  restored for electric power co-
generation and load  levelling.   The  Council  of Governments  should develop
figures for the management of suitable  local industries regarding the profi-
tability of electric power cogeneration.

    Interruptible service should be actively promoted, and the media should
be encouraged to give consumers  information  on peak power demand hours,  so
that they can avoid using optional equipment at those times.  This informa-
tion could be included in weather reports.

    Electric cars should  be further  developed for short range use, and the
development of solar powered batteries for these cars should be encouraged.

RENEWABLE ENERGY SOURCES

    The National Energy Plan should  place  more  emphasis on the development
of the Nation's renewable sources of energy,  since development and utiliza-
tion of non-renewable energy resources will  not adequately  address the Na-
tion's long-term energy needs.   The  Nation's  capacity to utilize solar and
geothermal resources should be enhanced.

    The Council of Governments supports the development of a National Solar
Technology Clearinghouse to provide useful  information to builders and home-
owners on small-scale application of solar technology.  State tax incentives
should also be provided for the use of solar energy.

    The National Energy  Plan  should include  a policy that  encourages  the
utilization of refuse for  the production of energy.   Incineration of munici-

                                    169

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pal trash to produce steam and/or electric power for sale to local industry
should be actively pursued.

    Gasohol should be made predominantly from non-food products, and oil and
gas should not be used to fire the stills.

FOSSIL FUELS

    The Nation  must  exercise  caution  while  attempting to  accomplish the
near-term objective  of  the  Ntional  Energy  Strategy.   The United  States
must not deplete its own  non-renewable  energy  resources just to reduce the
importation of foreign oil.

    The use of  natural gas and propane  gas as an automotive fuel should be
encouraged.

    The Council  of  Governments feels that the National Energy Plan should
emphasize the utilization  of  currently available  fluidized bed technology
for coal.  Use of this  technology would  enable the Nation to more efficient-
ly utilize  its  non-renewable   coal  resources  during the near-term  future.

NUCLEAR ENERGY

    The Council  of Governments supports the prudent development of  nuclear
powered electric generating facilities  within  the  State and Nation as long
as the potential development risks (safety, security, waste disposal, etc.)
are adequately addressed during all phases of project planning,  development,
and operation.  However, we should not become over-dependent on nuclear pow-
er because the waste disposal problem is still far from being resolved, and
because of  the  possibility that  all reactors  should be closed because  of
a major accident anywhere.

    The Council  of   Governments  supports  the  production of nuclear fuels
(enriched uranium) for use within the United  States,  but the United States
should view sales  of  nuclear  fuels  to foreign  nations cautiously  because
of the unstable world situation.

    The Council of governments  supports  research  efforts  to  develop safe and
effective breeder and  fusion  reactors because these technologies may  suc-
cessfully address the Nation's long-term energy needs.  However, due to the
infancy of  current  breeder and fusion  technology,  the  Nation's short-tern
development emphasis  should  be focused  on the rapid development of other
energy technologies.

    The Council of Governments supports the position that a National policy
regarding the permanent disposal of  nuclear wastes should be developed imme-
diately, and that a  series of  permanent nuclear waste disposal sites should
be established in the United States.  Further, South  Carolina  should seri-
ously consider phasing out the  acceptance of nuclear wastes from other states
for "temporary" storage.   South Carolina's existing temporary storage capa-
city should be reserved exclusively for nuclear wastes  generated by facili-


                                   170

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ties located  within  the State, unless a  specific  exception is made  hy  the
State government.

ENVIRONMENTAL CONSIDERATIONS

    The Council  of Governments feels  that  the  National Energy Plan  should
specifically  address the trade-offs that  must  be made between the environ-
ment and  energy  production.   The federal  government  should develop a bal-
anced and  coordinated  energy  strategy that adequately  addresses both  the
environmental and  economic needs of the nation.

ECONOMIC  INCENTIVES

    The Council  of  Governments  is  opposed to  the  Windfall  Profits Tax.
(This was the only resolution  that was not  unanimouslv endorsed.)
ATTACHMENT #5

(1) The Energy Extension Service:   The  Federal  Government  has  prepared
many excellent books and reports on the practical aspects of energy conser-
vation and generation, which would be more valuable if they were more gene-
rally accessible.  These should be offered  free or at nominal cost to public
libraries, colleges, and technical schools, and local governments should be
informed of this action.   In  the  present  transitional period of governmental
cutbacks, these local institutions, which are the  natural  contact points for
the public seeking  information,  would be  delighted to be able  to  receive
useful material at little cost.

    A significant  quantity  of  material  to  be  distributed  could  probably
be obtained by emptying the  Federal warehouses, and the  rest could be pro-
duced by re-printing the appropriate publications, a process that is consi-
derably  cheaper  than  was  the   printing  of  the  original   publication.

(2) Low Income Weatherization:   In my  testimony,  I favored low income wea-
therization over LIEAP, whereas Mr. K. Dorsey of  the  National Black Caucus
of State Legislators attached equal significance  to both  programs.   On re-
flection, I feel  that the apparent disagreement  is due  to  differences  in
regional needs.

    In South  Carolina,  the  substantial  majority  of  the  population  still
lives in  single  family houses,  ranging  in value  from shacks  to mansions.
The older structures,  inhabited  primarily  by low  income  people,  were built
before the start  of  the  energy  shortage  and do  not  have  storm  windows,
insulation, or other  forms  of Weatherization.  These are usually  owned by
the low  income  people  themselves and  should  be  weatherized before  any
LIEAP program is implemented.

    On the other hand, it is probable that many of Mr.  Dorsey's legislators
represent inner city districts, where  the predominant form of housing is the
rental apartment.  Here, the  tenant  usually pays  for the utilities  and is

                                   171

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not in a position to weatherize  the building, whereas the landlord generally
would not qualify for  low income aid and would have little to  gain from a
program that would merely reduce his tenants' expenses.  While some program
needs to be developed to stimulate weatherization of these buildings, LIEAP
may well be the  only short-range option to  keep these apartments liveable.

    This difference  appears to  me  to underscore the wisdom of  lumping Low
Income Weatherization and LIEAP  together into a  single block  grant program
and allowing local  governments  to  adjust the emphasis  between the two pro-
grams as their individual situations and priorities dictate.

DR. RIEGEL:     Thank you.   Open for questions.   I'll take the Chairman's
            prerogative and begin  with  a question  of my  own.   Dr. Kline, I
            was interested in a number of your observations and in particu-
            lar the  well  thought  out  remark that  energy  assistance funds
            are more in the nature of a continually accruing expense, while
            weatherization is a  one-shot kind  of investment that is likely
            to provide dividends for a long time to come.

                I was also  very interested in your remark that the schools
            and hospitals program is  perhaps  in the strongest position to be
            cut loose from future Federal involvement and support.   I wonder
            if you could elaborate  on why you feel that  sector is particular-
            ly likely to be able to do well in terms of conservation invest-
            ment without any continuing  Federal involvement, and to what ex-
            tent your local situation might  be  extrapolated to  the  rest of
            the country.

DR. KLINE:      Well, I can only argue  from our local situation, but both
            the schools and hospitals are financed  countrywide in our area.
            We have  a  very strong and  growing  tax base  from the industry
            that is  moving  into  our  area from all over  the world,  and the
            county governments have consistently shown support for the hos-
            pitals.  The school  districts have independent taxing authority,
            and they have  seen  very little  consumer  resistance to raising
            taxes as necessary.   So  the money is there, and  I'm sure that
            the Council of Governments,  the state, and  the local municipali-
            ties would be  able  to  help  them  with technical  advice in terms
            of the appropriate conservation measures.

MR. POWER:      I'd  just like to ask Mr.  Brown to   elaborate  a little  bit
            more on the problems of the  low-income households in the Middle-
            town experience.  Do you feel  that the Middletown experience
            suggests that  they  don't need  any  additional help  other than
            the community  self  help that  was catalyzed,  kicked off  in a
            sense by this very small grant from ACTION?

MR. BROWN:      I'm  not sure I understand the question.  When you say don't
            need any  additional help,  do you mean no further  programs of
            that sort, or do you mean no massive sort of Federal assistance?

MR. POWER:      I didn't hear in your remarks specific treatment of how the
                                    172

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            low-income households would fare, whether they would get enough
            help from the kind  of measures  that  you  saw being created, the
            kind of institutional measures, the  bonding and  so  on,  or whe-
            ther you were  implying  that we still  needed  to  do weatheriza-
            tion, but given  that, we were going to  also  be  benefited from
            this other apparatus.

MR. BROWN:      I think there's lots of need and room for other programs. I
            was trying to say that those Federal programs need to be organ-
            ized according to the kind of  criterion I was stating, like this
            particular program  was.   Dr. Kline  mentioned the  schools  and
            hospitals program.  It's not dealing with low-income households,
            but it's a program with a good goal.  A  lot of schools and hos-
            pitals need some encouragement to sort of get off  dead center and
            do something about it, but that  program is so  laden with bureau-
            cracy and format that a lot of agencies just  simply don't want to
            bother with it.

                I think that Federal  programs have to be designed to have the
            maximum impact with the least assistance.   The City of  Middle-
            town does use HUD  funding,  for  example,  for its  rehabilitation
            program, and we  have  designed some  very, very  innovative uses
            of low cost passive solar  and  conservation  now in every build-
            ing, including housing that's being  redeveloped.  It's  part  of
            the city's revitalization program.

                Another example is about  30 percent  of  the  city's  housing
            stock is tenant owned.   The Department of Housing and Urban De-
            velopment is spending millions and millions of dollars on energy
            conservation programs at  one  end  of its building,  and  at  the
            other end,  has  a program  where it  makes  its funds  available
            for the construction and subsidy of  low-income  housing.   They
            encourage the private sector  to build low  and moderate  income
            housing.

                Landlords who own HUD subsidized apartments have to apply to
            HUD for rent  increases.  This is an enormous  impact on the city's
            housing.  Increasing energy costs  is a  perfect  example  of  how
            a landlord can go and apply.

                There is no  HUD regulation  which encourages landlords  to
            use any of the money that they get in rent  increases for energy
            conservation;  therefore, because of  Federal regulations, energy
            is being not  only wasted, but  here  is an  opportunity to  save
            hundreds of  thousands   of  barrels  of  oil  without  spending
            one Federal cent.

                We simply need to be thinking out programs  in  this way, and I
            think there is a very strong need for Federal assistance in  en-
            ergy conservation programs,  particularly in  revitalization  of
            energy communities, of rundown  communities, et  cetera.   But  I
                                   173

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            just think  that they  have  to  be  innovative  in the  way that
            this particular program is.

MR. PFEIFFER:   Mr. Prano, when the weatherization program ran out of funds
            this spring, was there any  hope of getting  any  money from the
            state to continue those efforts?

                Does the  state  contribute  any  money to  weatherization in
            Indiana?

MR. PRANO:      No, absolutely not, and, in fact, in our political  govern-
            ment it's not even to  be  addressed,  because  it  would be in de-
            fiance of  the Presidential  direction  if  the state continued
            to support a program that may or may not continue under Federal
            guidelines.

MR. PFEIFFER:   How do you feel — how easy do you feel it would be to move
            toward using  this  low—income  energy assistance  program as  a
            source of funds for low-cost weatherization?

MR. PRANO:      Well,  when I was with the CAP agency, I was also  Director
            of the  Energy Crisis  Assistance  Program and  also  some  other
            energy conservation money that we could use for weatherization.

                I agree with most of the speakers.  At least, weatherization
            is something we can measure; it's there.  It's permanent if it's
            installed properly.   You can see its benefits virtually for the
            existence of the household, and with the energy  or  LIEAP pro-
            gram, you know,  you're paying  a  permanent  subsidy  and  you're
            automatically teaching people  to  come  to  you with  their hand
            out.

                We had this happen in  our agency.  They automatically waited
            for the state announced funding date  to  bring in their utility
            bills.  We, in turn, subsidized —  in the private sector, nor-
            mally a business has to charge to its clients the amount of bad
            business that it does.  The utilities do it also, but then they
            pick up a big  percentage  of their net profits by us providing
            LIEP assistance, especially  on a continual  basis,  so  I'd  say
            a better formula for  funding  would  be  if a house had  not  re-
            ceived weatherization then  it  should be eligible  for whatever
            the established  criteria  is for  maximum amount  of  assistance
            under LIEAP.  But if it received  weatherization  and  it  reduced
            the amount  of assistance  or  need   by  40  percent,   then  that
            LIEAP assistance should be  reduced  proportionately  so  it'd be
            fair for everybody.

                It's not fair  for one person to  get a  house weatherized,
            get $400 worth of LIEAP assistance and get everything else, when
            there's still a lot  of people out there who have not  gotten the
            first thing, including food stamps or whatever.
                                   174

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DR. RIEGEL:    I'd like to thank our witnesses for very interesting presen-
            tations indeed, and to  invite  the  next three  witnesses to come
            forward:  Anthony  Maggiore,  Keith Dorsey,  and  Peter Robinson.
            Anthony Maggiore comes to us  from the Wisconsin Community Action
            Program, Keith Dorsey  from the National Black  Caucus  of State
            Legislators, and Peter  Robinson  from the  City of Maynard, Mas-
            sachusetts.

MR. MAGGIORE:   My name is Anthony J. Maggiore, Jr.  I am the Associate Di-
            rector for  the  Community  Relations-Social  Development Commis-
            sion - a public intergovernmental social planning and Community
            Action Agency in Milwaukee County.   Until  recently, I was also
            a member  of the  Fuel  Oil  Marketing Advisory Committee  of the
            U.S. Department  of  Energy  and  served as   Chairperson  of  a
            committee which published  reports on Low  Income Energy Assist-
            ance Programs in  1979 and 1980.  A  copy of  the  latest  report
            dated July,  1980  and  titled   "Low Income  Energy  Assistance
            Programs -  A Profile  of Need and Policy  Options" is submitted
            to the committee for the record. (This report was reviewed, but
            not included in the Transcript due to its length.)

                I want  to thank  you for the opportunity  to testify before
            your committee on the needs of low income people  and the national
            weatherization program.

                The major issues confronting all energy consumers today are
            partially the result of a  government policy which promotes in-
            creased costs for energy in order to promote needed conservation
            and increased  domestic  production.    In  my  opinion,  another
            policy is  essential,  a  policy  which  relieves  low  income  and
            elderly of  the  immediate  and  intolerable  burdens   imposed  by
            this policy  of  increased  costs.  Without  such  a  policy,  the
            health and  safety  —  even  the  lives — of  low  income persons,
            and especially the elderly, will be jeopardized.

                During this testimony, I will attempt to outline the impact
            of rising energy  costs  on low-income households, comments regar-
            ding the DOE low income weatherization  programs, some brief com-
            ment on the  Administration's proposal, and my  response  to the
            1981 Section 11 review issues.

            I.  IMPACT  OF  RISING ENERGY PRICES ON  LOW INCOME  HOUSEHOLDS

                A report published in  July,  1980 by the Fuel Oil Marketing
            Advisory Committee  (FOMAC)  of  the  U.S.  Department of  Energy
            finds that, overall the poor:

                1.  will expend  at least 35%  of  their income  directly  on
                    energy and will  spend  at least 21% of  their income  on
                    household energy;

                2.  will still continue to pay nearly 4 times more the per-

                                    175

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        centage of their  income  on  household energy  than  the
        average American household;

    3.  suffered a loss  in  average  total income in  real terms
        since 1971,  making  the  acquisition of  adequate energy
        for this group more  difficult;

    4.  have lost over  $6 Billion  in purchasing power  in 1980
        due to increases in  energy  costs;

    5.  have experienced, in certain  regions  of the  country, a
        particularly harsh and disproportionate  burden in paying
        for energy;

    6.  have  less  ability  to   offset  increased  energy  costs
        through product  substitution  in  the  marketplace  than
        for any  other  necessity utilized  by poor  households;

    7.  use less than  50% of  the total energy  consumed by  the
        average American  household  and 25% less household  en-
        ergy;

    8.  will  continue,   by  necessity,  to  occupy  low-quality,
        energy inefficient housing  stock that  further penalizes
        them  in  their    effort  to  cut   energy  costs;   and,

    9.  lack financial resources to implement  significant addi-
        tional conservation  improvements.

II. DOE LOW-INCOME WEATHERIZATION PROGRAM

As energy prices continue to rise,  the need for conservation be-
comes even more acute.  A number of basic realities  must be  ac-
knowledged if a  long-term solution to  the energy needs of  the
poor is to be found:

1.  The residential  structures  of  low-income  people tend to be
    in poor  condition and less  energy  efficient than  those  of
    higher income families.  As  a recent national housing survey
    shows, basic energy  conserving  features are more likely to
    be absent in  the  housing  of the  poor  and near  poor.  (See
    Table 1).

2.  This lack of energy efficiency results in annual fuel bills
    substantially higher than they should be.

3.  In terms of simple conservation measures,  such as thermostat
    set-backs, caulking,  and  weatherstripping,  the poor  have
    already conserved as  much as possible.   Yet, they  lack the
    necessary funds to  invest  in additional  conservation such
    as weatherization  and  use  of  alternative  energy   sources
    which would result in greater energy savings.  A recent DOE

                         176

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                                         TABLE 2

                  EXISTING ENERGY-RELATED CHARACTERISTICS BY 1977 FAMILY INCOME _!/
                                     (Winter 1978-79)


TOTAL
STORM WINDOWS
All windows covered
Some windows covered
No windows covered
STORM DOORS
All doors covered
Some doors covered
No doors covered
ATTIC INSULATION
Have insulation
No insulation
Don't know
HAVE WALL INSULATION
Yes
No
Don't know
I/ Source: U.S. Department
Less than
$5,000

100%

30
19
52

30
18
52

41
37
22

28
44
27
of Energy,
$5,000
to
$9,999
100%

34
20
46

38
22
41

57
29
13

41
34
24
1977 FAMILY INCOME
$10,000 $15,000 $20,000
to to to
$14,999
100%

39
19
43

36
21
42

68
19
14

51
25
24
Residential Energy
$19,999 $24,999
100%

48
18
34

41
25
34

74
15
11

56
25
19
Consumption
100%

43
25
32

39
25
34

80
9
11

57
23
20
Survey :
$25,000
or
More
100%

48
22
30

37
31
31

86
9
5

63
18
19
Conservation ,
Washington, D.C., February, 1980, p. 31.

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    survey of  conservation behavior  shows  that  the  poor  are
    just as  likely  as  the average  income households  to  take
    cost-free conservation measures (such as  shutting off rooms;
    see Table  2).   However,  as the  cost of  conservation  mea-
    sures increase  (such  as  adding  insulation)  the  poor  are
    less likely  than  average  income  households  to  implement
    such measures.

    The Federal  weatherization program  has  been  in  existence
since 1973.  The program was developed  and administered by the
Community Services Administration  in  response to  the  impact of
OPEC price increases on  low-income households.  Through congres-
sional action, the  program was transferred to the U.S. Depart-
ment of  Energy  (DOE)  in  1977.  Under  the DOE program,  grants
are made  to  states, which generally subcontract  to  community
action agencies  to  serve  as  local delivery  mechanisms.   Most
geographic areas  of  the county are presently being  served by
the program.

    Though the DOE weatherization program initially had serious
management and coordination problems, during the past year, the
program has  improved  significantly.   For example,  during the
calendar year  1979  the  DOE program weatherized 144,000 housing
units throughout  the  country.   During  calendar  year  1980, the
DOE program  has  weatherized  over   311,000  housing  units  - an
increase of over  100%.

    Recent studies  of the  DOE  weatherization programs  in Indi-
ana, Michigan,  Minnesota,  Pennsylvania,  Utah, Washington  and
Wisconsin indicated an  annual household  energy   saving  of 20-
25%.  Since  current data  indicates that  low income households
on the  average,  spend  at  least  21% of  their  income  on house-
hold energy  (in  the  Midwest  and  Northeast region  of  the  U.S.
it is  over 30%), the  20-25% energy  conservation  saving is ne-
cessary for  the  household  to  have  sufficient  finances to pur-
chase food, shelter, clothing, etc.

    The national  weatherization  program serves  eligible  low-
income households  with   a  priority placed  on the  elderly and
handicapped.  The recent  success  of the program has documented
clearly the  effectiveness  of the  program  and  the   financial
relief  provided  to  the   household's   receiving    services.

III.  THE ADMINISTRATION'S PROPOSAL

    The Administration  has proposed  that  the existing Depart-
ment of  Energy   (DOE)   low-income  weatherization  program  be
phased out  during  FY  81.   The legislative  authority  for the
program would  be transferred   to the  Department  of Housing and
Urban Development  (HUD)  without  explicit  line  item  funding.
                      178

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                                    TABLE 2

                CONSERVATION EFFORTS UNDERTAKEN IN 1978 BY 1977 FAMILY INCOME _!/
                                (Percentage of Households)

Type of Conservation
Measure:
ROOMS CLOSED OFF
Yes
No
No answer
ADDED INEXPENSIVE INSULATION
Yes
No
ADDED INEXPENSIVE EQUIPMENT
Yes
No
ADDED EXPENSIVE INSULATION
Yes
No
ADDED EXPENSIVE EQUIPMENT
Yes
No
I/ Source: U.S. Department
Less than
$5,000



28
59
13

18
82

4
96

3
97

3
97
of Energy,
1977 FAMILY INCOME
$5,000 $10,000 $15,000
to to to
$9,999 $14,999 $19,999



33
55
12

23
77

4
96

3
97

3
97



31
56
13

26
74

7
93

6
94

5
95
Residential Energy



31
61
8

32
68

8
92

6
94

5
95
Consumption
$20,000
to
$24,999



32
57
11

31
69

11
89

8
92

7
93
Survey:
$25,000
or
More



30
60
10

27
73

12
88

9
91

8
92
Conservation,
Washington, D.C., February, 1980, pp. 31, 115.

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The program  would  be  one  of  several activities  eligible for
funding from  HUD's   Community  Development  Block   Grant  (CDBG)
program.

    The impact  of  the  Administration's  proposal  would  assure
the demise  of  the  low-income  weatherization  program.   The
program would be  competing for  funds with CDBG  and  Urban De-
velopment Action Grant  (UDAG) programs.   As  always,  the  poor
would lose in such competition.

The Administration's proposal  would yield the following problem:

    1.  The  CDBG program  is,   by  itself,  a $4  billion program
        with strong  competing interests  for  its   funds  at the
        local level.  The  considerably smaller  weatherization
        program (FY  81  appropriation  - $182 million)  would be
        lost in  the midst  of  such  a wide  ranging  program.
        There would not necessarily be any targeting to weather-
        ization since competing  interests include  streets and
        sewer projects,  housing  authorities,  water  projects,
        downtown development projects, neighborhood parks, etc.

        Since the other competing interests  have considerably
        more political  power  than low income people,  the poor
        would lose  in  such competition.  In  addition,  if  CDBG
        is restructure  to  allow  more  flexibility  to local gov-
        ernment, it  is  highly probable that  such  block grant
        monies will  be  utilized  to  offset  fiscal  pressures on
        the local tax dollar-further  jeopardizing the continu-
        ation of the low  income weatherization program  at the
        low income  weatherization  program at  the local level.

    2.  CDBG is primarily an urban program whereas the DOE wea-
        therization program is  a  rural and urban program.   For
        example, almost 75% of the FY 80 CDBG funding was allo-
        cated to large  cities and urban counties, while the re-
        maining 25%  was  allocated   to less  populated  areas.

    3.  The household income eligibility guidelines between the
        two programs are significantly different.   The  CDBG eli-
        gibility guidelines are  more  lenient  than current DOE-
        0MB eligibility guidelines.   CDBG currently serves low
        and moderate income households  and the DOE weatheriza-
        tion program  serves  poverty  households  as defined by
        OMB.  Thus,  the program would  not be  targeted  to the
        most needy households.

    4.  Linkages  between the  weatherization  programs  and the
        fuel assistance program  would be  difficult  to achieve
        since they  would  have  differing  income  eligibility
        guidelines and  would  operate  under two different block
        grant programs  (weatherization-local  block grant,  fuel

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        assistance - state block grant).  Such linkages are im-
        portant if a national goal is to reduce the need for fuel
        assistance through weatherization  of low-income dwell-
        ings.

    5.  There would be no national standards of services or re-
        quirements as well as no national policy regarding wea-
        therization of low-income dwellings.  National weather-
        ization standards developed  over the  past  7 years  by
        the Department of Energy, Community  Services Administra-
        tion, National Bureau  of Standards, and  other  Federal
        agencies may  not  be  utilized  by  local  governments
        under the  Administration's  proposal.   Thus,  if  the
        program continues on a local level, "the wheel  may be
        reinvented" at substantial administrative  cost and hard-
        ship to low-income households.

    6.  The  currently   effectively   operating  weatherization
        program with  trained  personnel, management  systems  in
        place with existing space, vehicles,  tools,  and  equip-
        ment would be dismantled.  It would be cost  inefficient
        to dismantle the  current  program and at  a  later date,
        when consumer conservation becomes popular again, estab-
        lish a new program.

    Finally, the poor cannot afford "conservation through price
    increases", as they simply  do not have the resources to make
    conservation improvements and at the  same  time,  cannot af-
    ford to pay their fuel utility bills.   The  energy problems
    of the poor will only worsen if a  national,  targeted wea-
    therization/ conservation effort  for  low-income  households
    does not exist.

IV. RESPONSE  TO THE SECTION 11 1981   ISSUES FUNDING  MECHANISM
    AND STRUCTURAL ISSUES

    A.  In light  of the  proposed  changes,  how can  the  nation
        maintain an  effective   low-income  weatherization  pro-
        gram?

        As indicated  previously,,  the  Administration's  propo-
        sals do not assure the  maintenance or even the continu-
        ance of an effective low-income weatherization program.

        The continuation   of  the program  can  only  be  assured
        through categorical  funding or modifications  of  current
        block grant proposals  whereby  the  continuance   of  the
        program is mandated.

    B.  If weatherization is tansferred into the  HUD Community
        Development Block Grant, what agencies would  be  effec-
                        181

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    tive sponsors at the community level?

    The current agencies operating the program  - community
    action agencies, non-profit organizations,  and  in some
    localities, local units of government.

    Such agencies have  dramatically  improved  the  program
    from a  management   disaster   (due  largely  to  lack  of
    staff from the Department  of  Labor  CETA Program)  to an
    effective and successful activity.

    The President's  proposal  regarding  the  Community Ser-
    vices Administration does  not,  generally,   jeopardize
    the existence  and  continuation   of  community  action
    agencies, the major local  sponsor   of   the  low-income
    weatherization program.  The majority of community ac-
    tion agencies are non-profit  organizations that receive
    most of their funds from  sources  other  than the Commu-
    nity  Services  Administration   released a  report  on
    April 30, 1981 that stated "of nearly 900 CAA's (Commu-
    nity Action Agencies)  reporting  in  FY  1980 only $288
    Million was provided to  CAA's from the  Community Ser-
    vices Administration and over $1.7 Billion was  received
    from  other   Federal,  state,  and   private  sources."

    The report also  indicated  that such agencies served over
    25 million poor and near-poor during the period covered
    by the report.

C.  How  can  problems  involved in  transferring  the program
    from one agency to another be minimized?

    Such problems can  be  greatly reduced by retaining and
    continuing existing local  sponsors of  the program.   As
    indicated previously,  current local sponsors of the pro-
    gram have  trained  personnel, management  systems  in
    place, vehicles,  tools,  equipment,  and  such  supplies
    and arrangements that  are necessary for program contin-
    uation.

    Nationally, such problems can be  minimized by transfer-
    ring existing national staff  to the  new agency.  Since
    the low-income weatherization program has already exper-
    ienced one transfer  to a  new agency (CSA  to  DOE),  it
    would be inadvisable,  from a programmatic and producti-
    vity perspective, to promote  or initiate actions regard-
    ing national staff  that  would interrupt the continuity
    and performance of a successful program.

    In addition, continuation  of  current national  perform-
    ance, and  service  standards  and  income  eligibility
    guidelines, would minimize  the  negative impact  of  na-

                    182

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        tional organizational  changes  on low-income households
        receiving services.

IMPLEMENTATION ISSUES

A.  If a  state decides  to  phase  out community action agencies,
    how can their resources  and  expenses be transferred to the
    new weatherization sponsor?

    As indicated previously, community  action  agencies  are not
    dependent on  the  Community  Services  Administration  and
    states' sources  of  funds  for  their  continued  existence.
    Such agencies are,  generally  non-profit organizations that
    recieve a  variety  of  Federal,   state,  local,  and  private
    funds.

    If some community action agencies were  phased out, their re-
    sources and experience  can  be  transferred to new weatheriza-
    tion sponsors by the following:

    1.  Transfer to  the  new sponsor ownership  of  vehicles,  e-
        quipment, supplies, etc.,

    2.  Employment  of  existing  staff  by  the  new  sponsor,

    3.  Local training programs.

    It should be  understood that if  the  above was necessary, the
    interruption of the existing program through local organiza-
    tional changes would disrupt  program operations and services
    for a period of  time and performance standards would be com-
    promised.

B.  Should LIEAP funds be utilized for weatherization?  How can
    the LIEAP program  coordinate  its activities with the  wea-
    therization  program at  the   state  and/or   local  level?

    The option to utilize LIEAP funds for weatherization should
    be available to the states.  A percentage limitation should
    be placed on  transferring energy assistance benefits to wea-
    therization.   It should be noted that in northern and east-
    ern states a  low-income  household's health and  safety can
    be jeopardized in a  weatherized house  if there is insuffi-
    cient fuel to heat  the house.   Weatherization does  not re-
    move the need for fuel assistance.   Therefore, such options
    should be utilized  only when  it does  not jeopardize the
    health and safety  of low-income families  and  the elderly.
    Coordination of the activities of the LIEAP and weatheriza-
    tion programs can best be designed when Congress determines
    whether or not both  programs  are categorical in  nature  or
    block grants.  Coordination between the two programs would
    be difficult  to  achieve if the  Administration's proposals


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    were enacted by Congress.   The  Administration has proposed
    that the LIEAP program be funded through state block grants
    and as  mentioned   earlier,  the  low-income  weatherization
    programs be funded, at  the  discretion  of local government,
    as one of several  activities of CDBG local block grant pro-
    grams.  The Administration's proposal does not include any
    requirements or even suggestions regarding coordination act-
    ivities of  both  programs.  Thus,  if the  Administration's
    proposal were enacted,  coordination would depend  upon the
    state design  of  the LIEAP  program and  local  governments'
    decision as to whether  or not it  will  fund  the low-income
    weatherization program  and  if  so,  the  design  of such  a
    program. •

C.  What is the most equitable and cost-effective weatherization
    program?  Should the Federal government continue to provide
    substantial assistance  ($1000-$2000/Unit)  to  a  relatively
    smaller number of  houses?  Or, should  the program be re-
    structured to  provide  minimal  weatherization ($200-$300)
    to a large number  of units?

    The most equitable and cost-effective weatherization program
    would be for the Federal government  to provide  assistance in
    the unit cost range of $1000-$2000 per unit.

    The Federal fiscal appropriations  for the program has  limi-
    ted, severely, the number of households that  can be served.
    Such appropriations  need  to  be   increased   dramatically.

    It appears that we have two options:

    1.  Fund the low income weatherization program at a realis-
        tic, level,  in  order to  conserve energy,  relieve the
        energy fiscal   burden  on   low   income  households,  and
        reduce future  costs of the LIEAP program

        OK

    2.  Continue, out  of  political  and practical necessity, to
        annually increase  LIEAP  funding to  protect  the health
        and safety  of low  incone  households and  the  elderly.

    Our national priorities appear to  be  confused.  We plan to
    allocate $1.875 Billion for LIEAP during the next fiscal
    year, and maybe $150 Million for weatherization, or none at
    all.  Yet,  the  weatherization  program  will  save energy,
    reduce the energy  cost burden of low-income households, and
    reduce the need for yearly  increases in the LIEAP program.
    Common sense would  dictate  that  a  significantly  increased
    weatherization program resulting in long-term housing bene-
    fits would be more preferable to increasing the cost of the
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    LIEAP program that does not yield such benefits and does not
    save energy.

    Until we, as a nation, plan and act logically regarding the
    energy problems confronting poor  people, we will continue to
    spend money foolishly  and  at  the  same  time  not achieve our
    intended objective.

D.  How can  CETA  workers  be retained in the weatherization in-
    dustry?

    Many CETA workers  who  were previously  employed in the wea-
    therization program have been retained in  the  weatheriza-
    tion industry.   Since  the  CETA program,  for all practical
    purposes, has been phased out over the past year, the ques-
    tion today is not completely relevant.  It appears that many
    CETA workers have been  absorbed into the weatherization pro-
    gram subsidized by DOE funds.

    Additionally, large numbers  of  CETA workers have been laid
    off and  are,  currently,  unemployed  receiving  unemployment
    compensation or welfare.

Finally, the  following recommendations are  proposed to  EPA:

    1.  Section 11 should  adequately address  the impact  of ri-
        sing energy  prices on  the 14 million low-income house-
        holds in the United States;

    2.  Section 11 should recommend legislative, budgetary, re-
        gulatory, and  administrative  solutions  to  the  energy
        problems confronting low-income households.

    3.  Such recommendations should include continuation of the
        current national  weatherization,   energy  fuel  assist-
        ance, state  and local  conservation programs  at,  mini-
        mally, last year's funding levels;

    4.  Such  recommendations should  also  include  continuation
        of the existing solar  and alternative energy programs,
        especially where  such   programs  utilize  technologies
        that are renewable, low  cost,  and  labor intensive.  An
        example of a successful  program  in  this  area  is the
        National Center for Appropriate Technology.

    An increased versus decreased government  role  is needed in
    the implementation of  energy policy, especially as such pol-
    icies impact on consumers.   The average citizen,  especially
    low-income people, cannot  possibly compete  with the power
    and influence of  the business  community in Washington, B.C.,
    state capitals, or local municipalities.  Low-income people
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            and the average middle  class citizen  need the strong  role of
            government to protect their interests.

                As stated earlier, "conservation through price" is not pos-
            sible for low-income people since their incomes cannot tolerate
            the burden of rising energy costs.

                Thank you.

DR. RIEGEL:     Thank you.  Peter  Robinson  is  the  Executive Director of
            the Maynard Community Development Office.

MR. ROBINSON:   Good afternoon.  It's a pleasure  to have  this opportunity
            to talk to  you.   A little  on  my  own  background.   I've  been
            in the energy consulting business  for a  few  years, and  I am
            currently the Director  for Public  Affairs  for the Association
            of Energy Engineers in New England.

                My main reason  for  being in community development is lati-
            tude.  It gives  me an  opportunity to  put a  lot  of different
            fields together.  The purpose of these hearings is to determine
            how to maintain an  adequate level of  attention  towards  the
            existing energy program imperatives.

                You'll probably hear some accusations that the Federal gov-
            ernment is abandoning underprivileged  and-low  income citizens,
            but I happen  to be encouraged by the new directions of the Fed-
            eral energy policy.

                Decentralization itself is highly desirable since it allows
            programmatic adaptation to  the  needs  of the different regions.

                As for funding  cutbacks,  these  will affect programs in di-
            rect proportion  to the  cuts effectuated  in  the  new  budget.
            Market projections  indicate  rising prices of  energy commodi-
            ties, and they  should  be  considered  accurate in spite  of  a
            temporary hiatus.

                The current glut of oil can be  relied on only  so  long as it
            is politically expedient to the needs of the area.  The politi-
            cal history of the Middle East is consistent only  in  its incon-
            sistency.  When projecting a continued rise in the price of en-
            ergy, market forces will be created  to  enforce  ongoing conserva-
            tion efforts.

                It's natural to look to state and local units  of  government
            to take over many of the activities that were previously funded
            by the Federal  government; however, these units  of  government
            are faced  with  the same  trend  toward  less  government,  less
            regulation and  less  taxation.   This  seems to  contraindicate
            any involvement of  these units of government with  actual imple-
            mentation of  conservation  retrofits.   In Massachusetts, propo-


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sition 2  1/2  is  tearing  away and many say, gutting the effect-
iveness of  state and  local  governments.   This  indicates that
state and local governments will not be able to maintain present
levels of  services  let  alone  extend themselves  to additional
expenditures in  the name of conservation.

    Major cities are not  the only areas  that are  on  the brink of
bankruptcy.  Many of  our smaller towns  at the heart of America
are for  the  first  time  experiencing  financial  difficulties.

    Government efforts to date have been needlessly complicated
and expensive due to the  multiple levels of administration which
have been needed to insure regulatory  compliance.  This mountain
of regulations is the root and cause of the trend away from big
government and its attendant evils.

    In the  course of  aligning   itself with  consumer  oriented
groups, the  government has unwittingly  adopted  an adversarial
position in relationship to business.

    This position is  simultaneously a  foundation  block and a
stumbling block  for all  resulting legislation.   The purpose of
business has never been,  nor will it ever be, fleecing the pub-
lic.  Business has always  endeavored  to supply  goods  and ser-
vices to the  public  at  an  affordable price;  albeit,  with an
acceptable profit margin.   This means that  business  is doubly
accountable to  the  public  since  they  must  be   responsive  to
consumers as  well  as  to  their  stockholders  or  investors.

    Federal government  has a mandate to rationalize and reduce
needless expenditure.  This  means that  very  possibly a  great
many programs will have  to  be  dropped.   It is,  therefore, rea-
sonable to  assume  that  the  private  sector will  take  the lead
in offering  the  consumers  reasonable   alternatives  to  those
activities which were  previously subsidized.  Adequate  atten-
tion to  conservation  can  be  assured by  encouraging  business
to take  over many,  if  not  all  of  the  activities previously
subsidized.

    Program cutbacks will  inevitably  reflect  the amount of the
cuts.  Zero funding will, in many cases, result in total cessa-
tion of activity in  the affected  areas.   Hopefully some of these
projects will be resurrected  by business when market economics
indicate potential for a profit.

    It behooves the Federal  government  to  assist and encourage
the assumption of these activities by the private sector.  Gov-
ernment regulatory involvement has done nothing to date to dis-
courage their efforts.

    In order to  entice business to  prioritize conservation ef-
forts, it Is necessary to  allow it to continue  to  exist.   For

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business, existence is predicated on a reasonable profit, wbicb
is necessary to  remain  in  and do  more  business,  stimulating
the economy.

    Examples of  efforts in  innovative  financing at the state
level.  One innovation involved is having a utility company is-
sue grant subsidies to  consumers  for  weatherization retrofits.
Needless to  say,  the  utility was  not particularly  enthused.

    NECPA mandates that the utilities   supply consumers with en-
ergy audits, and  otherwise refrain from entering allied weather-
ization or  financial  fields.   Since the  passage  of NECPA, it's
become apparent  that  under  the restrictions  of  NECPA,  no  one
else cares to become  involved  in  these fields.   There has been
a great deal of  negative public commentary on  the hidden costs
of legislative energy  audits.   In  Massachusetts,  the are "hid-
den" on  all  gas  and  electric utility bills  as   "RCS  charges,
30c."  30c times   2.6  million utility bills  translates  to  a
cost of over $100 per  audit,  even  if  they achieve their target
figures.

    Virtually no one has seen  fit  to  comment   on the fact that
free audits have  always  been  available from the  insulation in-
dustry.  The most noteworthy  of  these provides a  free "thermal
analysis", so as  not  to compare  with their legislated  energy
audit.  The audit includes  a  cost  estimate with  simple payback
calculations, a  full   three-year  warranty  on  work  performed,
and also  includes a  free thermographic inspection  to  test  for
and correct voids.   Strangely enough, this program  is  offered
by a utility  company which was grandfathered  into the insula-
tion business under NECPA.

    The banking  and   investment   industries are   beginning  to
enter the  industrial   retrofit  business  with  the  concept  of
avoided cost financing.  This  concept uses the  savings genera-
ted by  the  retrofit  to make  the  payments  on the  equipment.
Although  final costs are frequently higher than if the measures
had been  fully capitalized, this  means  of financing is  highly
attractive  to a  large number of institutions, including munici-
palities confronted with tax  cuts  at  the state  level.  Avoided
cost financing turns  out to  be  more  interesting to them than
the schools and  hospitals  program,  since that  program requires
that they front  100 percent of the  cost against the possibility
of the  50  percent  fund match.   Several  banks   are  currently
investigating the  feasibility  of  an  energy  management  and
financial planning  package  which  works  in  conjunction  with
avoided cost financing.  In this  way, a  consumer may realize a
return on investment  while  simultaneously lowering fuel bills.

    Federal government must make every effort to assist business
and industry in their forthcoming  ventures  into the field of en-
ergy conservation.  Some means of assistance are:  one, informa-

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            tion and market analysis;   two, program  development and synthes-
            sis; three, removal of inhibitory legislation;  four, promotion
            of enabling legislation;   five,  formation of  a  loan guarantee
            pool to  allow low  income  participation  in  the  new financing
            packages; and  six,  formation of a  subscriber paid  interactive
            energy information  network which  would utilize existing data
            communication technology.  The interactive mode  should greatly
            facilitate monitoring  and  evaluation  of the  new programs  as
            well as suggesting new directions for further business partici-
            pation.  In  summary,  the  Federal  government  in general,  and
            the Department of  Energy  in  particular, are  invaluable sources
            of information  which  can  be  utilized  to   stimulate  economic
            recovery  and   revitalization   of various   industry  sectors.

                Promotion of enabling legislation will allow a synthesis or
            combination of business, industry and banking interests for the
            welfare of the nation.

DR. RIEGEL:     Thank you very much.  Next on the agenda is Mr.  Keith  Dor-
            sey, representing  the  National  Black  Caucus  of  State Legisla-
            tors.

MR. DORSEY:     Good afternoon.  I'm the special assistant to the  National
            Black Caucus of State Legislators,  and I'm here actually to pre-
            sent testimony of  the  Honorable  Larry Young  who  is a member of
            the Maryland  House  of  Delegates  and the  Executive  Director of
            the National  Black  Caucus  of State Legislators  as  well  as the
            Chairman of its Energy Committee.
            STATEMENT OF MR. LARRY YOUNG

                It is a  pleasure for  me  to be here  today to address  the
            topic of Federal energy  conservation programs and  their  adequa-
            cy or  inadequacy.   This  is a  most  important  process  because
            energy conservation  is  one  of  the most  significant tools  we
            have as a nation to become energy secure.  While I will not dis-
            pute that energy production must take an important role - it has
            to - nevertheless,  conservation still  remains the cheapest and
            most cost-efficient source of energy we have.

                According to one source, energy conservation  programs have
            helped over the last two years to reduce U.S. oil  imports from a
            peak of 8.8 million barrels per  day to  about  5.6 million barrels
            per day.  In 1980 alone, this amounted to savings in the amount
            of $25 billion in the cost of U.S. oil imports.
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    So I cone to this hearing today with  mixed  emotions on the
Administration program to cut 70-80% of the funding for DOE con-
servation programs.  The budget cuts, while looking nice in hud-
get columns, in fact  will not only destroy valuable ongoing, ef-
fective programs hut  will also foreclose valuable payoffs in the
future.  I believe the long-term impacts will be substantial and
that the budget cuts  are at best a gimmick  to reduce Federal out-
lays without considering the impact of the cuts.

    Not only are Federal conservation programs effective for our
nation as a whole,  but  they are especially effective for minori-
ty and low-income  constituencies  - represented  by me and other
members of  the  National Black  Caucus of  State  Legislators  -
as energy prices continue to rise.

    In this  regard,  I  believe  the Administration has  violated
one of its  own principles  as presented in  the  National Energy
Plan III Discussion Paper that stated:

    "Formulation of energy policy must be sensitive to  the needs
    of the poor.  But energy policy should not be used as an in-
    come transfer  program.   For  example,  holding energy prices
    down for rich  and  poor  alike is  an  ineffective way to help
    the poor."

Energy conservation  programs  do  not  hold down  energy prices -
they offset  the impact of rising prices.   Oil decontrol has oc-
curred and natural gas decontrol  is next.   Decontrolling pricing
may encourage production of more oil and gas, hut producing more
energy will  not help minorities and the low-income to  pay  their
fuel bills.  Therefore, the only long-term solution available is
a vigorous  conservation  effort  aimed  at  reducing fuel consump-
tion by  the  low income,  with  a reseulting reduction in  their
energy costs.

    The  items  outlined in  the EPA Public Hearing  Issue   Paper
are interesting  points that I will try to  answer in a general
fashion  from the perspective of a state legislator.

    I think  that most  state and local energy agencies are cur-
rently wondering about their mere existence.  The  state and lo-
cal responsibilities  in  the area  of energy  conservation were
primarily  responsibilities  vested by the Federal  government and
funded with  Federal dollars.  With the budget  problems  that most
states and  local  governments  are currently  facing,  I  do not
think they  are in a position to pick up new energy  functions
overnight.   In  fact,  under the  current budget  proposal,   37 of
50 state energy  offices could be  eliminated.  This is  an action
that would  destroy the partnership and undermine  confidence be-
tween the  Federal, state and local governments.
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    The Reagan Administration  simply has  moved  too quickly in
phasing out  Federal involvement.   This  phase-out  should have
occurred over  a  period  of  years,  say  five  for  example, with
the state's share of costs gradually increasing.  The 21  states
with biennial  budgets  probably will  react by cutting  back on
energy staff and programs in the short-term.

    The first activities to be phased-out  by  states will  likely
include all or most of the Federal energy  programs administered
by the  states.   In blunt  terms,  the money is  just not  there.
You can expect the  Energy Extension  Service,  Residential Con-
servation Service,  Emergency  Energy  Conservation  Planning,  to
name a few, to end.

    Local governments  can  only pick up  new functions with some
source of  funding,  be  it  Federal  or  state, or  local  taxing
policy, and  I  think that all  three  of  these potential sources
will not  be  able  to  provide the  resources  needed  to keep
these current conservation programs operating.

    Information exchange  will  be  severely curtailed,  both by
the closing  of DOE  Regional Offices and the  severe curtailment
of DOE  outreach  and training  grants.   I think it will  be up to
the governmental  public  interest  organizations  to  form "net-
works" to  continue  the exchange  of  data.   However, even these
"networks" will  suffer because many  of  the Federal grants for
energy outreach have been cut.

    In regards to alternative financing for energy conservation,
certainly the  private  sector   will  not  help  out.   Conservation
runs contrary  to their  philosophy of  produce and  sell.  Tax
incentives and tax  credits are fine  except they have no rele-
vance to  the poor  who pay no taxes.   One of  the  best  alter-
native financing  plans  that I  have seen  is the proposal being
advanced by  other  state and local  government groups to  estab-
lish a separate energy block grant  to preserve Federal  spending
for energy  conservation  and   give  states   and  localities more
latitude in  using the  money.   I  tend to  agree with this quote
from Mayor Walsh  from Warwick, Rhode  Island who said:

    The Federal  Government cannot  and  should not  dictate how
    we run our cities  ... However,  there is a Federal responsi-
    bility which  cannot be abandoned.

    I next  want   to look  at the  weatherization  program.   I am
very concerned over the current Reagan Administration proposal.
To fold  the  weatherization  program  into  the  Department  of
Housing and  Urban  Development's  Community  Development  Block
Grants, with  no  accompanying  transfer  of  funds  for weatheri-
zation, and  in fact an  overall decrease  in  CDBG funds.  This
move will  virtually eliminate the weatherization  program for
low-income households.

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    The current delivery  mechanism (Federal  categorical grant
to the  state,  which  contracts  money  to local  agencies),  has
proven effective.    It  assures  even   provision  of   services,
greater quality control, and more  effective training and moni-
toring of  the  personnel  providing  weatherization  services.
Local agencies  already  are  given  much  authority  in  running
the program, with  the  state primarily  as  administrator of the
program.

    I have  the  following concerns  about the  proposal  to fold
weatherization into local CDBG funds:

1.  The primary purpose  of Community  Development  Block Grants
    and the purpose of  the weatherization program are different.
    The purpose of the CDBG program  is to develop communities
    according to the various developmental needs in the indivi-
    dual recipient communities.  The purpose of the weatheriza-
    tion program  is to  help  those with limited  resources  to
    conserve energy.

2.  Some  areas of a  state,  particularly  rural  areas,  would
    receive no  weatherization  funds  at all,  since  CDBG funds
    are distributed unevenly in  states, with the hulk  going to
    cities and  towns.   In  Region III,  for  example,  38 percent
    of eligible clients  live  in  rural areas, ranging  from 20
    percent rural  in  Maryland   to  81  percent  rural   in  West
    Virginia.

B.  IMPLEMENTATION ISSUES

    (1) At  this point,  I  don't think  it is  really  clear who
        the new sponsors will  be.   If it turns out to  be local
        government agencies,  I  think  the  potential  will exist
        for a serious weakening of  the  program.

    (2) Low  income energy  assistance   funds  should not be used
        for Weatherization.   The  programs  have  two   separate
        goals.  Many local community  action  agencies have coor-
        dinated the programs by requiring  individuals receiving
        energy  assistance funds to have their homes weatherized.
        I  think this is very important.

    (3) The  method of program  operation over the last year is
        the most  effective  approach.   Experience in Region III
        demonstrates the  advantages  of  administering   the wea-
        therization program from the  state  level.  When the or-
        iginal  CSA weatherization  program  began  operation in
         1975-1976, the  Region  III  states  were the only  states
        in the  nation  funded on  the  state  level.  Funding for
        other  states went  directly from the Federal government
        to individual  local  agencies.   The  states  in  Region
         III were  soon  far more productive than  other weatheri-


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        zation program  in  the  nation.   Local agencies  in the
        states in Region  III had the highest  material quality
        standards, most  efficient  crews  and  paid  less  for
        materials than  other  regions.   Since  1976  in  Region
        III alone,  115,000  homes have  been weatherized,  at  a
        current average materials cost  per  unit  of $450.00.  I
        think the current  approach of  making available $1,000
        per unit  makes  the most  sense and  is  the most  cost-
        effective method.

   (4)  It  certainly  would be  difficult  to move  CETA workers
        into the  industry.   For one,  some  CETA  workers  do not
        have the  skills that  are  needed  for them  to be hired
        by private  building  contractors.    Many  CETA  workers
        would be  displaced,  but  others would have  the  chance
        to continue working because  they  already  possess the
        necessary skills.  This question needs much more study.

    The Low  Income  Energy  Assistance  Program,  not part  of  a
block grant, should maintain its own separate identity.  Provi-
ding financial  aid  to  the  poor  is  too  important  a task to
dilute by allowing these funds  to be  used  for other functions.

    Before I  close  my  remarks, I  just want  to  say  this:  I
think efforts  to aid  the  poor with their  energy needs  will
receive priority  attention  in  the   Congress.   If-low  income
assistance efforts are  curtailed,  cruel decisions  must be made
- the heat  or  eat scenario.   "Conservation through price", the
cornerstone of the Reagan  program,  is  not a  viable option for
the poor.

    Information should  be   collected  by DOE  to  at least  keep
tabs on what  is available  in  each  state.   I think  surveys of
government, companies  and  homeowners  makes  sense.   However,  I
still don't believe that the  Federal  role  should end with just
surveys.

    Probably the  most  important study that  could be undertaken
would measure  the relative position  of the low income  now in
regards to energy, and  then compile information monthly to see
if individuals are getting  better off  or  worse off.  This kind
of data would help government  bodies  and  citizens  know whether
the  Reagan  energy   policy  is living up  to   its  promises.

    In closing,  Federal conservation   programs  should  be the
backbone of our  national energy policy. As  a  nation, we never
have produced  all of  our  energy needs and we  probably never
will.  Remember,  even  though we  only  obtain about 15%  of our
oil requirements  from  the  Persian Gulf,  in  the even  of  a
global cutoff, we would lose  35  to 45% of  our  total require-
ments because  of our participation in  an  International Energy
Agency agreement  which requires  the  sharing of  the  remaining
                      193

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            supply among  all  members.   According  to  a  recent  Lawrence
            Livermore National Laboratory  study,  such  a  sudden reduction
            in U.S.   oil  supplies could trigger  the worst economic rever-
            sal the  nation  has suffered  since the  depression.   Conserva-
            tional programs  are  important and  they  cannot and  should not
            be eliminated.

                Thank you.

DR. RIEGEL:     Thank you,  Mr. Dorsey.   I turn now to the panel for ques-
            tions and discussion.

MR. GLASSBERG:   I  have  a question  for Mr. Maggiore.  Is  the  present  wea-
            therization program too  restrictive either  in the legislation
            or the regulations with  respect  to the types  of weatherization
            activities that can take place?

                In other words, is  the program too oriented toward certain
            types of activities that might be more applicable to the North-
            east, Midwest and not as applicable to South Carolina or Arizo-
            na in  different  types of  building construction,  and,  also do
            you have  any  data  on  what the implications would  be for a re-
            duced funding level for the weatherization program down to $150
            million, and  what  that  would  mean in terms  of  reduced levels
            of weatherization?

MR. MAGGIORE:   In terms of the guidelines, they are a bit  restrictive and
            not as applicable  in  a minor  way though,  not a major  way, to
            South and Southwest and to big and small cities.

                One of the  problems  that has  existed in the weatherization
            program from  its  inception is weatherizing  dwellings in large
            cities.  That has not been adequately addressed.

                Let me  say  this,  though,  the  program   has  dramatically
            improved by  at  least  300  percent in   comparison  to  what  it
            was.  The administration on the  part  of the DOE  staff now is
            very decisive.   It  was  quite  different  than  the previous pro-
            gram.  So though it's  improved,   areas  of  future  improvement
            in my  estimation would  be some  of  the specifications  as it
            relates to  the  part  of  the country  you live and  whether you
            live in small cities or big cities, small towns and big cities.

                Relative to the funding level, the DOE during  1980 weather-
            ized 311,000 homes, a dramatic increase from the previous year
            when the  program was plagued  with  problems,  literally almost
            double the number of homes in  1980.

                At the  current  DOE  spending  level  ($300  million at  least
            for the past six months at that rate), if the funding level was
            $150 million, the current  effort  would be cut  in half.  That is
            assuming  that in the  event, the  block grant  for energy assist-

                                   194

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            ance went  through and if there  was  a limitation or  percentage
            there they  could  use for weatherization, that might  reduce  the
            nature of  the  cut on a state and local level, but  by and  large
            I would  say at this point,  a minimum of  50 percent based  on
            two reasons  — one, current level of  funding for the last  six
            months;  two,  the reduction of CETA slots.

                With the  reduction  of  CETA  slots,   it's a minimum  of  50
            percent reduction at $150 million.  In  fact, to be  precise,  I
            might say  it's a  60 percent  reduction.  We  can't underestimate
            the impact  of  the  CETA dollars  that have  been  phased  out.
            and are being  further phased out  by  the  end of September.   So
            it's probably  close  to  the  60  percent  reduction,  and  that
            means not only  in dollars, but in  production  as  well.

DR. RIEGEL:     I have a question for Mr. Dorsey.   You correctly point  out
            that the  weatherization  program  and  the  Low  Income  Energy
            Assistance Program have quite different objectives.   Meanwhile,
            we find  ourselves this year contemplating  shrinking  resources
            and perhaps  the  necessity  of addressing ourselves  to  making
            trade-offs in  areas where it is  sometimes not entirely attrac-
            tive to do so.

                A witness who  appeared before you, Richard Kline,  suggested
            that investment in the weatherization program was  in a sense
            more meritorious  for the long  term than the  low-income assist-
            ance program,  and also  made  remarks  about the relative funding
            levels of the  two  programs.

                Do you have any additional comments  on the balance between
            those two?

MR. DORSEY:     Well,  I'd just  like to  state that  they are both  equally
            important, in light of the forthcoming — potential forthcoming
            legislation regarding  the  deregulation  of  natural  gas,  where
            it's been  predicted that for all  consuming  groups  across  the
            nation, the costs  will  double by next year if there were imme-
            diate deregulation.  With that, and the rising  fuel oil costs,
            without an immediate continuation of the weatherization program,
            you will find  the  low-income families  who are the  ones who  are
            most in need of weatherization  will be spending not only more
            for their fuel  costs,  heating  costs,  but  a greater percentage
            because of  the inadequate  shape  of  the housing  that they're
            using.

                So  we believe  it's  very  important that the  two  have  to go
            hand in hand; one,  to cut down on  the  waste of energy with  the
            weatherization program,  and,   two,  to  offset  the  immediate
            impact  of  deregulation  on  low-income  families.   We have  to
            continue with low-income assistance.   So  I would  say it would
            go hand in hand.
                                   195

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MR. POWER:      I'd  like  to  ask Mr. Robinson  about the  regional energy
            planning mode.  I  was  curious about that.   One  of  the effects
            of the phase-out of state programs will be to reduce the amount
            of information coming to  us  on  what the states are planning to
            do, how they see their individual situations.

                Do you see a way  that that  might be undertaken  on a basis
            other than having the Federal government sponsor it?

MR. ROBINSON:   I think  that it  might  need an  initial  kick-off by  the
            Federal government, but  once it  was in place it  would be self-
            supporting.

                I talked  to  about  40  towns  in  my  area,  and  they  have
            objection to a subscriber fee of a couple of  hundred a month.
            In a  lot  of  cases, these  towns  are  small  and have  no  data
            processing equipment and could use it.

                This would give them an  excuse  to  buy it and make use of
            it through word  processing  or accounting as  well  as receiving
            energy information  or  community  development  information  that
            they don't have.

                I find myself doing a great deal of research finding infor-
            mation and the town next-door doesn't have it.  I see no reason
            not to have  an information  clearinghouse,   and  when presented
            by, say, electronic mail, it  could  just  go  through  say a chief
            executive officer  of  the  town  or  city manager  for executive
            decision.  Here's  the  information, are  you  interested? Here's
            the information  we would like.   It  could be  interactive.   So
            you could find out just what is going there.

                The government  has  a habit  and  is very  good  at compiling
            statistics, but the information  often dead  ends; it's  not put
            to use,  and  the statistics   can  be  very valuable  to  indicate
            trends or opportunities of many different natures.

                This represents a  savings to  the  towns,  because to set up
            a local energy  office  costs  $30-100,000 a year.   The trend in
            the face  of  budget cutting,  say  take  Joe  Purchasing Agent,
            and, say, hey, you're  the energy manager.   The  guy is already
            doing a  full-time   job;  so  as  a  consequence  nothing  happens.

                If, for a  nominal  subscriber fee, they can have the infor-
            mation available  on  the executive  level  where  it  would  go
            anyway, if you have an  energy manager looking for information,
            he still has  to  present it  to  the chief executive.  This way,
            you're shortcutting the whole routine.

DR. RIEGEL:     I'd like to thank the  panel,  and   then   inform  you  that
            there's been  a  slight   schedule   change.   We have   one  final
            witness, Mr.  Neal  Gale  of Philadelphia.

                                    196

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MR. GALE:       My name is Neal Gale,and I am speaking today out of my con-
            cern for the well being of our planet.

                The purpose  of my  testimony  is  to  expand  the   focus  of
            these hearings  beyond  the  question  "can energy  conservation
            programs survive  the  withdrawal  of Federal  support?"   It  is
            not that I think  that this question is unimportant.  I am sure
            that many  people   will  answer  it  competently,  and  show that
            energy conservation will be diminished.  This undesirable result
            must be addressed,  and  I  acknowledge those who have undertaken
            this task.  They  have given me  space to  carry the discussion
            further.

                I want to include a look at  the more  distant  consequences
            of this turnabout  in our  national  energy policy.   The  shift
            away from  conservation  and  renewable  resources  is manifest in
            the proposed Department  of Energy budget  - which includes more
            money for the nuclear industry and  less money  for conservation
            and renewables.    The  justification  for this  is found  on page
            five of the issue  paper for  these hearings; point  five  of the
            guidelines established to form the  third  National  Energy Plan:

                "Federal public  spending  for  enrgy  purposes  should  be
                limited to those areas  where the private sector is unlikely
                to invest  sufficiently,  such  as in  high  cost,  long lead
                time technologies, with substantial prospects  of  high pay-
                off.  Public  spending   should  not be used  to  subsidize
                domestic energy  production  and  conservation  since  this
                buys us little  additional  security,  and diverts  capital,
                workers and  initiative  from more productive  uses  elsewhere
                in the economy."

                This position  is  enhanced  by the  stated intention  of the
            Department  of  Energy to allow  free  market forces  to  determine
            the viability  and  growth of energy technologies.  The  result
            is that conservation and renewable  resources  will not be sup-
            ported by  the Federal  Government,  while  the nuclear  industry
            is clearly  given  a leg  up.    This  is  a  dangerous hypocrisy.

                We are  being asked in these hearings to identify the effects
            of this program on energy conservation.   I think  that   it  is
            important  to  look  at the entire  picture,  and ask what will  be
            the results in  terms  of  the  survivability  of  the planet.

                In as  much as  the Federal government  disseminates  informa-
            tion,  swaying  public attitudes,  the  open abandonment  of  energy
            conservation and  renewable  resources,  in  favor of  the nuclear
            industry, is  wrong.   It demonstrates  tacit  approval  of  the
            industry, and  effectively turns  attention away from  the  ques-
            tions  surrounding  nuclear development.

                What is  generally unspoken and  unquestioned  is  that  the

                                  197

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            reduction of  government  support  for  energy  conservation pro-
            grams is being accompanied by the silent commitment to a nucle-
            ar future.   Such  a  commitment is permanent.   The  consequences
            will be with us virtually forever.  That is why  we must consi-
            der all aspects  of  this choice.  The  people  who  will  inhabit
            that nuclear future will not  be  able to turn  back - to choose
            a non-nuclear world.  We are choosing for them.

                I am not pretending to be an expert in the field of nuclear
            energy, and I realize  that  I am  stretching the  stated purpose
            of these hearings by including a statement about it.  I believe,
            however, that we  can  no longer  afford  to pretend that  we  can
            ignore this problem.  It will not disappear by magic or science
            or faith  or luck.  We  must  take responsibility  for  it  now.
            This requires a  willingness to  own  the problem in  a personal
            way.  To examine  the  problem with an open mind  -  being guided
            by the truth  that is  revealed there.   Not to  dismiss the prob-
            lem as someone else's.

                I would  like  to  suggest  a few  topics  to facilitate  such
            an examination by anyone seeking this responsibility:

                *   The infringement of civil liberties by the military and
                    /or intelligence agencies,in  an atmosphere  of  nuclear
                    terrorism and sabotage.

                *   The possibility of civilian nuclear power plants  being
                    used against U.S. citizens,  by  hostile foreign govern-
                    ments, in time of war.

                *   The on-going poisoning of our food and  water supplies,
                    with plutonium and other nuclear byproducts.

                *   The increasing probability  of  nuclear annihilation as
                    nuclear weapon  technology and  materials  are  exported
                    around the world.

DR. RIEGEL:     All right.  Discussion?  Thank you  very much for appearing
            with us today.   I'd also like to extend my thanks to the panel
            for assisting  EPA  in  the  Section  11  review  this  year.   As
            I pointed  out,  these  hearings are more crucial  to the Section
            11 proceedings  than  in years past,  because there has  been no
            prior workshop activity leading up to these hearings.

                We will be  looking  at  all of the formal  statements and at
            the discussion  very  closely in  preparing our  final  report.

            (Whereupon, the meeting adjourned at 4:55 p.m., July 14, 1981.)
                                   198

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                                                         PROCEEDINGS
                                                         JULY 15, 1981
                                                         MORNING SESSION
HEARING PANEL

    Kurt Riegel



    Eugene Frankel


    Ted Kapus




    Gregory Ondich



WITNESSES


    Carroll Benson

    David Davia

    Richard Russell

    Sheldon Cady

    Karen Anderson

    Robert Naismith

    Robert Manahan

    Richard Esteves
Acting Director, Office of
Environmental Engineering and Technology
Environmental Protection Agency

Professional Staff
House Science and Technology Committee

Deputy Director
Buildings and Community Systems
Office of Conservation and Renewable Energy
Department of Energy

Section 11 Program Manager
Environmental Protection Agency
Dallas Power and Light Company

Public Service Company of Colorado

Edison Electric Institute

Mineral Insulation Manufacturers' Association

American Public Power Association

Potomac Energy Group

Thermal Insulation Manufacturers Association

General Public Utilities Corporation
                                      199

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DR. RIEGEL:     Good  morning.  I'd  like to  welcome  everyone  here  this
            morning to  the   hearing   that  the   Environmental   Protection
            Agency is conducting this  year under  Section  11  of the Federal
            Nonnuclear  Energy   Research   and   Development  Act.

                This is the act that created the Energy Research and Devel-
            opment Administration in  1974 and  and  that contained  the  so-
            called "Section 11" provision, charging the Council on Environ-
            mental Quality to  review annually  the  programs  of  the Energy
            Research and  Development  Administration,  now  the  Department
            of Energy, with  respect to the  adequacy of treatment  to  hoth
            conservation and environment.

                That responsibility  was  transferred  within  the  executive
            branch from the  Council on Environmental  Quality  to  the Envi-
            ronmental Protection Agency  in  1977.   This  year's  Section  11
            review is the  fourth  annual  review  that  we have  conducted  of
            Department of Energy programs.

                From year to year,  we  have  shifted focus from  one part  of
            the energy research program to another,  and this really repre-
            sents the  second  look  that  we  have  made at the  conservation
            element of the program.   We feel it is particularly appropriate
            to look at the Federal conservation programs this year, because
            the Administration has  announced  fundamental  new directions  in
            pursuit of  our  national  energy  objectives.   A  conspicuous
            feature of that new  direction is de-emphasis of   Federal   in-
            volvement and investment in  conservation,  but with a reaffir-
            mation of the importance of  conservation  in  the national  pic-
            ture and a public  statement  by  the  Administration  that conser-
            vation responsiblities  most   efficiently  and  effectively  are
            to be picked up by state and local governments  and the private
            sector.

                A fundamental purpose of this year's  review  then is to ad-
            dress this problem of  transition of  a  rather large  and  ambi-
            tious Federal program to one  which  is less resource-intensive,
            but which  nonetheless  intends  to have  a  large  and  important
            impact on the energy picture  for this country.

                Just a few words  about  how we would like to  run things  this
            morning.  Many of  the  witnesses, who  incidentally  represent a
            very diverse  set  of  backgrounds and  experience,   will arrive
            with prepared statements.  I assure you  that  these statements
            will be put into the  official record of this hearing.

                I would ask the  witnesses to  the extent that that they can
            to summarize  those  prepared  statements  so  that  we  can  turn
            rather quickly to  questions   and  discussion  involving members
            of the panel.
                                   200

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                I'm Kurt Riegel,  from the Environmental Protection Agency.
            At my far left is Greg Ondich, who is also with the Environmen-
            tal Protection Agency and has been the Program Manager for this
            year's Section  11  process.   Representing  John Millhone  from
            the Department of Energy  is Ted Kapus who  will  be here for at
            least a portion of this morning's proceedings.  He is the Depu-
            ty Director  for  the  Buildings  Conservation Program;  and  then
            finally, to my immediate left is Eugene Frankel, from the House
            Science and Technology Committee.

                With no  further  discussion  then,  I would like to turn this
            morning to our witnesses.

                We will begin with Mr. Carroll Benson from Dallas Power and
            Light.

MR. BENSON:     Thank you.  I'm Carroll Benson, Director  of Program Devel-
            opment for Dallas Power  and Light Company,  and  by way  of in-
            formation, DP&L is  a metropolitan utility serving approximate-
            ly 450,000  customers  in   the  city  limits  of  Dallas,  Texas.

                We appreciate the  opportunity to be  here  this morning and
            to discuss the  changing  role of  the  private sector  in future
            conservation activities.   Before  I begin  that  discussion,  I'd
            like to say  that we  have no serious  quarrel with  the public
            discussion package for the third  national energy plan that was
            published by DOE in March of 1981.

                Despite the events  of June 26 in  the  House  of Representa-
            tives, we are convinced that  the  underlying assumptions of the
            Administration regarding  a  return of  these responsibilities to
            the private  sector  are  correct and that  in  the  final analysis
            the roles of government and the private sector will be restruc-
            tured.

                The focus  of this  hearing,  as   we  understand  it, is  to
            evaluate the role  and reaction  of the private  sector to  this
            change in philosophy, and particular  emphasis  has  been reques-
            ted by EPA on preparations for assuming these new responsibili-
            ties, which  activities will  receive  priority,  what new initia-
            tives or opportunities may develop, and  finally  what the Fede-
            ral government's proper  role may  be  and some methods  for the
            government to  monitor  the  effects   of  this  new  direction.

                Addressing each  of  these  in  order,  I  would  have  to  say
            that DP&L has had  some difficulty in determining  any  new re-
            sponsibilities.   We've been  a leading advocate  of  wise energy
            usage for many,  many years, and in fact,  our company was recog-
            nized by  the President in  a White  House ceremony  in January
            1981, and  I'll  quote,  "for  its  outstanding  contribution  to
            America's economic  and  national  security  through  exemplary
            leadership in the national effort  to achieve energy efficiency."


                                   201

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    I offer  this  comment on  the  President's Award  for  Energy
Efficiency not as a  brag on  our  part,  but as evidence  of  our
early and continuing  commitment to wise energy use.  The award
was based  on over 30 distinct conservation  oriented  programs
offered by DP&L to its  customers, none of  which  were  required
by any, and I'll repeat, any governmental entity.

    Our programs emphasizing  wise energy use and  the  control-
lable relationship between  energy usage and  cost  will  continue
to receive priority emphasis  in all of  our customer communica-
tion programs.  Those programs which have  particular  signifi-
cance in terms of peak demand  reduction and/or  load factor  im-
provement will receive emphasis.

    The philosophical shift in the government's energy program
emphasis proposed by  the  Administration has  not directly crea-
ted any new  initiatives  or opportunities  for  our  company,  but
may in the  future  as institutional and regulatory barriers to
program operation are removed.

    Specifically I'm  referring to innovative  cogeneration  and
small power production  options that  may be  available, as  well
as the opportunity for  creative  financial  incentives  and  con-
servation measure installation programs.

    Although the opportunity was  not  created by government dis-
involvement, I would like  to take  just  a  minute  to desribe
DP&L's latest program.

    Panel members, the  same chart  is  in the  back  of your pac-
kage.  Effective  May 4  of  this  year,  the  Dallas Power  and
Light Company  through  its  Your  Energy  Share  Program  began
assisting customers with  the  purchase of high efficiency cool-
ing and heating  heating equipment as  well  as  solar  and  heat
recovery devices to  supplement electric water heating  systems.
(See Tables 1 and 2).

    Your Energy Shares  are monetary  incentives to help  custo-
mers offset  the  increased  cost  of high   efficiency equipment
and can be  applied as payment on the customer's  electric ser-
vice bill.  As the cost  comparison in Table  3 illustrates,  re-
placement of a four-ton central cooling unit with  a SEER of 6.0
in a typical home in Dallas which has  gas heating  with a simil-
ar sized heat pump with an EER of 8  will yield  a net payback
to the customer in  less  than five years  at current  energy costs,
and thereafter produce  a net  annual  energy savings of  better
than $400 per year using current  dollars.

    Those numbers include the  Your Energy Share incentive, which
is shown down at the   bottom and in this case  would be  $320, or
$80 per ton.  That's  a  certificate that we actually provide to
the customer  which  he  can  use  to   pay  his utility  bill.

                      202

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                                    RESIDENTIAL

                                      TABLE 1
             YES
               YOUR ENERGY %-IARK
            How Does It Work?
1. When you buy equipment* that meets YES
  Program standards, you become eligible for
  Your Energy Shares.
2. Your dealer or contractor will provide a
  form for you to send to DP&L.
3. A DP&L representative will contact you to
  verify installation.
4. After verification, DP&L will send you Your
  Energy Shares that you can redeem for
  electric service.
" Installed after May 3, 1981


      How To Earn Your Energy Shares
 The more energy efficient the equipment,
the more energy shares you will receive.
Equipment that qualifies for the YES Program is
based on its efficiency rating. See reverse side
for details.
               New Homes
 To qualify under the YES Program, new
houses, condominiums and apartments must
be certified energy efficient  according to
DP&L's E-OK rating system. Ask your builder
about E-OK standards, or call a DP&L
representative at 698-7000 for a free E-OK
booklet.
              YES
               YOUR ENERGY SI-IARII

    YOUR ENERGY SHARE INCENTIVES

            AIR CONDITIONERS



Central systems
Window units
12,OOOBtu and
below
Window units
12,001 Btu and
above
Efficiency
Rating of
8.5-10.49
$60 per ton
$60 per unit


$100 per unit


Efficiency
Rating of
10.5 and higher
$120 per ton
$120 per unit


$180 per unit


Central systems
Window units
12,000 Btu and
below
Window units
12,001 Btu and
above
HEAT PUMPS

Efficiency
Rating of
8.0-10.49
$80 per ton
$80 per unit
Efficiency
Rating of
10.5 and higher
$140 per ton
$140 per unit
$120 per unit  $200 per unit
      Solar-assisted Electric Water Heating
          $120 per system or device

  Heat-recovery System for Electric Water Heating
          $120 per system or device
                                              Credit:
                                              Example:
                 Example
         $60/ton with efficiency rating of
         8.5-10.49
         4 ton with efficiency rating of 9 0
         4 X $60 = $240
         $240 Energy Share Credit to Customer
                                               7-81
                                        203

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                                         MUL7IFAMILY


                                           TABLE 2
             YES
               YOUR ENERGY SHARE
            How Does It Work?
1. When you install equipment that meets YES
  Program standards, you become eligible for
  Your Energy Shares.
2. Your dealer or contractor will provide a form
  for you to send to DP&L.
3. A DP&L representative will contact you to
  verify installation.
4. After verification, DP&L will arrange for Your
  Energy Shares to be credited to your electric
  service account.


      How To Earn your Energy Shares
  The more energy efficient the equipment,
the more  energy shares you will receive.
Equipment that qualifies for the YES Program is
based on its efficiency rating. See  reverse side
for details.
            New Construction
  To qualify under the YES Program, multifamily
units must be certified energy efficient
according to DP&L's E-OK rating system. Ask
your representative about E-OK standards, or
call DP&L at 698-7528 for E-OK information.
              YES
               YCXJR ENERGY SHARE

 YOUR ENERGY SHARE QUALIFICATIONS

            AIR CONDITIONERS



Central systems
Window units
12,OOOBtu and
below
Window units
12,001 Btu and
above




Central systems
Window units
Efficiency
Rating of
8.5-10.49
$60 per ton
$60 per unit


$100 per unit


HEAT PUMPS
Efficiency
Rating of
8.0-10.49
$80 per ton
$80 per unit
Efficiency
Rating of
10.5 and higher
$120 per ton
$120 per unit


$180 per unit



Efficiency
Rating of
10.5 and higher
$140 per ton
$140 per unit
12,000 Btu and
below
Window units     $120 per unit  $200 per unit
12,001 Btu and
above
      Solar-assisted Electric Water Heating
          $120 per system or device
  Heat-recovery System for Electric Water Heating
          $120 per system or device

                 Example
Credit:    $60/ton with efficiency rating of
         8.5-10.49
Example:  2 ton with efficiency rating of 9.0
         2 X $60 = $120
         $120 Energy Share Credit per unit
                                                      7-81
                                     NATIONAL
                                     ENEMY
                                     WATCH
                                                204

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                                  TABLE 3
      /?.-
to
O
U!
SIZE: 2000 square feet
COOLING UNIT: 4 ton (6.0 SEER)
GAS HEATING
INSULATION:
  ceiling   R-13
  walls    R-7
  floor    none
THERMOSTAT SETTING: 78° summer
                     72° winter
HEATING USAGE: 875 ccf
HEATING COST: $333 per season
COOLING UNIT USAGE: 11,200 KWH
COOLING COST: $728 per season
COOLING UNIT DEMAND: 8.0 KW
COST TO REPLACE COOLING
UNIT WITH SAME EFFICIENCY: $1,200
                                      SIZE: 2000 square feet
                                      HEAT PUMP: 4 ton (8.0 EER)
                                      INSULATION:
ceiling
walls
floor
R-13
R-7
none
                                      THERMOSTAT SETTING: 78° summer
                                                           72° winter
                                      HEATING USAGE: 6,156 KWH
                                      HEATING COST: $215 per season
                                      COOLING UNIT USAGE: 8,400 KWH
                                      COOLING COST: $546 per season
                                      COOLING UNIT DEMAND: 6.0 KW
                                      COST TO REPLACE COOLING UNIT WITH
                                      HEAT PUMP: $3,000
                                      YES INCENTIVE: $320
                                      PAY BACK: $3000^$ 11200_— $32p=$1480=4.9years
                                               (heating savings: $118  $300
                                               & (cooling savings: $182)

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    At the same  time  this efficiency  changeout  occurs, DP&L's
summer systems peak, is reduced by 2 kilowatts.   We can consi-
der this  system  peak  as permanently deferred  construction and
ultimately it  will   lead  to a reduction  in the need  for fu-
ture facilities expansion.  It will improve our existing equip-
ment utilization, and  it  will reduce  our  requirements  for new
capital, actions  all  of  which slow the  rise in  energy costs
faced by the company's customers.

    In the second example  (see Table 4),  just changing the air
conditioning results in a  net 2.1 year payback  and thereafter
a  $273  seasonal savings in cooling costs.   Again  these  are
based on  current  dollars.   This  replacement, from  a  unit  with
6 SEER to  9.6 SEER equipment,  will reduce  DP&L's  system peak
by 3 kilowatts  and  can  also be considered  as  permanently de-
ferred construction.

    The same   incentives   are available  for new construction
meeting DP&L's  National  Energy  Watch  E-OK Home  Conservation
Construction Standard — a standard, incidentally, which exceeds
the levels required by the Residential Conservation Service and
which was  instituted  two  years prior  to the  passage  of NECPA.
Meeting the conservation  construction  standard  also allows for
smaller equipment  sizing,  yielding  yet  another increment  of
peak demand reduction.

    The YES program  is applicable to  all  residential housing,
including multi-family, and has  been  highly  successful in its
first two months of operation.

    Within the next month,  DP&L will institute its newest Your
Energy Share  load  management  activity for all  customers.  In
this program DP&L will pay the cost differential between popular
and high  efficiency  lower  wattage  fluorescent  lamps.  Payment
will be made directly  to dealers and distributors of lamps, and
within six months to  one  year we  expect  that regular fluores-
cent lamps  will  no  longer  be  stocked  in  the Dallas   area.

    Other peak  reduction  load factor  improvement programs may
include demand  limiters,   sharing  interruptible  loads  between
groups of buildings, radio  controlled  and temperature sensitive
demand limiting  of  non-critical  loads, such as  electric water
heating and  swimming  pool  filter  pumps,  as  well  as  thermal
storage systems for large building air conditioning.

    The overall  goal  of  these load management  programs  is to
reduce the Dallas Power and Light  system  peak by 206 megawatts
in 1985.   Your Energy Shares  is  a part of  an   overall   Texas
Utilities  Companies  System goal of  reducing the  1985  peak by
1000 megawatts,  the   equivalent  of   one  large  power  plant.
                       206

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                                  TABLE  4

o
—i
  SIZE: 2000 square feet
  COOLING UNIT: 4 ton (6.0 SEER)
  INSULATION:
ceiling
walls
floor
R-13
R-7
none
  THERMOSTAT SETTING: 78° summer
  COOLING UNIT USAGE: 1 1 ,200 KWH
  COOLING COST: $728 per season
  COOLING UNIT DEMAND: 8.0 KW
  COST TO REPLACE COOLING
  UNIT WITH SAME EFFICIENCY: $1 ,200
SIZE: 2000 square feet
COOLING UNIT: 4 ton (9.6 SEER)
INSULATION:
  ceiling  R-13
  walls    R-7
  floor    none
THERMOSTAT SETTING: 78° summer
COOLING UNIT USAGE: 7,000 KWH
COOLING COST: $455 per season
COOLING UNIT DEMAND: 5.0 KW
COST TO REPLACE COOLING
UNIT WITH HIGH EFFICIENCY: $2,000
JYES INCENTIVE: $240 )
PAYBACK: $20qp-—$1200—$240 =$560 =2.1 years
          (cooling savings: $273)  $273

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                We view the proper role of government  as  a  facilitator and
            information exchange medium for new and  innovative initiatives.
            In those areas  where  barriers exist,  government should  seek
            ways to assist in their removal,  and  rather than talking about
            the reasons why ideas  won't work,  we  need to work  together to
            discover how they  can be made  to.

                We need an unbiased information exchange  regarding what is
            being done, how and where  it's being  done, in order  to stimu-
            late additional activities. We also view the government's role
            as that of a  goal  and objective setter  for a rational and co-
            herent energy future,  not  as   a  specifier of  how  to  achieve
            those goals and not  as an  advocate for any  particular favored
            source of energy.

                Evaluation and monitoring  are always difficult  and thorny
            issues, and we suggest, however,  that the private sector makes
            its living through evaluation  and  monitoring  of  its activities
            to determine which  are profitable, and, therefore, to  be ini-
            tiated or  continued.   The  private sector, therefore,  is in an
            excellent position to provide  suggestions  on specific programs,
            suggestions which  may have more   merit  and  practicality than
            those  proposed by government  personnel or  their paid consult-
            ants.

                We earnestly solicit the  opportunity  to help evaluate pro-
            posed and  active  programs  and to  be  involved in the decision
            making process through participation, advisory  commitees, task
            force activities and other  avenues of  cooperation.

                Rather than rehash past  successes and failures,  we prefer
            to look instead to  the future, a  future which portends an era
            of improved  cooperation,   innovation  and  shared  achievements
            between government and the  private sector.  In the final analy-
            sis, we have  the  same objective  in view — a stable, growing
            economy which is not dependent on  foreign suppliers for signi-
            ficant portions of our energy.

                The only practical way  to  get  to that point  in our judgment
            is to  unleash the  creativity of  American   free  enterprise.
            Thank you.

DR. RIEGEL:     Thank you very much.   We,  of course,  will be coming back
            with questions and  discussion,  but right  now, I  would like to
            move on to David Davia from Public Service Company of  Colorado.

MR. DAVIA:      Thank you.  First, I  would like to  thank  EPA and the gov-
            ernment for asking for this review and for showing concern with
            this country's  energy future.   As stated,  I  am  David Davia
            with the Public Service Company of Colorado.  We  are a combina-
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tion gas and electric  utility  with a total of 820,512 electric
customers and  680,615  gas  customers.   We  serve  approximately
70% of the population in the State of Colorado.

    During May, 1981, our average residential cost for electri-
city for customers  in  the Denver area was  $.059/kWh;   gas  was
$3.59/mcf ($.43/ therm)  this compared  with $.04/kWh and $2.54/
mcf just one year ago.

    Currently,  we have 100  field  representatives  involved with
residential audits and conservation;   30  field engineers doing
commercial audits and other conservation activities;  7 employ-
ees working full time in our Conservation Center and 10 employ-
ees in  Training and  Program  Development  working  on training
for our residential  auditors.   In addition, we have  a  gas  lab
and other various support groups.

    Our experience with residential conservation is as follows:

    *Residential R-30  Attic Insulation  Program  (started  Sep-
      tember,  1975)

        75,000 homes inspected
        34,500 homes insulated under our program
        75 contractors used to install material
        Gas use reduced  by  12% overall (corrected for weather)
        Approximately 40%  of  jobs  sold   financed  on  monthly
         utility bill

    *Air infiltration test involving 90 homes
        Final Report 3rd quarter  1981

    *Furnace derate and testing on 90 homes
        Final Report 4th quarter  1981

    *Residential Audit Program started in 1979
        20,893 audits requested
        15,633 audits complete
         4,973 request cancelled

    *RCS type  audit  with  computer  assist  started  May  1981
         4,419 audits requested
         1,216 audits complete
           309 request cancelled

    *Conservation Center,  Conservation Booklets, and Customer
     Programs  in the last 12 months:
     (started  January, 1980)
         16,706 customers have visited the center
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         33,746 customers have called for conservation informa-
                tion
        266,238 customers  have  entered  conservation  product
                drawings
         35,637 conservation brochures picked up  or  mailed out
    Under general question Number  One,  you ask,  "How  are  pri-
vate firms, state governments, and  local  agencies preparing to
assume their new responsibilities?"

    First of all, we  do not  feel these are  "new responsibili-
ties", we had these responsibilities  before  NECPA and we  will
have them  after  RCS and  all other  programs  have   run   their
course.  We feel  that  since  1975  our company, along  with the
Edison Electric  Institute,   the  American  Gas  Association  and
many other utilities,  displayed extreme  innovation with market-
ing conservation.   Remember  that  a  regulated  utility  is  the
most efficient way to provide gas and electric  service to  cus-
tomers.  In the  past  when each  new  power plant added  to  the
system meant  lower  rates  for  everyone,  utilities   were  out
marketing for more  growth.   Now  that  we see  today's  market
180° changed from the past we see utilities marketing conserva-
tion very actively.

    We at Public Service feel that  our  existing programs would
be much  further  along had we  not had  to take  the   last   two
years to develop and comply with the RCS Program.

    Whatever happens to RCS,  CACS,  REEP,  or  BEPS we will  con-
tinue to  deal  with our customers  in maximizing their  energy
efficiency while managing demand and cost through whatever pro-
grams are necessary.

    If I may digress for  a moment  and report  that conservation
in our area is occurring mostly with natural  gas.  We have seen
a substantial reduction in gas use  for  space  heating and water
heating.  This is supported  by an  American   Gas  Association
(AGA) report dated  March  20,  1981,  that  showed, and  I  quote,
"The highest  rate  of  decline in  gas  consumption was  3.6% per
year in  the  mountain region".   Our  own  data   supports  that
finding — we show  from 1973 to 1979 a   reduction   in gas use
of 3.5% per year.

    The electric  side  of  our  Company shows  just the  opposite
is happening.  We see  electric use increasing  both  as a func-
tion of  more  use per  customer and also  growth due  to  steady
in-migration to  our  energy  areas.   In  our  1979  statistical
review we  see average  annual  residential consumption  in  1979
at 5913  kWh's,  up from  4,621  kWh's  in  1969.   This  is  due to
increased appliance load and increased  saturation of new types
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of appliances.   The  following  numbers point  to  some of  the
problems:

    water bed heaters -12% saturation
    second refrigerator in use - 14.7% saturation
    second food freezer in use - 3.8% saturation

    These along with a  greater  dependence  on electrical energy
show demand  problems  which are  not  being addressed  fully  by
any Federal  program.    Our  problem  is with  demand more  than
energy.

    As to  your  question  Number  Two,  "Which  activities  will
get priority  form public  and private  organizations  and  what
will be the  consequences  if  some  activities are discontinued?"

    We feel  an  energy audit done  on site  with the homeowner is
the best way to diagnose  the energy  ills  of a  home.  Although
most people  feel  that   conservation is labor intensive,  which
it is,  it  is  also education intensive.    Therefore,  we  will
continue to  pursue  programs  like  the Residential  Home  Energy
Audits which completely evaluate  the customer's thermal envel-
ope, appliance  use,  general  conservation   opportunities,  load
management, habits habits  and attitudes.   These  programs  will
be supported additionally by  our  Conservation  Center  with its
state wide  hotline,   conservation  booklets and  programs  for
group presentations designed  to meet  the  needs  of particular
groups through proper education.  We are now training 60 audit-
ors to do  audits  in  low income housing in the  Denver  area and
have also  done  a  master  conservation  program  and  low income
grant writing program.

    An issue  which continues  to  get  greater  interest by our
company and  many  other  companies  is  residential  space heating
equipment.  We have found that existing equipment has  a number
of problems  which include  oversizing,  seasonal  efficiencies
of 45% to  65% with some  as  low as  30% and very poor  or  non-
existent maintenance.

    We are removings our test  equipment  on 90  derated furnace
sites and  are  currently developing a  furnace  tune-up  program,
both of which  should  show  us the  most cost-effective way  to
direct future  conservation  efforts  in  this  overlooked  area
of heating equipment.

    Of note  here  is the fact that  in the  field  of  energy  con-
servation and  solar  heating  the  government   has  encouraged
activity in  the hardware  arena.    We do   not  agree with  this
policy because  customers  may buy  the big  ticket item for its
tax value  and  completely  miss the  boat on energy  savings.   A
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good example here  are  storm windows.   We know  that  in  most
cases caulking and weatherstripping are  much  more cost-effect-
ive than an additional pane of glass.  Most buyers  never check
for such things  as thermal  breaks or  infiltration  rates  and
thus buy windows which do not perform.  The  homeowner  is  left
with two panes of glass  to maintain but  no reduction in energy
used.  The  solar buyer in Colorado is motivated  by statements
like, "Buy  solar  for its  70%  state and  federal  benefits".
Also, because  the  solar credit  is  70%  and  the  conservation
credit is  only 35%,  solar  must  be  of  greater importance,  at
least that  is  what  the homeowner thinks.  We know  this is  not
the case.   Nevertheless, many   people  are doing  one   of  two
things.  Either they do  solar installations before  any  conser-
vation is addressed or they  are waiting for  a  solar "miracle"
and not doing any conservation at all.

    The one glaring error in this  entire  program  is that  gas
furnaces are not addressed straight  on.   You  are  encouraged to
fix what you have by  adding  a  vent damper  or  an electric igni-
tion", but  this at best  is  just  using the  "band aid" approach.
If we could initiate   some sort  of incentive  replacement  pro-
gram that  would  encourage existing  45-65% seasonal efficient
heating equipment to  be replaced  with  newer appliances which
are available, are  85-95% efficient  and replacement of these
older units looks cost-effective in today's market.

    Point Three,   "Have  any  new  initiatives  or  opportunities
been created as a result of the shift in Federal energy  conser-
vation programs?"

    The initiatives  and  opportunities  have   been  for  those
people or  organizations  who do  not  fall  under  one of these
"cradle to  grave" Federal programs.

    As a result  of  the RCS listing requirements  and $15 price
limit, we have seen many  companies want  to contract for servi-
ces, want  to  be   consultants,   offer computer  software   and
offer solar  site  selectors.   Auditing   companies  which we  do
not wish to use in our program threaten law suits.  Contractors
yell "foul" as to  the way the  state originated  and maintains
the master  list.

    Initiatives and opportunities?  No.   It's more like confu-
sion and aggravation with constant change.

    Point Four,  "What is the Federal government's  proper  role
in the period of  transition?"

    We feel  that  the   government should do  more directing  in
the area  of  education,  product  specification  and  results.
Utilities along  with   the private contractors can  develop  the
                        212

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 necessary programs  and procedures  needed  to  carry  out  conserva-
 tion and load management.

     Although this  argument has  been used and  used again,  the
 market  system works  and works  well.  As  the price  goes  up,
 usage goes down.   We  know  that  people need  energy as much  as
 food and  other essentials.   But  the fact  still  remains  that
 we  are   living  in homes  that still  waste  30%  to  50%  of  the
 energy  purchased.   Until this pattern of  waste is  changed  the
 buying  public will  continue to be frustrated by higher monthly
 bills.

     Utility  companies   have   been,  and  are,  very  willing  to
 help.   It's  much  easier to talk to  a customer about  conserva-
 tion rather  than  a  high bill.  But if everyone is  recommending
 storm windows and  insulation  and the  installed  products  do
 not  perform,  or are  unsafe  or  installed improperly,   no  one
 is  any  further ahead.   If conservation and  load management  are
 not  done right the  first  time,  they will have to be redone.

     If  the government  would  educate  the  potential  buyer  about
 how and what to buy  and not  spend all  your regulatory effort
 with people  watching  the  way  other people  are  doing  a   job,
 success would be of much greater magnitude.

     Utilities are not  banks;   we  are not  code  bodies.  By  our
 granting loans  and  doing  inspections,  we  duplicate  services
 which are  already  available.  Audits and conservation inform-
 tion should  be done  by utilities.   The  sale of  equipment  to
 correct  problems  and  improve efficiency should   be  left   to
 the  private  sector.

     Point  Five,  "How  should the  Federal government  evaluate
 and  monitor  the effects of  its new energy policies  and program
 changes?"

     If  you  are doing  conservation programs,  you  should  make
 sure  they  are  cost-effective,  are  supported  with  customer
 demand  and  have  results  with  measurable  reduction  in  peak
 demand  or  energy used.  Each  region  should be monitored to see
 what  results  are being  attained.

    As  stated  earlier,  this  company along with  many  other
 utilities are very interested in load management,  conservation,
 improved efficiencies,  and  and   customer attitude.   We  will
 continue to  strive  for improvement in all these areas.  It's a
 big  job  that  utilities,  government agencies,  and  the consuming
 public all have a very important role in.

    I feel that the  low income people need  immediate  help not
with paying  bills,  but  with  reducing energy  waste  in  their


                       213

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            homes.  I know  programs  like the Low  Income  Energy Assistance
            Program (LIEAP)  are necessary  for the interim but  they should
            not be the only cure.  LIEAP recipients  should have audits and
            have  weatherization  done,  in   addition   to  financial help.

                Weatherization programs  should  be run  by agencies looking
            for results  —  not jobs.   We  worked on  low  income  projects
            where the manager of the program was more interested in getting
            a grant for  a computer  than reduced  energy  use for  the  poor
            people he  should  have  been helping.   We  have  seen  programs
            where bad material  and  poor management  add  future  problems.
            These programs  do  not  get  the  results  our  tax  dollars  are
            being spent for.

                In summary,  we feel  that utilities have a place in conser-
            vation doing  audits and  customer  education.   The  RCS program
            should be modified  to reduce the  burden on  utilities.  Items
            like contractor  list,  follow up  inspections,  arranging loans
            and installations and massive recordkeeping should  be removed.
            Flexibility on a  regional  or  state-by-state  basis should  be
            stressed.

                The government should  reduce  and modify its role in trying
            to be  all  things  to  all people,  and allow each  region of the
            United States  to   respond   to  this  common problem of  energy
            conservation and load management  in a way  that  brings results
            and an eventual  solution to this menacing problem.

                Thank you.

DR. RIEGEL:     Thank you.   We now turn to Mr. John Russell  from the Long
            Island Lighting Company.

MR. RUSSELL:    Thank you.   My name is Jack Russell, Vice President of the
            Long Island  Lighting  Company  and  Immediate  Past  Chairman  of
            the Customer  Relations,  Conservation  and  Energy  Management
            Executive Advisory Committee of the Edison Electric Institute.
            Today, I  am  speaking on   behalf   of  the   Institute's members
            which serve  77%  of all  89.5 million ultimate customers served
            by the electric utility industry.

                On behalf of  EEI  and  its  member companies,  I appreciate
            the opportunity  of presenting  the  electric  utility  industry
            view on  the  DOE   conservation  programs  and  to provide  some
            insight into what EEI companies, particularly my own, are doing
            in the conservation arena.

                The necessity  of  conservation  is well established.  Some
            view conservation  as  an energy  source;  some  have  declared  it
            the moral  equivalent  to   war;  and   many  organizations  have
            committed themselves to its cause.
                                   214

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    But what  is conservation?

    - Customers  view  conservation  as  a  way  to  alleviate the
      increased cost of energy.

    - Utilities view  conservation as a way  of saving fuel and
      capital expenditures.  Perhaps, more importantly, conser-
      vation  should strive  to  improve economic efficiency, al-
      though  more  correctly stated,  economic efficiency should
      fuel conservation because the driving force for conserva-
      tion is economics.

    For "energy  conservation"  to be  truly effective,  both of
the previously  stated objectives have  to be  fulfilled.   When
the electric  utility  saves, the customer will save,  and  it is
therefore in  the   customer's  best  interest  that  the  utility
save energy  in a  cost-effective manner.   For  example,  let's
look at  a  typical  customer  and  the  way  he  can  conserve.

    First - A customer decides "I won't turn  on  my air condi-
tioner until  I  can't  stand it anymore!"  This may  be a common
response from  customers,  particularly  as the cost  of energy
continues to  rise.  There   are,  of  course,  different levels
of tolerance  among customers as to when  the  degree of discom-
fort overrides the perceived value of the savings.

    Depending of   course  on  the  particular   electric  system,
the first  effect   certainly will be  a savings  in fuel.   For
some utilities  this  fuel will be oil.   But  what  effect  does
this response have on  the utility's load shape?  In many cases,
this will  cause a system spike  which results in  little  or no
capacity savings.   The end   result is the  least  desirable type
of conservation from  both  the  utility's  and  customer's  view-
points, i.e.,  the utility  doesn't   save  on  capacity  and  the
customer is uncomfortable for much of the summer and the utili-
ty still has to file for additional rate increases.

    The second  type  of energy conservation  category involves
measures such as  customer action  to  upgrade the thermal treat-
ment of his or her home, or  the use of more efficient equipment
(air conditioning,  heat  pump,  or  other  electric  appliances)
or through the use of  thermal storage.

    The thermal  storage approach  to energy   conservation  in-
volves a deliberate attempt to improve load  shape.  Depending
upon the utility,  thermal  storage may save fuel  or change the
mix of fuels consumed.  If  this methodology achieves widespread
use it may become  the  best  method of energy  conservation from
a utility viewpoint.   Even  though, with thermal  storage,  there
are losses associated  with the  storage,  these  losses may  be
                       215

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made up  for by  using  more efficient  offpeak  generation.   In
any event  increased insulation,  highly  efficient  appliances
or thermal  storage achieve the double benefit  of  saving custo-
mers money and improving utility load factors.

    Because of the unique load characteristics of each company,
conservation programs are  much more cost-effective  when these
characteristics are  taken  into  account.   The  RCS  program  is
a national  concept  that  ignores the individual  company chara-
teristics.  And which,  we believe, will prove to be very costly
to utilities and their  customers.

    The cost  of  the RCS program  (some  $4.9  billion dollars,
according to  DOE)   does  not   justify  the  incremental  energy
savings that will result from the program.   The electric utili-
ties are  already involved  in programs that  are  locally  cost
justified, and  that meet  a  majority  of   the  goals   of  RCS.
Therefore, any  savings  attributable to RCS are  actually  only
the difference  in  savings  (if  any) between  RCS  and existing
or planned  utility  programs.   To  comply  with the  Federal  RCS
program, utilities will  have  to stop or reduce  the activities
of these  existing  programs  that are a  benefit to  the  end  use
and the  company  itself.  The  RCS program is  only one approach
to energy conservation  and is  probably  not the  best approach
for many utilities and  their customers.

    I can give you  some concrete  data  on  what  the  expected
customer response to RCS based  on  the  experience  in New York
State, which has had an  RCS-like program in  effect  since June
of 1978.  This program  was  passed into  law  despite   a  1977
statistically reliable  study  financed by the  Federal and state
governments and New York State utilities  which  concluded that
as of January,  1977, over  three  million dwellings in the state
had some attic insulation,  over 60% had some wall insulation,
and about 80%  had  storm protection  on  all windows  and doors.
Thirty percent of those  homes had  received  some  additional  in-
sulation between  1974  and  late  1976,  and  the  owners of  an
additional 30% planned  to  add  additional  insulation  in 1978.

    The utilities have  implemented excellent programs  in  com-
pliance with  the  New York  State law and  those  customers  who
avail themselves of the  Class A  audit get a good value for the
$10.00 fee  they  pay.  The  balance of the  $79.00 to $95.00 cost
of the  audit   is  picked up  by  the  body  of  the  rate  payers.

    However, from June  15,  1978  to September  30,  1980, out  of
the 3.5  million eligible households  in  New  York  State,  only
58,089 or  1.6% have availed  themselves  of a  Class A audit.
The overall  cost of  the program to the  rate  payers  of  New
York State has been $7.8 million,  of which  only $411,000 or 5%
has been recovered through  audit fees.


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    If we include  the  250,000 consumers who  asked  for Class C
audits, which  are  nothing  more  than  a  do-it-yourself  audit
booklet, the program  can be  said  to have reached  9.0%  of the
eligible households.

    Now to  those  critics  who would  say  the  utility industry
has not  tried  hard enough,  I would cite the results  of the
program of the New  York  State Power Authority in the territory
of certain  municipal  utilities who had  done  little to promote
conservation previously.    They gave  the audits away  free and
report spending over  $3.00  per  customer served to market the
audits.  Their results show  that  only 16 1/2% of the customers
took advantage of the free audits and that 37% of those audited
indicated they  had already  implemented  conservation measures
before the auditor came.

The RCS Survey

    EEI has conducted  a survey in which  the responding companies
serve over  80%  of  all  investor-owned   utilities'  eligible
residential customers.  According to the results of this survey
the response  to  the  RCS  program  will  only   be  approximately
3%.  Because  of  this, we question  the  wisdom of  the Federal
government imposing a  program on  the American  consumer  under
which the vast  majority   of  rate  payers, who  initiate and pay
for their own conservation measures,  will subsidize 95% of the
cost of  the  audit  service  for  those few  consumers who  will
avail themselves  of this all  but  free  ride  under RCS.   In
addition to  the  expected response,  some points   of  interest
obtained from our survey are:

    1.  Only 12 companies have expressed interest  in financing
        conservation measures.

    2.  Only 4 companies  are  installing any conservation measure
        under the RCS program all  the rest will be contracted
        to outside contractors.

    3.  Investor-owned utilities  will spend  in excess of  $24
        million just  for  outside  contractors  in  the  first
        year.  (Computer  time, training, etc.)

    4.  Investor-owned electric utilities  will spend $142  mil-
        lion  just  in   announcements   for   the   first   year.

    5.  The  cost of an individual  audit  is over $120.  This is
        in contrast to DOE's  analysis  that   states  a cost  of
        $62.50/audit.

    6.  Post audit  inspections will  add at   least  $70  million
        over 5 years to the cost of the program for our members.

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    As a summary, it appears that DOE's overall cost estimation
is not far  off, if  they assumed  a  3%  response,  not  7%.   To
handle a 7% response as projected by DOE, the cost would proba-
bly double the $4.9 billion.

GAGS and BEPS

    Changing gears  for  a few  moments,  the  cost  justification
of the  Commercial  and  Apartment  Conservation Service  (CACS)
program likewise is  suspicious.  DOE's  own research has "indi-
cated that similar (non-Federal) utility programs have achieved
the significant  participation  and  energy  savings  projected
for the Proposed Rule (CACS) case  without  mandatory goals" (46
Fed Reg 4500).   This suggests to  me  that  once  again the pro-
gram's cost to the private sector will not  justify the benefit,
especially since the private sector's involvement will acceler-
ate with the  recent  decontrol  of oil prices  and  gas deregula-
tion.

    In addition,  the  Energy  Performance   Standards  for  New
Buildings (BEPS) as  originally proposed,  is  a  classic example
of a  program whose  goal  has  already  been  satisfied by  the
private sector  and  local government.   Forty-seven  states have
energy conservation  codes and  standards in effect and working.
DOE on the other hand to date has spent  $50 million on a program
that is yet  to  be   implemented.   The  proposed  rule published
in November  of  1979 received  so much  criticism  that Congress
saw fit to direct DOE to postpone promulgation  of  a final rule
for two years.   It  seems logical that  the best solution would
be a statutory repeal of the BEPS program.

    A much better approach  is  to allow the free market economy
to determine  the amount  and  type  of  energy  conservation  we
need.  The  Energy   Information  Administration  in  their annual
report to  Congress, concur  stating "that  energy conservation
- not  government  regulation!"   (U.S.   Department   of  Energy,
Notice of  Public  Hearings   and   Staff   Working Paper,  March,
1981, DOE/PE-0022).

    The free  market approach  assumes  that  consumers  will act
in their own self-interest, if given the economic incentive and
the information  on  how  to accomplish the task.   From a utility
standpoint, the  free market dictates that  some energy conserva-
tion alternatives are  more  valuable than others.  As previous-
ly stated,  the  value  to the  utility  will depend   upon  two
criteria.  First,  what  effect  the  conservation  will  have  on
the fuel  that the  utility  is  using to generate electricity.
Often the  savings  will  result  in a reduction in  oil  use,  if
the conservation  alternativse  reduce   the  need  for  an  oil
generated peaking unit.
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    Second, what  effect  will the conservation alternative have
on electric system plant requirements such as generation trans-
mission, distribution and load curve?

    The economics to a utility of a brand of energy conservation
depends on  the  effect  of that particular  brand  of  energy con-
servation on  each of  the two types of  savings.   From an over-
all utility  viewpoint,  the  best  conservation option  saves  in
both categories followed by those that  reduce capacity (plant)
requirements.

What are the utilities doing?

    As energy  costs have  escalated,  the  public has demanded
that electric utilities  involve  themselves  with  energy conser-
vation.  Accordingly, electric utilities have organized energy
conservation programs  with  the  purpose  of  reducing the  use
of critical fuels,  minimizing  the need for costly  new genera-
ting facilities  and  helping homeowners manage  the  size  of
their energy  bills.  As  an  example,  more  than 170  electric
utilities are participating in the National  Energy  Watch or-
ganized by  EEI.   Energy conservation  is  not a  new  topic for
electric utilities.   For more than 20 years, electric utilities
have successfully lobbied  builders to surpass the  HUD minimum
property standards for insulation requirements.  Electric utili-
ties have  also  provided  homeowners  with  energy  conservation
pamphlets covering  such  topics  as  wise  use  of  appliances and
energy referral  services.    They  have  sponsored  energy  use
seminars, panel discussions, advertisements, all with the theme,
energy conservation.   Examples   of what utilities  are  doing
are published in  a  study  by EPRI  with  initial  results  of  80
utility thermal  storage  projects  and  93 load control ongoing
at this time.

What are some of the programs utilities are involved in today?

    Long before  "conservation"   became   a  buzzword,  the  Long
Island Lighting Company  (LILCO)  was telling  the  people  of the
community it  serves that  the efficient use  of energy  makes
good sense.  The  rising  cost of all energy forms has probably
been more  effective  than  our  many   programs  in   convincing
the consumer  that  an  investment  in  conservation  not  only
saves limited  resources  of  oil  and  natural  gas,  but  also
saves money.  The results of price  elasticity and the combined
conservation efforts of  our customer,  our company,  and  other
private sector  companies  and governmental  agencies have  been
dramatic.

    For example, in LILCO's  service territory, dramatic  reduc-
tions have  taken  place  in  residential space  heating  energy
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usage in  the past  ten years.   In  1970  our average  electric
space heating  customer used  21,327 kilowatt  hours.   By  1980
the annual  average  use had dropped  5519  kWh or  26%  to  15,818
kWh!

    Statistics of the  local  oil heating  association  show that
over the  same  ten years  oil  heating customers on  Long  Island
reduced their  usage 17.3%  from 1500  gallons  to 1150  gallons
per year!   In  1970,   LILCO's  average  residential  gas   space
heating customer  had  an  annual  use of 188.6  MCF of gas.   By
1980 this annual  usage had dropped to 157.6 MCF  of gas.   This
is a  reduction  of  31.0  MCF  per  customer or   16.4  percent!
Because Long Island is primarily an oil heating area,  we  served
only an average  of 137,400  gas  space heating  customers  over
this span  of  time.   However,  we  were  able  to serve  almost
24,000 additional space heating customers  from  this  conserva-
tion of  gas.   And  these  new  gas  customers  formerly  heated
their homes with oil.

    We are  now  taking  a major step  forward  in serving  the new
markets created by  consumer  awareness  of  conservation.   A new
company, called LILCO  Energy  Systems,  Inc.  is   being  formed.
The new company,  a  wholly-owned  susidiary of the  Long  Island
Lighting Company, will market energy efficient, fuel conserving
equipment.  The subsidiary is  planned as a non-regulated corpor-
ation which will operate in the marketplace in competition with
any others  who  wish to offer  similar  services.   Consumers who
deal with ULCO Energy  Systems  can have  confidence  in the pro-
duct line,  not  only because  of the service reputation  of the
parent company, but  also  because  high quality equipment,  pro-
perly installed,  and  properly  serviced,  will  be the  hallmark
of the  new  company.   Installation work  will  be  subcontracted
to experienced  contractors  with  good  reputations  for  quality
workmanship and good service.

    Initially, the  new company will have two product lines  -
high efficiency gas heating  equipment  and  solar  water  heating
systems.  But these two product lines  are  only  the beginning.
We expect to expand into  solar space heating,   solar  systems
for business  use,  and  certain types  of  electric  heat  pumps.
We are  also looking to  a  future  with  electric vehicles  and
photovoltaic cells  for  the   direct  conversion  of   sunlight
into electricity,  just as  soon  as technological  advancement
makes these devices  commercially practical.

    Our studies  have   shown  that  there  has  been  very  little
marketing on Long Island  of high  efficiency gas  heating  equip-
ment which  consumers can  buy  to replace  aging  heating  systems.
These new  systems  cannot only  save  money for  the  customer
who buys  them,   but can  also  provide another   benefit.   The
                       220.

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gas they  save can  be made  available  to  their consumers  who
wish to heat  their homes with  gas.   LILCO  has  extensive exper-
ence with  gas heating equipment,  so  this  seemed  like  one of
the best  areas  in which  to begin  the new  business.   Experi-
enced  LILCO  employees will form the  core of  the  new company.

    Another line in  which  the  company  has  considerable exper-
tise is  solar  water  heating   equipment.    Our  initial  solar
water heating  demonstration program,  that  began  in  October,
1978, involved over 650 homeowners.  The results of the program
have shown that  the  combination of  solar  energy  and  a backup
electric system  that  uses  electricity at  off-peak periods  can
halve energy  consumption  and  water  heating  fuel bills.   In
addition, the greater  use  of electricity  generated at off-peak
periods financially benefits all LILCO customers.

    No doubt  you are  wondering what  if  any  effect  this  new
subsidiary will have on our ratepayers.  I've already mentioned
that its  success  will  free  up  additional  gas  supply  for
those who need it  for home heating and that the increased use
of our  electric  facilities  at  offpeak periods  will  help to
moderate electric  rates.   However,  the  costs  and  revenues of
LILCO Energy  Systems  will be  entirely separate from  those of
Long Island Lighting,  and  will, in themselves,  have  no direct
effect on rates.

    The money  to capitalize this new  business will  come  from
our shareowners.   Although the  investment  is not large, in re-
turn for taking the risk in  this  venture,  the  shareowners will
rightfully expect  to  earn a  return.    Because  ratepayer money
is not involved,  this  subsidiary will  not be  regulated by the
Public Service Commission.  This  is  a distinct  advantage in
that the organization will be able to respond rapidly to chang-
ing conditions without the time  lag  that  inevitably occurs un-
der regulation.  The  subsidiary will also be  able to  make its
own decisions  on the types  of  equipment  to market  and how to
best market  it.   The  future  of LILCO  Energy  Systems  will be
determined solely by what  the consumer needs and wants, and how
how well it   serves those  needs.  Free market economics in  eff-
ect.

    We believe that  endeavors  such  as this which utilize the
vast technical and marketing resources of the  utility industry
are the  best  way  to  promote  energy  conservation among  this
nation's gas  and electric users without  placing non-effective
cost burdens  upon the already escalating rates.

    Another example  is  Oklahoma  Gas  and  Electric.    In  the
summer of  1980,   Oklahoma  Gas  and  Electric  began  a  test to
measure the  reduction in  peak  demand  when  ceiling insulation
is added  to  typical  residential homes  with  central air condi-
                        221

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tioning.  The company had  six additional  inches  of attic  in-
sulation installed in each home  in the  spring  of  1980,  in pre-
paration for  the  experiment.  Test  results indicated  an  11%
drop in summertime peak demand and a  10%  reduction in  kilowatt
hour consumption.   All  this  was  done without  the  constraints
associated with the RCS program.

    In addition, OG&E has  a  "Peaks"  program which  is  aimed at
reducing the peak demand.  The  reduction is to be  achieved by
incorporating radio-controlled devices  to  cycle off air-condi-
tioners for brief  periods of  time or through the use of  tempera-
ture sensitive devices  that cycle air-conditioners.  The "Peaks"
program is  projected  to reduce  demand  requirements by  50  MW.

    Oklahoma Gas and  Electric's  major  load  management  program
has been titled "Residential  Load Mangement."  This is a program
that will  help control the  demand  of  a residence  through:

    1.  Insulation
    2.  Air conditioning system replacement
    3.  Reduction in A/C requirements

    This program  is  estimated to save  275 MW  over  the  next 5
years.

    Three major conservation  programs that Arizona Public Ser-
vice Company has in effect at this time are:

    1.  APS is using the "INTERCOM" system in their residential
        weatherization program.   This  system is  a computerized
        energy audit  program  enabling  in-depth  analysis  of
        structures.  The program requires R-30 in the  ceiling
        and R-ll  in  the walls,  "hot  tap"  water  heat  recovery
        and the use  of  high E.E.R. air conditioning.   APS has
        published and  distributed an  "Energy  Consumers  Guide"
        which displays  various  energy  profiles  and  costs and
        equipment information.  This  audit is designed specifi-
        cally for  APS  customers  and  does  not   include  many
        non-cost effective   components of   the  RCS  program.

    2.  APS  is participating  in the  DOE/Booz, Allen electric
        vehicle program  and  has  taken   delivery   of  20  Jet
        pickup  trucks and  seven  sedans.   They are planning on
        using this  fleet  for meter  reading  and  other duties
        around  Phoenix.

    3.  APS  has   introduced  an on-site   computerized  energy
        audit system  for  commercial  and small industrial  (less
        than  100 kW) customers.   The  program includes 13 oppor-
        tunity  areas  for analysis and  provides a print-out of
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        the solutions.  The  system  is  a  comppletely  indepen-
        dent system  and can  be  programmed  in  the field  for
        special applications.

Iowa Electric  is  in the  process  of  conducting  four  energy
conservation programs:

    1.  A  pilot  program   using   24  electric  thermal  storage
        furnaces to  determine the  operating  characteristics,
        the electric  system effects  and  possible  customer sav-
        ings.

    2.  Iowa  Electric  is  beginning  the  construction  of  a
        service center  in  1981 and  plans to  install demonstra-
        tion units which  will include,  but not  be  limited  to,
        solar; electric thermal   storage;  solar assisted  heat
        pump; and  infrared heat,  both gas and  electric.   This
        will benefit  other design communities in  Iowa that  are
        investigating similar complexes.

    3.  A  pilot  program   of  add-on  heat pumps  operating  in
        conjunction with oil  or  propane  furnaces to  be imple-
        mented this year.   The purpose is to determine customer
        savings and electric system effect.

    4.  A program  to  purchase approximately six electric  vehi-
        cles in  1981  for  the  utility fleet  in Cedar  Rapids,

        Iowa.  The  purpose of  this  project   is  to  determine
        operating characteristics,  climactic  problems  and  the
        electric system effect.

    Public Service  Electric  and  Gas  of  New  Jersey  has  a
solar water heating program that is aimed at creating an envir-
onment whereby  customers   of  the  company can  obtain  a  sound
engineered and cost-effective solar installation.   Two standard
installations will  be  available  in  six  zones  of the  PSE&G
Service Area:  one with an electric  back-up,  the  other using a
"two tank" system  using existing  gas  water heaters  as back-up.

    The contractors  selected  will  be  given hands-on  training
to insure  that  their  knowledge  of  the  specific   systems  and
installation techniques meet the company's standards.

    The utility  will provide  a  warranty  and   service for  a
five-year period.  In the "two tank" installation,  the warranty
will not cover the existing gas-fired water heater.

    In March  of  1980,  PG&E  came forward with an  innovative
proposal to  offer  zero interest  financing  to  customers  who
install  certain  cost—effective   conservation  measures.    In
                       223

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PG&E's proposal,  repayment  of  the  principal amount  financed
would be made upon sale of the property.

    The Weatherization  ZIP  program is  just  one  example  of
PG&E's expanded program  plans for  the  next  three  years.   The
company's customer-related   conservation  program   plans  for
1981, 1982 and 1983 include:

    1.  The  Homes,  Appliances,  and  Systems  Program  -  which
        focuses on more  energy  efficient designs  and  features
        in new  construction and promotes the  sale and  use  of
        energy-efficient appliances.  The program  also encour-
        ages efficiency  in lighting, heating, ventilation and
        air conditioning systems;

    2.  The  Community and  Consumer Services  Program -  which
        assists cities, counties,  municipalities  and other gov-
        ernment entities,  with  their conservation  efforts and
        provides conservation  assistance  to  low  income  and
        disadvantaged customers;

    3.  The Commercial-Industrial Agricultural Services (C-I-A)
        Program which  provides  services, incentives,  informa-
        tion and instruction to C-I-A customers through compre-
        hensive audit, energy management and support programs;
        and,

    4.  Program Evaluation  Activities  - which  center  around
        measuring the  impacts  of  PG&E's conservation  programs
        on the need for energy resources.

    In addition to the other customer-related programs mentioned
above, PG&E  has  seven other  conservation programs, including:

    1.  The Conservation Research Development and Demonstration
        Program which  examines  the  latest in conservation con-
        cepts and technologies;

    2.  The  Load  Management and  Load  Management  Research and
        Development Program  - which encourages  off peak usage
        by all PG&E customers;

    3.  The  Cogeneration and Solid  Wastes  Program -  which is
        designed to encourage the  development of   cogeneration
        plants and the use  of solid waste and biomass as fuels;

    4.  The  Conservation  Voltage  Regulation  Program -  which
        saves energy  by  reducing   the  annual average  service
        voltage delivered  to PG&E customers;
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    5.  The  Energy  from Biomass  Program  -  which  currently
        involves the production  of gas  from landfill projects
        and agricultural waste products;

    6.  The  PG&E  Facilities  Program  -  which  reflects  the
        efforts made by various departments within PG&E related
        to reducing energy usage;  and,

    7.  The  Street  Lighting  Conversion  Program  which  will
        convert approximately  250,000  street lights  in  PG&E's
        service territory to high  pressure  sodium vapor lamps.

    Texas Utilities has  one  of the newest  and  most innovative
programs that  I know  of, entitled  "Buy  Back Capacity",  Mr.
Carroll Benson will discuss this in detail later in the hearing.
Because of time constraints,  I have discussed just a few utili-
ty programs  in detail.   These are  not that  unique, I  could
have used  Georgia  Power,  Potomac  Electric  Power,  Southern
California Edison,   Alabama,  Iowa  Power or any  of  the  other
companies participating in the NEW program.   All these programs
are functioning  without the RCS  constraints.  These programs
are some highlights  of the residential  programs  on-going,  EEI
also has documentation on similar  programs in the commercial
industrial sector for any interested parties.

Results of existing free market response to the oil price in-
crease of 1973:

a.  Effects on load and energy use

    1.  Growth of electricity consumption since 1973 has dropped
        to 1/2  of  the  growth  of  electricity consumption prior
        to the 1973 oil embargo.

    2.  Capacity growth  also went  from 6% per year expected to
        3% actual since 1973.

    3.  Electricity use  for non-weather related uses in house-
        holds has  decreased  since 1973  by  approximately  25%.

    4.  In  LILCO  service area,   average residential electric
        consumption for  non-space  conditioning  uses  in  the
        year following  the Arab  oil embargo dropped  9%  and in
        1980 the electric use is  still 6.5% less  than  it  was
        in 1973.

Conclusion

    In conclusion,  the Edison Electric Institute is in complete
agreement with the  present Admininistration's  attitude towards
conservation, stated in  the  President's Economic  Recovery Pro-
                        225

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            gram Budget Reduction of Energy Conservation Programs of Febru-
            ary 18,  and  I  quote,   "Motivated  by  rising  energy  costs  and
            substantial Federal  tax credits,  individuals,   businesses  and
            other institutions are undertaking major conservation efforts."
            Evidence of  these  conservation  efforts  is   clear   ...   "Some
            Federal conservation programs are,  therefore,  no longer neces-
            sary, while  others  may impede private  initiatives  by imposing
            too great a  regulatory burden on the  public."   However, until
            changes in funding  or the statute  are completed,  RCS  and the
            CACS program  will  continue   and  the  electric  utilities  will
            have to  live  with  the  programs.    Private  firms,  especially
            electric utilities,  have  assumed the  responsibility of provi-
            ding energy  conservation  programs  to  the public.   The  results
            of conservation  are  significant,  yet  no  Federal   program  is
            universally adopted at this time.

                From a purely practical point of view,  many utilities have
            no choice but to pursue load and energy management initiatives.
            Contrary to what  some  believe,  the  demand for electricity con-
            tinues to grow, albeit  at lower rates.  Yet high interest rates,
            regulatory burdens and  capital market  constraints  coupled with
            other factors make it difficult (and in some cases,  impossible)
            for utilities  to  continue  building  generation plants  at  a
            price customers  are  willing  to  pay.   As a  result, utilities
            in this  situation have no choice  but  to attempt to slow load
            growth and  reduce  or  obviate   the  need  for  new  generation
            capacity.  There  is  evidence to  support the  proposition that
            energy and load management techniques  can free  up  capacity for
            other customers,  at  a  price less  than  what  those customers
            would otherwise pay.

                The electric  utility  industry  has  been  involved in cost-
            effective conservation.   It   would   be  an  injustice if  these
            programs are  shelved  just  to  fulfill the  requirements of  a
            Federal program  that  is  cost  intensive  and  benefits   such  a
            small number of individuals.

                I would  close  by   echoing  Mr.  Benson's   comments   on  the
            role of  government  in  a  future partnership  with  the  private
            industry.  Thank you.

DR. RIEGEL:     Thank you very much.   I would like now to throw it open to
            questions and  discussion  on  these  three very  important  and
            useful contributions that have been made.

MR. ONDICH:     I have a question for Mr. Benson.  In the  two months since
            the YES program  has  been  implemented,  how many  of  your custo-
            mers have taken advantage  of  it? secondly, a lot of the programs
            you talked about had to do with, what  I would consider, middle
            income programs.  Does your company offer any specifc assistance
            to low income families, audits, or whatever.
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MR. BENSON:     In the  first two  months  since the  program  began, we've
            had approximately 1200 participants,  and we have  not  yet done
            any advertising  on  our   own.   Utilities  have normal  billing
            cycles that they  run through,  and in the  summertime,  our bil-
            ling inserts  are typically  directed  toward   air  conditioning
            and how to  control  the  size of your utility  bill,  and we have
            to run through a pre-planned cycle before we can insert adverti-
            sing and other items.

                So this month our YES program bill insert is  running.  The
            1200 that have  taken advantage  of the  program thus  far have
            been by word of mouth or by dealer advertisement.

                Programs for low income  include this  program.   95 percent
            of the housing  stock in Dallas,  Texas  has  some  form  of  air
            conditioning, and this  program is  applicable to  window units
            as well as  to  central air  conditioning systems.  In  the bro-
            chures in back  of  the  testimony  package,  there   are  outlined
            what the company does in  the form of  an incentive  for  a custo-
            mer who replaces  a  central unit.   So  since 95 percent  of  the
            housing stock is air conditioned  with  one  or  more  window units
            or central air  conditioning,  this program is  just as  applica-
            ble and  perhaps  even  more  advantageous  to  the  low-income
            folks, because  it  helps  them  to buy  an  efficient  piece  of
            equipment at a reduced price, which will also  lower their cool-
            ing costs from now on.

                Other programs that  we have for low-income folks  include a
            program we're very proud  of  called Dallas  Con*Serve.   It was a
            part of the package  that  the President  recognized in  January.
            It's not mentioned in the testimony.

                It's a  pyramid   type  organization  where   we   go  to  civic
            clubs and principally to  churches, and  provide education to a
            core group  of people within these organizations who,  in turn,
            have made a  commitment  not only  to weatherize  their own home,
            but to go  out  and   weatherize  five homes of  people  who  are
            either unable  or financially  not  in  a position  to  do  that
            for themselves.

                This program has been extremely successful.  We  anticipate
            the weatherization of 50,000 low-income  homes in Dallas during
            1981 through this program.  We have any number of  other low  in-
            come programs - referral programs in operation.  We have a pro-
            gram we call Special Friend, where a  customer who  is in danger
            of interruption of  service for  non-payment of his  bill can  au-
            tomatically  include   a third  party notification  provision   so
            that when the possibility of service disruption for non-payment
            comes up,  a  third and responsible party can  automatically  be
            notified.  This   would  be   particularly  useful   for  elderly
            folks who tend to misplace their  bills  and problems  like that.


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            They can  notify  a  brother,  sister,  daughter,  even  an agency
            who  might  be in  a   position  to  provide  some  assistance.

MR. RUSSELL:    Could I comment on the low income situation? I'd like  you
            to know  that  our division in  EEI this  year  held  a  three-day
            dialogue with consumer organizations on the question of assist-
            ance to low-income people  with regard to  their utility bills.
            We had  representatives  from  many national  organizations,  to
            governmental organizations,  Health  and  Human  Services,  DOE,
            we had  the  National  Council  of  Churches, the  National Urban
            League,  NAACP,   American   Association  of   Retired   People.

                We had a couple of  consumer  lawyers, and the  list went on,
            a number  of  utilities.   We  spent  two  and  a  half  days  just
            exploring this whole  issue,  and 1  see that  we have  two basic
            problems.  One of  the  problems  is,  do  you  help  these people
            pay their bills  today,  with  grants,  such  as the  heat program,
            or do  you weatherize.   Or how  do  you  put  those two things
            together.  I  think we  came  to  the  conclusion  that  in the
            short range,  you're  not  going  to  solve the  weatherization
            problem overnight.

                It's very  complex,  and it's  very  different from  the prob-
            lems that relate to  the average homeowner.  You're absolutely
            correct that these programs  appeal to and can  be  picked up by
            the middle income  type  of person  who owns  his own  home, and
            some of  the  upper  middle  income  people  today   who  are feeling
            the effects of the price  question  now, such  as  the question of
            affordability any more.

                I think there's a danger if you try to tie  the two programs
            together, you  know,  there is some indication of  that.  On the
            weatherization side,  in  suburban  utilities, and,  of course,
            you can't generalize  too much,  but  I know  from my experience
            that much  of the  low-income  housing  stock  is   rental,  single
            family, all  dilapidated  type  of  housing, and we have  found
            that there's  little  incentive  to  the  owner,   because the low
            income family pays the bill.

                Very often,  they're paying it with government money  through
            various programs,  either  Social  Services or   things  like the
            grant program, and that  the  local welfare and Social  Service
            authorities don't  want  to push the landlords  too much, because
            they're afaid of that housing stock for these low-income people
            drying up.

                Now, in  order  to  demonstrate what this  problem is, I mean
            anybody can  take  and do  calculations and  show  what  can be
            saved, but I  think there are unique problems here.   So out of
            that dialogue, the utilities  have  agreed to  undertake a little
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            demonstration program  which  is  under  development  right  now
            in which we will get at least 10 homes in each of the 50 states
            that are  basically low  income rental  units where  the people
            are subsisting  through government  funds,  and we  will  upgrade
            those homes, and we'll make case studies out  of  them.   Out of
            the case  studies,  we'll  be able  to,  I think,  define, within
            about a year, what the unique problems are.

                This isn't  a question of saying an uninsulated house needs
            six inches  of  insulation.  We think it goes further than that,
            and that the  current  programs are  not reaching this group of
            people.  Now,  come of the  things that  we  hear being  done at
            other places also  add  to that, but  I  think it's  a two-pronged
            problem, and it needs  a lot of addressing.   I  don't think RCS
            is going  to  reach it,   even  if  you  give  the  audits  away.

MR. OND1CH:     Are you just starting that program?

MR. RUSSELL:    In  the 50  states, that  program is  just  being   started,
            yes.  It just came out of a dialogue which we had in the begin-
            ning of April,  and it's given to one  of the committees in EEI
            which is developing it  now.   Some of the companies are already
            looking for the homes.

                It will take about  a year, a year  and  a half.   One of the
            criteria is going  to  be  that  we  have to be able  to  know what
            the heating and utility  bills were in  those  homes  in  the year
            prior to starting under the old system.

MR. FRANKEL:    Could I follow up on  that?  Do you see  anything wrong with
            the utilities  actually  assuming the  responsibilities that  are
            now carried out by the weatherization  program, and  going into
            poor people's  homes,  weatherizing  them,  and then  putting  the
            cost of that weatherization into the  consumers'  rates  so that
            the consumer sees the same bill but —
MR. RUSSELL:    I can give you a general answer, and  that is, I think that
            any  such program  should  have to  be  shown  to have  a cost avoi-
            dance effect within the territory of  the  utility  involved.  I
            don't think  that  you  should  expect the  whole  base   of  rate
            payers to pay,  you know,  to go in  and  weatherize  the house of
            a landlord who won't do it on his own.

MR. FRANKEL:    I wasn't talking about subsidy.  I was talking about direct
            payment out of  the utility bill of  the  cost of weatherization.
            Often, it's the renter  who  sees the utility bill  so  he'll see
            nothing different,  the same utility  bill,  only  half  of  it will
            go to fuel and half of it will go to —

MR. RUSSELL:    As I say,  the  utility should be able to  show a cost avoi-
            dance.  It shouldn't cost other rate payers.
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MR. FRANKEL:    But you have no resistance to doing that kind of a program?

MR. RUSSELL:    I'd have to look at the program,  and I think it has to have
            those basic parameters.

MR. DAVIA:      I'd  like to  make a couple of  comments on that.   We have
            worked with a lot  of  low-income types of housing  and some low
            income programs.   The  problem  I  see  is  the  weatherization
            people do not address  heating  equipment  adequately,  and it's a
            recurring problem,  because in  many  of  the  homes we're  look-
            ing at where  the energy  use  is three  to four  times  more per
            square foot for  that  type of  house  than it is  for  the middle
            class house,  you've got  maintenance problems  which would  be
            solved mainly by changing a furnace filter.

                The other  thing  is  that  a  lot  of  these  weatherization
            programs are  addressing  specific  items  like  broken  windows.
            Broken windows are  the biggest cause  of  infiltration problems
            nationally and  a lot  of  times they're  not addressed.   They
            throw the  insulation   in  the   attic,  put  on windows,  they're
            putting vent  dampers   on  furnaces that  are  in crawl  spaces.
            It's really idiotic,  but  that's happening out  there.   So it's
            maintenance, and  it's  ongoing, and that's the  biggest problem
            with some of the weatherization.

MR. RUSSELL:    I can give you an example.  In our own territory of looking
            for homes to  fulfill  the  10 houses we're  going to  do, we can
            upon a house  in  which the landlord had  replaced the  oil burner
            with a brand new, modern, efficient oil burner, hadn't weather-
            ized the house  efficiently.   The  customer  wasn't able  to pay
            the oil  bill.   So they had an empty oil tank,  and   they  had
            spent the whole  winter heating the house  with plug-in electric
            heaters, and insufficiently weatherized house.

                So you see, what I'm  saying to you is that there are unique
            problems here.   It's   not just  go  in and  do  nice  things and
            resolve the  problem.    You take this  low  income  house,  you
            spend money,  a  rental house,  and you upgrade it, and maybe the
            landlord decides  now he doesn't  want  that low  income family in
            there, and he boots them out, and they  go  off someplace else,
            and he rents it  to a higher income person.

                You can't broad brush  that problem.

MR. BENSON:     Real quickly, I think  there's a more generic question here,
            and that is whether there is a  role  for the  federal government
            in determining  whether or not  utilities  should or  should not
            run a  specific  kind  of  a program in  their  service territory,
            and I  think  the thrust of, at least my  understanding of, the
            direction government  would  like to  move  is  away  from that
            kind of a program.


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                The program being discussed is outside the bounds of virtu-
            ally anything  that's been  proposed  or  thought  of  seriously.
            The free  market  will  create plenty  of  opportunities,  and if
            it's in  the  best  interest  of  the  ratepayers in  a  particular
            service area, that  program  will go,  and if  it's  not  in their
            best interest,  the  program  won't  go,  and  it  should  not go
            because of some government fiat.

MR. RUSSELL:    I'll give you a  good example.  Mr.  Benson's program is an
            excellent one demonstrating  a  cost   avoidance  feature.   If  I
            come to my company  right  now,  and some would look at a program
            like that,  governmental  people  typically  have  looked  at  a
            program like that  and  say everybody  should have  that  program.

                When you come  to my company,  we  are  going to  build genera-
            tion for  oil back-out,  okay,  and  we're not  going  to  have  a
            capacity problem  for the balance of  this  century  as  we  can
            see it.   So  we wouldn't  want to turn around  and spend money in
            that way  in  our  territory.   I'm not  being   critical  of  his
            program.  For his   purposes,  that'll  be  great,  but  to spend
            money because there  won't be a  cost avoidance,  because we're
            going to have to  build  capacity anyway,  we have  to  direct  our
            efforts in  a different   way,  and  I  think   that's  the point
            we're trying to make here.

DR. RIEGEL:     I'd  like to  make a  point and also  ask Mr.  Benson  about
            the YES program.   This  is one  of the  clearest  examples  that  I
            have seen of a company  taking  a position and  clearly articula-
            ting to the public its view  of  what  I will  call the  even-hand-
            edness of investment in production versus investment  in conser-
            vation.  If  I understand  the program clearly,  you  are  indeed
            putting the  utility's  money where its mouth is,  in investing
            through rebates  that  are  redeemable  for electric energy  pur-
            poses for a number of conservation investment.

                I think  for  many  utility  service areas  that is  entirely
            appropriate,  because  as   you rightly  point   out,  the  avoided
            costs or  deferred   costs  of  major  capital   investment  has  a
            value not  only  to  the  customer but  to  the  utility,  provided
            the utility is adequately rewarded for that kind of investment.

                I have two basic questions.   One is whether you have  come
            to any conclusions  about  how activities  of   the Department of
            Energy or  the  Federal  government could  help  to  foster  that
            kind of evenhanded  investment  by other  utilities where  it is
            appropriate around the country.  Secondly, could  you give us  a
            tangible update  on how the program is going.

                Are you finding that  indeed the YES  shares are being snap-
            ped up with  enthusiasm in your  service  area?  Do  you  see in
            the future anything like  a parity in  investment, the stream of
            investment dollars  going  into  the  conservation option  versus

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            the new central facility option?

MR. BENSON:     Well, with  respect to your first question,   I see the role
            that government might  play,   as  I  mentioned  in  the  testimony
            earlier, as an  information gatherer  of this  kind of  program
            and a disseminate of this kind  of program,  and as a  facilita-
            tor in  terms  of  helping  to  remove  any  barriers that  might
            exist to the operation of programs like this.

                Until the Energy Security Act was passed last summer,  there
            was some question  whether a  program  such  as  this could have
            been offered,  and by government fiat, utilities were prohibited
            from  becoming   involved  in  the   installation and   financing
            business.  Congress wisely  changed  the  requirements  of  NECPA
            by the  Energy  Security Act and  removed that prohibition,  and
            these are the kinds  of roles  that  I see  government  playing -
            now that the free economy  needs  to  operate as  a free  economy -
            and government's proper role  is  to  work with the  free  economy
            to help remove  any  barriers  that  might exist,  and not to advo-
            cate any particular scenario.   Report  that  this  is what's hap-
            pening this is  what  apparently has  worked.  Government should
            suggest that companies  as entrepreneurs who have  shareholders
            who demand  a  return on their  investment  ought to  see  whether
            or not this program might be  applicable  in their area as  well.

                The second question was,  what's been the response  to YES.
            We've had 1200  customers  receive  YES incentives in two  months.
            We initially designed  the  program and set  the  incentive  level
            at a point that we thought would  get  between 40 and 50  percent
            of the  market.   We're talking  about  40 to  50  percent of  the
            air conditioners which fail would be replaced by high efficiency
            equipment, 40 to  50 percent  of all  the  new equipment that's
            purchased and installed on our lines would be  high efficiency
            equipment and the same in new construction.

                Our expectations range on the order  of 60  to 75 percent as
            a result  of the program  over a  five-year period.   It's been
            fantastically successful.   Obviously  with  a limited  staff  and
            dollars to  devote  to the  program,  there's only   so  much that
            our folks can do.   So we have to depend on the  dealers and dis-
            tributors to  carry  the ball  to  the  public,  and  they've done
            that in a terribly unique and aggressive fashion.

                We see ads  running  in the newspaper where  one dealer will
            say, go  out and make your best  deal,  bring the deal to  me  on
            paper, and  I'll beat it  by  $5  and  I'll install your unit  for
            free.  People are actually comparison shopping for efficiency,
            and there's a  two-stage  level  in  the  incentive  payment;   if
            you buy a unit  between 8 and 10  1/2  EER,  you  get  one  kind of
            an incentive.    If  you  buy  10  1/2  or above,   you get a much
            larger incentive.


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                So the customer  now has  a reason for  looking at  the  tag
            that's on  the  equipment that  says  what the  EER is.   Up  till
            now, there's  been  no  justification  really  for  looking  at
            that.   He  has  attached  a  monetary  significance to  that  tag,
            and we  think the  program is  going  to  be  really  phenomenal.

                It is  only  the  beginning.  The  program  is  applicable  to
            all residential  structures,   multi-family  and  otherwise,   It
            covers 95  percent  of  our customers  since  95  percent  of  the
            housing stock has  some form of air  conditioning.   The payment
            goes to the  tenant  or to the  person  who buys  the  unit.  Many
            of the  apartments,  for instance, are unairconditioned and  the
            tenants have purchased room air conditioners for air condition-
            ing purposes.

                Payment of  the  incentive  is  made  only  to  those  persons
            who pay  a utility  bill.   No  assignment  of  the  incentive  is
            permitted in  existing  housing (99+%)  for  this  part  of  the
            program.

                The second  program  is   the  lighting  program  which  will
            virtually eliminate  fluorescent tubes  like  those  right  over
            there.  Instead  of  40-watt  fluorescent  lamps,   we'll go to  a
            33-watt fluorescent  lamp,  and as  soon  as the  program is  up
            and operational, within a  year or  so, those  lamps  won't  be
            stocked any more, and  we pick up  7  watts per  lamp  forever  in
            terms of  peak  reduction as  well  as  the  customer  getting  the
            same lighting level for less money.   We've  got  some other pro-
            grams that will  be  coming  over the next year,  year  and a half
            or so.  You  don't  build Rome  in a  day.   You must  start brick
            by brick.

MR. FRANKEL:    Let me  follow  up on  that  with a question.   To transfer
            information about this  program to  other utilities  that might
            be interested, is that a proper role for the Federal government
            or for  the  trade association,  Edison Electric  Institute,  and
            does Edison  Electric  Institute have  a program  to  inform other
            utilities of  successful programs that  have been  carried  out?

MR. BENSON:     Certainly.  To a great  extent,  the information gathering
            and information  exchange  activity  is duplicative, but  I would
            submit that the  Institute deals  solely with  member  companies,
            and the Federal  government has a role not  only  in dealing  with
            member companies in the  association, but  also the  public  at
            large, and particularly other governmental agencies.

MR. RUSSELL:    Within the industry and the division of which I was chair-
            man this  past  year,  at  an  executive advisory  committee level
            which hit 65 or  70  vice presidents which  take  the  bulk of  the
            customers in our industry and they meet regularly and exchange
            information,  and below us,  we have  what  are  called  subject


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            area committees,  and  our  subject area  committees,  some  with
            150-200 members representing all  the  utilities,  the  commercial
            area, the residential area, the major function of those commit-
            tees is a  day-to-day  gathering  and dissemination on  programs
            of this type, and regular reports are disseminated.

MR. FRANKEL:    I want to ask  another question along those lines.   There's
            a general philosophical agreement with the thrust of  the Presi-
            dent's program that often obscures the actual details  of  what
            is being done.

                Now the  government  has several different tools  it  uses to
            motivate energy  conservation.   There's  R&D,  information  pro-
            grams, incentives and  regulations, and I'd like to cover each of
            those.

                For the R&D area, Mr.  Davia,  are you aware  that there was
            a program in the Department of Energy which the  man  on my left
            knows something about,  called  the  technology  and consumer pro-
            ducts program that was trying to develop very efficient burners
            and boilers, gas fired heat pumps which could have an  efficiency
            of 150 percent,  electric  heat  pumps which  improved  efficiency
            by 25 percent.

                Do you think that that program, the  technology and consumer
            products program,  was an  appropriate Federal program, and do
            you agree with  the Administration's decision to  terminate it?

MR. DAVIA:      Well,  I'm not fully aware of all  the details of   that pro-
            gram, but I  do  know  that  there  is a common  problem,  and  that
            is that we're  trying  to replace existing heating  systems  with
            more efficient ones  and the market  is  not ready, because the
            thing I'm  getting  from heating  contractors  in our  area  is
            that they go  out  and  try  to sell an  efficient unit  that  has a
            seasonable efficiency  of   greater  than  85  percent,  and  the
            customer is not buying it.

                It's $200 to  $300  more,  and  they  cannot understand  that
            that's going to use that  much  more  or less  energy,  and, there-
            fore, I think  any time  we  can generate  interest in replacing
            air conditioners,  electric  heating,  gas  heating  with  more
            efficient, that's good.   I do not know the details.

MR. FRANKEL:    Do you  think it's appropriate for the  Federal  government
            to do  research  and  development  to  generate  products  that
            would improve energy efficiency?

MR. DAVIA:      Yes, the government and private industry working   together,
            Lenox, Hydro-Pulse, all those  others.  One thing I might add
            is that on heating equipment, what  we  see happening  again with
            low-income people  is  that the  existing heating  equipment  they
            have will not  perform and  will  not supply enough heat  to the

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            structure, because  of poor maintenance,  poor design  and just
            rundown equipment.

                So what they  try  to  do is supplement  that heat  with elec-
            tric or with  gas ranges.   Last winter I went  into many homes
            where the humidity  level would be about 80  to 90  percent,  be-
            cause all four  top burners and  the oven  were on  in  the home
            pumping all that into the house in a means to try to keep warm.

                If weatherization  or  whatever  had  corrected  the  problem
            with the  furnace,  that  wouldn't have happened, and  the health
            and everything  else wouldn't  go  downhill on  those  customers.

MR. RUSSELL:    I'd like to  make a  comment on  that if I could.   I think
            that, for instance,  now  there's  pretty good incentive  for  the
            manufacturers to  get  into  efficiency  R&D  on  the  standard
            types of of equipment that are being used.

                I find that  sometimes there  are inventors,  entrepreneurs,
            manufacturers, who  are hesitant  in  some cases in  getting into
            governmental programs, because the  inertia  that gets  involved
            with it,  and  I  had  a particular case  in mind  of  oil  burner
            that would save 15-20 percent  that the  inventors  took to Sweden
            and Switzerland and put  on the market  in this country probably
            within a  year,  developed  by   a  couple  of  NASA  engineers  in
            their time off.   They didn't  want to deal with a  governmental
            program.  But where I  think there is a role for government  is
            in the  development  of  technologies  where  there's  promise,
            but there is a definite short  term market available.

                I'm talking  about photovoltaics,  electric vehicles,  that
            type of  thing.    The  government,  I think,   can  provide  some
            longer range  R&D  money   and   efforts  and  things  like  that.

                I don't necessarily see where the government has to get into
            having a manufacturer improving the  efficiency of his gas burn-
            er.  So let's see something newer than that.  The  incentive  is
            there.

                The reason my company  is  going  into  doing that  is,  as Mr.
            Davia pointed out  before, too many  people  are spending money
            maintaining equipment  which  can  never get  up to  a  seasonal
            efficiency of more  than  40 or  50 percent when they  ought to  be
            spending money in replacing that  equipment.

                Now there is  enough  equipment there  that's  already  good,
            and we're  going to sell  that to  our  customers  and  they're
            going to  benefit  by  a   15 to 30 percent  savings  in gas and
            money and we're  going to  benefit  because  we're going to recover
            that gas  and  sell  it  to other  customers  and  backout  oil.
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MR. FRANKEL:    Mr. Davia,  if  people aren't  making  these cost-effective
            decisions to purchase  new energy efficient equipment  like  gas
            furnaces that we talked about, do you  feel that there's a need
            for a  greater  Federal  incentive,  or should the utilities have
            some sort  of  a  program  to help  meet  the  upfront  financing
            costs of these, or  should we just wait until  the  market takes
            care of the problem itself?

MR. DAVIA:      Well, I think  that waiting for the  market to take care of
            itself is going  to  be the  longest  scenario.   We  see  furnaces
            that are  30  percent  efficient  that  will  never  wear  out.

                They can take a  direct hit because they were  so overbuilt
            initially and, you  know,   they'll  still  continue  to perk away
            in that basement.

                The problem is that there's no incentive right now federal-
            ly or  state for  replacement  furnaces.  There  are replacement
            burners for  oil  furnaces, but a large percentage  of  the homes
            are heated  with natural gas,  and  if  the  incentive  for  replace-
            ment — all you have to do  is  write  a  tax  credit that  said, we
            will give  an  X  percent  tax  credit  for  any  furnace   that is
            installed and is greater than 85  percent  in seasonal efficiency.

                That would be an incentive,  and I think the private sector
            is ready, waiting in the wings with enough material and techno-
            logy that it  doesn't have to  be  developed, it's there, but the
            consuming public  is  not  aware  of  it, and any  time, you know,
            furnace contractors  do not have a  great credibility  in  the
            market a  lot  of  times, because  people  make  replacements  that
            are unnecessary  and  things like  that.  So they go in  with a
            credibility problem  and  a lot  of  times   customers   are   very
            leery  of  them  and will not let them explain  that  this is  more
            efficient or we're going  to save you money.

                So that's  the kind of trigger  or hot button,   I  think,
            that's necessary to  get this market going.
MR. RUSSELL:    Those things are not  being sold by the private contractors,
            and I  think  that  you  could  refine  the  Federal  government's
            role by again  looking  at  them stimulating through tax credits
            the early adoption of  some  of  these activities.

                We started  with  our  solar  demonstration  program,  solar
            water  heat  demonstration  program in 1978, October.   We had a
            goal of putting  in  650 units, and  we sold them to customers,
            installed them.   We restricted greatly  the size of the family
            and the  orientation of the house  and so  forth to get a homo-
            genous sample.
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                At that  time,  we were  calculating  that  when  a customer
            converted from  oil water  heating  or  electric  water heating,
            it was about  a  15-year payback.  We completed  two years ahead
            of schedule  on  those 650 units.   By the time  we  got through,
            we were  calculating the payback to be  about  seven years each,
            and that's due to two specific  factors,  the  first  factor being
            backed out, the sharp increase, and the second, the federal tax
            credit.  I  think  this has  demonstrated to  people  in our area
            that solar water  heating  is viable, and  I think that in order
            to get people to  look at efficient equipment  that  the Federal
            government could  have  a role there  too,  and then when  it  be-
            comes understood, you  know, and the paybacks are  really there
            without the  credits,  the  government  can start  to  phase  the
            credit out,  but   they  can bring  the  public  awareness  to bear
            out when you're  trying  to develop a new  type  of action on the
            part of the consumer.

DR. RIEGEL:     Well, I  hate to  bring this  discussion to a close, but we
            have another  half-dozen witnesses  or  so this  morning  and  I
            feel the press  of  time.   I'd like  to  thank  all three  of  you
            for appearing with us this morning.
                                                    break  now  and  convene
DR. RIEGEL:
MR. CADY:
    We're going  to  take  a  very  short
again at 10:30 sharp.

(Whereupon, a brief recess was called.)
    We'd like to get  started again.  As in the past, we'd like
you to  summarize  your  statements  to the  extent  possible,  and
we will turn  as quickly  as  we can  thereafter  to the dialogue
between the witnesses and panel.

    Let's begin with  Mr.  Sheldon  Cady from the Mineral Insula-
tion Manufacturers'   Association.   Did  I  get  that   right?

    Close.  Good  morning,  thank you.  My  name is  Sheldon H.
Cady.   I am Executive Vice  President of the Mineral Insulation
Manufacturers'  Association  (MIMA),  of   Summit,  New  Jersey.

    The membership  of 48-year  old MIMA consists  of  a majority
of the manufacturers of  mineral fiber insulations for buildings.
This includes both  rock wool and  glass fiber products manufac-
tured as batts,  blankets, and  loose wool.   I  am  speaking  on
behalf of most, but not all, of MIMA's members.

    As an Association,  MIMA has been active for  well over the
past decade in  educating  the consumer,  agencies  of the Federal
government and state legislatures regarding the measures neces-
sary to achieve  the goal of  energy efficiency in our nation.

    The efforts of the Reagan Administration to reduce the cost
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and other negative aspects of unnecessary government regulation
are applauded by our industry.

    The efforts  to  reduce  Federal  activities  concerned  with
building construction could, however,  do great harm  if  needed
national guidelines and low  cost programs were  swept  out along
with those costs  that  are excessive or  whose  requirements are
an unnecessary  burden.  This is particularly true  of attempts
to improve energy efficiency through proper building design and
construction.  "National"  standards prepared with  the homeown-
er's interests in mind  are  required to  provide  guidelines for
reliable,   cost-effective  energy  conservation  measures.

    Without these  standards,  the desired  improvements  in the
thermal performance  of  buildings are   unlikely to be  accom-
plished.

    We agree that higher  energy costs provide  an  incentive to
conserve energy  and  also  that enforcement  of  thermal perform-
ance standards  can  be  carried  out at  many  local  levels  by
building inspectors.   Unfortunately,  there  are many  areas  of
the country  that  are not  covered  by  any  energy  conservation
standards and  poorly  informed  home  buyers  can  unknowingly
purchase improperly  insulated  homes  resulting  in  excessive
heating and cooling costs.

    We cannot  agree  with  the  Administration's  concept  that
"Free market  forces  establish acceptable performance"  of cur-
rent housing  construction.   It  is obvious that  this concept
can result in  unacceptably  high  costs of  heating  and cooling
in some  new  homes.   Builders  and  prospective homeowners are
entitled to  a  reliable  and  unbiased  Federal  recommendation
for minimum acceptable thermal performance  levels.

    The nation  is  already confused by too  many guidelines and
standards relating to thermal performance of houses.  To elimi-
nate the Federal  standards  and replace them with a multiplici-
ty of local  and state  codes is not a  satisfactory alternative.
The vast  majority of  current  standards (other  than Federal)
are based  on ASHRAE Standard 90, which  contains  data now over
seven years  old and  are totally inadequate when curent projec-
ted energy  costs are  considered.   A  three year lead time is
normally required  to  effect  changes   in   the  Model  Building
Code.  After  this  is accomplished the changes  must be adopted
by the  states  in  a  lengthy  process.  To eliminate Federal
standards and  replace them  with a  multiplicity of  local and
state codes  is  not  a  satisfactory alternative.   The overall
effect  is  to  ignore the  homeowner's  plight  in  attemping to
keep  home   operating  costs   below  his    mortgage   payments.
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    Without a  unified regulatory  system,  our  industry  faces
tremendous problems if 50  different  states  enact 50 individual
standards for  thermal  efficiency.  Even though this  is counter
to the  Administration's  program  of  decentralization  we  feel
that, in  the  interests  of business  efficiency,  central  rules
and regulations  are  necessary.   Fragmentation   of  50  states
involved in  legislation  would  increase  the  cost of  services
both to our industry and to the consumer.

    One example,  which  our  industry has already experienced,
will illustrate  this  point.   In  enacting  thermal  efficiency
legislation, individual  states  have  required  information  each
considers appropriate  to  be  printed  on packages  of  insula-
tion.  While  some  of this  information  is  standard  to  all,
several neighboring  states have  required additional  and  dif-
ferent information to  be added  to the bag label.  The products
of one manufacturing  plant may  be  shipped into  as  many  as  a
dozen different  states.    Shipment  of  different  bags to  each
state is economically  unfeasible  and realistically impractica-
ble.  Supplying all  of the varied information required  by all
states on one package would result in an assembly of information
that would  be overwhelming  and unreadable.   In  either  case,
the consumer  loses.   Similar  expressions   of  individuality,
multiplied by  50,  are an  appalling  prospect  for  the  industry
to face.

    We specifically recommend the following:

    o   DOE's R&D  work on the  residential  portion of  BEPS be
        expedited and completed so that  the costly and volumi-
        nous technical effort  (now  largely accomplished)  can
        be finalized  into  simplified  guidelines  for  use  by the
        builder and building code authorities.

    o   When  the BEPS  activity  within DOE  has  produced the
        simplified thermal performance guidelines, these should
        be nationally publicized  as  the new recommended  stan-
        dards for acceptable energy  efficient  construction and
        be promoted for adoption by the states.

    o   HUD, FMHA  and the VA should  continue to enforce their
        present minimum  thermal performance   requirements  for
        federally insured housing until the  states are prepared
        to implement  this  responsibility with  federally  pro-
        mulgated simplified  BEPS  guidelines for one  and  two-
        family residences.

    o   For other  than  federally  insured  housing,  DOE should
        promote the use  of the  FmHA Thermal Performance  Stan-
        dards as the recommended minimums for  new construction
        for the interim period.
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                EPA's charge  from  Congress  "to  carry  out  a  continuing
            analysis of the adequacy  of attention to energy  conservation"
            leads us to a  second  issue.  In our viewpoint, the  consumer's
            attention to conservation has been  inadequate.

                Since the  early  seventies our  industry has  been  calling
            attention to the  need  for  public  education  and  information
            programs on the benefits  of  retrofit  actions  to the  building
            owner.   The private sector alone cannot accomplish this although
            we have tried,  and are trying.  For instance:

                The Committee   for  Home  Energy  Conservation  (CHEC)  was
            organized by leaders   in industry,  labor, government,  consumer
            and civic  groups  in   1979 under  the auspices  of the  National
            Institute of Building  Sciences  (NIBS).    Its  purpose  was  to
            build consumer   awareness  of  the  benefits  of  reducing  energy
            waste in homes  with  a basic  checklist  of ten  major  steps,
            called the   Big-Ten  Checklist.   As  a  result  of an  in-depth
            publicity campaign,  it  is estimated that  roughly  two-thirds of
            the families  in  the   country  have  received   copies  of  the
            Big-Ten Checklist  through 1980.  The CHEC Committee  was  recon-
            stituted recently  to  consider other  ways  to  get the  message
            across.

                We suggest  that the government  should take  steps to heigh-
            ten the  awareness  of  the public  for  savings possible   from
            conservation activities.  There  is  a precedent  for  this.   In
            World War II coal  had  to be  conserved  because  of  transportation
            problems and the  government  took  steps   to launch   a  vigorous
            campaign to encourage  energy efficiency.  A heat  loss  limita-
            tion was set  by  the  War Production  Board.   The FHA extended
            its insurance  terms  to  encourage  insulation.  The  Office  of
            War Information scheduled  a  fuel  conservation  drive  on  the
            radio and  in  the  press  and the private  sector  also actively
            participated in the program.

                A cooperative  effort  by  all  concerned,  led by the  govern-
            ment, is as appropriate  in  the  1980's  as it was  in the 1940's.

                We strongly urge   everyone  concerned  with  keeping energy
            use and home heating  and cooling costs within  reasonable bounds
            to support  these   recommendations   and  work   to  bring  about
            legislated actions  which  will  eliminate wasteful  use of our
            natural resources. Thank you.

DR. RIEGEL:     Thank you,  Sheldon.  I'd like now to move  to Karen Anderson
            from the American Public Power Association.
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MS. ANDERSON:   Good  morning.  My  name is  Karen  Anderson  and  I am the
            Energy Conservation Manager of  the  American Public Power Asso-
            ciation.  APPA is   the   national  trade   association  for  the
            nation's  2,200  local,  publicly   owned   electric  utilities.

                APPA's perspective on the Department  of Energy's "adequacy
            of attention to energy conservation methods" is somewhat unique,
            because we have  members that  are  intimately  affected  by  DOE
            programs like  the  Residential  Conservation  Service and  many
            others that are  not  directly  affected.  The public  power  sys-
            tems that we  represent range  in  size  from the town  of  Sever-
            ance, Kansas with  52  electric meters,  to  the  City of Los Ange-
            les, with 1.1 million electric meters.

                Only 45  public  power  systems  are  large   enough to  fall
            under the mandate of programs  such as the Residential Conserva-
            tion Service.  Unfortunately,  the  experience   of our  members
            would indicate that a detailed,  prescriptive and costly program
            like RCS is  not  worth the money  and effort being lavished  on
            it.   The audit procedures  are complex,  overly-analytical,  and
            time-consuming.  The municipal  electric  utility  of  Knoxville,
            Tennessee,  for example, has completed  close to  20,000 audits a
            year.  They plan to increase this to 64 audits  a  day by having
            16 employees make four audits  each.   But,  under RCS,  the utili-
            ty will need  to  send  out  eight teams of two  auditors.   Each
            team will be able  to  perform  only two audits per day — redu-
            cing the total number of audits  from 64 to 16.

                Even more distressingly,  there is evidence  that implementa-
            tion of RCS  has  thwarted existing  conservation  programs  that
            worked.  One municipal  utility,  for example, employed  commer-
            cial insulation  salesmen  as  auditors.   The  crew was  trained
            and carefully supervised by the  utility.   Customers  were  hap-
            py with the audit  service and  the end result —  the  number  of
            installations performed — was  far  more  successful  than  other
            utility audit programs.  The  practice was  eliminated by  RCS.

                In another  case,   the   Palo  Alto,   CA  municipal  utility
            developed its home  insulation  program using  four local  firms
            as subcontractors.   The  firms  were  selected   under  open  and
            fair bidding processes  and  provided insulation services at  a
            set  rate.   Two   years   into  the  program,  the utility   noted
            that insulation prices in  surrounding  metropolitan areas  were
            almost twice  as high as  those provided to its  customers  under
            the  utility  program.   This  practice, too,  was outlawed by  RCS.

                In a final instance, let me  cite the conservation  program
            of a municipal utility  that  is  too small  to  come under  RCS.
            This spring,  voters in  Burlington,  Vermont approved  a $2  mil-
            lion bond issue  for conservation  and load management.   Half
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of the money  will  go to  cover  the cost of purchasing  and in-
stalling a sophisticated load management system.   The remaining
$1 million will  be  spent directly on  customer  conservation —
on wholesale purchase and utility  installation  of  shower  flow
restrictors, water heater  jackets  and  outlet gaskets.   While
in the home,  the utility  representative will take other low-cost
action, such as turning the water heater thermostat and showing
the owner where caulking is needed.

    The Burlington conservation program  benefits  everyone  —
local suppliers,  who  sell  more  conservation  devices  to  the
city, the  customers  of  the  utlity,  and  the utility  itself,
which expects to save  2  to  9 million KWH/yr  from the program.
Burlington is fortunate  in  that it is a  small  community.   Its
cost-effective, simple conservation  program  would be  illegal
under RCS.  Additionally, if the utility has decided to finance
customer conservation  measures, it  would  be  precluded  from
doing so  under  provisions  of  the Windfall  Profits  Tax  Act.

    Federal impediments  to  utility  conservation  —  such  as
prohibitions on  publicly-owned  utility financing  conservation
measures using their regular method of  raising  capital — tax-
free municipal  bonds,  or prohibitions on utility conservation
devices — are  major  obstacles  that   should be  eliminated.
APPA's experience with federally-mandated  utility conservation
programs has been discouraging and is the basis  for our recom-
mendation that the forthcoming Commercial and Apartment Conser-
vation Service Program (CACS), required under the Energy Secur-
ity Act,  be  implemented  on a  voluntary basis.   The  reasoning
is not  to give  utilities  relief  from  assuming  conservation
responsibilities, but  to assure development  of  a variety  of
approaches to commercial and  apartment conservation.   The re-
sults of all these experiences  should  be  instructive in point-
ing the way  to  programs  that work and  that  are  cost-effective
for consumers and the utility.

    It is  APPA's position  that Federal  conservation programs
are useful  and  welcome  where  they  support and  enhance  local
initiatives, but that they are non-productive, and may actually
result in  less   conservation  when  they  consist   of  prescrip-
tive, inflexible rules for the entire country.

    What kinds  of conservation programs  can  we  expect  from
public power  systems  now  that  the  Reagan  Administration  is
de-emphaeizing mandatory  utility  programs?   We  are  noting  an
overall increase in the number of public power systems develop-
ing energy management  programs.  Not  surprisingly, these pro-
grams are  as  varied  as  the communities  served by  the public
power systems.  Let me provide a few examples.
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    In Kissimmee, Florida  (population:   16,000),  the municipal
utility is  using  monies from a  gas  supplier refund to provide
customers with  20 percent  rebates  for installation  of approved
solar and  conservation measures in  their  homes and commercial
buildings.  The   improvements  will  save  an  estimated  90,000
kwh per year.

    In Newport, Oregon,  the local  public power  system has an-
nounced it  will pay costs  of  installing  insulation and other
conservation in  the homes  of  its  electric heat  customers if
the cost  of doing  so  is less than  would be  required to  meet
the utility's energy needs  through  construction of new genera-
ting capacity.

    The  Sacramento Municipal Utility District  has  a  passive
solar home  program, where the main objective is to increase the
use of  passive  solar  design,  thereby  reducing the  impact of
new homes  on the  utility's air conditioning  peak  demand and
annual energy  use.   To  do  this,  SMUD  provides  free  computer
analysis of  home designs  submitted  by local  builders,  which
simulate the heating and cooling requirements  of the proposed
new residences.   If the  design  requires  at least  50 percent
less energy  annually  to  heat and  cool  than  a  typical home,
then SMUD  will  provide marketing  assistance.   The program has
already attracted  the  participation  of  some  of  the  area's
largest volume  homebuilders and the utility  plans  to  expand
it soon  to a larger  range of housing  types  —   condominiums,
cluster homes, and maybe apartments.

    A close look  at the kinds of  energy management activities
under way  reveals that electric utilities  are not  just furn-
ishing kilowatt  hours   anymore.  They  are  helping  cities  set
energy efficiency  standards for new  construction.    They  are
in their  customers' attics, installing insulation,  or  in the
basement, helping  to  turn  the  customers'  water  heaters  into
pseudo-peaking plants.   Utilities are  bringing on staff solar
specialists.  One public  power  system looking  toward  a  future
fuel supply of  waste wood chips  even has a department forester
as a full-time employee.

    The umbrella  term   for  all  this new  activity  is  "energy
services planning"  and it  is  the  direct  result  of  the  new
economics of electric  power production.   A decade  of sharply
higher costs is signalling  utilities that  they cannot consider
themselves monopolies  anymore.   Increased costs  are rendering
utilities susceptible  to  competition  —  and  consumers   are
already investing in  alternatives,  from  wood  stoves  to solar
hot water heaters.

    Energy services  planning  is a  concept  derived  from  the
                        243

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premise that  the  consumer  is  interested  in  certain  energy
services — heat, lighting, operation of various appliances, —
rather than electricity per se.   Basically,  the energy services
concept has four elements:

    1.  Emphasis on provision of  consumer  services (as opposed
to simply  selling  electricity or  some  other form of energy).

    2.  A  goal  of  meeting demand  for a given level  of service
in the  most cost-effective  manner (including  the possibility
that the result will be a reduction in use  of electric capacity
and energy.

    3.  Planning ahead on a  variety of  alternatives  stretching
from end-use controls  through consumer-utility cooperative ener-
gy endeavors  to conventional  power  plant  construction  (with
the objective  of  determining  the  least-cost   answer  for  any
planning period).

    4.  Utility  investment  or assistance  in putting  in  place
energy facilities which  save  consumers  money (even though such
aid may  be outside  traditional  generation,  transmission  and
distribution projects  and may involve consumption rather than
supply).

    Energy services planning  offers  cities  the  chance to  blend
services economically, e.g.  off-electric peak pumping for sew-
age disposal, introduction of a turbine-generator in connection
with the local  water  supply  reservoir,  downtown heating and/or
power production  by  incinerating  garbage,  cogeneration  from
a city  hospital use of  waste heat from generating  facilities
to distill  alcohol  to fuel  city  vehicles,  tapping  of methane
gas at  sanitary landfills and  sewage disposal plants  to burn
under boilers.

    The new  economics  of power  supply  is  causing  a  revival
of interest  in  decentralized  power  production  in   smaller
units.  Small scale hydro-electric  installations  are experien-
cing a  renaissance  ...  municipal  waste-to-energy  programs  are
under way  ...  cogeneration  arrangements are being  worked  out
with local  industries,  and  many  more.   In  the future,  it is
not difficult  to envision public  power  systems more involved
in the  business  of  installing,   servicing  and/or  operating
dispersed energy  production  equipment  (such   as  photovoltaic
arrays on  customer roofs)  as  opposed to  supplying  electric
power only  from large  central station power production plants.

    APPA believes  increasing numbers of  public power  systems
will become  involved  in  energy  services  planning  because it
will be in  their best  economic  interest to  do  so.   The Federal
government can  help by identifying and  removing legal, techni-
cal or environmental barriers that  stand in the way  of coordi-

                      244

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            nated energy activities.   Further,  the Federal  government can
            help encourage  communities  toward  energy  services  planning
            with educational  materials,  conferences,  etc.   that  inform
            and bring together the various  sectors  who must be involved in
            such planning.  The success  of  energy  services planning may in
            the end rest on institutional questions:  whether city planners
            will coordinate  with  the  electric  department,  whether  the
            water department  will incorporate  a new solar  utility,  etc.
            Only when all affected interests within a community are willing
            to work toward a common  goal  of energy  security and controlled
            energy prices will the concept  of  energy  services be turned to
            reality.

DR. RIEGEL:     Thank you.  The next presentation is from  Robert  Naismith
            who is President of the Potomac Energy Group.

MR. NAISMITH:   Thank you.  My name is Robert  Naismith, and I'm  President
            of the  Potomac  Energy  Group.   I'm a  licensed  professional
            engineer with 22 years of experience in energy systems.  During
            the last  seven  years  we  have  been  primarily  involved  in
            building conservation  issues.    This work has  included  both
            volunteer work and for profit funded efforts.

                Two years ago  we  founded Potomac  Energy Group as  a  small
            for-profit business to  fulfill  what we perceived as  a strong
            need for private  sector energy  services.   We  provide a  wide
            spectrum of  services  for  private   clients,  as  well  as  state
            and Federal agencies.

                Our primary focus is in  working with what we  call indivi-
            dual energy consuming  decisionmakers, homeowners, home builders,
            building inspectors,   heating  contractors,   building  owners.

                In our outreach program,  we  have done  things such as devel-
            op a cost cutting  clinic for homeowners which  was probably one
            of the most  successful programs  under  EPCA in that  it  reached
            over 50,000  people  in the   State  of  Virginia  alone  and  was
            adopted,  at least in  part,  by 19 other  states.

                In the  last  three  months,  I  have  personally  conducted
            workshops for over 400 builders in two states and  seminars for
            heating contractors and  oil  dealers in  four  cities.   It  is
            this direct experience with the needs and reactions of  working
            level decision-makers  in small  business that  I wish to  share
            with you today.

                My first impression  is  that the concept  of the policy  of
            using price as an incentive for energy conservation is  working
            very well.   The attendance at  our meetings, the attentiveness
            of our audiences,  and the   response  to  our  recommendations,
            both in our  seminars  and  for our  private clients, is  clearly
            driven by the cost  of  energy  and  little  else.

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    It is also  clear that  we're getting  increasing  attention
in our  private  sector  from energy  prices,  and  this  is  true
whether we're talking  about  individual  homeowners   or  multi-
family or  small  commercial buildings,  all  of  which  we  do.

    In this environment,  we ask  ourselves what  do  we  see  as
the role  for  DOE  in an  environment  where  their  resources  are
limited, and  we  see three  things that  are particularly impor-
tant.  We see a  real need  to  fund basic  research and  evalua-
tion efforts  which  would not  otherwise  be taken.    This  work
is really  critical   to   the practitioner  in  the field.   The
work must  be focused  in large  part  on  buildings   which  are
occupied by real  people,  and which  are built  by conventional
construction practices.

    Unless the work  is directed  towards  this  real world exist-
ing building  stock,  it's of limited  use  to  the  practitioner.
Work, for  example,   like the  Twin  Rivers work  in  Princeton
has been extremely helpful  to the practitioner.

    The work  at Brookhaven  on  furnaces and that  sort of thing
has been very helpful.   We  see the need  for  evaluation of  new
techniques and  equipment.   So  both   the  practitioner  and  the
public has  some   sort of unbiased evaluation of  the worth  of
new products as they come on the market.

    If there  is  no   independent  evaluation, the  consumers  and
practitioners together are  left in  sort  of  a wasteland or a
thicket of  unsupported  manufacturers'  claims, and   that  very
significantly affects how  much  investment  will  be made  and
how much risk will be taken by people who are trying to respond
to the price.

    In particular,  we  see  several areas that  we think should
be emphasized.  The effects of retrofit  options on the  control
and mechanical  systems  in  single-family  dwellings needs to  be
worked very carefully.

    The Twin  Rivers  work is excellent on  the shell  of  single-
family dwellings.  We would like to see more work in  the mecha-
nical and control systems,  the  shells.   And  the  environmental
effect, such as  solar and the other parts  of the environment for
both single  family  and   multi-family,   we see  as  important.

    We see  little work  being  done  at present  on multi-family
retrofit options, and their effectiveness, and we see  that  as
an important  area.   Also,  improved  field evaluation  techniques
and analytical tools are very  important.   When  we  evaluate a
building, the payback  on an  individual  option may   vary  from
three to seven years, depending on whether  or not we missed the
R value in a  roof assembly  by two or three.
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    In one  case,  the  investment is going to be very attractive
for the  building owner  and  look like a  great investment.   In
the other case, it's going to look like a very marginal  invest-
ment at best,  and  so our analytical and examination tools need
to be improved.   The  second  critical  need  we see  is  for good
focused localized energy information.

    First off, it  must  be accurate, based  on the research ei-
ther of  the Department  of  Energy or  others,  and  in  that in-
stance, it's  important  that  the information  be  timely.  It's
much more  important  to  the  practitioner   to  have  information
promptly even  those where it's  identified  as preliminary than
to  have   research   quality   information   years   downstream.

    Our clients,  the  building  owners,  must  make  decisions.
We need the data as quickly as possible.  Secondly,  the informa-
tion must  be   on  a  localized  or regionalized basis.   When we
talk to buildings about passive  solar, the  issues are enormous-
ly different   whether  we're  talking  to   Houston  or   Boston.

    When we did  some work  for  the  weatherization  program,  we
found many  excellent programs  which  would work in one locality
or one region, but which  would  work disastrously  in   others.
It's very difficult to write  rules and regulations and  be pre-
scriptive on a national basis and get good  effects every place.

    In general,  we find  the text  or information  that's done
on a national  basis is either so general it's not to be useful,
or so confusing with  exceptions for locations and that  sort of
thing as to be confusing  and  not good information for the people
to think it's  important  that the information  that  be  supplied
be localized,   whether that means it is produced locally  or whe-
ther it is  produced centrally and localized in its outreach is
a separate issue, but it has to be localized.

    Thirdly, it's very  important that the  information  be pre-
sented in the  terms of the people to receive it.   We very often
see information on  heating systems  which   is  written  in terms
of the academic  or  the engineer rather  than the  trade practi-
tioner who is  really going to be the person who has to make the
decisions about whether  his  company is going  to  try to market
these devices  and how they're going to be installed, so  we see
a need for very focused,  very directed language.

    The third  need  that  we see, and  it's   sort   of  out  of our
area,  but  we   see  a critical  need  to provide  for those  who
can't provide  for themselves.   Our clients, the  people  that we
do work  for,   clearly  are responding  to price,  and we think
that's a healthy  way to  provide incentives  for  conservation.
But we never see the people  who can't afford to  respond.  Pro-
viding for them, it seems  to me, is a legitimate form  of gov-
ernment activity.

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                So, in summary, we feel that a greater emphasis on the mar-
            ket and price  will result in substantial  reductions  in the a-
            mount of energy  used  in buildings, and  a  corresponding dimin-
            ished load on  our  environment.   We feel,  however,  that  it's
            critical that the limited resources be carefully focused on re-
            search, information and assistance programs, as I've mentioned.
            Thank you.

DR. RIEGEL:     Thank you.  I'd now like to turn to the panel for questions
            and discussion.  Ted Kapus?

MR. KAPUS:      Thank you.  I appreciate your calling on me first this time
            because I got  cut  off before.   I have a question  for  Mr.  Nai-
            sniith, is it?

MR. NAISMITH:   Yes.

MR. KAPUS:      You had mentioned that the first area  of interest that DOE
            should contine  its involvement  in is the  basic  research and
            evaluation which would not  otherwise  be  undertaken.  Now basic
            R&D can really be broken down into  two areas, that which normal-
            ly would not  be undertaken for various reasons, and  I agree with
            you there, but there's  another area  that's somewhat  shaded.

                Would you  agree  it would be  a reasonable  involvement for
            the Federal government on technologies that had to be accelera-
            ted into the marketplace?

                I know the Department  of  Energy's  research   area  and  a
            number of its programs have been involved  in helping to accel-
            erate the  introduction of  this energy  efficient  technologies
            by three  to   five  years.   Do  you  feel  that's  a  worthwhile
            role?

MR .  NAISMITH:   I  think  the  reduction of risk  on  a  new technology  is
            an important  function  of  government;  however,  the  acceleration
            of the  marketing process or  the  interaction  with  the  market
            itself, I'm  not  sure  couldn't  be  better  done  by  the  private
            sector.  But   I agree  that  the  identification  of new  techn-
            nologies the   reduction of  the  risk  to the  point that  they
            can be picked up by the private sector is important.

MR. KAPUS:      If I may  move then to Karen.  You had  mentioned a stimula-
            tion of interest  as  a result  of  the new  economics in  decen-
            tralized power  production,  the  small-scale hydroelectric  in-
            stallations experiencing  a  renaissance  in municipal waste  to
            energy conversion programs.

                I've been  given   to  understand that because  of  the  high
            risk and the  high cost involved  in the waste to energy  conver-
            sion programs  that  if Federal  support  in  this  area is  with-
            drawn,  there  would be no continuation  of  these programs.   Is

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            this a  reasonable  assumption,   or  are  you  given to  believe
            otherwise?

MS. ANDERSON:   I think in a climate of high interest rates any major  pro-
            ject like  that  becomes  more questionable.   Our members  do
            have access  to tax exempt  bond  funding,  which  still  is much
            higher these days than they're used to paying.  But the City of
            Columbus, for  example,  is  going  ahead with  its  solid  waste
            fired plant.  Most cities that can justify the thing can  justi-
            fy it  without  — Nashville  is  going  ahead  with the   second
            installation.  I  can  think of a number that  are  going  to go
            ahead whether  the Federal  government  can help  them or not.
            But again,  not as many  would as  if  they had the assistance.

MR. KAPUS:      One area that was conspicuous by its omission here was that
            you made  no reference  whatsoever  to the  concept  of district
            heating and cooling.  Was that intentional?

MS. ANDERSON:   No, I think I did or I meant to.  I didn't  explain it very
            well.  We're very  keen on district heating,  and  we would very
            much like to see,  as  you  probably  know, increased Federal sup-
            port for  district  heating.   That's one  technology where a lot
            of systems  in Minnesota,  for example,  very small towns have
            existing  district heating systems that are becoming very  expen-
            sive to maintain.  They're  not the latest technology.  They're
            using steam  instead  of  hot  water.   They're  leaking,  and it
            almost pays the city to scrap the whole system.

                We'd  rather  see  some help  from the Federal  government to
            invest in a new, more efficient  system.

MR. KAPUS:      It's  really not a new technology, but it's a costly one.

MS. ANDERSON:   Yes.

MR. KAPUS:      Thank you.  One  last question before I get off.  Mr. Cady,
            I realize  it  would  be  of  no assistance  vis-a-vis  having to
            deal with  a patch quilt  of  state  standards,  but just  as  a
            thought, had  the  association  or the  industry ever  given any
            thought to  generating  and  monitoring  and   standards  program
            for the insulation industry itself?  Certain appliance manufac-
            turers have done  this.

MR. CADY:       Yes, we have  considered it,  but would we be believable?  We
            could be  claimed  to be tooting  our  own horn, selling our own
            products, if  we set  insulation  levels  at the ones we thought
            were appropriate.   R-60 sometimes is appropriate,  but I don't
            know how  you get  it in  the  attic,  so  we would rather have some
            independent source of standards  rather  than from our viewpoint.

MR. KAPUS:      I appreciate  it, thank you.


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MR. FRANKEL:    Let  me  ask some  more  questions on the  specifics of the
            Reagan program.   Do  you   think  that  the  increase  in  energy
            prices justifies  an 80 percent  reduction  in Federal  funding
            of conservation?

MR. NAISMITH:   Is that directed to me?

MR. FRANKEL:    Anyone who wants to respond.

MR. NAISMITH:   I think price is the most effective thing that we see oper-
            ating out there, and it's hard for me to say whether 80 percent
            is the  right  number,  and  those  are  not   judgments  that  I
            make.  But the most  effective programs  that  I find tend not to
            cost very much,  and the  biggest  effect I  find in  people who
            have to  make decisions about  what  they're  going to,  whether
            they're building  owners  or  homeonwers or   whatever,  I  find
            that very strongly driven by price and nothing else.

                So at least  philosophically  it  seems  to me that  price is
            going to  give  the right signals,  whether it's  enough  and whe-
            ther the  budget  should be 72 percent or 80  percent  or 43 per-
            cent, that's a separate issue.  But  I  do see prices  being very
            effective out there.

MR. FRANKEL:    I'm talking about a cut of 80 percent.

MR. NAISMITH:   Yes,  I know.

MR. FRANKEL:    Let me  be specific then.  A  number of you have  mentioned
            information and you  talk  about the  need for local information.
            There was  one  program  in  DOE that  attempted  to  generate that
            kind of  information called  the  Energy Extension  Service, and
            in many  cases  the  Energy  Extension Service has coordinated its
            activities with  the  local  municipal   utility,  redoubled the
            impact on a certain  town.

                We've always  thought  that program was  a pretty  well run
            program,  because  they allowed it  to  be  run  locally,  and the
            other program, I think, we would  support  continued  funding for
            is, of course, the low income weatherization assistance program.

                There's nothing  to replace that, and it's  just  that  those
            people need help.

MR. CADY:       Also  in answer   to  that,  it  also  seemed  to me that the DOE
            extension service  was a duplication  of a very  successful one
            that has  been  in place  for  years, the Department of  Agriculture
            group, and  I  never  could  figure  out why there  were two, when
            one was  working effectively.

MR. NAISMITH:    I think  there's  also  a  legitimate issue  about quantity.
            When we  suggested information is  needed,  one  of  the problems

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MR. ONDICH:
that many of  the  decision makers have had  in  the past is that
there's been an enormous  amount  of information that it is very
difficult for  them  to  sort  through  it  and  make  decisions.

    I think a limited output of  very  focused information could
be done fairly efficiently in terms of cost.

    1  have a  question  for  APPA.   We  were  talking, as you
probably heard,  with  the  earlier group  of  witnesses  about
low income  assistance  programs.    Some  of  your  testimony  ad-
dressed these  types  of  programs,  but  are you doing  any thing
as specific as the EEI.   50-state,  10-unit study that directed
towards low-income tenants.
MS. ANDERSON:   Well, we're not exactly the size of  EEI.  We have a  total
            of 30  staff members.   We're a  small  outfit,  non-profit.   We
            never would  have  the  money to do  that.  What we  try to do is
            take examples  of  programs that  our  members  have  developed,
            cost-effective programs, and play them  up as best we  can in our
            magazine and  our  newsletter and things  like  that,  when you've
            got 2200  basically towns  out  there.    It's  a  little  hard to
            coordinate their  activities  as  if  you had  300  major  size
            utilities.  So we're not doing anything  directly.

DR. RIEGEL:     I have a  question  for  Sheldon  Cady.   You   argued  very
            strongly  for   preservation  of    building  energy  performance
            standards, as I understood it,  for reasons that had  to do with
            a fear  of  a  multiplicity  of  conflicting state  regulations
            that might affect  either  the  insulation manufacturing industry
            or perhaps some other  industries as well,  home building opera-
            tors that may  operate  across state  lines,  and so  forth.  Yes-
            terday we heard from many people  who testified that  reductions
            in funds  proposed by  this Administration  for  state programs
            would lead either to  the  closing  or  a striking  reduction in
            the scale  of  activities  in  state  energy  offices.   If  you
            consider that fact, I  wonder if one  consequence might  be that
            the conflicting  state  regulation  in the standards  area which
            you mentioned  may, in fact,  be  forthcoming.  Another thing
            that I frankly wonder  about and  would like your reaction to is
            whether you  feel  that  the  states  will   be  relying  more exten-
            sively in the  future  on  natural  competitive  forces  that  will
            be developing  within  the  home  building industry  and improve-
            ments in the  technology  and in the  general level  of expertise
            and knowledgeability  about  conservation,   the  techniques  to
            employ to see  that houses  are built to quality and high per-
            formance, or whether you  feel that  a strong pressure will con-
            tinue to  exist at the   state  level   for  regulatory  action.

MR. CADY:       That's a  long  question  with  lots of  subquestions.   The
            very first part I want to  emphasize is  that I did  not argue in
            favor of BEPS, and I want  to  get  that  cleared up.   I was argu-
            ing in favor  of the research  that  had  been paid for and accom-

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            plished under  BEPS  and the use  of that for  other purposes as
            far as standards are concerned.

                A widespread  education program  would  help  to  accomplish
            the level  of  competition that you were mentioning in the last
            part of your  question, and  that would undoubtedly  be helpful
            to the consumer  and the industry  involved  in energy conserva-
            tion.

                If state energy  offices  were  eliminated,  who would assume
            responsibility for  energy  conservation?   It  would  be  left
            again to  the  marketplace, I  assume.   Does  — would  the mar-
            ketplace —  I'm  answering  your  question  with  a  question.
            Would the  marketplace   in  the future  be adequately informed?
            I doubt  it very  much, and  —  we're  overregulated  without a
            doubt, and  I'm in the  awkward position of  saying,  okay,  get
            rid of some regulations, but not us.

                I'm aware  of  what   I'm  doing in this  thing,  and  I'm sure
            there are plenty  of  people who  are doing  that too,  but  we do
            feel that voluntary —  not  regulations  but  voluntary standards
            — are entirely appropriate.

MR. NAISMITH:   Can I comment on the  issue of  regulation,  building codes
            and the BEPS  thing?  We  talk to  builders  a lot, and  we also
            do a  lot   of  training  programs  for  building  code  officials,
            and so we work in that area a fair amount.

                The real example of what happens  when one tries to regulate
            the level  of  insulation  in  homes, for  example,  is  the  90-75
            based codes.   My  data   on  that says  that  first  off  in almost
            any market area,  it  is  impossible  for a  builder to sell a home
            if it is only made to the 90-75 based  codes.

                And whether  you  talk  about  NAHB  survey,  whosever  survey
            you take,   the market   is  demanding  a  much  higher level  of
            insulation than the 90-75 code generally.

                Now,  of course,  there are always  some  marginal  operators.
            How we deal with them,  I'm not sure,  but the market is doing a
            nice job of being  aware of the  fact that insulation and  storm
            windows and tightening  the house is  important, and  the market
            is strong  enough in that feeling that  it's  driving  builders
            who tend to avert  risk if they  can to putting in much tighter
            homes, much more  energy efficient homes than are  required  by
            the regulations  in  most places.   So  I think we  don't have a
            lot of babes  in  the woods  out  there.   I  think  the  market  is
            responding, and  whether it's  enough  and  whether we may  need
            to press it more  may be a valid issue.  But there really is a
            lot of information  out there, and there's  a lot  of response,
            and the builders  are finding  it,  and they're  building houses
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            which reflect  it,  and they're  way ahead  of  the regulation in
            most areas.

                You just can't sell a house if it's only made to 90-75 base
            standards in most  market areas  where I  talk  to the builders.

MR. CADY:       You missed my presentation, but I inferred the same  thing.
            They're completely inadequate,  but my question is what percen-
            tage of the  builders  are doing this  properly  and what percen-
            tage are not.  Nobody knows, of course.

MR. FRANKEL:    Also, we've heard  data that even the  best current practice
            is still 50  percent less  energy efficient than is economically
            cost-effective over even,  let's say,  seven years occupancy of
            a house that many builders  don't  realize just  how  much more
            energy you can squeeze out of a house.

                You can  put  a lot  more  insulation  in,  you can  also put
            vapor barriers, triple  glazing.  There are a  lot of conserva-
            tion techniques  that  are  still not  part of  common practice,
            yet are from the  consumer's  point of  view,   very,  very cost-
            effective.

MR. ONDICH:     As a follow-up on  Gene's question, Alan Miller NRDC, yest-
            erday said he surveyed, 18 to 20 building  sites in the Northern
            Virginia area, and his  informal survey  indicated that builders
            in these high  interest  times  are not  installing  overhangs,
            high efficiency  furnaces,  or  adequate  insulation because  of
            the cost.

MR. NAISMITH:   Part  of  that  I  agree  with.  I think,  in general, we'll
            find that the  insulation is going in.   There are  many issues
            in terms of  how  one  deals with the energy efficiency of homes
            other than the shell  that are not well  understood,  and that's
            one of the things I specifically mentioned.

                We have  a  lot  of understanding,  I  think,   and  a  lot  of
            response for  insulation  and   storm  windows.    We  don't  have
            nearly as much response  in terms  of  quality  control,  in terms
            of passive solar,  although we're seeing much  more  of that,  in
            terms of selecting mechanical  systems on  some  sort  of optimum
            basis, and we're  now seeing builders beginning  to  respond to
            the question  of  what  sort of  mechanical system should  they
            use.  But that information process  is very early, very meager,
            not very widespread.  The one about  insulation  and  storm win-
            dows, I think,  is much more generally understood.

MR. KAPUS:      Are you running into a  problem in your  circles  now  that
            the houses are becoming  tighter,  are the  builders  showing any
            kind of concern  for  air  quality  within  the  structure  itself?

MR. NAISMITH:   We look at a lot of buildings, and we're not  finding  very


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            many buildings  that  we  think  are  getting  below the  half air
            change per hour  that  I  feel is going  to  get  us into problems.

                We are  finding lots  of other  things that  are happening.
            For example we're finding houses where the fireplace is getting
            its air  supply  by pulling  it down  the  chimney  of   the  gas
            furnace, because  that's  the only  opening in the  shell.   See,
            that's the  kind  of  interaction that  we're  getting  into, and
            one of the  areas I specifically  mentioned  in  terms  of inter-
            action, and what's going on, we're seeing lots of subtle things
            that are happening  out  there  that  need  to  be  understood  much
            better, which is why we think this whole business of looking at
            existing houses  with  conventional techniques is  really impor-
            tant.

MR. FRANKEL:    One of the things I feel  I'm hearing you say, all  three of
            you in different  ways,  is  that even  though  prices are a  very
            strong motivating  factor,  there   are  still  market  barriers,
            market imperfections  and  that  it  is  — in areas  such as  lack
            of good  information,  sometimes lack  of  upfront  capital,  lack
            of understanding  of  how  equipment  works —  there still  is  a
            proper governmental role to play.

                Is that an accurate paraphrase of what you said?

MR. NAISMITH:   Yes, how large that government role is is an issue  certain-
            ly.  Certainly an important critical government role.

DR. RIEGEL:     Well, I  wish to thank  the witnesses for appearing with us
            today and  to ask  the  following  people  to   come  forward,  if
            they are all here.   Richard  Esteves, Alan  Rimer, if  he's in
            the room, and  Robert Manahan.  We'll begin with Mr.  Manahan.

                Mr. Manahan  is with  the  Thermal  Insulation Manufacturers
            Association.

MR. MANAHAN:    Good morning.  As  Kurt pointed out, my name  is  Robert C.
            Manahan,  representing   the Thermal   Insulation  Manufacturers
            Association.  The  membership   of  this 41-year-old  association
            consists of  a majority  of manufacturers of insulation  products
            for a  wide  range  of  applications in  power  and process indus-
            tries, in  air  handling  systems,  high   temperature  specialty
            work in  the  form of  refractory fibers,   as  well as insulation
            for building  envelopes  — the  roof,  the wall  — and   for pre-
            engineered metal  buildings.

                In fact,  TIMA is  virtually  the  entire  producing segment
            of the  insulation  industry dedicated  to  our   country's  most
            vital need,  conservation  of  energy.  Through  TIMA,  both its
            individual member  companies and  the  public are  benefitted by
            the identification  and  definition  of  increasingly  effective
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methods for reducing energy waste to a minimum and for creating
opportunities for better energy utilization.

    The specter  of  Americans once  again waiting  in gas lines
is a  possibility that  will  continue  to exist  as long  as  we
depend on foreign sources  of  oil.   Obviously, energy conserva-
tion measures must  be  implemented  by this  nation's motorists
and automobile  manufacturers  to lessen  the  possibility  of gas
lines, but  conservation measures  shouldn't  begin  and  end with
the gas pumps.

    There is  also  a   staggering  potential  for energy   saving
within the nation's industrial sector.   At current cost,  indus-
try can save well over  $23 billion in the 10 years or one bill-
ion barrels of  oil  equivalent,  and  if energy costs continue to
skyrocket, industrial energy conservation will have an even more
salutory effect on the  nation's economy.

    An extensive TIMA  study  of  15  of the most energy intensive
industrial groups  in   our  economy  shows  that  industry  can
sharply reduce  Amerca's dependence  on  foreign  oil  simply  by
employing  insulation,  a  well   known   conservation  measure.

    Industrial use  of  insulation  may  seem  like  an  obvious
solution to  most  people,  but  the  unfortunate  fact   is that
industry as a  whole has not  committed  itself  to  a  full-scale
energy conservation program.

    Energy cutting  measures  employed by industry  to date have
primarily been  simple,  housekeeping  items  such  as  repairing
broken windows,  turning off equipment  and lights when  not  in
use, and  setting back  thermostats.   With minimal  capital in-
vestment, these  have  increased  awareness in  a sense  and ef-
fected an immediate, if modest, savings.

    However, to  its credit,  it  is  encouraging to note that the
Industrial Energy Efficiency Improvement Program, created under
the Energy  Policy  and  Conservation Act,  reported  a  weighted
average energy  efficiency  improvement of  15.4 percent  at the
close of 1979 as compared with 1972 efficiencies.

    Total energy  savings  for  the  reporting corporations  in
1979 amounted to 2.2 quadrillion BTU's per year, the equivalent
of over one million barrels  of  oil per day,  compared  to what
would have  been required  in 1972  energy per unit   of   output
levels.

    The DOE  1979 annual report  to  the Congress  and  to  the
President indicated that the most significant low cost improve-
ment of energy  conservation measures  is the  use  of increased
insulation and in process equipment.
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    But according to  our TIMA  survey,  there  is  still a  need
for true long-terra  energy  conservation in industry.  This  can
only be  accomplished  by  the  application  of high  performance
insulations to  industrial  equipment and  piping,  resulting  in
savings of hundreds of  thousands  of barrels of oil equivalent
each day.

    The cost of bringing current insulation levels up to energy
efficient standards  is   a  necessity  which  will  result  in  a
dramatic return  on investment  for  business and  the  nation.

    TIMA conducted  the   study  and  it's  entitled,  "Industrial
Survey of  Steam Process Piping  Insulation," which  exposed  an
unquestionable need for industrial  energy  conservation.   The
TIMA study focused  on steam process piping  which comprises  42
percent of total industry use.  In  all,  15 Standard Industrial
Classification groups representing  85  percent  of total indus-
trial energy  use were   examined.   These  groups  included  the
chemical, lumber,  paper, petroleum,  plastics,  food,  metals,
stone, glass and clay industries.

    TIMA completed  the   study  by  researching  the  insulation
practices of  500 typical industrial plants  representative  of
the entire  country,  as  well  as  each  one  of  the  industrial
classifications.  The report reveals that there are  325 million
feet, two and  a half  times  around  the globe, of  steam process
piping in use by these industries in the 15 groups.

    Nearly 72 million feet  of this  type  of piping is complete-
ly uninsulated.   The  rest  of  the  piping   on  the   average  is
under-insulated by  today's  standards,  with  only  about  1.7
inch thickness  on  large piping,  that's  above  two  inches,  and
one inch  on  small  piping.   To  meet   today's  and  tomorrow's
higher fuel  costs,  these thicknesses  should increase,  on the
average, to  three  inches  on  large pipes  and two inches  on
small.  These were calculated using TIMA's ETI,  that's Economic
Thickness of Insulation computer program.

    The wasted  energy that  results  from uninsulated and under-
insulated steam  piping,  we have  estimated  at  305,000 barrels
of oil  equivalent  per   day.    At  $22.33  per   barrel  of  oil
equivalent, the  cost  for this is $6.8 million per  day or $2.3
billion per  year,  more  than  is used by the entire  rubber and
plastics industry,  and  exceeds the combined total  of textile
and lumber industry use.

    The study  points  out  that  the total  cost  of  insulating
bare pipe and  replacing existing  insulation with a more effec-
tive type would be  $6.2  billion.  But the  study went on to say
that the  payback period  would  be  an  astonishingly  short  30
months based on  the average price per barrel of oil equivalent.
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Future savings  would be  even  greater  as  the  cost  of energy
continues to rise.

    The TIMA  study  suggests support of  Senate  Bill 750, enti-
tled "Industrial  Energy  Efficiency and  Fuel  Conversion  Tax
Incentive Act of  1980"  introduced by Senator  Wallop of Wyoming
and its  companion House measure, H-2650.   These  will serve as
amendments to the Internal  Revenue Code,  and addenda  to the
National Energy Act of  1978.

    The bills  raise  the  tax  credit  allowed  for  new  energy
conservation investments from  10 percent  to 20 percent.  This,
in addition to the 10 percent investment tax credit established
in the 1978 Energy  Act, makes for  a total  of about 30 percent
for new conservation investments.

    Additionally  I invite your  attention  to Senate  Bill S-1288
entitled "Commercial  Business  Energy Tax  Credit  Act  of 1981"
introduced by Senator D. Durenburger, and this  seems  to fill a
void and encourages  greater  conservation by  commercial busi-
nesses through  greater  use  of  energy  saving  equipment.   It,
too, provides a  20  percent energy  Federal income tax  credit
for installing insulation in an existing industrial,  retail or
commercial building or  facility.

    Qualifying property would  include  not only insulation, but
also a variety of other items designed to  reduce heat loss or
gain when put in  place  after 1980 and before 1987 with a useful
life of at least  three years.

    One would assume  that the  return on investment  for insula-
tion is so attractive that  it  is a top priority capital expen-
diture and that   bare  surfaces  and poorly  insulated  pipe and
equipment would  be   autmatically insulated,  just  like  poorly
insulated attics.  Yet  there are still  32 million under-insul-
ated houses in  America, and,  as the  study shows,  253 million
feet of underinsulated  steam pipe.

    The disinterest  in  Insulating  possibly  stems  from  high
interest rates and economic uncertainty which cause management
to pare  down  its list  of  investments.  Conservation invest-
ments often are  the  first  to be  cut  or eliminated unfortunately.

    The obvious  need  for  insulation has been  clearly substan-
tiated in  the  TIMA study.   If   it  takes  tax credits  or other
incentives to encourage conservation,  it is  a  wise investment
for the future of America.   The sooner  we lessen  our dependen-
cy on foreign oil sources,  the  stronger we become as a nation.

    Industrial energy conservation will be expensive.  Yet bil-
lions of dollars  are  being  spent by the auto  industry to  save
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            gasoline, and  millions  are  spent  on home  insulation,  which
            does qualify for a tax credit.

                Americans must choose  the  most direct and  effective  means
            of conserving energy.   Considerable time  and  taxes have  been
            spent in research  and development  of  the Department  of  Ener-
            gy's Building Energy  Performance  Standards,  BEPS,  for commer-
            cial buildings.  Implementation  of the long delayed  standards
            has been stopped  or  put  on hold  because of controversy  over
            its prescriptive nature  and added building  costs.   Yet  even
            BEPS is projected to  save only 216,000 barrels of  oil equiva-
            lent per day, in comparison with  the  305,000 barrels estimated
            saved if industry  follows  the  common  sense  insulation method.

                TIMA believes that  it  is  past time  for industrial  users
            of energy to  make  the financial  commitments needed for  major
            savings that must be achieved in the future if we  are to lessen
            our dependence on  foreign  fuels.   Incentives such  as  those in
            the referenced legislation may be  the  best means  of attracting
            scarce investment  capital  to  energy  conserving  uses.   Energy
            saved in the  industrial  sector and commercial  buildings  is an
            achievement that is worthy of national attention and encourage-
            ment.

DR. RIEGEL:     Thank  you very  much.  Before  turning to questions,  we'll
            hear from Mr. Esteves.

MR. ESTEVES:    Good  morning,  I'm  sorry for being late.  I  had a  little
            trouble getting around the beltway.

                My name  is  Richard  Esteves.   I'm  head  of   Conservation
            Programs for  General  Public  Utilities.  We're  by no means one
            of the largest companies  in  the United States, but we do have
            the enviable  pleasure of  owning  Three Mile Island and  being
            in a very capacity-short situation.

                We are  purchasing enormous amounts  of outside  power  from
            neighboring utilities, and even from  Canada.   So  it's to our
            corporate benefit and especially  the  benefit of  our  customers
            to do  whatever  we can  to  reduce  the  need for electric  usage
            in our service territory, especially during any on-peak periods
            when purchased power  costs go up,  and I'm  just  talking  about
            the base  energy  costs,  go  up  about  10^ a  kilowatt  hour.

                We've had  instances  where  we're   buying  power  from  other
            utilities at  about  15
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    Now let  me  turn  to  the subject  of the meeting,  which is
what happens now  with the proposed  changes  in regulations and
what's going to happen with conservation efforts.

    Our general feeling is: "Them that wants to will, them that
don't want  to,  won't!"   I'm not  talking  here about utilities,
regulatory bodies and institutions.

    We've seen  over the past three  or four years  a  number of
major regulatory  steps  to increase  conservation  in the United
States.  Yet we can  look  at  these  programs and  see  a widely
divergent effectiveness  within  the  programs  depending  upon
locality and local  circumstances.  Yet  they're all  coming under
the same set of guidelines and regulations.

    Why?  It goes  back  to the people  who  are  trying to imple-
ment the  programs  or are  claiming  to try to  implement  the
programs.  It's  a matter of  local  concern, and  it's  a matter
of local  effectiveness.   I  do not  believe,  and  the  company
does not believe  that the way to do  this  is through an exten-
sive set  of regulations  at  the  Federal  level.    However,  we
do strongly  encourage the  continuation of  a number of develop-
ment efforts and  research efforts  in  the  energy  conservation
field.

    Someone earlier  mentioned the  Twin Rivers  project.   This
is the type  of  thing that we  need,  an examination  of  what is
currently available  and  a very  objective  in-depth  analysis
of the cost-effectiveness  of  that  program.   Our  own  R&D pro-
grams are  frequently looked upon  somewhat  askance by utility
regulators or by  the manufacturers  or by  the builders  or by
consumers.

    When we have had  an  independent  body,  such as the National
Bureau of  Standards or the Environmental  Protection  Agency or
the DOE that we can say has completed  this  study that we have
faith in,  and here are the results  and we  recommend  that you
move along in this  area, we've gotten good response from that.

    Let me take  an example outside  of the  energy  field.   For
years, we've had tire evaluations which were completely volun-
tary and nobody paid  any attention to them until fairly recent-
ly, when the marketplace picked it  up.  Now there are a number
of tire  manufacturers that  are  advertising  that they're  in
compliance with  these  voluntary   standards.   I   believe  that
is what is happening  in a  number  of areas  in the  energy field,
that thermal  insulation  people  and   others  are  picking  up
information and data  that was published as a result of studies
by the DOE  and   others  and saying  this is  what  we can  do at
your local  place,  and the  pricing  mechanism  is  forcing  that
into the marketplace  now, much faster than the Federal regula-
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tory programs  or  the  local  regulatory  programs  were  doing
prior to this.

    I think this morning  Dick  Russell from LILCO discussed the
RCS program.   I  have  the pleasure  of  working  with two  RCS
programs, one in Pennsylvania and one in New Jersey.

    These two  are  approved by DOE  and yet there  are items in
one state that were  specifically not  approved by  DOE  for the
other state.  There are items in one state which had previously
been thrown out and were put back in within a couple of months.
Yet in both states,  responses  to the  RCS  offer is significant-
ly less  than  one  percent.   Our Pennsylvania  Electric  Company
had previously put out an offer  of  its own,  and  the response
to that  was well  over five percent.   I  believe  someone else
mentioned this morning a  New York  Power Authority  effort to
which response was 16 percent.

    I'm not  saying  that  the  auditing  program is  not a good
program.  It is  a  good program.  It's  an  outstanding program.
It is  a necessary  program.   However,  I do  not  believe that
it's going  to be  effective  unless  the  people  at  the  local
level are  interested in  doing  this  program,  and the  same is
true of  many  of  the  other  programs  that  were   going  under
evaluation.

    Now, I  guess it  comes back  to  the  old  story of  you can
lead a  horse  to water,  but  you can't make  it  drink.   Well,
some of  the regulations  proposed  that, maybe  if you  beat it
over the head  a  couple of times, it'll start  drinking.   Well,
some of  these  horses  are  pretty muleheaded,  and they'll  just
wind up  sticking their  muzzle  in  the water  and  swishing it
around a  little  bit, and  you'll think  they're  drinking.    I
think that's  what's  happening with a  lot of  the proposed pro-
grams.

    The question  came  up  earlier  about  whether  or not the
pricing mechanism  is sufficient now  to justify  an 80 percent
cut in  the  budget.  That presupposes  that  the previous   budget
was cost-effective,  and we have seen  in  many  cases where  that
program was not  cost-effective.

    I don't  know if  it deserves an  80 percent  cut,  but I do
firmly believe that  the previous budget was not cost-effective
and was  not cost  justified.   So even before  we  got into the
pricing mechanism, I think  we have  to examine the value  of the
individual  programs.

    I'd  like  to  do that  quickly with a  couple of programs in
particular.  The  RCS  program,  I believe,  is  a  good concept.
I  believe much of  the work that  was done at Oak Ridge in  evalu-
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ating audit procedures,  cost  benefit  analysis and this sort of
things is extremely valuable.

    We have  incorporated  much  of  that  information  into  our
own efforts and  recommendations.   What  has  not  been valuable
is the  requirement for  each  state to have  a  uniform system
across the state  and  for all the states  to have their program
approved at the Federal  level.   This has  resulted in some very
significant problems  in  implementation at the local level, and
it has  certainly  undermined  the ability of  the local utility
companies or  the  oil manufacturers   or  others  to  develop  a
program which  they believe is  cost-effective for them and for
their customers.

    The commercial  program I'm  not  that familiar  with except
that I did notice in  the cost  benefit analysis  which was done
as part  of this,  there  was  a  significant  difference between
the base program  in which  there were  mandatory  rules and the
optional program  which was  totally  voluntary.  The significant
difference that came  about was  in  the response  of  customers,
the building  owners  and the  builders,  and  yet this  was  not
affected by whether or  not the  rules  were  mandatory or volun-
tary.  I really don't see  an appreciable  need for a  commercial
program.

    Information services -  I would like to separate information
services into  two parts.   One  is information provided  to the
conservation industry  which  is a  very  wide group   involving
the solar industry, the  insulation  industry,  utilities, energy
producers, everyone else which  is  more  of  a research effort.

    This has been extremely valuable.  Under no circumstances
do I  suggest  that  we cut  those back,  and I would  urge that
there be more work done  in  this  area.  The other side is consu-
mer information.

    Time after time,  our own evaluations  of what our  customers
are interested in learning from us is  that  they have  had  it
with conservation  information, unless  they're about to do some-
thing themselves.   They  say  that  they've  already  done  as
much as they  can   reasonably  do,  and  don't send  them any more
information on  conservation.   When   they  want  conservation,
then they'll come  and ask  us for it,  and  we've  seen this time
after time.

    I suspect that the  information that  is  generally provided
by utilities  across the country is the  same.   It's probably
the same as that  which  is   provided by DOE  and by the National
Solar Institute Clearinghouse,  by the manufacturers,  and many
others.  You  find  a  significant  repetition  of this effort.

    I believe  that many  of the consumer  information programs

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that are  being  cut back  or being  suggested for  cutbacks  are
duplications of existing efforts, and as such will  not  be sig-
nificantly missed.  What  will  be missed  if they are  cut back
are those  efforts  which  border the   differential  between  a
strict research effort and  the ability  to  get that information
into the commercial marketplace.

    The weatherization question,  as  I understand it, is between
weatherization as  a separate  program  and  that  of  rolling it
into a block  grant for  state use.   I  must  go back  again to
the idea  that  you  can't  force  a state or an  organization to
do something it does not  want  to do, and  whether  this  be with
weatherization or anything else,  it  still holds true.

    Again, I have  the  pleasure  of  working  with  two  separate
weatherization organizations,  one in   New  Jersey  and  one  in
Pennsylvania.  In  New  Jersey,  there was  a good deal  of  money
spent on  weatherization,  and  in my  home   county,  I know  the
people rather  well, and  they're very conscientious  people.

    However, their  feeling  was one  that  if  the people  wanted
weatherization, they were going  to  see  to  it  that  they  went by
the book.   For  example,  in  the  entire county,  there was  one
location where you  could  sign up for  weatherization services,
and you had to do that  in person.

    We tried  to  get  weatherization  forms  put in our  local
business offices  for  our own  indigent  customers.    That  state
refused to  do  that because  they had to screen  the individual
applicants, and perhaps  there  is a  reason for this.   I  don't
know, but  the  fact is  that that state was not interested in
doing more.

    In the  other  state,  they  were  much   more  interested,  a
much more  out-going program,  so much  so that we wanted  to
assist them, and  we had  a  program that  would save a particular
user of  electric   water  heating  approximately  $88  to $100  a
year.  It  required  some  equipment.   We  offered to purchase and
give them  the  equipment.   They   said,  fine,  that  they  would
like to do  that,  but  that  it  would take  them about a  year to
process the  changes  in  their   standards   in  order  to  allow
their work people to install that equipment.

    Incidentally, by the  time  we got  around to doing  so,  the
cutbacks came,  and they  said,  no,  we can't  do   it,  because
we're waiting  until the  weatherization   program  has  settled
down.  Again,  they stated  that   they  had   a  plan   approved  by
Washington, and that they could  not  deviate significantly from
that plan without  going  through  public  hearings  and approvals.

    One last thing on the  weatherization  program:  there's  a
fuel assistance  program  which  has  been  very  successful  in

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            temporarily alleviating hardships  for  people who are  short on
            heating fuel.  However,  in neither of  the states  which  I was
            involved were they using the applicants  for fuel assistance as
            a target group for the weatherization program.

                In one  state, they  refused  to do  that,  because  they're
            handled by two different  departments,  and in the  other state,
            they're requested  to  do  that at  our  suggestion and  were told
            they could not do so  because  it was  confidential information
            and that  they  would  even refuse  to  do  a  special mailing to
            those people because  that  was invasion  of privacy.   These are
            important considerations,  invasion of privacy  and  others, but
            yet I  feel  that  many of  the  people  who  are  requesting  fuel
            assistance would  have  benefitted significantly  and  would have
            been very happy to have been  informed  and to have  been solici-
            ted for free insulation and other materials.

                I would  like   to  indicate one  thing,  and   that  is I'm  a
            member of the EEI,  investor  owned  utilities, and  we  have some
            excellent programs,  and  many  of  our  individual  members  have
            outstanding programs.

                However, some  of  the very best programs I've  seen in the
            United States are  coming out of public  power companies,  and I
            know Karen was here  a little  while ago speaking about this.  I
            believe that the  reason  for  this is not  because of the profit
            question, but simply because they have much greater flexibility
            on a local level and do not have to concern themselves signifi-
            cantly with getting regulatory approvals.

                Time after time,  utilities have been able  to  go  to an REA
            co-op and suggest to them programs which we've  taken six months
            or a year to get  developed and get  approved  as  part of  our way
            of doing  things,  and they've been  able to put  it  into effect
            in three weeks or  a month.   I wish  that we  had that flexibility.
            I believe  anything  that  will  help  move  the  decision-making
            process closer to  the customer,  closer  to  the  point  where the
            customer interacts with  the  company or  the  energy supplier or
            the service suppliers, the insulation manufacturer, the closer
            you can  get  that  decision process to  the  contact point, the
            more  effective   the   program  is   going  to  be.   Thank  you.

DR. RIEGEL:     Thank  you very much, Mr. Esteves.  We'd like to go  now to
            discussion involving members of the panel.

MR. ONDICH:     I have a question for Mr. Manahan.  For those 500 industri-
            al plants surveyed in your study,  did  you find any difference
            in the types of cost accounting system used for energy expenses
            in those plants,  Do you think that would influence their decis-
            ion in any way toward energy conservation measures?
MR. MANAHAN:
Possibly so.  I'm  not sure  that the report actually high-

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             lighted  the differences,  however.  There are a  lot  of  personal
             prejudices and so forth on  how various firms approach  a  common
             problem  of that nature based  on previous experience and  proxi-
             mity to  local production  points — that sort of thing  — which
             reflect  on  economics,  but   I  don't  think  the  report  actually
             highlighted the differences.

MR. FRANKEL:    Mr.  Manahan, I  must admit  I'm   shocked by  your testimony,
             because  after all of the presentations  we've had this  morning,
             telling  us  how  increased prices were  going to  send the sig-
             nals that are  needed to effect all  this   energy conservation,
             now you're  telling  us  that with  signal   that  you   can  get a
             30-month payback  these  industrial   firms   are not   responding,
             and I'm  wondering why  aren't  they   responding.   Why do we need
             an additional tax credit such as you're proposing if  the market-
             place is, in effect, sending them  this very clear price signal?

MR. MANAHAN:    Well, we can only  observe on what  we have  perceived, and
             what we  have  perceived  is  a rather intense   study  in  the last
             four and a half to five years.  We have seen  by actual accoun-
             ting the thicknesses  of  insulation on the   average  increasing
             only as  little as about a quarter of  an  inch on large  diameter
             piping and as  little as two-tenths  of an  inch  on  small dia-
            meter piping, and that, to us, doesn't  translate into  a  drama-
             tic shift in  the  recognition of the  need   to conserve energy.

MR. FRANKEL:   Why won't industry do it on its  own with a 30 month  payback?

MR. MANAHAN:    I think all  industry today is   pretty  well  strapped  for
            disposable funds.  Granted,  some industry,  perhaps the  chemical
            and oil  industry in  the recent  past,  the last   year  and  a
            half, two years,  have experienced an improvement,  a  substantial
            improvement in  profits.   It  wasn't  too  long  before  that  I
            think that most  all  of  the  firms were  suffering  in   profit
            generation.

                Again, I  think  there are  reasons for  that,  possibly  an
            overburden of  regulatory requirements  that  soaked   up  their
            energies, their  resources,  their  time,  directed at,  in   many
            cases,  much needed  improvements,   but perhaps also  trying   to
            respond  to an overkill posture.

MR. FRANKEL:    Isn't industry aware of this  potential savings?

MR. MANAHAN:    We're doing  our best to  carry the  message to  them.  One
            thing that we've  started I think is  rather  unique.   It happened
            right here in Washington  as  recently as May  14  where we collec-
            tively with the  National  Bureau   of  Standards,  the  National
            Institute of Building  Sciences,  the  National  Insulation Con-
            tractors, the union itself,  that  is the Asbestos   Workers, con-
            ducted a  full  day  seminar/workshop   on  the merits  of    proper
            insulation  materials,   their  thicknesses, their   application
            techniques.
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            It, unfortunately, became,  in my  judgment,  more of  a  seminar
            than a workshop,  but at any  rate,  it  was fairly well attended.
            I think there were  something like  130,  perhaps largely  govern-
            ment personnel,   but  some  private  sector  people there.   The
            results were such that we  were  encouraged to  proceed  on with a
            like program to other sections of the country, and the planning
            committee has had two meetings  to program a  similar seminar/
            workshop for the  City of Houston,  probably  early next year.  I
            think  mid-February  is   being   looked   at  as  a possibility.

                The emphasis in the new program will be to try and get back
            to more of  a workshop technique where we engage, somehow,  the
            audience in  the  actual  problem solving techniques  that  will
            be demonstrated there.

MR. FRANKEL:    Are you  aware of the study by Bob Marley at  the DOE Policy
            Office, where he  argues that  of the  15 or  16  percent energy
            efficiency improvement by  industry only about 3 percent  is a
            response to  increased  prices.   The remainder  is  the  continua-
            tion of  trends  that  existed before  1973  when  energy prices
            were, in fact,  declining,  and  industry was still improving its
            efficiency by about  2 percent  per year, also of  switches by
            consumers to less energy intensive products  as the  more energy
            intensive products  become  more  costly,  also  a  switch  to more
            labor intensive  industrial practices  which are  less  efficient
            from a productivity  point  of view, but  use  less energy.  Thus
            only a very small fraction of the actual response that industry
            has made so  far can be attributed to direct response to higher
            prices.  Do you know about this study?

MR. MANAHAN:    No,  I'm  not  acquainted  with  that particular  study.  My
            associate handles DOE and  I don't have  that  much traffic with
            them personally.

MR. KAPUS:      Just one question of Mr. Esteves.    Early  this morning the
            implication was  advanced  that   the  probability  is   high  with
            some of the  cuts that a good  portion of the  state  energy of-
            fices are going to  be  eliminated.   From your perspective, what
            kind of an  impact,  if  any,  would that have  on your  firm if
            they were  eliminated  say   in  New  Jersey  and  Pennsylvania?

                Do you  rely  a  great  deal upon  interfacing  with them?

MR. ESTEVES:    No, we  don't.  The  state energy offices  to date in those
            two states have not  had a significant  impact  on the  public or
            the commercial  sector,  although the potential  for   assistance
            is significant,  and  has been.   To date,  I think the   results
            have been  relatively  small  compared  to  what   was  available
            prior to  that   in  the  legislative branches  through  the energy
            committees and  through  the  normal  regulatory   agencies  that
            were set up at  that  time.
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MR. KAPUS:      Thank you.

MR. FRANKEL:    Mr. Esteves, I  share  your distaste for Federal regulatory
            programs that overly  specify  what  a  state or another organiza-
            tion is supposed to do.

                In the  case  of the  weatherization program, there  are two
            problems that are often raised with the Administration proposal.
            One is that  it's one  thing to  fold  weatherization  into block
            grants, but then when you cut the block  grants  by 25 percent,
            and the  weatherization has to  compete with  existing programs
            for a  smaller pie,  it  seems to  many people  that  it's  very
            likely that,  in  fact, what you will  see  is quite  a lot less
            weatherization.

                The second problem with  the  overall block  grant approach
            is that  from time  to time states have  chosen to  take block
            grants intended  for  one purpose  and  use  them for something
            entirely different, such as  taking  a  block  grant designed to
            improve housing  in  low income  areas and build a  country club
            in an  upper middle class  residence.   It's that kind of abuse
            of these Federal programs that  leads to  these kinds of regula-
            tions.  So  my question,  I think,  is  how do you  deal with those
            two problems, with  the concept of folding weatherization into
            a block grant program?

MR. ESTEVES:    I believe the block grant  programs have review  procedures
            that are supposed  to preclude  that  type  of  activity  in which
            money in a  block grant is used  for items which  are not counted
            in the block  grant.   If  that  sort of activity is  taking place,
            and I'm sure it has taken place, the problem is  not necessarily
            in the  block grant procedure, because  that could  happen  in
            individual allocation procedures as well.

                As far  as your  first question is  concerned  about having a
            smaller pie,  that   is a  difficult  question.   I  do  not  like
            seeing the  weatherization program cut, whether  it be done di-
            rectly in terms  of a  25 percent  cut  in  a  weatherization line
            item or whether it be lumped  in with a number of other programs
            and all the programs cut by 25 percent.

                I think that whatever  its merits that it should be handled
            locally.  I  personally  believe in  a  weatherization program.
            I think  there are  some difficulties  with it  which I'd like to
            see corrected,  but  as I  say,  I believe in  it,  and my company
            believes in it very strongly.   I would not want to see anything
            that would harm it.

                I do,  however,  believe  that  the  decision  as to what  is
            most important for  the locality should be made by  the locality.
            We've had many instances  in which  block grants  that were meant
            for one thing were used  for police and fire protection.  That's

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            probably the  most   common  item  for a  misallocation  of  grant
            money in our part of the country, which is the greater metropo-
            litan New York area.

                I don't like that happening.   But it was certainly the deci-
            sion of  the  local  people  that  to  them  it  was  worth  more to
            spend money  on  that item, at least in the short  run,  than it
            was to  spend it on whatever the grant was  meant to  be  for.

DR. RIEGEL:     I would like to thank our final two  witnesses  this  morn-
            ing, Mr. Manahan,  and Mr.  Esteves.  It is now  the lunch hour
            and we will break,  reconvening again promptly at 1:00.  We have
            a roster list of approximately 10 more witnesses for the after-
            noon, and I look forward to seeing you then.

            (Whereupon, the meeting recessed for luncheon.)
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HEARING PANEL


   Gregory Ondich


   John Miilhone
                                                    PROCEEDINGS
                                                    JULY 15, 1981
                                                    AFTERNOON SESSION
Section 11 Program Manager
Environmental Protection Agency

Director
Buildings and Community Systems
Office of Conservation and Renewable Energy
Department of Energy
WITNESSES
   Randall Vosbeck

   Alan Rimer

   John Hark ins

   Carol Allen


   William Chandler

   Katherine Ellett

   Stanley Ezrol
American Institute of Architects

Management Improvement Corporation

Mechanical Contractors Association of America

N.3. Community Action Program
  Executive Directors Association

Environmental Policy Center

League of Women Voters of Maryland

Fusion Energy Foundation
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MR. ONDICH:     Good   afternoon.  My  name  is   Gregory   Ondich.   I   will
             chairing  the hearing  session this  afternoon.
                                                              be
MR. RIMER:
    We have  some  changes  for those  who  are  following  this
afternoon's schedule.   Dr.  Riegel  and  Dr.  Frankel  won't be
joining us on the panel,  but we are pleased to have  join  us Mr.
John Millhone who  is  Director  of  Buildings and Research  in the
DOE Office of Conservation and Renewable Energy.

    Those are the changes on the  panel.   As far as  the witnes-
ses are concerned,  we are also having some changes  this  after-
noon.

    As you can  see,  Mr. Rimer will be  one of our witnesses in
the first  session  followed  by Mr.  Vosbeck,  President  of the
American Institute  of Architects,  and Mr. Harkins representing
the Mechanical Contractors Association of America.

    For those  who may be  joining  us  this afternoon  for the
first time, I would like  to note the changes from the scheduled
witness list.   Both  Mr.  Manahan from  the  Thermal  Insulation
Manufacturers Association and Mr. Cady from the Mineral Insula-
tion Manufacturers'  Association  testified  this  morning,  and
unfortunately, Mr.  Roccapriore  from the  Solar  Power  Institute
will not  be  able  to  join us.   Likewise, we  will  have  some
changes later  this  afternoon.   I have  just  learned  that  Ms.
Habib from the  National Wildlike Federation  will not  be  able
to join us.   I  will  advise  you of  the  other  changes  as we
proceed.

    Now, I would like  to  start with the first group  of witness-
es this afternoon.  What  I  would  like to do is  follow the  same
procedure that  Dr.  Riegel  used.    We will have  each  of  the
witnesses present testimony, then we  will have some discussion
about that testimony  following all three witnesses.

    How much time do we have?
MR. ONDICH:     We would like to keep your comments to about 10 minutes, if
            we could, Al.

MR. RIMER:      Are you  looking at breaking this at say quarter to two  or
            something?

MR. ONDICH:     For your group we would like to finish the presentation and
            discussion in  about  45 minutes,  then another group  of three;
            breaking after that.  With that, why  don't  we start on the far
            right with Mr.  Vosbeck from  the  American Institute  of Archi-
            tects.

MR. VOSBECK:    Thank you.
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MR. ONDICH:     One more administrative thing — the microphone; you  might
            want to move the other one.

MR. VOSBECK:    Thank you.  I am Randy Vosbeck, and I'm  President  of  the
            American Institute  of  Architects,  and  I'm  also  a practicing
            architect in Alexandria,  Virginia.   Also,  today,  I am represent-
            ing the Passive  Solar  Industries Council which  is  an umbrella
            group of construction  industry  organizations  which are inter-
            ested in promoting passive solar building design.

                I'd like to  talk  to  you  a  little  bit about AIA's  and the
            passive solar building industry's  views  on some of the recent
            directions of  the Federal  energy  conservation  efforts  which
            appears to  be   guided  by  two general  principles:  The  first,
            higher energy  prices  will  speed up conservation  efforts:  and
            the second  that  the private  sector will  be  able  to  pick  up
            activities that were previously carried out by the Federal gov-
            ernment.  I'm  going  to  focus my  comments  on  two areas  of the
            Federal conservation program:  First,  information dissemination
            on buildings and  energy  use  to  the design profession  and the
            building community,  and,  second,  the  research  priorities  for
            improving the energy efficiency in buildings.

                These two  areas,  information  dissemination  and  buildings
            research, are  beginning  to feel the real  impact of  these  new
            Federal directions.   First,  let  me comment   that  since 1973,
            our AIA members, architects throughout the country have report-
            ed a  perceptible  increase  in the  number of  clients  who  are
            concerned about  energy  operating costs  and  are  demanding that
            buildings be designed to use  less energy.

                Now, obviously there are  several reasons  for this.   First,
            obviously higher energy costs have a significant impact.  Addi-
            tionally, the availability and use of better technical informa-
            tion by   both  building   designers and  clients  has  helped.

                And, lastly, designers  and owners  have,  I think,  a  genuine
            concern for the impact on our nation's economy of the diminish-
            ing supplies and increasing demand of fossil fuels.

                Most building designers can  show their clients the economic
            benefits of more  efficient  buildings.   Many design profession-
            als can now  tell  clients the payback  periods  for a variety of
            design options,  and,  in turn,  clients  use  this  information
            when making their investment  decisions.

                We feel  that most  of  this  information  and most  of this
            capability is  a  direct  result of  the  Federal energy  conserva-
            tion program.   Five years  ago,   such  terms  as  energy audit,
            retrofit, thermal  mass,  solar access,  daylighting,  life cycle
            costing were not commonly used terms in the design and building
            industry.


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    This information  flow has  speeded  up  innovation  in  the
building industry; design manuals,  seminars,  computer programs
provide tangible  design  information  for designers  willing to
try new  solutions.   This design  information and  criteria  are
important to encourage building design innovation by architects
and engineers.

    However, we  know  that  the trial and  error  approach is not
appropriate for the building  industry.   A building constructed
with an  energy  approach  that  is  not  based on  proven design
criteria and  then non-functional   cannot  be thrown  away.   You
can't throw away a building.

    The Federal  program  has  both  speeded  up  the  transfer of
information as well  as increased  the  availability of  it.   We
know that  this  information  has   produced  a  better  informed
design community  and a  better informed  clientele,  and without
a question,  this  is  yielding  a   better stock   of  buildings.

    Unfortunately, we now  find this information  flow about to
be cut  off.   Funds   for  seminars  and  conferences have  been
severely reduced,  and  the  printing and  availability  of  most
publications has  been eliminated.   Now,  of course,  industry
will be able to pick up some  portion of these information disse-
mination activities.  My own organization,  the  American Insti-
tute of Architects, has begun an unprecedented energy education
program called  the  Energy   Professional Development  Program,
and the AIA is spending about a dollar  out  of every $12 of our
membership dues on this  program, about a million dollar program,
to educate  and train our members  on energy  conscious design,
and we'd  like to point  out  that  our energy  education program
is a  direct   out-growth  of  the  AIA  research  corporation's
participation  started  back   in  1976  in  the HUD/DOE buildings
energy performance standards program.

    While building a  base for  a  regulatory program,  we found
out how  to increase  the proficiency  of architects  to design
energy efficient  buildings.   We plan to reach over 8000 design
firms with this energy education program.   Our current schedule
calls for  about   200  educational   seminars   in  the  next three
years.  But  I think  it's important  to  point out,  and  we  want
you to know that  there are many types of  information activities
that the  AIA   or  other segments  of  our industry  just  cannot
take over.

    We cannot  reduce  large   scale  computer  programs  such as
DOE-2 and BLAST into simulation programs  for hand-held calcula-
tors that  our  small practitioners  so  urgently  need, and   I
really don't  think the computer  industry  is going to provide
this for  us  either.   We  cannot educate the banking and  invest-
ment communities  about the benefits  of  energy efficient build-
ings, and  this is desperately  needed.   And we  cannot  conduct

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valuable research  on  materials  and building  systems  that  we
need to improve energy efficiency — which brings me to my next
point of concern.

    The next generation  of  energy  and  building research, — as
we understand it,  the  new directions  of  DOE  call  for  a basic
R&D approach  for  building  products  and  components  with  the
primary emphasis on long-term high risk  research  with unknown
potential benefits and less  emphasis  on demonstration,  commer-
cialization and understanding the performance of occupied build-
ings.  We understand that most  all research projects have been
eliminated that have potential  to  help the industry  solve its
short and mid-term problems.  Now,  as an architect and a build-
ing designer, I'm  dismayed  when I  see  that this  high risk em-
phasis has eliminated  many  ongoing research projects,  many of
which are  close to providing solutions  to  technical problems
that the industry cannot solve itself.

    I question  the  economic  efficiency  of turning  off poten-
tially beneficial  projects  in midstream.   The  entire building
industry is  made  up for  the most  part of small  firms.  Most
architectural firms, for example, contain nine  or fewer members.
These small  firms  will  not  be able to  pick up the  integrated
research on  a   national  scale that  has  characterized  much of
the Federal  buildings  research.   A design  firm  cannot  go to
product and  component  manufacturers  and  ask   them  to  provide
coordinated  research for materials and  systems.

    The building industry  just cannot underwrite national  pro-
grams on  energy performance  in  buildings.  We  cannot  instru-
ment and  monitor  the  performance  of  a  nationwide  sample of
occupied buildings.  We  will not be able  to advance  the metho-
dology of  estimating  the energy performance of various design
options.

    We must  stress that, in  spite of the  construction, indus-
try's annual contribution of  about  $127 billion to  our  nation's
economy, we're  a very diverse  and fragmented  industry, and  I
might add,  the  construction  industry  is quite  soft  right now
in many parts of the country.

    We all  know the  state of the housing  industry  and  high in-
terest rates have  slowed commercial and industrial  construction
as well.  We should not expect our  construction industry to  pick
up this  additional burden.    I believe  that one result  of  less
federal  involvement in the development of computer programs will
be the proliferation of proprietary computer programs  that  model
and  estimate energy performance.  One large development and con-
struction  firm  has already  developed  an innovative  program that
predicts  energy performance.  They sell  its analysis through  a
service  to  other  design  firms.   This  practice means  that the
user will  always  be dependent on the  service and unlikely  to

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learn the effects  of his design decisions  on  the program out-
come.  One  of  the  greatest needs  of the building  industry is
to understand how  effectively to retrofit  existing buildings.
Both residential and commercial projects are  needed.   80 per-
cent of the  existing building stock will still  be  here in the
year 2000.   Effective  retrofit  is  a most difficult  problem for
designers.  Retrofit  options  are frequently  in  conflict  with
fire and  safety  codes.  To meet  all the conflicting  codes is
frequently a very  time  consuming  and expensive proposition and
existing tax credits are not adequate  incentives  for building
owners to take on  this capital intensive venture.

    It's our assessment  that  DOE  has not yet  begun to scratch
the surface  in encouraging  retrofitting of existing buildings.
Without some continued  Federal assistance,  building designers
will not  be able  to solve  the problems that  accompany energy
efficient buildings.  The  interior  air  quality  of  super-in-
sulated buildings  and the  psychological effects of buildings
with fewer  windows are  just  two  of the problems  that require
additional investigation.

    I wish  I could  be  optimistic that  the  new program direc-
tions would  create new  opportunities   or  efficient allocation
of the  remaining resources.  However,  we  question the wisdom
of allocating the remaining  Federal funds to high risk projects,
especially when  some  short-term  studies  need  just   a  small
amount of additional assistance to conclude them.

    How can  the  Federal government  help during  the period of
transition?  My  answer  is   simple.   Let the  building industry
assist you  to  allocate the  remaining  resources  to  problems
that really  need  solving.   We believe  we  know best  what  kind
of research  and  information  is  needed   to  provide  more energy
efficiency.

    We're willing  to accept  a  leaner   Federal  budget, but  we
must voice  our  strong  concern about  the   few  remaining  funds
going to uses  that may assist us five  years  or further in the
future, particularly  now when  the  entire  industry is lacking
vitality.

    Allocation to  industry  priorities  will  help us get through
the slump  until  the  industry is  on the  upswing  and  able to
begin to  take  on  more  responsibilities.   So  as  the American
Institute of Architects' current president  and as  an architec-
tural practitioner,  I'm less  than optimistic  about the abili-
ties of a  fragmented industry  such  as  ours  to carry  out  the
components of a  successful  research program that would provide
architects and  engineers with  the   tools  and  the  information
they need to carry out energy conscious  design.

    Therefore, I'm asking you to  consider  our priorities  for a

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            redirected program, coupled with industry effort to push energy
            efficiency forward, a limited amount of Federal assistance will
            enable us to  move toward meeting  the  goal put  forth  by DOE's
            Solar Energy Research Institute, that is a reduction of 30 per-
            cent by the  year 2000  for  energy use  in  the environment.  Do
            not let the  lack  of  information and  new research  impede the
            building industry  from attaining  this important  goal.   Thank
            you.

MR. ONDICH:     Thank you, Mr. Vosbeck.  I recall your assistant telling me
            that you had to leave early.  Is that still the case?

MR. VOSBECK:    Yes.

MR. ONDICH:     I will make a  small change in that  regard,  particularly
            since you mentioned  this  about a  week ago to  me, and  ask if
            Mr. Millhone would have any questions of Mr. Vosbeck?

MR. MILLHONE:   I appreciate the  thought that was  given to  your prepared
            remarks, and the  suggestion  of  closer cooperation in determin-
            ing the use of funds that are available and think that's a con-
            structive suggestion  that  DOE  should  look  at  right  away.

                I had just  one  question that  occurred to  me.  In your dis-
            cussion of the importance of focusing on the retrofit of exist-
            ing buildings, do you see the need  there as primarily one of re-
            search or of  information dissemination  or  one of financial in-
            centives?

MR. VOSBECK:    Well, Mr. Millhone,  I think that a balance  is  needed.  I
            think that we  must have some financial  incentives,  — and the
            financial incentives  obviously  to the  building  owners for the
            most part.   Building  designers though  are faced  with needing
            some research  on  just  how  to approach  the  redo of these build-
            ings that were designed,  you know,  20, 30,  40  years  ago with
            no energy efficiency  in mind,  and  just how  to  accommodate an
            efficient mechanical  system into a  building  shell  that  is not
            designed for  it,  how  to diminish window  sizes,  how  to do some
            of this retrofitting  within  some  of the  life  safety  code re-
            quirements we  have now has  gotten  to  be  a  major  concern for
            many architects around  the  country.   So I think it's sort of a
            combination of  the three things that are needed.

MR. ONDICH:     I just have one question.   When you suggested the building
            industry assist  the  federal government   in  the  direction  of
            future research, what mechanisms would you recommend?

MR. VOSBECK:    Well, I don't know  that  I've got a  specific  answer on  that,
            but it  seems to me that there  is  not much of a communication
            dialogue now  between  most  of  the industry  and  DOE.    Somehow
            we've got to,  I think, start  talking to  each  other more than
            we have been of late,  so  that  we  can — so  you  can  hear our


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            concerns, and  we  can hear  yours.   But  as  to a precise mecha-
            nism, I don't know that I have one other than just start estab-
            lishing a communication dialogue.   It's  not now existing other
            than in meetings like this,  and  this  is  one of the first, and,
            you know, I  hope  that  we  can expand  on  this  kind  of a meeting
            in a less formal  way and  really sit  down  across the tahle and
            talk about  some  of  our concerns with  the  appropriate people.

MR. ONDICH:     Thank you.  With that, I would like to move on to  the  next
            witness, Mr. Alan Rimer, from MICA.

MR. RIMER:      I'm Alan Rimer from the Management Improvement Corporation
            of America in  Durham,  North Carolina.   I'm  Senior Vice Presi-
            dent of the division that  deals with energy studies and identi-
            fies energy   conservation   (cost reduction)  measures  for our
            clients in both the public and private sectors.

                In March  of  1981,  of  this  year,  the Department  of Energy
            outlined in  their  public  discussion  package  for  the national
            energy plan a  statement which I think is key to the testimony
            that I'd like  to  give,  and that is that  the  government's role
            is to establish sound public policies which are based on econo-
            mic principles and national  security  concerns and  a due regard
            for environmental  value,  so that individuals,  and this is the
            part I'd  like  to  emphasize,  and firms in the private sector
            have the incentives  to  produce  and  conserve  energy efficient-
            ly.  This should  all  be  consistent  with the  national energy
            policies.

                So the objectives  of  this testimony that  I'd  like to give
            are threefold.  First, is  to offer a private  sector company's
            perspective on some  of the  issues  which affect the development
            and implementation of a functional comprehensive energy conser-
            vation program which is an integral part of the national energy
            plan.  Also to offer some recommendations  on the  government's
            role in  conservation given  the  changing  funding  environment.
            And finally to discuss very briefly what our firm has  done to
            assist public  and  private  sector  clients in  the  conservation
            effort in light of some of  these changes.   I believe this will
            highlight some of the problems that are inherent in the program
            now.

                I personally view conservation  of energy as an increase in
            productivity utilizing a  finite  set  of  energy  resources,  and
            on that  basis,  an increase  in  productivity  for a  private  or
            public sector  organization  results  either  in  more  profit  or
            lower taxes  with  the same  capital  and personal resource base
            available.

                So in this context,  energy  conservation  really  has  to  be
            viewed as an investment in the future value of  society without
            sounding too high-falutin'.   It's our view that the purchasers
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of conservation  programs,  whether  they're  public  or  private,
really lack sufficient  incentives  at this particular  point in
time to employ energy  conservation  measures  at  a  rate  which is
consistent with what  the  DOE and the national  interest  has in
mind at the present time.

    Our firm believes  that  private  firms  in partnership  with
state and the Federal  DOE's  can do much to  speed  up this  con-
servation awareness.   There's  been a  lot  said in  the hearing
about the role  of  government  in  conservation.   Daily, we in
the private  sector  are  exposed  to  ever  increasing  energy
costs at a time when  energy  supplies are dwindling.  Conserva-
tion is no longer a luxury,  obviously,  but  rather a staple ne-
cessity for our very existence.

    From a private  perspective, we believe that  the  Federal/
state conservation  efforts  have  some   short-comings,   one  of
which is  a  lack  of  a central  energy  conservation strategy.
Most aspects of the program, except possibly the weatherization
assistance program  and  the solar information network,  are not
results focused.  The program emphasis tends towards regulation
and paperwork instead of problem solving.

    We believe that a simple transfer  of  conservation  activi-
ties to the states  is not  going  to  promote energy conservation.
Why?  Because we personally  experience  impediments at both the
Federal and  state  levels  with  respect to  implementation  of  a
rational conservation  program   for  both  public   and   private
clients, the public being local governments whom we deal  with
almost exclusively.

    In the  past,  the  Department   of  Energy  has  treated the
conservation program  almost  as if  it was  a stepchild,  and has
been slow  to  formulate policies that are  consistent  with the
overall mission of  DOE.   These  problems, of  course,  have ameli-
orated in  the  past  couple  of  years.   However,  the  undertain
funding and future  of DOE has  promoted  a  new  round of  skepti-
cism among  both private  and  public  entities.    Where  are the
programs going?   In  this  hiatus,  people  are  postponing  deci-
sions  on  conservation  programs.   This  undesirable effect has
significant national  ramifications primarily in the ineffective-
ly used energy  resources.

    As with  any organization, direction must come  from the top
and pass  through the  organization.   Inducements such  as grants
are slow  to filter  down   from  DOE, through state  governments,
to the client.   As  an example,  one  of  our  recent  clients,  a ma-
jor hospital  in our  region, was  approached to have  an energy
conservation engineering  study done for  them by our firm.   Some
 18 months  elapsed before the study  was  undertaken.  The hospi-
tal stated  that money was  probably (as  it  subsequently  was)
forthcoming  from a  DOE  program to  complete   the   study.   The


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study fee was slightly more than $29,000 and when the study was
completed, it identified  first  year  savings of nearly $229,000
in energy costs, with implementation  costs of slightly less than
three quarters  of  a million  dollars.   Further,  a  few minor
changes in their  existing energy management  system would have
resulted in immediate energy savings which would have more than
paid for the cost of the study  in less than 5 months.  But they
waited, and in  waiting, they  suffered in terms of the expense,
and so did the  nation  in  a sense.  The  point  of this simply is
that the  Federal  and   state  programs  offered  impediments  to
exactly what we're  trying to  do and  that's  to conserve energy.

    The states  are  slow  to  respond  too,  because  they're  not
sure that their own initiatives are  going  to be  in line with
what the Federal government has in mind.  They can only respond
to the Federal  mandate when the Federal folks  understand what
it is that they want.   That often means that  the  state cannot
effectively manage  even their  own  programs,  because  they are
not sure how they will interface with potential or proposed gov-
ernment programs.

    The moral  that  I'd  like  to  draw  from these  examples  is
that we  believe  a  framework  is  necessary  for  conservation
activities which  involves  not  only  the  DOE  and the  state agen-
cies, but has the input of private firms,  not  unlike Mr. Vos-
beck with the AIA and  with the Mechanical Contractors Associa-
tion, etc.   We  believe that  with those groups,  participating
in a partnership  with  the private sector,  and  with the proper
incentives for  energy  conservation   offered,  can  go  a  long
way towards at  least beginning  to implement nationwide some of
the programs.

    We believe  that there is little  to  be  gained  by shifting
programs between  governmental  agencies  (Federal  and  State).
An increase in  the  involvement  of local communities  and private
sector companies  should be fostered  because  of  the profit mo-
tive is a strong  incentive to produce results in a  competitive
marketplace.   Local  governments  are closest to  the  problem
(need) and can  work closely  with private  business  to achieve
energy conservation.

    I have some very  specific  recommendations which  I'll end
with.  They're divided into three different  parts, the Federal,
the state and the local governments.  MICA  believes that while
education of  public officials  and  private  customers   on  the
vast potential  for  conservation techniques   can  impact  very
significantly on  their particular economic picture,  they need
the proper incentives  to   follow  through with  their programs.

    In the private  sector, such incentives  might take the form
of increased tax incentives and/or tax credits where applicable.
In the public sector,  such incentives  might  take the  form  of
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grants for good projects after implementation.

    Specifically, steps the federal government  should take in-
clude:

    - Define the  conservation program's  goals  and  objectives.

    - Provide dates for implementation of various facets of the
      program and then stick to them.

    - Provide tax incentives  for energy  work  -  studies as well
      as equipment.

    - Expand research  and development funding  (through direct
      grants) to   private   organizations and  individuals.

    - Allow  for  patents to be retained  by  investors  under the
      appropriate technology programs.

    - Provide  for personnel  transfers  from public  agencies.

    - Convince the President and Congress to provide the neces-
      sary funding.

    - In  short,  be consistent with the  initially stated goals
      and policies.

    State governments should take these initiatives:

    - Tax   incentives   for   energv   conservation   measures.

    - Have State Clearinghouse for energy information - send to
      local governments.

    - Establish  community  wide load  shed blocks for block  con-
      trol of demand and usage.

    - Establish  community based energy task forces to assist in
      energy conservation measures.

    Local governments,  where   we  believe most  of  the initia-
tives should be  taken,  should  take these initiatives:

    - Establish  energy  offices at the local level.

    - Offer property tax breaks for energy efficient structures.

    - Remove  code restrictions which impede  conservation  mea-
      sures.

    - Establish  community programs which  help in the area  of in-
      formation  dissemination.


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    We also  feel  community-based energy task forces  should be
established where that's practical to assist  in  energy conser-
vation  measure  definition  for   that   particular   community.

    MICA is an example of a private sector firm,  which from its
founding, has  addressed  the  question  of  energy  conservation
from an economic viewpoint.  MICA, as a corporation, identifies
productivity improvement  ideas   for  clients  (both public  and
private) in all  sectors  of the economy.  One of  the  company's
services, the TEMP Service (Total Energy Management Program) is
offered to public and private clients including:

   *  Communities                 * Housing Authorities

   *  Office Building Owners      * Private Colleges

   *  Condominiums                * Shopping Malls

   *  Nursing Homes               * Hospitals

   *  Motels                      * Hotels

   *  Industrial Plants

    TEMP is a comprehensive energy conservation and cost reduc-
tion service which  is results oriented,  profit  motivated.   In
the TEMP program, MICA uses  a staff of professiional engineers
to examine  a  prospect's  facility through the use of  a  "walk-
through" survey to  identify  what can be  done to reduce energy
consumption by  identifying energy  cost reduction  potentials.
Such potentials  range from  changes  in the  building  envelope
(insulation, insulating glass, etc.)  to energy management sys-
tems to control electrical demand and consumption.  Once poten-
tial corrective measures  have been identified,  MICA  will pro-
pose to the client  identify  and  describe corrective actions to
be taken.  Another alternative is for the client  to sign a TEMP
Service Agreement  to  install an  energy conservation measure
such as an energy management system.  In the latter arrangement,
MICA provides the client with a turn-key package for each ener-
gy conservation measure or for all  of the measures grouped to-
gether.  This package includes the necessary engineering design
work, equipment, supplies,  and installation  labor.   In  short,
MICA identifies, initially without  charge,  the  client's energy
problems and then provides a  total solution for that identified
problem.

    MICA brings  certain  important attributes to this program:

    -  MICA's staff is comprised of registered professional en-
       gineers with  specific  experience and training  in energy
       conservation.
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                - MICA does not manufacture, sell, or distribute any equip-
                  ment.  Thus, MICA  is  able  to  eliminate  vendor bias which
                  allows them to custom fit  equipment to  a particular cli-
                  ent's needs.

                - MICA  provides  the TEMP  service  on a  turn-key  basis.

                - MICA guarantees  to produce energy  dollar  savings  in ex-
                  cess of  the   cost   incurred  for  the   implementation.

                - MICA can  arrange  complete  third  party  financing  of the
                  TEMP service packages.

                The results oriented approach of MICA permits the client to
            see the results (to which everyone has contributed some portion
            of the  effort).   For private  sector companies,  the decreased
            energy costs from  ECMs  result  in higher profits.   For public
            sector clients, decreased  energy costs result in lower taxes.

                A well thought out and  implemented  energy conservation po-
            licy will significantly  stimulate the  goal  of energy independ-
            ence with the proper mix of private and  governmental programs
            to aid the implementation.

                In summary, we believe  that  there's little to be gained by
            shifting programs  between  various  governmental  agencies.   We
            really honestly  believe  that  there  needs  to  be  developed  a
            very strong partnership  between the  Federal,  state  and local
            governments as well  as  consultants  and  that   we  take  that and
            move with  it  and  the  existing  programs of   DOE  into  a  more
            rational basis for conservation into the year 2000.

MR. ONDICH:     Thank you.  Next  is  Mr. John Harkins representing the Me-
            chanical Contractors Association.

MR. HARKINS:    Good afternoon, Mr. Chairman and members of the panel.  The
            Mechanical Contractors Association,  known as  MCAA, appreciates
            this opportunity to comment regarding the national energy poli-
            cy.

                I'm John Harkins,  a  mechanical  contractor from Lansdowne,
            Pennsylvania.   I'm  also  the  Chairman of the  National  Energy
            Committee for MCAA as well  as a director on the national board.

                MCAA is  a construction trade  association  of  about  1700
            firms, employing  approximately   180,000  persons.   Our  members
            build systems that move  fluids,  both liquid and gas.  This in-
            cludes the fabrication and installation of heating, ventilating,
            air conditioning, plumbing  and process piping  systems, and fur-
            ther encompasses service, maintenance  and the testing,  adjust-
            ing and balancing  of these  systems.   Our work  affects  multi-
            residential,   commercial,   public  and  industrial  facilities.
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The equipment  MCAA members  install  is  the principal  user of
energy in  buildings,  and  energy  is  the  key to  our industry.
Consequently, we are deeply concerned about conservation and  the
effective use of our nation's fuel  resources.

   Although the United  States has  begun  to improve our energy
position since the Oil Embargo of 1973, this nation  still faces
serious problems in our energy supply and  demand.  MCAA has  had
an Energy Committee even before the OPEC embargo.  This Commit-
tee has worked  to educate  our  members .on the  nation's energy
problems and  what  they can do  to  promote energy conservation.
We have done this through  such  measures  as newsletters, bulle-
tins , reports and  a series  of  educational  seminars and work-
shops.  MCAA  also participates  in the  standards developments
process and inter-association and government activities related
to energy.  We believe firmly that  the resolution of our energy
problems requires a governmental and industry teamwork approach.

   The present  policy  of  the Reagan Administration to reduce
government intervention  in the energy  area and  encourage  the
free enterprise sector to develop sources  of energy  is  commend-
able.  There is no single answer to our energy problems.  It is
still necessary  for  the Federal  government to take action in
certain areas.  Our energy problems can  only be solved through
a broad undertaking — by working in  many  directions at once —
on a planned and phased basis.

   The opportunities in  both the public and private sector in
the energy field are  enormous,  and  many  businesses are seizing
them.  However, to be effective the national energy  effort must
be focused, guided and well-coordinated.

   As an association, MCAA has  developed  recommendations for a
comprehensive national energy policy, which is enclosed  with our
written statement.  (This report was  reviewed,  but not  included
in the Transcript due to its  length).  In the  interest of time
I will  not  cover  the  entire plan, but   comment  on  one facet
that we consider  essential to any  practical energy program —
and that is energy conservation.

CONSERVATION

   Conservation of energy in residential,  commercial and indus-
trial buildings,  in  appliances  and  in  transportation  is  the
most promising immediate, relatively untapped source of energy.
It is the cheapest, most environmentally  safe  and most produc-
tive method of increasing our nation's energy supply.   Signifi-
cant conservation can take place  in the  transportation sector,
but it is in  the  buildings that the  most  savings  can be made.

   Estimates show that our energy  usage  could  be  cut  between
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30 and  50  percent through  effective  conservation  measures in
buildings with little  or  no change in  comfort.   Existing com-
mercial and industrial buildings can be retrofitted (renovated)
to be much more  energy-efficient.   These  savings can amount to
a reduction of more than 3 million  equivalent  barrels of oil per
day.  In addition, energy  conservation  can  reduce energy costs
to consumers considerably.

   The commercial  building sector  alone  uses approximately 16
percent of the nation's  total  energy consumption.   Our nation
has an inventory  of  24 billion feet of floor space in commer-
cial, institutional and other buildings, many  of which have been
overheated in winter,  overcooled in summer, and overventilated
and lighted year  round.   Experts  agree that  these buildings,
on the average, waste  between  40 and 50 percent  of the energy
consumed.  Therefore the savings can be substantial.

   In addition, conservation means  immediate savings in energy.
Much of  the  engineering  knowledge and  technology for  making
existing buildings more energy  efficient currently is available.

   Conservation is not just a matter of installing more insula-
tion and  double   glazing  windows.   There  are  other  important
areas involved, such  as  the efficiency of  heating  and cooling
equipment, proper temperature control equipment, and more effi-
ciency of heating and  cooling equipment, proper temperature con-
trol equipment and more efficient means of lighting.

   A major problem is to convince building owners to accomplish
energy conservation.   In  this  vein,  MCAA  seminars in  recent
years have stressed procedures  and  techniques  to assist our mem-
bers to market energy conservation  work.  The practical experi-
ence of our members is that building owners need to be assvired
an adequate economic return on their investment — or a payback
within 2-3 years.   In  some cases the necessary payback is possi-
ble and  can be shown  through  proper engineering calculations,
but in many cases  even the present  prices of energy  are not suf-
ficient inducements.

   This industry  has  been dismayed bv  the  current  shortage of
accumulated capital by manufacturing companies  and real estate
investors.  Of monies  which are available  for  capital invest-
ment, particularly in  the  industrial sector,  large  amounts are
being allocated to meet stringent  requirements  for air and wa-
ter pollution control.  Although practical standards are neces-
sary from a social view, expenditures for impractical standards
do not contribute in a real sense to growth of industrial capa-
city, which in turn, produces more  goods and  jobs.

   We heartily agree with  the Reagan Administration's actions in
reviewing existing  standards  and legislation and  strongly en-
dorse Administration efforts to reduce  or repeal those that are


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impractical and unrealistic.   The  barriers to conservation are
therefore not technical but economic, social and political.  To
overcome these barriers, we need  a strong government policy that
advocates and fosters conservation.

RECOMMENDATIONS ON RETROFIT APPLICATIONS

    Retrofit Applications.  To assure that immediate  steps are
taken to conserve energy in existing buildings and that the ne-
cessary monetary incentive for owners is available we recommend
the following:

    1.  Residential Energy Conservation.   The incentives pro-
vided homeowners under the National Energy  Act should be expand-
ed.  They should preferably include  reimbursements  or tax cre-
dits up to 50 percent of retrofit costs (with rebates for lower
income groups)  to  install energy   conservation  improvements.

    2.  Commercial and Industrial Property, Energy Conservation
Program.  Because  of  the  diversity  and the  extent  of energy
that can be saved  in  the  commercial  and industrial  sectors,  we
strongly recommend  that  incentives  under  the  National Energy
Act be expanded to incorporate:

    a.  Tax credits of 40 percent of retrofit costs.

    b.  Low interest  loans  to  owners,  builders,  and developers
        of commercial property and  industries for  energy con-
        serving measures in new  as  well as existing buildings.

    c.  Loans to owners, builders or developers for engineering
        studies to determine the  cost-effectiveness of proposed
        energy-saving changes in buildings and  systems  of com-
        mercial and industrial establishments.

    d.  A system of rebates for each barrel of oil or the equi-
        valent in natural  gas  or electricity  saved  in commer-
        cial and  industrial  establishments  through  retrofit
        and other conservation measures.

    The measures outlined  above  are covered  in more  detail  in
the MCAA "Recommendations for a National Energy Policy" enclosed
for the record with this  statement.   They will significantly im-
prove our nation's  energy posture.   The  great advantages of this
plan are that:

    It encourages  conservation of  energy  in  a manner that can
    be quickly instituted  and  will produce an almost immediate
    payoff in fuel saved.

    It relies heavily on public encouragement  of and cooperation
    with private industry; and
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                It encourages the private sector to become deeply involved.

                MCAA considers  these  governmental  incentives  to be  short
            range, transitional actions.   In  the long range,  rising costs
            of energy will  bring  economic forces into full play and people
            will conserve  energy  because  of  its  high price  alone.   Even
            now the nation  is  consuming  energy at a lower rate  than 3-4
            years ago.   Temporary governmental  incentives  will accelerate
            the process  until  the market  place can  take  over completely.

            EDUCATING THE PUBLIC AND GARNERING SUPPORT

                A primary and perhaps the most  important  step in resolving
            our national energy problem is  to convince the American public
            that a national energy problem does,  in  fact, exist,  that  it
            is serious,  and that  they are  the key  element of the solution.

                A major  national  public relations  should be  initiated  to
            educate the  public  on the  energy  problem  and its  solutions.
            It should be dynamic,  sustained, imaginative and a central part
            of any national effort.  The  educational  program  is a task for
            both the  government  and  private  sector  working  in  concert.

            CONCLUSION

                This nation can delay no  longer  in  squarely facing our ex-
            tensive energy  problems.   We must  recognize  that  each single
            solution is  needed  and has  its place.   However,  we should de-
            termine the  most  promising, practical  approaches and  concen-
            trate on accomplishing them rapidly and  effectively.   The na-
            tion can and must  reach a  consensus by  bringing  all  factions
            and single answers into a cohesive, multifaceted and long-range
            plan.  Only  a  determined  approach  will  overcome  the  problems
            facing us, make us  energy  self-sufficient and able to continue
            our strong role as a world power.

                MCAA recognizes  that   this  program  calls  for  government
            involvement, including financial  incentives at  a  time when the
            Administration  and the country are calling for less government,
            less federal spending and no inflation.  MCAA strongly endorses
            those worthy objectives and believes that our proposals in the
            long run will aid in their achievement through increased employ-
            ment, decreased balance  of payments and  reduced  dependence  on
            foreign oil.

                Thank you  for  this  opportunity  to  comment.    I  will  be
            pleased to respond to any questions.

MR. ONDICH:     Thank you Mr.  Harkins.    I  would  like to start out with a
            question of  Mr. Rimer.  We  heard  this  morning from the Thermal
            Insulation Manufacturers  Association,  some  distressing inform-
            ation.  They did a  survey of  500 industrial  firms to determine


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            the level of  insulation use.  What they learned was that these
            500 plants were  not  insulating as you might expect with rising
            energy prices.

                In your experience  have  you found the  same results and is
            there any  reason  to  believe  a  residential  survey would  be
            significantly different?

MR. RIMER:      We don't do work in  the  residential  area.  We do in the
            industrial area.   We  do in residential as  it  relates  to doing
            block control in  smaller  communities,  but the residential work
            is not  as it  would  be for  small  air   conditioning  systems.

                In the industrial plants,  we do do a  lot  of work, and the
            problem, I think,  has been faced very squarely by Mr. Harkins
            and by  the  testimony  this  morning.   The  incentives  these
            industries think  they  need  are  either  tax incentives,  some
            form of tax incentive, a tax credit  or some other means to get
            that payback down  in  the two to  three year  period which we're
            finding most of these people need.

                Insulation sometimes takes  anywhere  from two to five years
            to pay back depending on the installation.

MR. ONDICH:     I believe they were talking about 30 months.

MR. RIMER:      Well, that's  kind of  in the  midband there.   We've found
            some that have  extended as long  as  five years,  some  that are
            two years.   These people  need  something  that  will  pay  that
            back more  quickly.  A  credit  could, of  course,  accommodate
            that.

MR. ONDICH:     So you do not think the rise in prices is sufficient?

MR. RIMER:      Not now,  very  definitely  not.   We're  working with Duke
            Power in  their  service  area in  the  conservation effort with a
            number of plants,  and Duke's a  very  efficient utility.  It has
            fairly low  rates, but  the industries in that  area  are very,
            very hesitant.   Their capital  resources are  very, very  thin
            right now.   They  need  to spend it  to  upgrade their product
            lines in  order  to  become  more  competitive   at   the  product
            level.  So retrofitting  their  HVAC system  or  insulating steam
            lines, it's  a very  low priority, in  spite  of the  fact  that
            that  energy   cost  is    really  affecting  that  bottom line.

                They need to get  it  down  below a two-year payback in order
            to feel  comfortable.  Apartment owners are worse,  a year  to a
            year and a half  for them,  and  that's across the board.  In New
            York City, in particular,  we're finding  they  don't want to do
            anything unless  it  will pay back in 12 to  18  months; there's
            no interest.
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MR. ONDICH:     I would like to move to Mr. Harkins for a second  question.
            Since you are a national  organization,  do  you  see any regional
            areas, the Northeast  or the mid-atlantic  states  where some of
            these industrial firms  may  be  picking up conservation measures
            because they are more  directly affected by fuel prices than in
            other parts of the country.

MR. HARKINS:    Well, the industrial section is picking up much more rapid-
            ly than  the  commercial  section,  and  as  for  regions  that  it
            would be picking up  in, it would be  basically climatal effect
            as I  know it.  The  Sun  Belt  wouldn't  be as  influenced,  and
            sure, the incentive  would  not  be there as  greatly as it would
            be up in  the Northeast  section in the  case of  insulation or
            heat loss, that type of thing.

MR. MILLHONE:   I have a  question that  occurred to me sort of  combining
            input from both of  the witnesses.  One was  the comment by Mr.
            Rimer about the audit that cost $29,000, if I remember correct-
            ly, with  a  four-month  payback  and  management   savings  that
            would, in  terms  of  just the  operation and maintenance,  that
            would pay for itself fairly quickly and then provide additional
            savings from the  retrofit.   I think  that  we are  all familiar
            with similar  instances, maybe some  not  as dramatic  as that.

                The other point  that was  made  is  that the  hope  of  some
            sort of  Federal  incentive might  cause  people  to forego action
            waiting for the  Federal financial incentives  to  be sweetened.
            This might cause the hesitancy of building owners  or industrial
            plant owners to take  actions that already  would provide fairly
            significant savings.

                The questions that  occur,  I  think,  to anyone hearing this
            is why  isn't more   retrofit   occurring  immediately  with  this
            kind of potential, and,  secondly, is  there a counterproductive
            effect of discussing  enriched  Federal  financial  incentives in
            leading people  to  forego  things  that  they  ought  to  be doing
            right now based on the present financial incentives?

                If either or  both  of  you  would  like  to  comment  on that.

MR. RIMER:      Do you want to start?

MR. HARKINS:    Okay.  I hope I don't   take   up all the time.   Well,  I'll
            let Mr.  Rimer  address the  counterproductive thing, because he
            experienced it.   We  have experienced it too,   and we're aware
            of his sample.

                As we  find   the  marketplace  in  the  commercial  side,   the
            ability to  pass  through the cost leaves no incentive for  the
            commercial owner  of  real estate  to upgrade  this  system.  With
            investors on the industrial side, everybody is  profit-oriented,
            and you  must turn  a  profit,  or who cares about three years


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            from now.  If we  don't make  a  profit  in  the corporate structure,
            we don't  move up,  or  our  corporation doesn't  have  earnings,
            etc., etc.

                So the  guys  who really  get the attention  are  the fellows
            who can produce the widget hy taking funds from the corporation
            and making  the  widget  go out  the  door properly.  Many times
            they have tax incentives  themselves, equipment, building, depre-
            ciation incentives.  Here we have  a  segment  of  the  industry
            which we are  identifying as an  industry in  its  own right,  and
            it has very little incentive to compete with  the already exist-
            ing incentives that are known and have heen proven.

                There is  also in  the  eye  of the  spender  a  hesitancy to
            believe.  He  asked for  a two-year payback which is 50 percent
            return on his investment, a three years payback,  a 35 percent
            return on  his  investment.    When  he's  assured  that  it  will
            happen, he  really may  not  even  believe  that  too.   It'll go
            back to the other  area  where he can make his investment and he
            knows that he can  get his profit  out of that whereas this  is a
            relatively new thing within less than  10 years,  and  he's  say-
            ing, well,  give  me a  greater  tax  incentive or  give  me some-
            thing more,  or  I'll  put  my money where I know  it's  safe,  he-
            cause I'll  be in  business two  or  three  years from  now  with
            this thing.  If it  goes  wrong,  I may not  be  here,  that sort of
            thing.

                That's how  I  can  answer  that,  and  I  reserve the  other
            answer for Mr. Rimer.

MR. RIMER:      I think the  question is very perceptive, and the view  that
            you can  give  of  taking energy  and  energy  savings or  conserva-
            tion in  industry  and  trying to convince  that person  that  it's
            a good  idea  is  to say  that you're  really   adding on another
            foot to  the  industry.   You're  giving them another two feet of
            production line,  because you're really  giving  them additional
            money to either make more widgets and make more money or you're
            actually bringing something to  the bottom line.

                In the  school  program  and in  the  hospital  program  and
            local government program which  we're familiar  with as well as
            the industrial program,  I think we  found many  of the clients
            that we've  served  absolutely unwilling to take the government
            money.  They  want  to   move  ahead.   They  are   convinced  that
            there is no  advantage to them in taking a small grant and  then
            filing all the paperwork  when they  can  go out and do the study
            and implement much more quickly.

                I think part of that  is  not really the government's  fault.
            I don't thi-k it's anybody's  fault.   It's just a matter of the
            program getting started and having all of those  initial impedi-
            ments that created the problems in the program.


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                Here we  are,  we finally got a  program set up that  appears
            to have  at least  some general, forward-moving  direction, and
            we're going  to  undercut it.  I'm all  for reducing the  Federal
            budget too,  but  I think we have to look very carefully at the
            potential  national  interests  that   are   being  lost  here,  and
            that's why I say I think  it's  a very  good question.   I don't
            know a real answer  to  it.

                I don't  know  where the  incentive  picture  lies  here.    I
            think it's a question  that  this whole hearing in many peripher-
            al ways  has  addressed.  Everybody  said  we needed incentives,
            but what are  they?   How do we  best fit  that  in  with Reagan's
            economic programs  which I  think are  sound  and  are  going  to
            demonstrate their  validity  in time, that  we need those incen-
            tives now.

MR. MILLHONE:   Just a  couple  of  what  I hope will be  quick  questions  and
            answers.  Mr. Harkins, does the Mechanical  Contractors Associa-
            tion of  America  undertake  any  research   activity  for  more
            efficient HVAC equipment?

MR. HARKINS:    Well, we do so  through  contributions  to  ASHRAE per   se as  a
            technical society.  We do not propose ourselves to be technical
            people and develop  standards in that aspect.

MR. MILLHONE:   Mr. Rimer, you mentioned the  desirability of  their  being
            local, state  and  Federal   energy  programs.  Do  you  think   it
            should be  the  Federal  government's responsibility to  pay the
            cost of  the  state  and local  programs  or  should  those  govern-
            ments pay the cost of  their own program?

MR. RIMER:      I  think the  government should  pay  the cost of  their own
            programs to the  extent that they can  and  maintain  a national
            program.  If  that  means that  a certain  amount  of  seed money
            has to come  from the  Federal  government,  I think  that  should
            be provided  to  the  extent possible.   But  I think  the local
            and state  governments  should do  as  much as they can themselves
            and many states  have.   But we  hear all  of  the  states  saying,
            oh, we're  going to  go  out  of  business  if you don't give us the
            money.  So  there may  be  some   seed  money  necessary to  keep
            them going.

MR. MILLHONE:   From your  perspective, I  guess, in  North  Carolina,  how
            have you seen the program over the last few years?

MR. RIMER:      I think locally  it's  become  somewhat  stronger,  because
            North Carolina,  South  Carolina,  to  some  extent,  Virginia, have
            forced the local  communities  to do a little  bit more  than   I
            know some  of  the  northern  states have, so  that  the  local pro-
            gram has  gotten  strong because  of  workshops  and  the like.

                The state program  itself  is relatively weak  if the  DOE


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            takes the money  out  of it, because  the  state has not taken as
            much initiative  as they  should to provide state funding.  They
            will. Our  legislature is  looking  this  fall  to  do  something
            about it if, in  fact, funds are cut off, because they recognize
            the importance of it.

MR. ONDICH:     As an observation, we had Dr. Kline, a City Councilman from
            Spartanburg, South Carolina,  state that his  community did not
            seek Federal assistance.   They had an adequate  tax  base, sup-
            ported by  the  industries that  are relocating  in that general
            area.

MR. RIMER:      That's great  for the  Southeast, and I'd  love to be  from
            there.  I was  born  and raised in  the  Northeast,  and we have a
            real problem up  there.   Energy costs are two to three times as
            high.  It's a real problem.

MR. ONDICH:     Okay.  Again thank you, and I would like to move on  to the
            next three witnesses,  Carol  Allen,  from the New Jersey Commun-
            ity Action Program, Bill Chandler from the Environmental  Policy
            Center and Katherine  Ellett from  the League of  Women Voters.

                Since we have significantly changed our scheduling, I would
            like to try to get back  closer to  that  schedule and start with
            Carol Allen  from  the  New  Jersey  Community Action  Program.

MS. ALLEN:      I work for the  Community Action Program's Executive  Direc-
            tor's Association  of New  Jersey,  a research  and information
            statewide office for  23  Community Action Agencies in the State
            of New Jersey.

                Community Action  Agencies  are  the  deliverers  of  Federal
            and other  anti-poverty  programs  in local   communities.   The
            Community Action Agencies  are the local  deliverers  of the low
            income weatherization  program which was  started  by the  U.  S.
            Community Service  Administration,  and  later,   when  expanded,
            became the  DOE  program,  but  in  many,   many cases  Community
            Action Agencies  have  continued to  be  the  deliverers  of  the
            program.

                I am  first  and foremost  an advocate of  that program as a
            Federal program, and, secondly, an advocate of energy conserva-
            tion as a national effort.

                Energy conservation is a national need.   The Federal  energy
            legislation of the past five  years was created deliberately as
            a national  response  to  the  energy  crisis.  Programs  such as
            Low Income Weatherization,  the  Schools  and Hospitals Program,
            Residential Conservation  Service and Energy  Extension Service
            should be funded by Congress.

                State and  local   government programs  are  also important,
                                   289

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but they are only  supplements  to  a  big national priority enab-
ling efficient  energy use.

    If our  representatives  in  Washington look at  the  national
energy picture  from the point  of  view  of individual households
or small businesses or  institutions  such as schools and hospi-
tals, the  burden  of  escalating  energy  prices  in  the  past  10
years has  been  overwhelming.   Before  the  1970's,  building de-
sign, location  and energy use  was based upon false assumptions
about the availability of abundant oil, electricity and natural
gas at affordable prices.   There  is  no need to  reiterate  what
happened to energy  prices after  1973.   Consumer  and  business
demand continuing at  unchanged levels  contributed  to the price
increases.  Since energy  is  a  necessity, it is price inelastic
in the short run;  price  inelastic  means that demand  does  not
decrease rapidly despite price increases.

    The immediate need was  for mobilization of information and
planning to sensibly reduce energy consumption.  Federal legis-
lation from 1975  to 1978 set  into motion  appropriate Federal
government leadership with the authorization of national energy
conservation programs.

    Research shows that the weatherization of homes in the form
of storm  doors,  windows,  insulation,   caulking and   so  forth
results in  substantial  savings in energy consumption.   A study
by U.  S.   Community  Services  Administration  and  the  National
Bureau of  Standards  shows  that   just  over  $1000  per  dwelling
in weatherization  costs  can result  in a  39 percent  reduction
in fuel bills.

    The DOE low-income  weatherization  program  helps people who
lack the  capital  or the borrowing power  to  make energy saving
improvements.  I would  like to commend for the record informa-
tion already presented in this series of hearings,  the Consumer
Energy Council's extensive  research.   They gave testimony yes-
terday and also presented a very  thick volume of research which
has been  read  into the  record.   I  commend also  the  DOE Fuel
Oil Marketing  Subcommittee  research which  was  read  into this
record yesterday.   Those  both document the need  for  and the
consequences of  low  income  energy  conservation  assistance.

    Income eligibility  in  the  weatherization programs  is based
upon 125 percent of poverty income guidelines.   That means peo-
ple who couldn't  really afford any kind of real capital expen-
diture.  The same people  are  eligible  for financial assistance
in paying  their  fuel  bills; therefore,  it  makes sense to pro-
vide a more lasting  solution  to  fuel  bill  problems  by making
houses more energy efficient.

    There  are  also those elderly people  with  different spend-
                        290

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ing habits  who  will deprive  themselves  of  adequate  heat at
today's energy prices.   So weatherproofing their dwellings  ena-
bles them  to  live in a  more comfortable  and healthy  environ-
ment.  Low  income weatherization programs have  been in effect
for a  few  years,  but  there are  still 13  million  low-income
residences  that need to  be weatherized.

    The need  for weatherization is  specific  and enormous.  It
should be  maintained  as  a specific Federal program with direct
funding and guidelines.   It  has taken a while to arrive at the
right program  design,   and  it  would  be  impossible  for 50
states to  assess  needs  and implement  weatherization  at the
scale needed  by  the 14  million low  income elderly and handi-
capped households in this country.

    The idea  that  low-income energy assistance programs should
be discouraged as  Federal energy policy because they're income
transfer programs is very poor  logic  in my opinion.

    The income  transfer  has  already been  set in  motion   with
the rising  energy prices.   The transfer is  from  consumers to
corporations.  It  affects  poor people  in a very  regressive
way, because  they pay a higher percent of their  total income
for energy.

    Home energy  consumption  is  not  discretionary  spending.
The only  way  poor  people can  consume  fewer  thermal units of
energy is  by  using  it  more efficiently.   It is too important
to leave to  states.   Weatherization  started  as  a  Federal  pro-
gram and needs to remain there.

    Senator Cohen  of Maine,  when  he introduced  a  low-income
weatherization act  to the  U.  S.   Senate,  quoted  a  study by
Urban Systems  Research  and  Engineering  in  Cambridge, Massa-
chusetts, where  they confirmed  that  actual  energy  savings of
16 to  35  percent  were  resulting  from DOE's  weatherization
assistance.  He  saw  it  in  terms   of   the  actual   saving  of
energy, that  one  million homes  already weatherized represented
saving of five million barrels  of oil a year.

    If we  take  a price  of  $36  a barrel, this  could represent
a savings  of  up to  $185 million,  and  this  has, of  course,  a
positive impact on U.  S. balance of  payments deficit problems,
and the problems of  the  strength of the  dollar,  and it reduces
our dependence on foreign oil.

    He's just  talking  here  about   low-income  weatherization.
This does  not  take  into account all  the  middle-income people
who may, through other kinds of incentives,  choose to  conserve
through their own  investments.   If  we were  to  weatherize all
low income homes in  need within the next 10 years, the pro lee-
ted energy savings would be  339 million  barrels  of oil a year,


                        291

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            about 16 percent of the oil  we  currently import.  If the price
            of a barrel  of oil were  to remain  constant  at  today's  world
            price of $36 a  barrel,  this would represent a  savings  of over
            $12 billion, and  one can  assume that  the price  of oil  will
            exceed today's  price.   So  the  savings  will  be  even  greater.

                Clearly it  is   in  our  nation's  best  interest  to  reduce
            energy consumption.  This   morning  I  attended  hearings  where
            Senator Weicker, whose proposed bill  S1166 is  a weatherization
            and state  and  local  energy  conservation block  grant  bill,
            heard various  testimonies.  Senator  Weicker's proposal  is that
            65 percent  of  state  and  local energy  conservation money  be
            allocated to  low  income  weatherization  for  the  next  fiscal
            year.

                His comment was that is  is  not  really government spending,
            but it  is  government investment to invest  in  energy conserva-
            tion of poor people's houses.

MR. ONDICH:     Thank you, Ms. Allen.  We'll come back with questions after
            we hear from  the  other  witnesses.  Next  is Bill Chandler from
            the Environmental Policy Center.

MR. CHANDLER:   Thank you very much.   My name is  William Chandler,  and I
            represent the  Environmental Policy  Center.  My comments today
            reflect nine  years of  experience  in energy   conservation  re-
            search, including  work  I did in  co-authoring  the book ENERGY:
            The Conservation Revolution.  I have  also served  as a consul-
            tant to the  Congressional  Office  of  Technology  Assessment  on
            a review  of  the Department  of  Energy's  conservation programs.

                Since the  Environmental  Protection   Agency's  mandate  re-
            quires  that it  address  the broad question which is, "Is enough
            attention being paid to energy  conservation?"   I'll begin with
            this assertion, that our policies for achieving energy conser-
            vation  are terribly inadequate.

                The Reagan  Administration's recent  efforts in this regard
            are, moreover,  counterproductive,  and I  will  refer  to these
            shortcomings as I  describe examples of policies that I believe
            are necessary  to  fully  capture our  energy conservation oppor-
            tunities.

                I'd like  to begin  with  the first  example  of automobile
            fuel economy.   Automobile  fuel economy may be  the single most
            important energy  conservation  measure  available to  us.  The
            truth of this  is  evident in that the quantity of  gasoline that
            we consume  almost  exactly  equals  the quantity  of  oil that we
            import.  Since  most gasoline is  consumed  in  private  cars and
            since the  efficiency  of  cars   can  be  improved  from  the  15
            miles per gallon  that  the fleet on  the  road  today averages to
            50, even  60 miles  per  gallon,  it is  clear then that  gasoline


                                   292

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consumption in cars  should  be our first priority.  Indeed, the
difference in the year 2000 between oil savings that the market
is likely  to  effect  and that  which  is  both  technically and
economically feasible  is probably equal  to about  two  million
barrels of oil per day.

    The Reagan  Administration  asserts  that   the  deregulation
of oil prices  will bring about all the  gasoline conservation
that is warranted,  that  is that  the  market will take  care of
the problem.  Figure  1 which  I have attached  to  my testimony
indicates why this probably won't  be  the  case.  (see Figure 1)

    The figure shows how if a driver of a  car that obtains 15
miles per  gallon  can  save  5  cents per mile by trading in his
car that gets 15  for a car  that gets 25 miles  per gallon, then
the savings, as I said equals about 5 cents per mile.

    The savings  decreases,  however,  if  you  go from  say  25
miles per  gallon to  50  miles  per gallon  to   the  point  where
you're saving  1   to  2 cents  per  vehicle  mile.   This  is not
enough of  an  incentive,  in  ny  opinion,  to  overcome the consu-
mer's reluctance  to  pay  a higher  first  cost  for the  car even
though the  consumer would  save money  over the  life  cycle of
that investment,   that  is  over  the  first  three  years of the
life of  that  car.  That's  because consumers  in  general   avoid
higher first  costs  even  when  to do  so  costs   them  money over
the life cycle of the  product they purchase.

    This is a problem in  all  areas  of energy  conservation,
except perhaps  in  industry.    This   problem  may  explain  why
Europeans who have  for years  been paying  prices  of $2  to $3
per gallon  of  gasoline drive  cars that average  only  about 25
miles per gallon.

    It's ironic  then that  one  of  the  first  actions  that the
Reagan Administration  took  when entering office  was  to put up
barriers to the importation of fuel efficient  cars.  The export
restrictions forced  upon the Japanese  will drive  up  the cost
of the  average   fuel   efficient  auto  for   sale in  the United
States by about $300 per car.

    This cost incidentally  will  be  equal  to  the  fuel  savings
of buying  that  car that  would accrue  over the  first  year of
use of the  car.   So the  Reagan Administration not  only is not
paying enough  attention   to energy  conservation,  it's making
conservation harder to achieve.

    The second example turns to industrial energy conservation.
It is  often  supposed  that  industry  will capture,  in   response
to the potential  for  cost  savings,  all the  opportunities for
                         293

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energy conservation  that  are  both technically and economically
feasible.  I   believe  that  this  supposition  is  incorrect.

    Most industrial  plants were  built  when  energy  cost  the
equivalent of about  $5 per  barrel,  and so that makes most U.S.
industry obsolete  with respect to  today's  energy prices with
respect to  the energy  conservation  potential  that  the price
increases of the 1970's have dictated.

    In fact, a  recent study by the Environmental  Policy  Insti-
tute has  estimated  that  the  need to  increase  investment  in
industry for  energy  conservation alone  amounts   to  something
like $20 billion  per year.   Industry is  not  making these in-
vestments because  of the  high cost  of  capital,  particularly
to those manufacturing  industries that have  very large  debts.

    A number  of  senators,  including  Senator  Malcolm Wallop,
have offered  a  bill  which  would  help solve  this  problem.   It
would make  part  of   the  needed  capital  available  through  an
investment tax  credit of 20 percent  for  investments in  energy
efficiency in industry.

    Since the  investment  tax  credit  gives the best  "bang for
the buck," as  it  were,  or in  other words,  the  greatest  amount
of private investment per dollar  of Federal revenue lost, this
bill could have a most beneficial effect; but the  Reagan  Admin-
istration has  not  supported this legislation.  This  aspect  of
Reagan policy  further exemplifies the  Administration's  incon-
sistency on matters of market  interference.

    Instead, the Reagan Administration's economic  recovery plan
will only make  matters  worse.  It  will  allocate  vast  sums  of
money to electric  utilities and  oil  refiners, thus  providing
even greater subsidies for energy consumption.

    My last example  is  in the buildings  sector,  and  it  refers
to the glaring  error made by the  Reagan Administration and its
ill-advised attempt  to  repeal authority  for  about  a  dozen
energy conservation  programs,   including  Low  Income  Weatheri-
zation, Appliance  Energy  Standards, the  Energy Extension Ser-
vices,  the   Residential   Conservation   Service,  and  others.

    These programs were  specifically  designed  to  fill  the  gap
left by  the  marketplace   in   providing   reliable  information,
technical assistance  and   financing  for  energy   conservation.
Fortunately, these programs probably will  not  be  repealed,  but
that is  not  to  say  that  they will  be   supported adequately.

    Table 1, (see attached) also attached  to my  testimony, shows
the distressing fact  that  the  present  level  of  funding for low
income weatherization would require  an  unbelievable  40 years
to weatherize  even at a  modest  level  the homes   of  America's


                       295

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          Table 1:   Low Income Weatherization
        LOW INCOME HOME WEATHERIZATION

The Need
  16 Million Low Income Homes X $500 per Home = S3 Billion

The Federal Response
  Weatherization Program = S200 Miliion per Year

The Result
  $8 Billion ••- S2CO Million per Year = 40 Years
                           296

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            neediest.  The   Reagan  Administration,   unbelievably   in my
            opinion, would devastate the weatherization program.

                Another program  for  which Reagan sought  repeal is the Ap-
            pliance Efficiency   Standards.   Appliances  can  be made  much
            more efficient  than  the market  now demands.   Figure  2  shows
            the efficiency  of  a  typical refrigerator  relaive  to  its  cost.
            One can  see  from this  chart  that small  increases in the pur-
            chase price of  refrigerators  can  greatly increase their effi-
            ciency.  The problem,  again,  is  that the  consumer reacts more
            to first costs  than to  life-cycle costs.   Moreover,  the con-
            sumer does not  even  pay the marginal cost of electricity;   he
            or she pays the average cost.  The consumer does not "see" cor-
            rect price signals, a situation that makes  it  impossible for the
            market to work  adequately.   This  fact  is  the major justifica-
            tion for appliance efficiency standards:   standards will, quite
            simply,  save  both   consumers   and   society  lots of  money.

                In summary,  I  have  cited  a  few  critical  examples  of  how
            the Administration has paid  far  too  little attention to energy
            conservation.  There are, of course, many  others.

                The fault lies not just in the leadership in the Department
            of Energy,  but  throughout  the  administrative  agencies.   The
            Office of Technology Assessment has urged  that  Congress provide
            DOE with an era of stability in  order  to implement the energy
            conservation programs  for  which  DOE does  have responsibility.
            This, I believe, is a sound recommendation.

                But the actions of each agency impinge upon energy consump-
            tion; therefore, each agency should review its  proposed actions
            for their impacts  on conservation and  without such attention,
            fiascos such  as  that   represented  by   the   automobile  import
            restrictions inevitably will be repeated.

                Thank you.

MR. ONDICH:     Thank you,  Mr. Chandler.  We will move on  to our last wit-
            ness in this segment, Katherine Ellett.

MS. ELLETT:     Thank you.  My name is Kathy  Ellett,  and today  I'm repre-
            senting the League of Women Voters of Maryland.  We have about
            3000 members in the State  of  Maryland.   I  am the First Vice
            Chairman and Energy Director.

                The League  of  Women Voters  of the  United  States  has been
            involved in  energy  issues  at  all  levels,   local,  state  and
            national, since  1974.   We  began  our energy  concerns  at that
            time with  the  rather  obvious  need  for  something to  be done
            about energy,  and  our  first   concern   was   for  conservation.

                We have always looked at  conservation of any resource in a
                                   297

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very positive  sense.   Don't waste  it,  use  it efficiently.  It
doesn't have to  be a  negative.   We know,  everyone  knows that
we are terribly  wasteful with energy in  this country.  We can
be more efficient  without  changing  our standard  of  living  or
giving up things.

    The League of  Women Voters of  the  United States  testified
before the House and  Senate Budget  Committee on their revised
1982 budget.   I  have  included  their   statement  on  solar and
conservation programs  in my  testimony, my  written  testimony,
because they could not send a witness today.

    Our concern is  for the  drastic  cuts  that have been recom-
mended in  the  solar/conservation  budgets.    We  simply  do not
feel that market  forces are  going  to  take  care  of  all these
things.  Higher  prices already have had  a  beneficial effect,
but they cannot carry the burden alone.

    Most of the technical reasons why this is true have already
been discussed.  Either  I've already heard them this afternoon,
or reference has been  made  to  them,  but they have  been brought
up in these hearings.

    So I  would like  to  spend the  time  addressing  myself  to
experience in  the  State of  Maryland.   Maryland has  an energy
office.  It was  organized in 1973  in response  to  an  emergency
situation.  A good bit of its funding has been from the Federal
government but not all of it.

    I have been  to many hearings  at the state level during the
General Assembly sessions.   The legislators  are  very  concerned
about energy conservation and  doing something about the crisis
in general.   However, they have a  very  serious  problem of cuts
across the board.

    They are directly  responsible  to  their  constituents,  and
their constituents can get at them very  readily and very easily.
I don't think  it's likely that they can  replace  all  of these
programs immediately.   So  to  take  them  away from  the  states
immediately poses  severe problems.   We in  the  League have had
a lot  of  pass-through  grants.   They've  been  for very  small
amounts of money.

    A lot of other voluntary organizations  have received money
also.  We have done  various public  education type things  with
this money.   It has  been well spent, and I  have included with
my remarks  some  examples  of  the  publications  that  we've put
out.  We don't think that loss of  that  kind  of  money will be a
big tragedy.   Public  education   is  something  the  league  has
been doing for 60 years, and we  will continue to do it without
any Federal money.
                        299

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    There are certain things, however, that the Maryland Energy
Office has  done  and  needs  to  continue  to do  that  it  really
can't do effectively  without  help  from the Federal government.

    I think  all  the programs that  are in place  are  important
and worthy  of  Federal involvement, but the three  I'm going to
mention are  ones  that  the  Maryland  Energy  Office  feels  they
cannot carry  out  without  Federal  involvement.   First  is the
ability to provide technical  information to all  sorts of small
businesses and industries.  A state the size  of Maryland with
some 4  million  in  population  doesn't  have  the  resources  to
pick up  on  this   kind  of  technical information,   let  alone
dispense it, so that there needs to be some kind of information
transfer bank.

    This has just barely  gotten started,  as I understand it in
DOE, and  it's  beginning  to  function  well.   It  doesn't  make
sense for  every  single state  to do  all  the  research  and all
the information  gathering  and  buy  big  computers and  so  on
to get  in  touch.   That  still cuts  them  off  from  what  people
are doing all over the rest of the country.

    This is  properly  a  Federal  function,  a  clearinghouse,
somewhere to get information and a way you can give your infor-
mation so  other people  can get  ahold of  it,  and,  lastly, the
ability to  provide  energy  audits  and  advice  to local  govern-
ments.  Again, it's helpful to  have some  kind  of support. For
instance, the  Residential  Conservation  Service  (the  Federal
mandate that it has to  be done)  is something  industry won't do
unless they're absolutely required to do it.

    I mention that the state is under severe fiscal restraints,
and, therefore,  they cannot really  pick up on this stuff imme-
diately.  A  certain  amount of  it,  I think, Maryland will re-
place, but  obviously  with  a  three-month  legislative  session,
they're not  going  to  do it  overnight,  and there are a  lot of
other things they're going to have to address  first.

    I would  like  to  close  then with  some  particular  things
that we  think  is  the  Federal  government's  responsibility.

    First, it should  establish  and  work  towards  specific goals
for energy  conservation.    Someone  earlier mentioned the  lack
of any  kind of  direction  or priority  setting.  We have had
this at  the  state  level  with  the  state conservation  plan.
Everybody then  knows  they're supposed  to get  15 percent  by
the first year  or  whatever, and this  is helpful,  because then
they can set out and  say,  okay, this is  the way we're going to
reach that goal, and  the public  knows  that that's  the way it's
being reached, and they're more likely to cooperate.

    Second, the  Federal  government  should   be  encouraged  in


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carrying  out  and doing  or  encouraging research  on more effi-
cient ways  to use  energy,   as  well  as  the evaluation  of the
conservation  techniques.  Again,  each state should not have to
do this  for  themselves.   It  doesn't make  good  sense.   Each
state shouldn't  do the  research on  how well  a house  can  be
insulated or  how these programs can  be  evaluated.   There is a
concern about  indoor air quality.  Every  state shouldn't have
to do research on that.

    Establish and  maintain  an  information  transfer system.   I
mentioned that  earlier.   Assess  and  work  to  remove  the many
institutional barriers to the attainment of  maximum conserva-
tion efforts.   Again, this  is  something  that has  to  happen
throughout the  whole country  because all  the  components that
go in  in the  building  industry  are  not  made in  each  state.
They may  be  made in  any state,  and they're marketed through-
out the  whole country,  something  that  has to  be  coordinated
at the Federal level.

    Five, continue  the  energy  assistance  programs.  This  is
very important.  It  has  to  be  done,  and,  again,  the trade-off
has to  be there.   If people's  homes are  not weatherized  at
all, then their  energy costs  will simply go up and up  and up,
and we know we  have to help  them pay those costs  for health's
sake.  Every citizen is entitled to  a  decent standard of living.

    My last remark the League feels very strongly about, treat
all energy sources equally.   The Federal  government should ei-
ther remove  all  subsidies  for  conventional  energy  supplies,
including nuclear  energy,   or  distribute,   which  is  what  we
would prefer,  what  subsidies  are  allowed  evenly across  the
board, and conservation  should  get  an equal share to any other
domestic source.

    We believe that  strong  national leadership is essential to
any effort in conservation  and  solar.  If the nation's leaders
act as though conservation  were  not  important or  convey  the
idea that it is not necessary, the public will act accordingly,
and we  believe   that  this   will have  severe  consequences  for
our economic health and for  our national security.

    Thank you.
    FOLLOWING IS MS. ELLETT's WRITTEN STATEMENT:

July 15, 1981

     The League of Women Voters has been involved in energy is-
sues at  local,  state,  and  national  levels  since  1974.   Our
first,  and  continuing,  concern has  been for  increased  public

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awareness of the advantages  of using any energy  source  in the
most efficient way  possible.   Thus  we  have   emphasized  con-
servation—not in a negative way  but  as  a  rational solution to
immediate energy needs.

    The League of Woman Voters of the United States included the
following statement in their  testimony to the  Senate and House
Budget Committees on the revised 1982 budget:

    "We are dismayed at the drastic cuts in  both  the solar and
    conservation budgets.  We oppose the Administration plan to
    slash over 77%  from conservation and more than 62% from sol-
    ar.  The  Solar  and Conservation Bank should  not he  stran-
    gled just eight months after its birth.

    The Administration cuts are proposed on the assumption that
    higher energy costs and tax incentives  alone will take care
    of energy conservation and  encourage the use  of  solar.  Of
    course, higher  prices will have, indeed already have  had, a
    significant-effect; and for that reason we supported  gradu-
    ate decontrol of the price of oil and new natural gas.  But
    higher prices will not  provide capital  to  the vast  number
    of individuals   and business who  can use  conservation and
    solar.  Higher  prices  and  tax  incentives  will  not  enable
    tenants to control the design and operation of the residen-
    ces and office  buildings they occupy and whose energy oper-
    ating costs  they pay.   Higher  prices will  not ensure that
    we achieve the  maximum cost.effective improvements in effi-
    ciency, even though  such  improvements  are clearly  in the
    national interest.

    In sum,  we  believe that federally funded  conservation and
    solar programs   are  needed  to expedite  "market  forces."
    They provide the   diversity of approaches  needed  to help
    break down institutional barriers to use of these resource.
    The Bank, for instance, was designed specifically to assist
    those who would not be expected  to benefit from tax credits.
    These programs   can assist   citizens  in  the  large number of
    small applications of solar and conservation  technologies.

    Ignoring all recent  major  energy  studies  and  without new
    analysis, the  Administration  axes the  Solar  and Conserva-
    tion Bank, building  and  appliance standards,  utility audit
    programs, funds for  state  energy offices,  and  public out-
    reach programs.    Crippling  reductions  for  local  school
    and hospital conservation programs are proposed."

    The Maryland Energy Office  (MEO) has been very effective in
organizing and  promoting  energy  conservation  throughout  the
state.  They  have   been  a  ready   soucre  of  information,  both
technical and  general,  to  local  governments,  business  and
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 industries, volunteer  organizations,  public  interest  groups
 and private citizens.  Maryland has a good State Energy Conser-
 vation Plan and  we feel  the  State has  so  far met  the  annual
 goals that  are  established  by  this  plan.   There  has  been
 demonstrable growth in conserving activities and use of passive
 and active solar energy in Maryland.

     The League of Women Voters of Maryland has been the recipi-
 ent of grants  to carry  out several projects  promoting  energy
 conservation and educating  the public.   Specifically:

 *  We published  a  fact sheet entitled "Energy Conservation...
    It's Good Business"  which  documented  the response  of state
    business and  industry to the  increased price of  energy fol-
    lowing  the   1973  crisis.

 *  In 1978-79 we reviewed local government programs and activi-
    ties relating to  energy conservation  in order  to  increase
    the awareness of local  officials, county government employ-
    ees and the general public.

*  In 1980-81 we  focused  our review on  a  survey of local energy
   coordinators, other selected officials  responsible for energy
   conservation outreach and assistance  programs, selected school
   officials and teachers.   Information obtained in these inter-
   views was made public in a variety of ways including publica-
   tions,  reports,  forums,   meetings  with  elected   officials,
   newspaper  articles and radio talk shows.

*  We cosponsored a  Solar Homes  Tour  which was  attended by some
   12,000 people statewide.

     These programs and  activities  would  not have  been possible
 on a  statewide  basis  without  the support  necessary to  fund
 printing, promoting, publicity, etc.

     If the Administration's proposed cuts are  approved by Con-
 gress, the Maryland  Energy Office will  be  severely affected.
 It would  probably  be reduced  to a  few  people who  would  know
 what to do in  an emergency situation,  but  could  not carry out
 necessary actions themselves.   There is historical  precedence
 for this  conclusion.  In particular there are certain functions
 now being performed  by the office that  would  nave  to be  cur-
 tailed without  continuing  federal  programs.   These  Include:

 *  The ability  to  provide  technical information  and advice  to
    small  and large  business and  industries on the  efficiency
    of  energy  use  thru  the    Technical   Assistance  Program.

 *  The ability to  obtain,  analyze and transfer information  of
    all kinds to the citizenry.
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            *   The ability  to  provide energy audits and advice  to local
                governments.

                The State Government is under severe fiscal constraints and
           it does not seem  likely  that they will be  able  to  pick  up most
           of these  very  necessary programs.   Consequently,  we  believe
           that the Federal  government has the  responsibility to actively
           support energy  conservation  by  carrying  out  the  following:

           1.  Establish and work toward specific goals for energy conserva-
               tion.

           2.  Carry out by doing or encouraging research on more efficient
               ways to use energy  as  well as  evaluation  of  conservation
               techniques.

           3.  Establish  and  maintain  an  information  transfer  system.

           4.  Assess and work to remove the many institutional barriers to
               the attainment  of  maximum  conservation  efforts.   Market
               forces are  not  sufficient  to  accomplish  this.  (addressed
               earlier)

           5.  Continue energy assistance programs to ensure a decent level
               of health and living standard for all citizens.

           6.  Treat  all  energy  sources  equally.   the  federal government
               should either remove all subsidies for  conventional energy
               supplies,  including  nuclear,  or  distribute what  subsidies
               are allowed  evenly  to   all  sources  of  supply,  including
               conservation.

                We believe that strong leadership is essential  in  this area.
            If the  country's  leaders seem to think that  conserving is not
            very important, the vast majority of  the public will act accord-
            ingly.  That  could  have serious  consequences on  our economic
            health and national security.

MR. ONDICH:     Thank you,  Ms. Ellett.  I  would like  to  open it  up for
            questions and begin with a question of Carol Allen from the New
            Jersey Community Action program.

                We heard over the last two days a great deal about the Wea-
            therization Program.  We had a representative from the New York
            Community Action Program yesterday talk about utility spillover
            effects to the weatherization  programs - audit programs infor-
            mation dissemination programs and so on.  Apparently these util-
            ity programs helped the New York CAP Agencies.

                This morning  we had a representative from  General Public
            Utilities that services  part  of  New Jersey,  and there was very
            little discussion about  what  GPU  was doing on their own, or in


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            conjunction with local organizations.  Are there any other pro-
            grams within the  state that specifically  help  the weatheriza-
            tion program?

                That's the  first part  of  the  question.  The  second part
            Secondly, how does  the  New Jersey  Weatherization  Program work
            with the Low Income Energy Assistance Program, LIEAP.

MS. ALLEN:      Okay.   The first one is national Residential  Conservation
            Service program which was a DOE program and  part of the Nation-
            al Energy Act  in 1977  or '78.   It  was  a mandated  program in
            that each  state held  hearings and  had  certain goals  whereby
            utilities are to provide  audits to  people and  also  to provide
            them lists of  contractors that  could  make energy conservation
            modifications and lists  of  lending agencies.  A  step  in  be-
            tween the audit  and this  list that  was  to  give  back  to  the
            person a list  of  the cost-effective modifications  which would
            be recommended for the particular person's dwelling.

                The New  Jersey  State  Department   of  Energy  had  already
            anticipated,  a  year  earlier,  a  program which  is  called HESP,
            Home Energy  Savings  Program,  so  they  had  a  kind  of  program
            going the year  before RCS  came in.  We  still have  our HESP,
            and I'm also familiar with the New York Program which is called
            HIECA, which is the RCS program.

                HESP is a potentially good program;  however, it  has very
            little for low-income people.  When they were  setting up HESP,
            according to  Federal  guidelines,  I testified  and  suggested
            several things that  they  might do  specifically  for low-income
            people with the  idea that low-income people wouldn't probably
            get into the  contracting and  the borrowing and  so  forth.   I
            also said I didn't  think  that  low-income people would  ask for
            a $10 audit even though  the cost of an audit  is  probably more
            like $100,  and  with all  the  follow-up  of  the  cost-effective
            modifications.

                Low-income people  would not  elect  to  spend  $10  without
            knowing why or  what  it was  going to lead to.   So I said  why
            didn't they give  the audits  free,  and they said  there's  one
            group of people who  receive a utility  allowance, elderly  and
            handicapped who received  a  state  utility  allowance,  who  are
            usually identifiable on utility bills because  of  being in that
            category.  They're actually  certified through  another  pharma-
            ceutical assistance  program.   So they have  a card  called  the
            PAA card with  which they  get  low  cost  prescription  drugs.
            That comes  out of the  casino gambling fund.  So they  also  get
            a utility allowance out of the same casino gambling money.   So
            they were easily identifiable on utility bills.

                The State DOE said, okay,  if  they ask  for a  free audit,  we
            won't have  the  utilities  charge  them  the $10.  That left  out


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            the rest, non-elderly,  non-handicapped,  the  so-called  working
            poor, the AFDC  recipients.   There  was  nothing  provided  for
            them.  They have  another state  DOE  program, a hotline,  which
            takes the input,  actually takes the  calls.   It's a  toll  free
            number for  HESP.    So  people  that  are  low-income people  and
            identify themselves as such, first of  all,  will  be referred to
            their nearest low  income  weatherization  program.   They  will
            receive some information  such  as how they  can do  a self audit,
            and some low cost/no cost tips, another kind of energy savings.

                So, to  answer  your question about the  utility connection,
            it's a  very,  very  important  subject.   In  fact,   I have  asked
            the National  Community  Action  Agency  Association  at  their
            annual meeting  to  have  a workshop  and  bring together people
            from all over who  can  talk  about this.  I  think  there are  some
            good ideas  out  there.   For  example,  the Tennessee Valley  Au-
            thority has provided  very  low  interest loans  for  woodstoves
            and solar  devices   for  people,  and  then  all the  way out  in
            California, and  similarly in  Washington and  Oregon,  they  have
            interest free loans on solar implementation and on conservation
            with some kind  of  a buy  back arrangement,   so it's essentially
            costless.

                In the New England states, they're trying to get new legis-
            lation passed.  Every  state either  has  a  bill  or a proposed
            bill to  get very,  very  low  interest  loans  for  conservation.
            As far as New York goes, I understand  that, in  the HIECA program,
            the utilities lend  at  their rate  of return, 9 to 11 percent.

                They lend to  people, and  I  know  of a couple  of specific
            utilities in the southern tier of  New York  State  who have very
            good cooperative programs  of  helping,  working with  Community
            Action Agencies, where the utility actually does all the audits
            for the low income weatherization program.

                One part  of the low-income  weatherization program  is  the
            initial audit and   assessment,  and in this  case,  the  utility
            does it, which, in a  sense, might  reduce  the cost of  the  low
            income weatherization services by 10 percent or so.

                But that's  very local,  and  I  think  it's very specific to
            one company.  So I would say, in summary, that there are things
            out there, but they're not really working for low-income people
            yet.

                I hate  to   criticize.   I  hate  to go   into  a  hearing  and
            criticize New Jersey   RCS,  because  it's  an important  energy
            conservation program.   It might  be for middle income people to
            take advantage  of,  so  I  don't like to be  harsh,  but  I have to
            say that  there  is  not  a great  deal  there  for  poor  people.

MR. ONDICH:     We  learned   yesterday that the audits  are now  free  under


                                   306

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            the New York HIECA Program.
            WAP Program in New Jersey?
Could you tell us about the LIEAP/
MS. ALLEN:      You mean how they connect?

MR. ONDICH:     Yes, if they connect.

MS. ALLEN:      The LIEAP people asked me to write two paragraphs to put in
            the LIEAP state plan about  the  weatherization which I did, and
            I included mention  of  the low  cost/no  cost  information on the
            DOE hot line.   They put it in  the LIEAP plan,  and  it  went out
            to all the county welfare offices who were delivering the LIEAP
            plan.  To the extent that people get  into a conscientious social
            service office where the person dealing with  them is interested
            in more than one thing, they  get  needed information and servi-
            ces.  This  often  happens in the  CAP agency  where  we  now have
            something called the Energy Crisis  Intervention Program, which
            does a  number  of things for  people,  including information and
            referrals.

                There's a section  called  Access  which means providing peo-
            ple with access to  all other programs, and that means referring
            them to  other  assistance  programs.   That  is the  only formal
            connection.  The weatherization program usually has a backlog.
            So it may not  be a great blessing to  be  referred to it at any
            given month of  the  year, because  chances  are it would be a few
            months in arrears.   So the person wouldn't  get taken care of,
            perhaps, through the next season.

                So that connection is the paper  connection, and, to  the ex-
            tent that people make  referrals,  then more  people  sign up for
            weatherization.

MR. ONDICH:     How do you  think the proposed  changes in going  from cate-
            gorical program  funding for  weatherization  into  block grants
            would affect  the  weatherization  program  in  the  State  of New
            Jersey?

MS. ALLEN:     I think  it would significantly threaten  low income weather-
            ization assistance.  I  don't  like to use the word program, be-
            cause we may  be talking about   something  else,   not the  same
            thing, but the  concept  of  low income weatherization assistance
            would be greatly threatened.

               Senator Weicker  is   coming  in with his  bill  that  says  65
            percent of  perhaps  $336 million for  state  and local conserva-
            tion programs,  but  this morning in testimony, the  Associations
            such as Counties, State Legislatures, Governors, Municipalities,
            and Mayors  all  came in together saying  they wanted  to see  a
            maximum of maybe 30 percent of  that  state and local  block grant
            for low income weatherization.
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                But they believed that 65  percent  was too high  because  of
            regional differences,  because  of  the need for flexibility  and
            so forth.  A number  of  senators,  more regional  than partisan,
            come in very strongly for low-income weatherization assistance.

                Two that I  mentioned,  Cohen  and  Weicker and  also  Senator
            Chafee from Rhode  Island  and  Senator Heinz  from Pennsylvania,
            have all come in very strongly  for  a low income  weatherization
            program.  One of the problems with putting it  into the  commun-
            ity development block grant, as has  been proposed, was  pointed
            out by Senator Heinz, who says  that  most of  his  poor people in
            Pennsylvania are rural,  and they're  outside  of  cities,  so  the
            HUD programs wouldn't reach  them even if  they had a weatheriza-
            tion component.

                There's some advantage  in  an urban  type program for  wea-
            therizing public housing  and  big  multi-family dwellings  occu-
            pied by renters.  Those  have been rather  hard to  get at  through
            low income  weatherization programs  so  there  is  a  need  for
            something there.

                As I  said  at the beginning,  I'm an  advocate  of  a  Federal
            low income  weatherization program  as  such,  because I  think
            it's the only way to get that particular  job done.

MR. ONDICH:     Thank you.  John?

MR. MILLHONE:   I have a couple of questions.    Although  I'm not  familiar
            with its details,  I  know that  there  is  some  consideration by
            the Health and Human  Services  Department in  changing its rules
            so that  some  of the assistance payments can be used for  wea-
            therization investments, assuming that the payoff  is in a rela-
            tively short period of time.

                The linkage  of  weatherization   to  assistance  programs  is
            something that  many  people  have  seen  would  make  a  great  deal
            of sense  for  some  time.   Is there any  reason why a state can't
            do that now, or do  you support  that approach?   Is that something
            that has some local difficulties  that are not apparent to those
            of us  who look  at  the  desirability of  joining  those programs
            from the national level?

MS. ALLEN:      Okay.  Let me speak from my experience.   I have sat on the
            advisory committees of the low  income energy assistance program.
            Since  fuel assistance is in  HHS, it  comes down  to  the NJ Depart-
            ment of  Human  Services.  There's another state  agency  in New
            Jersey, the Department  of Community Affairs, which administers
            the DOE weatherization program.   I've sat through  planning ses-
            sions  where they've had to institute programs based upon Federal
            regulations,  funding  requirements,  and   grant   processing.

                In the  case of the Fuel Bill Assistance Program, there is


                                   3Q8

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            a design  of  a  state plan where certain  choices are made  by  the
            state as  to  how it will  do the fuel bill assistance.

                Both  groups get  mixed in a great many details.  Therefore,
            I see  no  bureaucratic  advantage  in  bringing  them  together
            because that would mean that all  these people  would  have  to
            learn the  details  of the other  program.  It  seems  to  me from
            my observation  that they already  have  enough  details  to deal
            with.  A  referral  system  should be  conducted.   In  the  state
            plan for  fuel  bill  assistance,  there  were  a  couple  of para-
            graphs directing the  certifier to  ask the person if they would
            like to  sign up for  low income weatherization  and  send it  to
            the nearest  agency.

                That's the  referral system.  What  you may  be looking  for
            is some kind of  a  real  overlap where there  would be kind of a
            research  connection  such  as  identifying  those  people  with
            really outlandish  fuel  bills.  Tony Maggiore,  of  the  Fuel  Oil
            Marketing  Subcommittee  Study on Fuel Assistance might say that
            the connection is  to  find those people  who  have  the most out-
            landish fuel bills.  That's why  a vendor  payment  method   is
            recommended, because  it lets  the  social  agency  see the bill
            and analyze  the person's  energy  costs.   The  social  service
            agent could  go  over  bills with people  and  try and see if they
            can come  to  some  understanding of  alternatives  to  paying   so
            much for fuel.

                In that  sense,  there is  a connection in  terms  of  seeking
            out those  people  who  need   weatherization  assistance most   or
            who need  fuel  burner  efficiency modification  or  in  some cases
            who need  alternative  energy  sources more.  There  is  that con-
            nection, and that  has  not   been proposed  in  any  program yet.

                Chances  are if  it happened there  would probably  be a third
            agency connected which would  do just that.  I have the greatest
            of respect  for these  State  government departments  when they
            deal with  these very  hard questions of how to help people with
            these great  problems with   limited  amounts  of  money.    But I
            don't see  them being  able   to  pick up  and do  another  thing,
            which is to  put programs together.

                They've  had to change  agencies,  as  you  know,  in  various
            ways from  year to  year.  Programs  have moved  from  one  agency
            to the  other,  and  there's  a multi-layered  approach.   I don't
            see, at the  state  level, 50 states being able to efficiently
            design fuel  assistance  and  weatherization  programs  separately
            or both in combination.

                Maybe Massachusetts  and  Wisconsin  would  do  fine,  and  the
            rest of the  states would probably  get  completely bogged down.

MR. MILLHONE:   I'm afraid  you're   right, that sometimes the  state bureau-


                                   3Q9

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            cracies are as  difficult  to  get together to do something effi-
            ciently as Federal  bureaucracies.   I can  say  that  having been
            a state  bureaucrat  at one time,  head of  the  Minnesota Energy
            Agency and Chairman  of the Fuel Oil Marketing Advisory Commit-
            tee that  tried  to  develop what  we  thought was a  good plan to
            do this.

                Mr. Chandler,  a quick question.  In your  list  of programs
            that were  being excised,  you  didn't  mention  building  energy
            performance standards.   I wondered  if  that  was just  an over-
            sight or  if  you had  particular sympathy  with the  Administra-
            tion's effort to eliminate that one.

MR. CHANDLER:   That was a keen observation that I left out building energy
            performance standards.  I didn't  emphasize that mainly because
            of the acts that  Congress has already taken to change BEPS —
            which I think  effectively diminishes the  effectiveness  or the
            hope that  the  program will  accomplish  what it  originally was
            intended to accomplish.

MR. MILLHONE:   The new Administration is seeking  to deregulate the  price
            of energy.  Are there any implications  of such a policy, if it
            is pursued  successfully,  that   you think  that policy  should
            have as far as  the policies  of  the prior Administration?  That
            is, I don't think I asked the question  very  clearly,  but if we
            do proceed  to  deregulate energy  prices,  are there  implica-
            tions that you  see  should occur as  far  as some of these prior
            Administration policies,   such  as   appliance   standards,  BEPS,
            RCS or what  have you, or should we be doing the  same things
            under the  current  Administration  in those  areas  as  had  been
            proposed be done during the prior Administration.

MR. CHANDLER:   Let me answer it in two parts. First, I think from a strict
            natural resources  management point  of  view,   deregulation  of
            energy prices makes  a  lot of sense.  I think a great deal  of
            the problems that we've experienced  were due to oil price regu-
            lations.  I  think  natural  gas  price decontrol  would  have  a
            beneficial effect.  However,  I  think you  have to  couple price
            decontrol with  at least two  sorts  of policies, the  first being
            a policy  that  takes  care of  the  equity problems to  make sure
            that those who  get virtually crushed by rapid price  increases
            are taken care of, and specifically  T mean that the weatheriza-
            tion program should be increased many fold.

                The second  policy that  has to  be   implemented  with price
            decontrol is some  sort of policy to take care of the macroeco-
            nomic effects  of  shifting  large  amounts  of  money   from  one
            sector of  the  economy  to another, in other  words,  from consu-
            mers to energy companies.

                In terms  of whether  programs  such  as appliance efficiency
            standards, even building energy performance standards  are need-


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            ed, I think you  can make a very good  argument,  very good case
            that they still will be needed for several reasons, most impor-
            tant of  which is  the  fact that consumers  don't  see  the full
            marginal price of energy, especially electric or utility consu-
            mers who get  a price signal that reflects  the  average cost of
            energy and  not  the cost  to  society  which  is  the  marginal
            cost;  and  because of informational problems,  the market just
            does not work perfectly.

                So from a societal  point  of view,  I  think you  can still
            defend every one of these programs.

MR. MILLHONE:   Thank you.  Ms. Ellett, I don't want to ask an unfair ques-
            tion, and I know asking for specific information is difficult,
            because I've  been  asked  for  specific  information when I've
            been on the other  side,  but  I'm curious about the relationship
            between the amount of money  that  Maryland is  spending  on its
            energy programs  and  the  total state budget.  What I'm getting
            at, of  course,  is  what percentage  is  being spent  on  energy
            programs in your  state,  and  my hypothesis is that it  would be
            a fraction  of one  percent,  and then  my question would  be do
            the Governor  and  lawmakers  of  the  state  really  feel   as  if
            energy is that low  a priority  in terms  of  all the other things
            that they have to deal with.

                I want to tell you where I'm going before I ask.

MS. ELLETT:     I can't tell  you the  specific numbers except that it is a
            small amount.  They give a lot  of  rhetorical support to energy
            problems.  I  think the main  problem in the  immediate future,
            say the  next  two  years, for instance,  is  that there will be
            public pressure for expenditures of money in many areas such as
            education; —  financing  education  is  one  that  is particularly
            big in our  state.  It may be  big  in all the  states  right now
            because of the cutbacks.

                Cutbacks have  been  proposed across  the board  in  all pro-
            grams at the  federal level,  so  that  I don't see  them feeling
            they can give energy programs  a big  priority  and pick  up on
            these things right away.

                Then the state energy office might be disbanded again which
            has happened  before.   Not  entirely  disbanded,  but they  won't
            have the money to  keep  people there so  the  office can do very
            little, and then when things get squared away again, they start
            hiring.  It's been too much of a seesaw for them to work effec-
            tively, and that's why  I think  cutting these  programs  out sud-
            denly, or drastically reducing them suddenly is not fair to the
            states.

                Yes, maybe the states can and should be spending more money
            in many, many  areas, but this  has  to be a  gradual process.  It


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            shouldn't be
            not been  cut
            level.  It's
            the state if
            circle, and,
            signal sent
            need to pick
            not just the
 a  sudden reversal.   The tax,  for instance, has
 yet,  so  the  money is still  going to the  Federal
 not there for the  people in  the state to  give  to
 the state has  to raise more taxes.   It's a  vicious
 therefore, needs  to be a more gradual, definitive
to  the  states  so  they know in  advance  what  they
 up on, — I think  this applies  to all  the programs,
 ones  on energy conservation.
                Then, again,  there  are  the programs  I  particularly  men-
            tioned that  a   state   can't  handle   efficiently  by   itself.

MR. ONDICH:     To follow up on Mr.  Millhone's  question,  and,  I  do  not
            want to  ask for  unfair specifics  -  what  about  the  Maryland
            programs?  Over the last two days  we  have had a lot  of discus-
            sion about a number of  programs, the  weatherization  assistance
            program and programs in general that  assist  low income indivi-
            duals.

                Most of your discussion and recommendations do not specifi-
            cally address these programs.   Do you  have any specific comments
            about them - those in the State of Maryland?

MS. ELLETT:     I  don't know  a great deal  about the programs personally.
            I haven't recently talked to  anyone in  Health  and Human Ser-
            vices.

                In regards  to  the  weatherization  program,  again,  it's
            pretty much what you've already heard.   For  the State of Mary-
            land it's mostly  necessary in  rural  areas  rather than in the
            cities.  People don't live  in  their own homes.   So the problem
            is getting at  the  rental  properties,  and every  year  that  sub-
            ject is discussed by by the state legislators in hearings about
            how they  can  get  landlords  to do  something,  plug  up  leaky
            buildings.  In many cases it can't be done on a remotely feasi-
            ble economic basis.

                They just  don't know what  to do.   I don't  know  what to do
            either.  I  haven't  heard a reasonable answer  to  what  can  be
            done about rental property.  The League's position  on low income
            assistance is  essentially  what  you  just heard  Mr.  Chandler
            saying.  We are in favor  of the  decontrol  of prices.  We think
            that it is necessary so the public  gets the  right  signal about
            how to use natural resources.

                At the  same  time,  we  would prefer  this  to  be  gradual, and
            you have  to  have some  kind  of low income  assistance program.
            I did  ask  some  of the  people at  the Maryland Energy Office
            about the coupling of the weatherization and  the LIEAP program,
            and they  preferred  not to  see that done,  mostly  because  it's
            essentially getting at two different populations.
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                They don't  see any real advantages to  combining,  and they
            felt some instinctive disadvantages  might  be inherent in that.

MR. ONDICH:     Thank you very much.   I am looking at my  schedule,  and I
            believe we have only one  remaining witness, Stanley Ezrol from
            the Fusion  Energy  Foundation.   Is  Mr.  Ezrol  here?   If  he's
            not, I would  like to take a  break  for about  ten minutes,  and
            we will reconvene at 3:00.

            (Whereupon a brief recess was called.)

MR. EZROL:      I think the point to be made to  people,  including the audi-
            ence, who have  had a chance  or  will have  a chance  to  look at
            what I wrote  afterwards is that I  think  the philosophy behind
            the United  States  conservation  program  has  been  in  error.
            The idea  that's been repeated  over and  over  again is  that a
            barrel of energy,  a barrel of oil  saved  through conservation,
            is the equivalent  of producing a  barrel  of oil  at  less cost.

                That's been repeated  in many different  ways.   Now the fact
            of the matter  is,  there are two points to  be  made.   The first
            is that that  is almost obviously  false.   It should  be recog-
            nized as  false  on two  counts.  One  is that  I think the history
            of the 1970's  is  one  which  demonstrates  that there  is, first
            of all, very significant cost  in attempts to save  energy  through
            conservation.  Anyone  who drives  long  distances, I  drive  be-
            tween Washington  and New  York  City relatively  frequently, I
            think, either  has  no   respect  for  themselves  and  their  own
            time, or  they  recognize  it's  a reduction  in  living standards
            to drive at 55 miles an hour.

                It's not something  that we've  saved  at no  cost.   We have a
            situation where due to  changes in  standards for air condition-
            ing and heating,  we have elderly people who have died  because
            their homes haven't  been  heated to  the levels  that  maybe they
            used to heat their homes to.

                Otherwise, it's  just   a  lot less  comfortable  to  work  in
            buildings of 80 degrees than  it is  to work at  buildings of 70
            or 72 degrees and  people  who  work  in those  conditions are less
            productive than they would be otherwise.

                There is  significant  cost  that's  been  involved   in  the
            energy conservation  efforts  that  we've made so  far and if  we
            continue in  that   direction,  there  will  be added  significant
            unit costs.  You  know, the  fundamental  thing  which  should  be
            obvious is that the  certain level  of energy that  you use, call
            that 100  percent  for arguments' sake, the theoretical maximum
            that you  can   save   through   conservation  is  that   amount.

                There's no way  that you  can get any more  energy than that
            amount through  conservation.   Now  the  other thing which should
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be obvious  is  that the  more  you reduce your energy consumption
below that  100 percent, the more  difficult  it is  going  to be
to reduce more,  and  there might be an  easy  one or two percent
saving which is, you know, if there are people who take barrels
of oil out  in  the middle of the street and burn them for kicks,
you know, there's not  very much cost  involved  in saying don't
do that any more, but once you get beyond that, you have to in-
vest in various kinds of technologies and devices, and I'm sure
you've heard   all  about  them  in   the  last  couple  of  days.

    You've got  to do  all  sorts of things to  reduce the saving
below that  level which involves  investment  of  technology, an
investment of scientific manpower,  and an investment in terms of
human living standards and comfort.

    Now, on the  other hand,  there's such a  thing as  producing
energy and producing new  energy technologies  which is what the
human race has historically done when  it's  faced  situations of
energy shortage.

    We've brought new  resources  into  play.   Coal wasn't always
a resource for man,  but when he discovered how to mine it effi-
ciently and how to burn it  efficiently it  became a very impor-
tant resource.  Oil wasn't a resource until about  125 years ago.
It has become  a very important resource.

    I fundamentally reject the  idea  that  there  is some limited
quantity of resources that we have  and that therefore we have to
adjust our  technology  or  our use  of  technology  to some  fixed
limited amount of resources.  The fact of the matter is that we
have coming on line  the use  of  uranium in its  various  forms,
deuterium, tritium,   in  controlled  fusion  reactions to produce
energy, and the history of investment in these sorts of new en-
ergy technologies is  that  the more  you invest  in them, the grea-
ter your return is.

    In other words,  the curve of  investment  from creating new
technologies goes something  like  this whereas  your  current in
terms of return per investment  in conservation technologies goes
something like that.   So,  therefore,  it's fundamentally more ef-
ficient to  invest  in those  new technologies so  that  from the
standpoint of  the  conservation program,  the  thing to  look at
are things like magnetohydrodynamic uses of coal which give you
a higher  energy return  per  investment input,  and  frankly  I
would like to  see a lot of the  conservation  funds shifted into
R&D and  advanced technologies  although that  might  be  beyond
the scope of the hearings here.  Frankly, that's  the only thing
that can be done to save the nation.

    The other  point  I would like  to  make is  that  there  is an
ecology movement in  this  country.  There's  a  conservationist
movement in this  country, and  you've heard  from spokesmen of


                        314

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the Environmental  Policy  Center, at  least  they were  scheduled
to testify today.  There are  other  organizations of that sort.

    These people are  on the  public  record  as being liars,  and
just to refer one  incident of that sort, I witnessed the  lunch-
eon speaker  at  an Environmental Policy  Center  Conference  on
Water Resources  which was  held here  in Washington  this  past
March who was  someone who's gone under the names of Abby Hoff-
man and   Barry   Fried.   He's  a  convicted   cocaine   pusher.

    What he  said at  that  conference to the  great  applause  of
the Environmental  Policy people  who  were  in attendance is  that
we have a certain  point of view  to push and the way to  describe
that point of view in terms  of  water policy was the revival  of
worship of  river gods and  other sorts of  ceremonial  celebra-
tions of pagan river  gods.

    He said  in  terms  of  pushing our political  point  of view,
ignore facts,  ignore  science.   That's  the  enemy's  weapon,
that's not  our  weapon, so  that's  what I nean by being  on  the
public record as being liars.

    Another case  which  I  think is  worth  looking  at  is  an
organization called the  Club of Rome,  which  has an affiliated
organization in  the   United  States,  called the  United  States
Association for  the  Club  of  Rome.   They were  the  sponsors  of
the study  called Limits to Growth  which  was  published,  I  be-
lieve the year  was 1969,  and if you trace back a  lot  of  the
debate over conservation in this country, that book is  probably
the most widely  distributed and most widely  cited  source   for
the need to  cut  back in  consumption  of  energy  resources  as
well as other resources.

    Elizabeth Dodson  Gray  who  is  a member   of  the  Board  of
Directors of  the  U.S.  Association  for the  Club of  Rome   has
published widely  on  the  topic  of  ecology,   and  stated  at a
membership meeting of that organization in Washington,  actually
Chevy Chase, Maryland,  in  the beginning of this year,  that  her
purpose is not strictly conservation.   It's not strictly  ecolo-
gy, but her purpose is  to  eradicate the Judeo-Christian  system
of morality.

    Her specific  quarrel  with   the  Judeo-Christian  system  of
morality is that it places  man as morally  superior to nature,
and she equated  that  placing  of  man in a position of dominance
over nature as  being  the equivalent  of the  Nazis  who thought
that the Aryan  race  was   superior  to  the  Jewish  race  or  to
other races.

    So from  my   standpoint,  the United  States is  a  republic,
the United  States  Constitution embodies a  certain  respect  for
the dignity  of  man   which  emphatically  insists  that  man  is

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superior to nature and  emphatically continues the Judeo-Chris-
tian tradition  which is  that  the  earth,  nature,   the  living
things on the earth, the  resources  that  are here,  are here for
man to subdue and  to use to his own purposes, that  we are not
the slave of  nature, as  Elizabeth  Dodson  Gray  would have it.

    So when looking  at  the  so-called authoritative  studies  of
the Club of Rome and of organizations whose leaders are members
of the Club of Rome.  If you want to look at those, there are a
number of them in the ecology movement, you  have  to ask yourself
to what  extent   can  we  trust  the  conclusions  of  people  who
start from  the  premise   that  man has  no dignity.   That's all
I'd like to say.
FOLLOWING IS MR. STANLEY EZROL'S WRITTEN STATEMENT

    Conservation can never produce  energy.   United States con-
servation policy will continue to be totally incompetent unless
a vicious lie which  has served  as  the philosophical  basis  of
that policy is  eliminated  from consideration.   Before describ-
ing and  disabling  this untruth  which  lies  behind  most  of the
testimony you have heard  yesterday  and today,  I  want  to alert
you to the seriousness  of  the  situation — the perpetrators of
this fraud publicly state their intention not only to undermine
the United States and  its  Constitution, but to  eliminate con-
structors of this republic.  Consult the published works of the
sponsors of  the Forrester  and Meadows  Limits to Growth which
provides the impetus for energy conservation for  the last dozen
years — I refer  to  Club of  Rome spokesthing Elizabeth  Dodson
Gray, calling her thing with no intended malice but adopting my
usage to her own moral self description as a thing morally equi-
valent to inorganic objects, who claims the urgent task  of eco-
logists, conservationists, and  friends of  the eartb  to be the
destruction of  the Judeo-Christian  system because of the found-
ing injunction  of that  system to man to "Be fruitful and multi-
ply, and replenish  the earth,  and  subdue it  and have dominion
over the fish of the sea,  and over the  fowl  of  the air, and over
every living thing."

    The point to be  made  is  that this nation is  in the  process
of destroying itself, at least in part  by accepting the lie that
failure to use  energy  is  the  equivalent of  producing  energy.

    This is  not the case  because the pagan ecologist  view of
resources as being provided  in limited  quantities to man at the
fluctuating whim of various  little  nature deities is simply not
true.  All  of  Man's resources are  defined  by the  technologies
Man has  created.   Man has  abided by the Biblical injunction to
be fruitful and replenish  the earth by developing  increasingly
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energy-dense technologies which bring increasing proportions of
organic and inorganic nature under his dominion.

    A barrel of  oil  saved is not  the equivalent of a barrel of
oil produced because  the second  barrel  implies the production
of oil producing facilities.  More importantly, we must be in a
situation where  the  production of the  energy  equivalent  of  a
barrel of oil represents advances in technology which bring new
resources such as  Uranium,  Deuterium, and  Tritium under man's
dominion as energy resources.  The investment of capital in en-
ergy conservation can never  expand  the energy resource base —
for that reason so-called "conservation technologies" are pure
waste.

    To elaborate:  Denis Hayes has claimed  and frequently been
quoted in his lying claim that United States energy consumption
can be reduced 50%  without reducing living  standards.   He can
make this claim  only  by ignoring  what human life is.   For him,
the additional hours  of travel time caused by  the 55 Mile per
Hour speed  limit  are not  reductions in  living standards; the
drastic or  total  curtailment of  the  ability  of  the  average
American to travel between cities would be acceptable;  the in-
gestion of fifty pounds of algae to replace the protein equiva-
lent of one pound of  meat  would,  according to Hayes,  result in
a cost-free savings  in  energy usage.  To  this brutish, conser-
vationist view of human nature,  I  counterpose a  statement  by
American Economist E. Peskine Smith:

    Man's office in  the  world is that of engineer;  all his real
    power is mental.   It is a waste of  power  for him to take
    that upon himself which  can be  better and more cheaply ac-
    complished by brute matter.  He ceases to do so just as, by
    studying the laws which his  Creator  has  imposed  upon the
    material world,  he  rises to  his Creator's design  and be-
    comes its master.

    It is manifest,  too,  that there is a  law of  constant pro-
    gress in man's appropriation  of  natural forces independent
    of the discovery  of any new  motive  powers.  Every machine
    facilitates the construction of new ones.   It cheapens them;
    it enables us to undertake  those  previously impossible with-
    out regard to cost  for  want of  the necessary  quantity and
    duration of force;  and it  liberates men from physical toil,
    to study and experiment.   Each  new truth discovered is the
    key to a whole magazine,  and  each new  art  the parent of  a
    thousand.

    The fact of  the  matter is that  the  capital investment al-
ready mis-directed into conservation  measures throughout  the
seventies has not only  resulted  in palpable declines  in United
States living standards, but has  been a  deduction  from our po-
tential ability  to  develop new  energy  producing technologies.


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                You may  still  object that there  is  real energy  waste and
            that we must use energy more efficiently.  We should use energy
            more efficiently,  but  conservation is inherently inefficient.
            High energy density technologies like Magnetohydrodynamic tech-
            nologies make the  burning of  fossil  fuel more  efficient.   By
            contrast, the efficiency  of conservation  measures  declines as
            their intensity increases.  That is, the more you conserve, the
            more difficult it becomes to realize "savings" from the conser-
            vation effort.  Even  the  most  horribly LSD-deranged ecologiest
            must admit that the  absolute  savings  from energy conservation
            must be less than 100% of the energy used prior to commencement
            of conservation efforts,  less  the energy expended  in  the  con-
            servation effort.  The  closer  we  get to this limit  (and it is
            not possible to get very  close at  all  without slaughtering the
            human race wholesale),  the  more effort,  and, indeed,  energy we
            require to realize additional  reductions  in consumption.  This
            is analogous to the situation  which  oil  shale extraction engi-
            neers can explain  to you.   The  more  you  squeeze a  rock,  the
            less oil  you get per pound  of pressure applied.   The same is
            true of blood.

                The history of  the  exponential increases in  the  levels of
            energy man has made available for his own use demonstrates that
            investment in advanced energy producing technologies yields the
            opposite result:  a greater  return  is realized per unit of addi-
            tional investment  as the level  of  investment   is  increased.

                I wish to conclude with some remarks on the national secur-
            ity implications  of   conservation  policy.   As many observers,
            including former C.I.A. Director,  and  Secretary  of Defense and
            Energy James  R.  Schlesinger,  have noted,  diminishing reserves
            of energy and other resources will  potentially lead  to great and
            small wars over remaining supplies.  If this pressure  is accep-
            ted, the  conclusion  is  inescapable  that  conservation measures
            which direct investment away from  the production of new resour-
            ces and away from high energy-dense technologies which have di-
            rect weapons  applications,  tend to  condemn us to  a   situation
            where we will have to fight for resources with inferior techno-
            logies and an industrial  base  which has  been decimated by this
            mis-direction of capital investment.

MR. ONDICH:     The  focus  of these Hearings  is energy conservation, as it
            existed and how it may exist in the future.

                The concerns  that  we  heard  over  the  last   two  days  have
            been about a number of very specific programs in energy conser-
            vation, and  a lot  of  people  have  come  here  very   concerned
            about how low income  individuals  are  going  to  survive if some
            of the  assistance is  eliminated.   We are  not  talking about
            very sophisticated technology,  putting a  new window  in,  wea-
            therstripping and  caulking.   In fact,  these are quite unsoph-
            isticated.


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                How do  you  respond to this?   I think your  concern is the
            development of  technologies  that  are  quite  sophisticated and
            not the direction and focus of these hearings.

MR. EZROL:      The thing that  we're up against is that what you're really
            opening up here is a discussion not only of weatherizing, you're
            opening up a discussion of the artificially high cost of energy
            at this point which,  you know,  certainly goes  well beyond the
            range of the EPA's authority.

                Again, the general point to be made, and in terms of speci-
            fics, you know,  obviously if there's a broken window, it should
            be fixed and  so on, but  the  general point to  be  made is that
            the long run  efficiency  of  building new housing is higher than
            the efficiency of going back and retrofitting existing housing.

                Now we have  a problem given that the  Reagan Administration
            doesn't seem  inclined  to adopt  this sort of  economic policy.
            It would make it possible to build new and more effective hous-
            ing.  It also doesn't seem inclined to give much help to people
            who currently cannot pay  their  oil bill,  given  the cost of oil
            currently, and  can't  afford  to  do  the  other  sorts  of things
            that might be done with the housing they have.

                That's a  problem.  The  Reagan Administration has, I think,
            a severe problem in the  economic area,  and  I think if you look
            at the way  that  certain  aspects  of Reagan's  policies have been
            adopted in Britain  and  other places, I think  these things may
            eventually translate into the  same sort  of  political upheavals
            that we've seen elsewhere.

                That's a  problem  that I  would like to correct.   In terms
            of levels of investment,   I think I recall the figure, $184 mil-
            lion for things  like  weatherization aid.  If you  look at, you
            know, the entire  fusion   research  and development  budget  which
            I think comes in somewhere  under $400 million,  in  other words,
            roughly double weatherization, you know, looking at the economy
            as a whole, you've  got weatherization which has at best margi-
            nal impact  on  the  economy,  in  other  words,  at   best  you're
            going to be  saving,  you  know, somewhere in the  range of  a few
            percentage points of home heating  costs which  themselves  are a
            few percentage  points  of our  entire  energy   consumption,  as
            opposed to something like fusion,  which  could over the next 20
            years double, and that's  sort of  a rough figure,  but I think
            it's in the right order  of  magnitude, double  the energy output
            of the United States between,  say, now  and  the  end of the cen-
            tury.

                Beyond that,  it could  multiply the  energy output  of the
            United States by many orders  of magnitude.  So that in terms
            of balancing  one against the  other,  it should   seem  fairly
            obvious that, you know, first  of all  lowering the  cost of oil,


                                   319

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            lowering the  cost  of  energy generally may  be  much more effec-
            tive in  terms of  helping people  who are  currently  in  situ-
            ations where  they're  too poor  to afford  the  energy  or  where
            they're not  living  in  properly  heated  housing  and  so  on.

                Beyond that, the  investment that we  put   into  developing
            new technologies  is  far  more  effective  than  going  hack  and
            trying to  squeeze,  you know, a  few  more  percentage points and
            efficiency out  of  the  already low  energy production  levels
            that we've got now.

MR. ONDICH:     Okay.  That is all the questions  I have.  Do you  have  any
            other statement?
MR. EZROL:
That's it.
MR. ONDICH:     Again, I appreciate your coming.  This  concludes  the Sec-
            tion 11 Hearings for  1981.  We  open the hearing record for two
            weeks following  the  close  of  today's  session for  anyone  who
            would like  to  submit  testimony.    If  anyone  seeks  additional
            information about  the  Section  11  process,  we  would  be  very
            receptive to that  request;  you  can  send for  information  to
            the Environmental  Protection  Agency,   Office  of  Research  and
            Development (RD-681),  401  M Street,  S. W.,  Washington,  D.C.,
            20460.

            (Whereupon, the meeting adjourned at 3:45 p.m., July 15, 1981.)
                                    320

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V. J« ADDUCI                                        WRITTEN
President and Chief Executive Officer               TESTIMONY
Motor Vehicle Manufacturers Association
 of the United States, Inc.
1909 K Street, N.W. Suite 300
Washington, D.C., 20006

     The Motor  Vehicle  Manufacturers  Association  of  the United  States,
Inc. (MVMA) appreciates this opportunity to express its views on the impor-
tant subject of energy conservation.  MVMA represents a group of companies
whose primary business  is the manufacturing,  assembling,  and distributing
of motor vehicles and motor vehicle  related products.   Although  not consi-
dered an energy intensive industry, the members of  the  MVMA are  vitally
concerned with industrial energy conservation.

     MVMA is encouraged  by the changes  in government  energy policy  made by
the Administration  thus  far.  We wholeheartedly  support  the  Administra-
tion's drive to develop  an  energy policy focused on market realities.   As
most recently discussed  in  the  July  1981,  Department of Energy  report,
"Securing America's Energy Policy Plan," MVMA endorses  the new Administra-
tion's decision to break clearly  and openly with past energy policies that
relied so heavily  on  federal regulatory intervention.  We also  agree with
the energy  conservation  philosophy  discussed  in the DOE  report.  Reliance
on market  forces and the  decisions of  individuals and  businesses,  unen-
cumbered by artifical  government subsidies  or  regulatory controls,  will
produce cost-effective improvement in energy usage.

     MVMA members have participated  in  the  DOE voluntary  energy conserva-
tion reporting  program,  formerly the  joint  U.S.  Department of Commerce/
Federal Energy  Administration  program,  for  approximately  seven  years.
The most recent MVMA report  submitted  indicated an improvement in energy
efficiency by the  member companies  of  25.4 percent through  1980  from the
energy usage in 1972, the base  year.   These  results typify  the excellent
results of  U.S.  industrial conservation.  The DOE's  Office  of  Industrial
Programs data indicates that  industrial  energy use efficiency has improved
steadily since  1972.   Corporations  reporting under  this  program  reduced
their demand for energy in 1979 by more  than  2.2 quadrillion  Btu,  compared
to what would have  been  used at 1972 efficiency levels of energy consump-
tion.  This  is  an  outstanding  accomplishment in  view of  the fact  that
industrial output  increased  by  17 percent  over this period  (according to
the U.S. Department of Commerce,  "1980 Industrial Outlook.")

     These accomplishments  by industry  have  been achieved   solely  on  a
voluntary basis and  are unsurpassed by  any other  sector  in  the  economy.
These improvements have  resulted from  sound  business  decisions during  a
period of rapidly rising energy prices.  Industry will  continue to voluntar-
ily improve energy  efficiency in response  to the economics  of  the market
system.  MVMA anticipates that these economic pressures will increase and
that progress will  accelerate,  as natural  gas prices  are decontrolled as
oil prices have been.
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     The American motor  vehicle industry  currently faces  serious foreign
competition which, led by  the Japanese,  has made sizable  inroads into the
North American  markets.    A government  task  force has  estimated that  a
Japanese car  imported into the United  States  has a $1,000-$1,500  cost
advantage over a  comparable U.S. car.  MVMA members can meet this competi-
tion successfully,  but  suppportive  government  economic  and  regulatory
policies are  needed  to allow the  American economy to  recover.   MVMA sup-
ports the  Administration's economic  recovery  program and believes  full
implementation of it is especially critical to the  recovery of  the U.S.
motor vehicle industry.   MVMA believes  it is particularly important that
DOE, EPA and  other  government agencies deliver quickly on the President's
promise to reduce burdensome regulatory programs.

     MVMA applauds the Administration's efforts which already have elimina-
ted or modified a variety of unnecessary and costly DOE regulatory programs
including the  Federal  Emergency  Building  Temperature Restrictions,  the
Energy Information Administration Survey of Manufacturing Industries Energy
Consumption Study, and the Building Energy Performance Standards.  Further-
more, MVMA  supports  the Administration's  reductions  in  spending  for DOE
programs.  The  Administration's proposals  for freeing  up market forces,
improving investment incentives and bringing about economic  recovery will
foster the  adoption  of  conservation  measures  without the  need  for the
current federal, state and local conservation programs.

     MVMA endorses  the  Administration's  proposed  budget  reductions  to
mandatory state and  local  conservation programs.  The  promotion  of manda-
tory conservation programs  at the  state  and local  levels has  been increas-
ing.  Several states  have enacted mandatory conservation regulations involv-
ing lighting  for  new and existing  buildings, boiler combustion efficiency,
maintenance of  oil-fired heating  equipment,  and temperature  controls for
heating, ventilating  and  air  conditioning  equipment.   These  regulations
have resulted in  the expenditure  of  a  substantial  number of manhours  to
compile and  maintain  survey  information,  reports  and  records,  without
commensurate cost savings.  Rising energy  costs  will continue to provide a
more than adequate incentive to conserve energy? therefore these mandatory
state programs are unnecessary.

     MVMA believes that  free-market mechanisms should  be  relied upon both
to reduce vulnerability  to energy supply  interruptions and  to  respond to
such interruptions should  they occur.   MVMA consistently  opposed many  of
the standby Federal  Emergency Energy  Conservation  Plans — compressed work
week and restrictions on uses of motor vehicles — proposed by the previous
Administration.   We are pleased that the present administration has revoked
those inflexible and potentially burdensome conservation schemes.

     MVMA supports the  basic format  of the current Office  of  Industrial
Program's (OIP)  reporting program which allows corporations  to confidential-
ly report individual corporate energy efficiency data through trade associ-
ation consolidated reports to DOE.   MVMA agrees with DOE's current position
which allows industry to set its own conservation targets and report energy
efficiency in a manner which  is consistent with each organization's exist-
ing internal reporting procedures.

                                     322

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     However, MVMA strongly disagrees with efforts by OIP, initiated during
 1980, to  require additional  reporting on the basis of multiple SIC  (Stand-
 ard  Industrial Classification) codes.  These efforts would cause the program
 to become excessively  complex and  onerous for  MVMA reporting  firms and
 would lead  to the provision of  incomplete energy consumption data.  MVMA
 supports  the  concept that  currently allows  reporting  in  the  single SIC
 code of the manufactured end  product  of the  corporation.   MVMA reporting
 companies do  not separately meter  energy use  for different product lines
 and  many  plants  with complex product mixes has no other means available to
 them to  readily  identify  energy by SIC  code.   MVMA member  companies do
 not  design,  operate, manage or measure  energy conservation  or energy con-
 sumption  by SIC  codes.

     Finally, MVMA recommends  that DOE completely reassess the OIP's recov-
 ered materials reporting program.  The  current program is not cost effect-
 ive  and is  of questionable value.   DOE  should  discontinue  this portion of
 the  industrial reporting program until a full  assessment can  be made with
 proper input  from industry.

     In summary,  MVMA  opposes mandatory  energy  conservation  schemes and
 supports  the  Administration's  efforts to  further eliminate  the mandatory
 and  burdensome elements of existing federal energy  conservation programs.
 MVMA members will continue to  support voluntary industrial energy conserva-
 tion programs which  have proven to be successful.
The American Consulting Engineers Council
1015 15th Street, N.W.
Washington, D.C.  20005

FEDERAL ENERGY CONSERVATION PROGRAMS

     We have listened  to  the litany of  witnesses,  at the  EPA  energy con-
servation hearings,  lamenting  the loss  of  funds  for energy  conservation
and the effect  it  is likely to have on  their respective  interests.   It is
worthy to note  that  those expressing the most discontent with  a decreased
federal role  are  those  who have  benefitted  most  by  it in  the  past.

     The American  Consulting Engineers  Council  (ACEC)  does  not  view  a
lesser federal role  as detrimental  to the cause of  energy  conservation in
America,  On the contrary,  fewer government programs will result  in less
federal spending, thereby bolstering the economy.   The  ACEC has been and
is increasing its role in the  energy conservation area.  We are not alone
in this effort.  You have heard the testimony of The American  Institute of
Architects outlining  their  million-^dollar  program  on  energy  conscious
design.

     There is a  proper federal role  in all this.    It is  in the area of
research and information dissemination.   Working closer with trade associa-
tions to develop and get  information into the proper hands is  one  way the
Federal Government  can help.  Trade associations like ACEC have access to


                                     323

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that portion of the  private sector that can turn government  research into
practical application.  The Research and Management  Foundation of the ACEC
stands ready to assist in this undertaking.

     How are private  firms preparing to assume their  new responsibilities
in giving adequate attention to energy conservation?
ACTIVITIES OF THE ENERGY EXTENSION SEEVICE

     The American  Consulting Engineers  Council,  a  trade association  for
over 3700  professional engineering  firms,  has been involved  in  energy
conservation since before  it was considered an issue.  We are design engi-
neers whose  members  have  designed huge  undertakings like the  mechanical
and electrical  systems for the  United  Nations Building, the  Sears Tower,
as well as the  New York and  San Francisco  subways.   We have also designed
many small buildings that  incorporate passive  solar  and  other  state of the
art energy conservation measures.   Consulting  engineers are professionals,
whom engineers themselves go to  for advice and problem-solving.

     The Energy  Extension  Service provides information and technical  as-
sistance to  individuals,  small  business  and local  governments.   There is
no need to convince  our members of the importance  of  energy  conservation
and they  accept their share of the  responsibility in  moving toward an
energy efficient and independent America.   What follows is a more specific
description of  some  of  the activities  concerning energy  conservation in
which we  are involved.  Please  note:  The sentence at the  beginning of
this paragraph  describing  the Energy Extension Service  could  easily apply
to ACEC.  ACEC  is  embarking on a large scale professionally handled public
relations program  to educate the government and private  sector  on who and
what consulting  engineers  are and the services  they provide.   This pro-
gram is designed to reach  the energy conservation community from government
officials to  school  and  hospital  administrators   to  corporation  energy
managers.  Our  point is  that those who are serious  about energy conserva-
tion and  want professional technical assistance  can get  it.   The members
of ACEC are  available and have  the capabilities and expertise to provide
it.  Moreover,  we  are  determined that no  one should go without the assist-
ance they need.  We have  just taken out full-page ads in the  "Energy Users
News" and  the  membership  directory of  the Building Owners  and  Managers
Association announcing our energy services and listing  firms  all over the
country that  may be contacted.   We intend to continue  this  practice and
expand to other publications that will  reach the widest possible audience.
In addition,  our  50  state  and   regional  offices have  and are producing
energy directories to  be  distributed  to local officials and  businessmen.
These directories  will list local firms involved in the energy area.  The
Energy Conmittee of ACEC has produced a slide show entitled "If It's Energy,
It's Engineering"  that will be used by our  members for presentations before
local civic  groups.   This  show  contains  102  slides depicting energy  con-
servation projects and the role  engineers have  played  in  them.   It is
designed to  encouraged investment in conservation and point out the econo-
mic advantages.  We point  these things out to show how the private sector


                                     324

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is responding to  energy  conservation needs and how  there is less need for
government programs.

     We would like  to make one other point  in  regard to the Energy Exten-
sion Service.  A  recent  publication  by the Solar Energy Research Institute
(SERI) lists  state  offices and  contacts for energy conservation programs
and solar energy.   Each  state having three offices  to contact if you have
questions about  energy  conservation  makes absolutely  no sense.   This is
an example  of duplication  or triplication  and overlapping  of government
programs.
THE RESIDENTIAL CONSERVATION SERVICE

     The Residential Conservation Service (RCS)  which includes the Commer-
cial and  Apartment  Conservation  Service  (CACS) is  another  program  with
which we are concerned.  Our  concern is not that individual residences and
business should not  receive energy  audits but  where those audits  should
come from.  The members of the American Consulting  Engineers Council are
in the  business  of  providing  energy audits  to individuals,  businesses,
apartments and industry.   Having  utilities  required  to perform  audits if
requested by their custmers is no longer necessary because of the increased
awareness on the part  of the American  people for energy  conservation and
the availability of  consulting  engineers and others  to  supply these serv-
ices.  There is  no longer a  need to insert  the utilities as a middleman
between the recipients  of  energy  audits and those who provide the service.
That is what the RCS and CACS programs  do and results not  only in another
level of bureaucracy but an  unneeded penetration of  government regulation
into the business world.

SCHOOLS AND HOSPITALS PROGRAM

     As an association  whose members  have done many energy audits of schools
and hospitals,  we  support  the reauthorization of the program  and think it
worthwhile, but  at  the  reduced   levels  of  the  Reagan  administration.

     ACEC is aware of  the  critical  GAO report on the program  and has  some
ideas of its own  on how it  can be  improved.  GAO contends that  money for
the program  is  not  being  used  effectively  because  a  disproportionate
amount is going into Phase II design, purchase,  and  installation of energy
conservation measures,   when  it might be better used  in  Phase  I  energy
audits.

     We recommended a larger portion of  the Phase II money go for technical
assistance.  By using  professional  engineers to specify the  cheapest yet
most efficient items  when a school or hospital  needs  an  energy overhaul, a
more cost-efficient  building  will result.   It  is a  lot more  efficient to
spend $20 to specify a fan than  to  spend $20,000 to buy one  that may be
larger or smaller than  necessary.

     An energy audit,  the way  some  people approach it,  seems  a  simple
process very often  shown performed by complete novices with little training.


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A school  or hospital  is not  a private  residence.  It  needs a  lot more
detailed study by  someone properly trained and  competent.   Care taken when
choosing who will perform technical  analyses  can save thousands of dollars
when ordering and  operating equipment.   It  is  at  this critical  stage in
the energy retrofit process that the most damage or good  can be done.  The
more money spent at this juncture will increase exponentially the benefits
when the process is completed.

SUMMARY

     In sum, although we question the  current level of government activity
in the energy  conservation area and generally support the  Reagan Admini-
stration's funding levels, we  also  support  a federal presence as mentioned
earlier in the  statement.  Federal  monitoring  of  energy  activity  and a
program of  supplying  information and  results  of  research  activity  would
play a vital roled in achieving this country's energy goals.
FRED ARMSTRONG
Assistant Director,
Government Services-Construction
Portland Cement Association
Suite 700
1730 Rhode Island Ave., N.W.
Washington, D.C.  20036

     We wish to take  this opportunity to  ccrmaent on an assessment  of the
adequacy of  attention to energy  efficiency  and conservation  now  being
undertaken by  your  department,   in  compliance  with Public  Law  93-577.

     While there are  many approaches to  conservation methods,  we  believe
Section 11, Public Law  93-577,  "Federal  Non-Nuclear Energy  Research and
Development Act of 1974," provides a much  broader mandate  for  oversight of
federal conservation  activities  beyond  those proposals  outlined in your
June, 1981 Issue Paper For Public Hearings.  Since Congress does not define
"adequacy of attention,"  the section is  broad enough to  include a  review
of federal agency  actions taken,  or to be taken, to  encourage,  or  mandate
energy conservation  in programs  funded  by  federal  grants  or financial
assistance.

     There are  several  laws which  refer,  or mandated energy  conservation
by recipents of federal aid, to affect a reduction of the  importation of
petroleum.  Section  403,  Public  Law 95620,   "Powerplant and  Industrial
Fuel Act of 1978,"  serves this purpose very well.  Executive  Order 12185,
issued to implement the  Act,  expands  and  compliments  this policy.   Federal
agencies which administer programs  of financial assistance are directed to
take actions that maximize the efficient use of energy and conserve natural
gas and petroleum.  Further, such agencies  are required to  issue regulations
imposing conservation requirements as a condition of  continuing to  receive
the assistance.  Which  such regulations,   or revised  regulations, may have
focused attention  on  the need for conservation,  the  EPA  assessment should

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include an inquiry  into  subsequent agency actions to determine the success
of the program.

     We understand  EPA's desire to confine  its assessment activities  to
the spirit of the President's energy policy, to  rely on free market forces
and a  far reaching program  of regulatory  relief to induce  conservation.
This approach agrees  with the Administration's policy  that, "reducing  oil
imports at any cost is not a proper criteria for the nation's energy secur-
ity and  economic  health".  We agree  that the importance of oil,  tempered
with regard  for  its  cost and  use,  should  continue  if  we are to  remain a
viable trading partner with  the rest of  the  world.   However,  conservation
of the product, and its derivative products, through the use of alternative
materials that are  of lesser  cost, produce  equal  or  greater life  cycle
uses, domestically produced, and are proven to  be energy efficient, should
be given priority consideration.   We  believe this approach is one of many
activities that will  serve to bring  more  positive  attention  to  the need
for energy efficiency and conservation.

     Until such time  as  Congressional Acts, that mandate energy  conserva-
tion to reduced the importance of  petroleum are repealed, and  the  National
Energy Policy  implemented,  the  EPA  effort  under   Section  11,  Pulic  Law
93-577 should be  expanded to include an  inquiry  into those  federal agency
actions to carry out the purpose of existing statutes.
JOSEPH A. BEIANGER, Director
Energy Research and Policy
State of Connecticut
Office of Policy and Management
80 Washington Street
Hartford, Connecticut  06115

     The President's  overall  policy of  reducing government's  involvement
in the economic  sphere of  this  country has led  to  three major shifts  in
the direction of  federal  energy  policy:  petroleum prices have  been decon-
trolled,  the  Energy Emergency Allocations  Act was  repealed,  and  drastic
funding cutbacks  in energy  conservation programs have been  recommended.
These federal actions have already begun to have significant direct impacts
on all energy consumers in the  State of  Connecticut.   In addition,  they
have narrowed the range of activities  in which  the state government  can
be active as  it  seeks to  encourage both diversification of the fuels  used
in the state and  reduction in the  over reliance on any  single form  of
energy, while at  the  same  time protecting the quality of our environment.

     Connecticut relies upon  petroleum products  to  provide 70 percent  of
all of its  energy needs.    This  is a  considerably  higher proportion  than
that for the  nation as a  whole.   Increases  in the prices of these fuels,
which have occurred  frequently,  thus have  had and  will  continue to  have
much broader and  deeper impacts  throughout every sector of the economy  of
the state than  there will  be in  other  regions  of  the  nation.   Because
fifty four percent of the  generating capacity of  the electric  utilities


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within the state are  fired  with petroleum products,  price escalations have
also significantly  affected the  price of  electricity to  all users  (see
Table 1).

     In assessing whether the private sector will  respond to market deter-
mined prices in ways which will lead to the most efficient use of  society's
scarce resources,  several  long term  impacts  on the State  of  Connecticut
become apparent:

     1.  Increasingly higher fuel prices  will lead to  conservation activi-
         ties on the part  of the residential,  commercial,  industrial,  and
         transportation sectors.  The experience since the Arab oil embargo
         of 1973 has indicated that rising  energy prices  are the  strongest
         forces in  changing  energy  consumption  patterns.    Several  western
         European nations, where  the  cost of energy is higher than  it is
         here, have  compiled  better   conservation  records  than  has  the
         United States.  Results  of surveys  conducted by  the  Connecticut
         Energy Division also reveal that high cost is the largest motivat-
         ing force for energy conservation among state residents.

     2.  Certain segments  of our society and  sectors  of the  economy  are
         unable to respond directly to market price  signals in appropriate
         fashion.  For example, despite their desire to do  so, low income
         groups and persons on  fixed incomes  cannot  afford to  purchase
         insulating materials;  tenants do  not have the incentive to insulate
         buildings they do  not own;  and  transit  districts  frequently do
         not have additional buses  to  add to their  systms  when the demand
         for public transportation increases.

     3.  As  shifts are made  away  from the  use  of  petroleum  products,
         there are  various  incentives to act  in  ways  which  could  have
         significant detrimental environmental impacts.  In the residential
         sector, rapidly increasing home  heating oil prices  could  lead to
         the increased  use  of  coal stoves.  While  the sulfur content of
         coal for home  use  is  currently  limited to  one percent in Connec-
         ticut, it  would  not be  readily  possible  to prevent purchases or
         sales of higher sulfur coal.

              The industrial sector uses  petroleum products for a  variety
         of its  processes.   Connecticut's  air pollution  standards  are
         somewhat stricter  than those  of  the  other  New  England  states,
         primarily because a large  portion  of the air  pollutants  found in
         Connecticut come  from out of the  state,   most  notably   from  the
         Midwest and Mid-Atlantic regions.   Increased petroleum prices in
         the industrial  sector  could lead to significant pressures  on
         state government to relax  the existing air  quality standards,  and
         this could have serious long term  impacts on  the health  of all of
         the citizens of the state.

               The electric utilities, in their own efforts to keep costs
         down while meeting the electrical demand,  could  seek permission
         from the  appropriate  authorities  both to  convert  some  of  their


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                                   Table 1

                 Oil Use in Connecticut  and the United  States
                                by Sector:  1978
Residential
Commercial
Industrial
Transportation
                                  Connecticut

                                      72.6
                                      80.
                                      66.
                                     100.0
                      U.  S.

                      39.8
                      55.9
                      37.2
                      97.4
SOURCE:   State Energy Data Report,  U.  S.  Dept.  of  Energy,  April  1980
                                    Table 2

               Fuel Oil Prices in Connecticut and the United States

                               1973, 1979, 1980
                                   ($/MMBTU)
1973
1979
1980

SOURCE:
                                  Connecticut

                                       1.62
                                       6.48
                                       8.02
                      U.  S.

                       1.63
                       5.24
                       7.04
         Basic Petroleum Data Book,  American Petroleum Institute,  January 1981
         and Connecticut Energy Division Price Survey
                                   Table 3

                Average Cost Per Kilowatthour in Connecticut,
                            by Sector:  1970 - 1980

                                   (C/Kwh)
1970
1974
1978
1980

SOURCE:
                   Residential

                      2.3
                      4.1
                      4.7
                      6.4
Commercial

   2.2
   3.8
   4.4
   6.4
Industrial

   1.4
   2.9
   3.5
   5.5
         Connecticut Energy Outlook:  1980/81:  Annual Report of the
         Connecticut Energy Advisory  Board,  and Uniform Statistical
         Report - Year Ended December 31,  1980 for Northeast
         Utilities and the United Illuminating Company.
                                    329

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         generating units  to  burning  coal,  as  has  already happened  in
         Connecticut, and  to purchase  higher  sulfur  content oil,  as has
         occurred in neighboring  states.   These  too would add to air qual-
         ity problems.

     There is  a vast array  of evidence which indicates that conservation
is the most  cost-effective means to  respond  to  rising  fuel prices.   Cer-
tainly since the 1973 oil  embargo conservation activities have taken place
in all of  the  sectors  of the  state's  economy.   As fuel prices continue to
rise, the potential for highly cost-effective  conservation measures continu-
es to exist.   In addition to reducing direct energy expenditures, conserva-
tion has a variety of other beneficial effects on both  the economy and the
enviornment of  the  state.    Reduced demand for  petroleum products  in the
existing market determined price  situation could  lead  to an overall reduc-
tion in  fuel  prices; lower  fuel  expenditures resulting from conservation
activities would reduce  the pressures  to  relax  or trangress environmental
quality standards; large levels  of conservation  practices  will  both post-
pone the need for additional electric generating units and provide a longer
period during  which  diversification  of energy  forms and  greater  use  of
renewable resource technologies  can  take  place; and  because conservation
is more  cost-effective  than  other means  of responding to  rising  energy
prices, implementation of  conservation measures  lead  to a  more efficient
allocation of  society's  scarce  resources  than  would  otherwise  occur.

     The effectiveness and  scope of  private  conservation activity  can be
greatly enhanced through  public  programs  aimed  at developing both infor-
mation sharing  networks  between  energy users and  conseration  experts and
public information dissemination programs, and the creation of incentives of
various kinds  for consumers  to  implement  conservation measures.   Those
segments of society  which are unable  to respond to market  price signals,
and thus will  continue  to  suffer the  most  from energy price rises,  also
can benefit from publicly funded programs.

     Approximately 65 percent  of  the  State of Connecticut's energy conser-
vation efforts have  been  federally funded.  The  proposed federal cutbacks
will thus  have a  significant impact  on  the state's  ability  to  promote
conservation, which  in  turn  will  lead to a  greater possiblity that the
long term  environmental  and  socio-economic  impacts  discussed  above  will
result.

     It is the  federal government's stated policy to promote the efficient
use of society's  resources through reliance  upon  market determined price
signals rather than  through  direct government involvement.   This can only
occur when the public is  informed  about what the available alternatives are,
about what the overall cost-effectiveness of each of its options is, and when
groups bypassd by the market mechanisms are provided with support.  The Off-
ice of Policy and Management,  in its recent report to the State Legislature
on energy policy, has identified these activities as it  primary strategies in
dealing with the future of energy use and supply in the  state over the next
twenty years.   (This report was reviewed but not included in the Transcript
due to its length).
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     Continuation of the  federal conservation programs  identified in this
review process  would  provide Connecticut  and other  states  with the means
to promote  the President's  basic  energy  goals.    I therefore  urge that
these  federal   programs  be  maintained  at their   full  funding  levels.
ELEANOR BELL, Energy Representative
Unitarian Universalist Service Committee
  of Kansas  (UUSC/K)
1206 MacVicar
Tbpeka, Kansas  66604

     lhank you  for the  opportunity  to participate  in the  evaluation of
energy conservation measures.   I have enclosed an  energy policy statement
for our organization that defines the context for our concerns.

BACKGROUND

     Although the present evaluation focuses on nonnuclear energy technolo-
gies, government  policies  have  created  an artificial  interrelationship
between nuclear and nonnuclear  that distorts the perspective  on each, and
the two cannot be wholly separated.

     Independent scientific  evaluation  reveals  that various  solutions to
energy problems compare as follows:

     o  Conservation:   In  view  of sharply increasing  energy  costs (in
        terms of  real income—i. e. ,  gross national  product—energy costs
        have doubled  in ten years),  conservation  is  the  most efficient
        short-to-inedium range  response  to  the  energy  crisis.   Current
        rates of  implementation  of  conservation measures  will effect  a
        reduction of  power  needs  by the  year  2000  to three-fourths that
        previously projected.  It  is estimated  that one  quad per year can
        be saved; the nation currently uses 76 quads per year.

     o  Alternate technologies;   These  technologies—utilizing  renewable
        energy sources—arethe necessary medium-to-long range approach,
        with coal the transition fuel of  choice.   1b  rely  on any limited
        fuel source is to consign ourselves to chronic  crisis.

     Appropriate implementation  of  these  measures  has  been retarded  by
inequitable federal funding.   The least acceptable  approach to the energy
crisis—i.e. , nuclear power—has been heavily  subsidized to the detriment
of ultimate solutions.  Government priorities  for nuclear power generation
have had the  effect of discouraging  conservation by projecting  an erron-
eous implication  that nuclear generation  will  create  a panacea of ample
low-cost power.    In addition,  oil companies have  been  buying up alternate
technology enterprises—not  to develop  simple,  low-cost efficient systems,
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but to control development  (1)  by retarding  it  to assure high prices  for
oil and (2) by developing expensive and complex systems in order to continue
their control of energy marketing.

THE ISSUES

     We of UUSC/K are  concerned  that  this present hearing may be  merely  a
technical compliance with the Section  11  mandate rather  than  a  sincere
effort toward  effective  implementation   of  conservation  measures.   This
concern derives from the following  rationale:

     o  With  virtually  no  exception,  business  and industry  have  never
        voluntarily accepted responsibility for  the public welfare unless
        it coincided with corporate financial  interests.

     o  Current government policies promote a favorable climate  for busi-
        ness and  industrial  growth while destroying many incentives  for
        aggressive pursuit of conservation.

     o  Federal funds  to be  made available to the  states  for  all programs
        formerly administered nationally represent  larger cuts  than  the
        amount of administrative savings  to be realized.   Since apportion-
        ment at the  state level will be made primarily  by  business  and
        industrial leaders  (in   or through  state  governments),   programs
        with a negative  financial  impact on  the corporate structure will
        be largely eliminated from  funding.

     o  The  components of the  resource  construct cannot  be unitized  in
        terms of  state  boundaries.   Two  of  the most  critical—air  and
        water—are particularly fluid and  cannot be wholly regulated on  a
        state-by-state basis.  Similarly,  business and  industry  are fre-
        quently multi-state operations and  are  in a position to  play dif-
        fering state laws against  each  other  to  their own  economic advan-
        tage —  and often  to  the detriment  of  effective  conservation.

     o  Energy conservation  is a universal concern, and ideally  we should
        be moving toward world-wide  guidelines; to  retreat  from  federal
        control policies is a retreat from reality.

     In the  context of  these serious  reservations, then, we respond  to
your general questions as follows:

     Question:  How are private firms, state governments and local agencies
preparing to assume their new responsibilities?

     Answer:  In the absence of  uniform  guidelines, each of these entities
will establish individual priorities  within narrow parameters  of  parochial
concern.  The result will be a fragmented, inefficient  response  that will
weaken the long-range impact.
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     Question:  Which activities will get priority from public and private
organizations and  what will  be the  consequences  if some  activities are
discontinued?

     Answer:  Priorities  will  be  determined  on the basis  of short-term
economic consideration.  Long range programs—many of which might ultimate-
ly be  more  effectively—will  likely be  terminated.  Discontinuation  of
energy assistance programs for low income population could result in criti-
cal hardship.

     Question:  Have  any new  initiatives,  opportunities or efficiencies
been created as a  result of the shift  in Federal energy conservation pro-
grams?

     Answer:  The  shift may accelerate  energy costs more  rapidly thereby
creating a stronger economic motivation for conservation.

     Question:  How  can the Federal  government  assist  in this  period  of
transition?

     Answer:  Possibly the most effective  use  of the  reduced funding would
be an educational  program targeted primarily  at business and  industry  as
well as power providers.  There is  impressive documentation  for the finan-
cial feasibility of conservation measures,  and  this should be  placed  in
the hands of those who  would be motivated by such knowledge.  In addition,
small business needs  instruction  in techniques  for marketing conservation
systems and feasible financing plans for small consumers.

     Question:  How should the  Federal  government evaluate and monitor the
effects of its new energy policies and program changes?

     Answer:  This appears  to  be a  moot  question  as effective evaluation
and monitoring procedures require funding.

CONCLUSIONS

     Given current policies,  it appears  that the  most  realistic prospect
for energy  conservation  derives  from  the  motivation  of  sharply  rising
energy costs.  UUSC/K is not in a position to assess the detailed ramifica-
tions of the  individual  programs  listed  on pages 10  and  11  of  the EPA
Issue Paper.  However,  we feel our  role is to impact as significantly  as
possible on broad  policy determination.   When appropriate parameters are
defined, individual programs  can  be  structured to  meet specific  needs.
ENERGY POLICY  STATEMENT COMPILED  FOR THE  UNITARIAN UNIVERSALIST  SERVICE
COMMITTEE OF KANSAS

     Members of UUSC/K  are committed  to energy policies defined  in terms
of human  safety,   conservation,  ecological  preservation,   and  financial
feasibility.  Within  these parameters,  we  subscribe  to  the  following:


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     o  Conservation of  resources must be encouraged by  such  measures as
        economic incentives and mandatory  standards  of utilization such as
        construction codes.

     o  Safety for the human population—both short term and long term—must
        be accorded primary  consideration in  the determination of future
        energy production operations.  This includes the area of fuels (ac-
        quisition, processing, utilizing); production  (construction of fa-
        cilities, operations,  shut-down  or de-commissioning; and  disposal
        of waste products.

     o  Energy technology must focus on  simplicity;  the least complex pro-
        cesses that  can  be   efficiently  employed   must  be  initiated.

     o  All  energy-related processes must be  compatible with ecological
        preservation.

     o  All energy-related processes must be economically feasible.  Energy
        is useless to both producer and  consumer if the  purchase  price is
        prohibitive.

     o  Energy  consumers  at  all  levels  must  be  offered   incentives  to
        utilize available  resources to  provide  themselves  with  all  or
        part of their own energy by whatever feasible process is locally
        available to them.

     o  "Gimmick" processes advocated as  energy solutions must be avoided.
        These processes usually benefit special interest groups who ration-
        alize them in terms of energy.  They go largely unchallenged because
        others are unaware that  they actually  exacerbate energy problems.

     o  If  utility companies are  to  continue  to  operate  as  protected
        monopolies, regulatory agencies must be structured for the protec-
        tion of consumers at all levels.   They must not be allowed vulnera-
        bility to pressure from special interest groups.

     It is our conviction that  safe and practical energy policies can and
must be formulated within these  parameters to assure an  adequate  suppy of
energy, equitable distribution,  and appropriate rate structures.
GLENN L. BELLAMY
Project Energy Manager
Heery Energy Consultants, Inc.
880 West Peachtree Street, N.W.
Atlanta, Georgia 30367

     President Reagan's energy budget  proposals  are of  serious  concern to
all Americans.
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     Solar energy  and conservation  programs  are  being  cut  and in  many
cases eliminated.  Cuts  are deeper than  anywhere  else in the  budget,  yet
other less promising  energy sources such as nuclear energy are scheduled
for increase spending.   Also,  are the President's advisors aware that the
conservation program  has already  done more,  faster and  at less  expense
than anything else in America to reduce oil imports?  We have just scratched
the surface in adopting  already available cost effective  energy conserva-
tion measures.   Solar and other renewable sources  second only to conserva-
tion can also economically  reduce oil imports and to provide more domestic
energy.

     The shifts  in the  energy budget have  been described  by  the  Reagan
administration spokesman as  strictly  exercises to trim the Federal budget.
I do not believe this to be true.   If the budgets were being  trimmed for
purely economic reasons, then  the  nuclear budget would not be increased by
36% while the solar budget  was cut by 67% and the conservation budget cut
by more than  75%.  Isn't  the  so-called  free market  good enough  for the
nuclear and oil industries?

     Instead of taking a paring knife to some of the fat in solar programs,
Secretary Edwards has taken a meat axe  to  the muscles of the solar programs.
Secretary Edwards has said  repeatedly that he is  acting  on  behalf  of a
mandate received in the  last election.  He  claims that  a vote  for Reagan
was a  vote  for nuclear  power,  yet at exactly the time of the election a
national Gallup Poll found that  of seven  possible energy  sources solar was
by far the most preferred with adult Americans and nuclear was by far the
least preferred.   The most recent  Gallup  Poll  reinforces  this  same conclu-
sion.

     I do not ask  for an increase in  Federal  spending,  only that there be
a fair and  just  system in spending cuts.   In  other  words, not to make the
deepest cuts in the most promising areas such as solar and energy conserva-
tion while  increasing expenditures in much less promising areas  such as
nuclear energy.  The  D.O.E.'s  energy policy under President Reagan states
specifically "the  government's role is not to select and promote favored
sources of energy.   Doing  so  risks wasting the  nation's  resources".   If
this is Reagan's policy, then why is he favoring nuclear energy?

     Inasfar as  environmental  protection  is  concerned,  I do  not  think
there is any doubt that the environment of the United States will be much
less affected by solar  and  other renewable  energy sources than it will be
by conventional energy source or nuclear power.

     I believe  the  Federal tax  incentives  of  energy   conservation  and
solar energy in the commercial industrial sector  are inadequate and should
be increased.  I  also believe that depreciation periods  for  solar energy
equipment should be foreshortened.

     If we go back to the policies of the early and mid  1970's, as seems
to be happening, then we are  asking  for  a  real energy  "crisis" to follow
our present energy "problem".


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JOHN J. BENSON
Secretary and Executive Vice President
Construction Industry Manufacturers Association
1700 Marine Plaza
Milwaukee, Wisconsin  53202

     The Construction Industry  Manufacturers Association  (CIMA) is  a U.S.
trade association  which has  for  over  60 years represented  manufacturers
of construction  equipment  and  major  components.   The  approximately  200
domestic firms which are  CIMA members account for about  95 percent  of the
U.S. dollar volume of this industry,  which ships over $17 billion in pro-
ducts annually.  CIMA speaks  in behalf of the industry in various matters
and is action-oriented  to industry problems through  co-operative  industry
effort.

     CIMA members are deeply involved in energy conservation efforts  .  .  .
as fuel costs  soar,, energy efficiency  becomes  a  competitive  necessity.  At
larger companies, entire staffs have been  formed with this as their  single
objective.  Energy  experts on  CIMA  member  company  staffs  have usually
regarded reports to the federal government  as requirements  that  "go with
the territory,"  and have   compiled  cooperatively despite the  allocation
of time and  treasury  required.   Indeed,  CIMA was quick  to participate in
the Department of  Energy's (DOE's)  "Industrial Energy Conservation/Report-
ing Program,"  recognizing  that industrial  energy efficiency  improvement
reports can  be useful  to  both government  and  industry  alike.   In this
regard, you should note that CIMA's industrial energy efficiency percentage
improvement noted on CIMA's Consolidated  1980  Energy  Report  to DOE shows a
consolidated 1980  association  energy efficiency improvement  percentage of
24.5% when compared  with  1972  consolidated  association calendar year data
(9.5% in excess of DOE's 1980 industry target of 15%).

     We feel  that  any  new legislative and/or administrative  proposals to
extend industrial  energy  efficiency improvement reporting beyond  calendar
year 1980  should  extend such program  in  substantially the same  format as
the present program, including  the present rules which provide the identi-
fied corporate reporters  can report  in the "voluntary"  program  via trade
association consolidated  energy efficiency  improvement  reports to  DOE as
an option  to  "mandated"   direct  corporate  energy efficiency improvement
reports to DOE.

     We feel  that  DOE  "listened"  to industry  when  the  current  reporting
program (i.e.,  "DOE's  Industrial  Energy  Conservation/ Reporting  Program")
was designed  including  DOE's  current program  reporting   form  and program
reporting rules-this  includes  limiting  reporting to two digits for all
identified SIC code classifications.  We  do not see any  need for changes
and overhaul of  such program  forms and or program rules for any industrial
energy efficiency  improvement  reporting  mandated by Congress and/or the
U.S. President beyond calendar year 1980.

     We strongly  support  the concept  of  the present "voluntary"  reporting
program which assures industrial participants of confidentiality of indivi-
dual corporate data.  We  feel such confidentiality is one of the  hallmarks

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of this program and  is  absolutely necessary to protect individual business
corporations from  being forced  to disclose  confidential company  data to
their competitors.

     We are strongly convinced that any future DOE industrial energy effi-
ciency improvement reporting program should  authorize industrial reporters
(i.e., both associations and  corporations)  to use calendar year 1972  as a
base period from Which  to  measure industrial energy efficiency improvement
data.  Mandating  a  new base  period later  than 1972  would mislead  both
Congress and the American people  since  many industrial energy conservation
initiatives would  have  implemented  prior   to  the  new  base  measurement
period.

     We believe  that   if  new  industrial  energy  efficiency  improvement
targets are necessary  for  the period  from  the present  to December  31,
1985, such targets  should be  established on a cooperative  basis  between
DOE and industry.  (In  this regard,  please  see  the  enclosed CIMA letter to
DOE dated  January 22,  1980  suggesting an  energy efficiency  improvement
target for CIMA of  9.9%  for  a  reporting  period  from  1980-1985,  Letter
Attached).

     Finally,  we believe that in any future industrial reporting program,
energy reports for captive foundry operations (SIC Code 33) must be author-
ized for  reporting  in  the  SIC  Code  classification of  the end  product
produced by the reporting association or corporation  (in  the  case of CIMA,
this would be SIC Code 35).   We  feel this  qualification  is  absolutely
necessary to assure that for industrial reporters.

     In summary,  should DOE's  "Industrial  Energy  Conservation/ Reporting
Program" be retained beyond  calendar year 1980,  CIMA strongly urges reten-
tion in accordance with the present format, under the present  rules,  and
on the present DOE forms.  In addition,  should you need further assistance,
guidance or constructive Garments in regard to  this  most important issue,
please contact Steve Pitzner of this office nad a mutally beneficial meet-
ing will be arranged and/or additional  constructive  written comments will
be submitted.

ATTACHMENT

Mr. Ernest Loeb
U.S. Department of Energy
Conservation & Solar Applications
Industrial Programs CS-40
Industrial Reporting Branch
Porrestal Building
Washington, D.C.  20585

Dear Ernie:

This letter is written on behalf of CIMA member companies presently par-
ticipating in  CIMA's  "Industrial  Energy  Conservation/Reporting  Program"
under the  auspices  and guidance  of the U.S.  Department of Energy.   Any

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reference in  this  letter to  "CMA" or  the  "Association"  should  be  con-
strued to mean these  CMA member  companies  and only  these  CMA member
companies.

The purpose of this letter is  to advise  you that CMA has  established a
voluntary energy efficiency improvement  target  for  this  Association for
a future reporting  period;  i.e. ,  calendar year  1980  through calendar year
1985.   Such target  is expressed  as  a percentage  improvement  in the ratio
(Btu's consumed per ton produced)  for calendar  year 1985,  with calendar
year 1980 serving as the base year.

After careful consideration and review within the Association, we have con-
cluded that the most appropriate energy efficiency improvement target for
CMA for  such reporting period would  be  9. 9%.   We believe this target is
most ambitious, but we  think it  is attainable,  given  the strong commitment
of CMA member companies to reduce energy usage through all feasible energy
conservation initiatives.

It should be noted  that this energy efficiency improvement  (1980-1985) would
be in addition to  previous " CMA  energy efficiency improvements from  1972-
1979 (19.6% for the first six months of 1979  against the  first six months of
1972).   The new target represents  an approximate 30% improvement in 1985 when
compared with  1972.

CMA has voluntarily established the indicated target for such future repor-
ting period.  We trust  that DOE will  consider  CMA's past performance and
realize such target is most  appropriate for this Association.   If requested,
we would be pleased to meet with  DOE representatives to discuss  this matter
in greater detail.

                                      Very Truly yours,
                                      CMA
                                      Steven R. Pritzner
                                       Administrator
ROY BISHOP
Director, Office of Energy Conservation
One City Hall Square
Room 813
Boston, Massachusetts  02201

     The Boston Office of Energy Conservation was established in September
1980 with a mandate from Mayor  Kevin H.  White to reduce energy consumption
by all City departments,  as well as  to  promote energy conservation across
all energy use sectors in the community.

     The Office of Energy Conservation believes that we must come to grips
with the problems of:  a  lack of information on energy conservation, a lack
of incentives  for  implementing energy conservation, a lack of  skills  for
performing weatherization tasks, and a lack of financing for energy conser-

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vation improvements.  Therefore, we have defined our objectives as follows:

     o  to reduce energy consumption in all sectors, especially the munici-
        pal, residential, and small business sectors

     o  to inform and  educate these sectors about the importance of energy
        conservation and renewable energy resources

     o  to inform users  about existing financial mechanisms and incentives
        for conservation  and  to  encourage   the  development  of  others

     o  to develop  a  comprehensive community  energy planning  and policy
        process and role.

     Currently, our programs in these areas primarily focus on:

     o  municipal energy projects  for the reduction of  energy consumption
        in city buildings,  vehicle  fleets, and street lighting; and resource
        recovery, training and education programs

     o  neighborhood energy projects which focus on encouraging conservation
        in the rental market; the  formation of neighborhood energy commit-
        tees; and assistance to small businesses

     o  private sector initiatives  which include utility rate  case inter-
        vention; development of conservation financing programs with local
        banks; and the establishment of  an  emergency oil delivery program.

     In addition, we maintain an  outreach  and public  information program,
as well as  a research and planning  program which provides  information to
the staff and other city departments, develops data on energy use, analyzes
energy issues  in the  preparation  of energy  legislation,  and  identifies
resources for program development.

     Energy conservation is a high priority for  Boston.   In 1980, the City
itself spent  $32 million  on  municipal  energy  consumption  —   while  the
residential sector in Boston  spent approximately $350 million for heating,
lighting,  cooling and  transportation.   In  1980,  our community  exported a
total of approximately  $1  billion for energy.   This  represents a tremen-
dous drain on our local economy.   Conservation,  for Boston means more dol-
lars and jobs  in the local  economy —-  while  not conserving means higher
costs for  fewer municipal  services.  The  best case  for pursuing energy
conservation, for our city and for the nation, is the cost of not follow-
ing this option.

     At a time  when energy conservation is of  crucial  importance  to  the
very survival of cities and regions,  it  is  unfortunate  that  local  and
state governments are unable  to focus efforts and resources  in  this area.
In Massachusetts, municipalities are being  forced  to concentrate resources
on providing essential services due to the passage of a property tax reform
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measure which has sharply  reduced the revenues the city can  rely upon for
meeting operating and other  costs.   Therefore,  although energy is of seri-
ous interest to Boston, which  is concerned with encouraging and implement-
ing energy conservation, we  will not be able to devote the  level  of staff,
resources, and attention to this issue as we would like.

     It is questionable  as to  how the  federal administration can assure
that an adequate amount of attention to  conservation be paid  while cutting
already inadequate conservation and  renewable  energy  programs.  The argu-
ment is that the market  forces  of higher  energy  prices  will force many
consumers to pay attention  to conservation  — however,  many may  not  be
able to pay  any attention to conservation options  by  virtue  of financial,
information, and skills constraints.

     Low and moderate  income families already  consume the  least  amount of
energy.  In  Roxbury,  a predominately low-income Boston neighborhood,  the
median annual income  is $6300  —with annual energy expenditures of between
40% and 50%.  These people, as  well as many others, simply do  not have the
cash or skills  to  invest  in conservation — they are already  struggling to
keep minimally  warm.   In addition,  it  is  unlikely that such  institutional
problems as that of weatherizing the rental market will be solved by higher
energy prices alone.   Since  73% of Boston's housing  is  tenant  occupied,
this group  is of major concern to the City.  What  is  needed  for the resi-
dential and  other  energy  use sectors  is information,  assistance, training,
and financial incentives.

     Our office is prepared  to attempt to assume a number of  the responsi-
bilities that the  federal government  is  virtually abandoning. We plan to
provide energy  conservation information  and assistance to individuals and
groups and to work with the private sector to initiate conservation finan-
cing^ programs .  However, our priorities will remain in the area  of munici-
pal energy  conservation  — the economics  of budget cuts  and  inflation
force us to  focus on energy  use by city departments.

     It is  likely that  many  of the conservation programs  being  sharply
reduced or  discontinued,   such  as the  Conservation  and  Solar  Bank,  the
Residential  Conservation  Service,  the  Weatherization  Program, the  Schools
and Hospitals  Program, and  the Energy  Extension Service —  will  leave  a
vacuum that  a local  government, or many local  governments —  cannot possi-
bly hope  to  fill.    For   example,   the  Schools  and  Hospials Program has
enabled Boston  to invest  in energy conservation measures in a  number of
city buildings, as well  as to train staff in energy auditing.    In  1980,
Boston received over  $100,000  under this program  for energy conservation
measures  in city facilities.   This program has saved Boston  a substantial
amount of money.   Without these funds  for energy improvements we would not
have been able  to do  this  work because we could not have targeted operating
monies  into such measures.

      In the area of consumer  energy conservation program, we believe that
an auditing program  such as the Residential Conservation  Service is essen-
tial  and  should not  be  eliminated.   In  Massachusetts,  the Residential


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Conservation Service  is law.  However, the  budget cutting  climate in our
state may also endanger this program.  The Residential Conservation Service
provides a nationwide mandate for energy conservation,  while relying upon
the private sector as the primary participant.  Elimination of this program
and the planned Commercial  and Apartment Conservation Service will leave a
gap that no city  or  state initiative can fill.  The federal committment to
conservation that  this program has  illustrated has been  essential to its
widespread acceptance and success.

     It is  difficult  to  assess the federal  government's proper  role  in
this time  of transition  while holding to  the belief  that  the  national
government is substantially altering  its energy role by  greatly  reducing
state and  local  conservation  programs.  The federal government's  role is
to set an example and be  a  leader  by providing consumers,  business, indus-
try, and local  governments  with  needed information,  assistance,  support,
and training.  It is  impossible  for us to  succeed at  building an energy
"capacity" in Boston  without the active support of the federal government.
We cannot  fill  the role  of helping the consumer, the  poor,  the  elderly,
and the business  person when we  are  struggling to initiate  and  maintain
our own energy efficiency programs.

     It is  neither  a  cost-effective  nor  a  compassionate  energy policy
which relies solely on marketplace prices and forces to encourage conserva-
tion without providing  the  incentives that traditional energy sources have
received for many years.  The transition that we will be experiencing as a
result of  the federal shift in  energy policy will  be  a painful  one.
ROBERT F. BLANKE
Orange and Rockland Utilities, Inc.
One Blue Hill Plaza
Pearl River, New York  10965

     Orange and Rockland  Utilities,  Inc.  has been promoting energy conser-
vation since 1973.  Other utilities have  sponsored interest-free loans for
energy conservation  prior  to any  federal/state  mandates.   Conservation
programs allow the  utility  industry to  maximize  existing plant  capacity
and defer the  cost  of building  new plants.  With  continued  high interest
rates, utilities,  on  their own  and without government  intervention,  will
continue to promote energy conservation as a cost effective means of main-
taining the lowest possible cost of the commodity they sell.

     New York  and New  Jersey,  two  states  in  which we sell  our energy,
presently have laws  requiring the promotion of  energy  conservation.   It
certainly would not be politically expedient for anyone to suggest abolish-
ing these laws.  Present indications are for expansion of existing programs.
New York presently has laws pending which  would require  totally free resi-
dential audits and  audits of  multi-family residences.  The  utilities  are
financing a  study of  existing  residential homes  in  the state to  deter-
mine the effect of our conservation program which  was  started in  August
1978.  The data  from this study  can  be   compared  with  a  pre-1978  study.


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     The residential  market  sector  will  receive most  of our  attention.
Both the commercial and industrial market sector should have enough incen-
tive to effect their own conservation program - wore profits.  If increased
profits don't move  this market toward more  conservation,  legislating laws
certainly won't move them  in install the measures either.   Let us remember
that audits don't save energy.

     The federal  government was  the catalyst  to  start this program and
should not  be involved in  its implementation.   Of  course,  the  federal
government could provide technical assistance in devising  the  criteria to
be used in  calcuating energy savings.   This  data would only be useful if
it were available on a regional basis, indicated savings that were realist-
ic, were  compatible  with   computer  programming,  and had  input from the
people who were going to use the data.

     Since the real test of this program's effectiveness is how many people
installed conservation  measures,   it  would  seem reasonable  to  develop  a
short questionnaire which  could be  completed by each  state's  lead agency
indicating the response on a statewide  basis.  The simpler the report, the
higher the  acceptance and  the greater  the probability all parties  will
respond.  Each state  should be able to  indicate  the  measures  covered, and
by comparing  one reporting  period  to  another,  it would  be possible  to
determine how programs are being expanded.
BARBARA BROWN
Solar Times, U.K. Correspondent
P.O. Box 56
APO New York, New York  09127

     Once again  I  want to  thank the  Environmental  Protection Agency  for
providing an avenue and encouragement for a private  citizen to participate
in an energy policy review.   I am adamant  about  the importance of private
citizen participation, taking  into account the  nature of the  problem  and
the democratic principles upon which our  nation is  founded.   The  views I
present are my own and not necessarily those of Solar Times.

     The scope of the energy problem and the benefits  of conservation are
still not nationally,  or internationally as far as that's concerned, under-
stood.  Statistics may now be  widely known, but neither public policies or
expenditures, nor private lifestyles mirror the understanding of the finite
resource of fossil fuel or  the political and social  implications  of energy
dependence, or the environmental  and economic benefits  of people employed
to supply  safe,  sufficient  energy and  efficient products  and processes.
There are increasingly more  individual examples  of this understanding,  but
energy conservation initiatives  need  to  be on a  national/international
scale and the rule not the exception.

     Actually America's realization of the problem and program initiatives
to combat  it have been notable,  but  this  is all the  more reason not to
abandon our  commitment - the  problem still  with us.   I am  in  agreement

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with the Administration's  view that is it time for state and local govern-
ments as well as industry to take on more of the commitment, but government
program priorities must continue  to support  the  importance of  conserva-
tion.  I disagree  with the premise that public spending  for conservation
buys us little  additional  security and  diverts capital, workers,  and ini-
tiatives form more productive uses  elsewhere  in the  economy.   I'm afraid
such thoughts  disregard the  benefits  of  conservation  (efficiency)  that
numerous valid  studies have shown.  It  comes  down to  basic disregard for
credible studies and  statistics.   The thought  that the private  sector will
take upon  itself the  initiatives  to  operate  efficiently  without  federal
encouragement to do so may eventually hold true, but I don't believe this
is the case at the present,  nor  will it happen  as prudently as  need be
without federal policy priority.   The fact is lifestyle  changes  take time
regardless of the  amount of directions  of incentives.  Transition from a
quantity to  quality lifestyle has  not happened  yet  and  adequate coopera-
tion between federal,  state,  local authorities and the private sector must
be achieved  first.  The adequacy  of attention  to conservation  must come
from everyone; no one sector can abandon their commitment.

     America's consumption  rate,  compared to  the rest of  the world,  and
America's influence upon world economics  justify the precise energy plan-
ning we have seen with the  creation of  the  Department  of Energy  and a
myriad of programs.   The direction may change from federal to  state and
local funding and  industry and private  initiatives,  but the need  is just
as prominent.

     Energy is  a  world problem.   Concern for German  independence upon a
proposed Soviet gas pipeline  to Germany,  employment  possibilities  of con-
servation projects in countries like  England  where  unemployment  is being
blamed for  current riots,  hardships of  the renewable energy and conserva-
tion innovators which postpone  or  stifle these  needed  developments,  all
bring home  the  need  for national  as well  as  international energy policy
coordination.

     The adequacy  of   attention to  conservation  should include  assessing
the social  and  environmental benefits  of conservation,  not ignoring the
world energy and economic  situation.  Unemployment is  a world  problem and
so is energy.   People  worldwide  are recognizing  the  opportunity  to help
solve thse  two  very   big  problems.   Conservation  and  renewable energy
initiatives do create  jobs.   (Giving everyone  the benefit  of the doubt of
being aware  of  the numerous  supportive American studies,  let me  list to
British studies that concur with the job creation potential of conservation
and renewables:)  Energy Options and Employment, by the Center for Alterna-
tive Industrial and Technological  Systems, North East London Polytechnic,
1979; and Earthworks;   Environmental Approaches to Employment Creation,  by
Edward B. Barbier,  Friends of the Earth Ltd.,  1981.

     Many federal  officials seem to think that employment  has  no business
being a criterion  for energy  policy formulation,  but I believe they are
ignoring the fact  that no  segment of  society functions in isolation.   I
agree with the  Environmentalists  for Full Employment belief that any plan
for economic revitalization include a major investment in energy conserva-


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tion and  renewable;  that such  an investment would help  meet much  of our
energy needs,  stimulate  the economy  and enhance productivity,  and  create
large numbers of jobs.

     I've been  an  Air Force  dependent  wife  for 14  years,  a resident  of
military family housing  for over 8 years,  and involved  with conservation
and renewable  pro-initiatives  since  1977,  including the Military  Family
Housing Energy  Conservation Project since  1979.   I  can  say, with  what I
believe is valid  insight,  that adequate attention is  not being  given  to
energy conservation  by the Department  of  Defense,   specifically  military
family housing.  Energy   conservation facility  management practices  have
been forthcoming, but few initiatives  have been taken  to communicate conser-
vation adequately to family housing residents.  Military jobs coud be crea-
ted to present conservation as  adequately as fire prevention is presented.
With the increased DOD budget, I hope to see priority given to conservation
and renewables.  I think an increased awareness of the benefits  of conser-
vation for the military  community would perpetuate a better understanding
of the security benefits of conservation.

     Let me give one final  example  of a  security connection as well as the
importance of international cooperation  in  developing conservation priori-
ties.  Recently a  journalist  for a major British newspaper warned me that
many of his  anti-nuclear associates  would  not want to work  with me  on
pro-conservation and  renewable  projects,  not  because they  didn't  agree
with the importance  of such initiatives, but because I am an American! His
associates did  not want the American military  in the U.K.   and were even
questioning the benefits of the  NATO  alliance.   The   journalist  covers
Central America.

     Thank you  for the  opportunity to  present  my views.    If  anyone has
questions about any  of  my testimony,  please  feel  free to contact me.
ART CANTRALL
Acting Administrator
Economic Opportunity Division
State of Washington
Planning and Community Affairs Agency
400 Capitol Center Building
Olympia, Washington  98504

     Our agency administers  the weatherization  and Low Income  Energy As-
sistance Program  (LIEAP)  so  our remarks  will  be confined  to those two
areas.  Within the last year, weatherization has truly  become an effective
and efficient program in the  state  of Washington.   Up until Deceiriber 1980,
the weatherization  program was continuing  to  increase  production  to  a
point that over 600 dwellings per month  were being completed.  At the same
time technical expertise  had increased  to a degree  where our  crews were
able to do an  effective job  of weatherizing nearly any type of dwelling.
From an analysis of the energy savings achieved,  the low income weatheriza-
tion program has become cost-effective in terms of the energy costs for the


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recipient.  Fran our view, which is  shared  by  our Governor, weatherization
is certainly  a worthwhile program  that  is  worthy of  being  continued.

     LIEAP provides a very vital  service to our  low  income citizens.   The
program has gone quite well,  specifically when compared to similar programs
in the past.  local activities provide the  important  function  of identify-
ing those individuals  who quality  for  LIEAP  but are  not receiving  some
other form of public assistance.

     In response to  your specific questions the following  information  is
provided:

     1)  Funding mechanisms and structural issues:

         a.   Weatherization funding  needs  to  be specifically identified.
             If weatherization is  authorized  but  rolled  into  emergency
             energy assistance, the immediate priorities (emergency assist-
             ance)  in light of limited funds will take precedence over the
             long range weatherization measures.   We would like to see  a
             specific percentage  that must  be dedicated to weatherization
             with the flexibility to use additional funds if the individual
             state so chooses.

         b.   We have been examining this  issue in some detail.   Washington
             currently works   through 4   local  governments,  18  community
             action agencies.   For  the  most part,  these  agencies  remain
             the best  suited  to  continue  the weatherization  program  in
             their local areas.  Some modifications  may be necessary  such
             as a careful evaluation of  required  administrative  costs,  but
             the expertise,  outreach capabilities etc.  would be preserved.

         c.   Unless major  policy  operation changes result,  transferring
             the program should  not be  much  of a  problem.   However,  if
             weatherization funds are not fence,  a  new agency's priorities
             may reduce the program substantially.

     2)  Implementation issues:

         a.   Under  Department of Energy property  guidelines, the tools  and
             equipment revert  of the grantee  (state) as long  as they  are
             used  for weatherization purposes.   It  is our intention  to
             transfer equipment,  tools,  and in some  cases,  people to whom-
             ever will continue low income  weatherization.   The procedures
             to accomplish  this transfer  are in place  and have been  used
             in several  instances.

         b.   Yes.   By  coordinating  LIEAP and  weatherization efforts,  the
             energy cost burden is reduced for  a  long term.

         c.   We feel the current  levels of funding are optimum.   Some addi-
             itional flexibility  to  allow   certain  additional  funds   for
             repairs would  be  desirable.   A lesser  investment  would  not


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             achieve the  long  term  energy savings  that  the program  now
             accomplishes.

         d.  Although CETA has contributed significantly to weatherization,
             the program can be maintained on a  cost effective basis with-
             out CETA support.  If CETA support does become  available,  it
             could be used effectively.  Several programs have operated in
             Washington without CETA.  Our experience has  been the the  job
             can still  be done without an  inordinant  increase in  labor
             costs when you consider the number of homes weatherized during
             a specified time has  increased compared to homes completed by
             CETA personnel during the same time frame.

     If you want any other specific  information  or statistics, please call
me at (206) 753-4979.
CLIFFORD P. CASE, III
President
National Recycling Coalition, Inc.
45 Rockefeller Plaza
Room 2350
New York, New York  10020

     My name  is  Clifford P.  Case, III.   I  am President  of the  National
Recyclying Coalition, a nationwide  grouping  of organizations and individu-
als in 45  states,  dedicated to the increased recyclying and  conservation
of all of  our resources.   I am submitting this statement on behalf of the
Coalition to assist  EPA in  its obligation under Section 11  of  the Federal
Non-Nuclear Energy  Research and  Development Act to  analyze the  adequacy
of attention to  energy  conservation in the United States, particularly by
the federal government.

     The Coalition believes  this  hearing  is  particularly timely,  since the
significance of energy conservation as an important element of governmental
policy is  under  increasing  attack at  precisely the  time  when  spiraling
costs of both imported energy and new energy  sources  should  be forcing all
of us to pay more,  rather  than  less,  attention  to  energy  conservation.

     Naturally, we  at the  National Recycling  Coalition want  to  promote
energy conservation  through greater  recycling of  wastes.   The  potential
for saving energy in this field is truly immense,  and  as of yet only barely
tapped.   Most people are aware that use of scrap rather than virgin materi-
als in manufacturing products  saves energy,  but they  are generally unaware
of the extent to which these energy savings  can mount up.   For example, if
recycling of  steel  increased by  one-half and recycling of  paper  tripled,
energy equal to  500,000 barrels  of oil a day would be  saved.   At current
world oil  prices,  these savings  would be worth approximately  $6  billion
each year!  This amount of  energy is also the equivalent of the output of
14 nuclear power plants.
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     Naturally, this  kind  of  major  commitment  to  increased  recyclying
could not be achieved overnight, and the capital costs would be significant,
but it seems clear to us that these  inceased  costs  would be far outweighed
by the benefits  to  society which  would accrue, both financial and  non-
financial, in terms  of  enhancement  of  our national security  through  less
reliance upon imports,  reduction of waste and pollution, and  creation  of
increased job opportunities within the  recycling  industry,  particularly  in
our depressed urban areas.

     In any such major shift to recycling,  a  number of parties must parti-
cipate.  Industrial participation is,  of course, pre-eminent,  since it  is
the basic industries of the United  States which must make  the investments
necessary to permit them to use  greatly increased quantities of scrap,  but
government has a very significant role to play as well—by documenting the
benefits of  a national  recycling  policy; providing   incentives  and  tax
benefits to  industry to  stimulate  the  necessary  investment  in  greater
recycling capacity;  promoting waste disposal  policies  at  the  local level
which will assist in supplying the necessary raw materials for such a recy-
cling increase; and  stimulating the  market  for recycled products by appro-
priate purchasing policies at all levels.

     It is with great regret that we must state that the level of perform-
ance of the government in this area has  been abysmal.  The federal Department
of Energy has shown  little  or no interest  in  documenting through reliable
studies the extent  of energy conservation possible through recycling,  or
in investigating the necessary  capital  investment costs to achieve such an
increase.  In  fixing targets  for  the use  of  scrap   in energy-intensive
industries, DOE  completely  reneged  on  its  statutory  responsibilities,
fixing goals which  enshrined the status  quo  in the face of a  variety  of
economic and other trends which will of necessity make increased recycling
both economic  as  well  as  attractive  from a  policy  standpoint.  EPA  has
failed in  its  statutory  responsibility  to issue  guidelines   for  federal
procurement of recycled products,  four  years after the  statute requiring
issuance of those  guidelines, the Resource Conservation  and Recovery  Act,
was passed.  Both  DOE and  EPA have  fostered  local  waste disposal policies
which emphasize incinerating garbage, thereby  making recovery  of materials
difficult-in the case of  metals and glass—or impossible—in the case  of
paper.  What increases in recycling  have come about have been due to local
initiatives carried  out with little or no  assistance,  either  technical  or
financial, from higher levels of government.

     We believe the facts  speak for  themselves.  Total reliance  on  the
production of new  energy and importation of energy from abroad are a per-
fect blueprint for disaster  insofar as  the  United States is concerned.
Energy conservation through recycling represents an almost untapped resource
in this  country,  when  the  actuality of  industrial recycling  is compared
with its potential.  We urge EPA to at once establish  a program to docu-
ment the  extent  of  the benefits  possible through  recycling  and  provide
reasonable technical  and  financial  assistance to  those parties who  are
working and will  continue  to work  to  make increased recycling a reality.
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     For further information:   Clifford  P. Case,  III,  President, the  Na-
tional Recycling Coalition,  Inc.,  45 Rockefeller  Plaza,  Room 2350,  New
York, New York 10111.  Telephone (212) 765-1054.
EDITH CHASE
Energy Chair
League of Vfamen Voters of Ohio
65 South Fourth Street
Columbus, Ohio  43215

     The League of Women  Voters  of Ohio has studied energy since  1974 and
believes that top priority must be given to energy conservation and renewable
resources.  The EPA Issue Paper  summarized a great deal  of valuable infor-
mation.  Because the  Reagan  administration's  National Energy  Plan III has
just been released and I do not have a copy, I would like to comment brief-
ly on  the March  1981  DOE   statements  on  pages  4-5  of  this EPA  paper.

     There is no goal  nor statement of purpose given.   The League recommends
that not  only as a responsible member  of the world community but also in
the national  interest,  the United  States must make a  significant  and pro-
gressive reduction in its energy growth  rate.   To achieve this  goal, the
nation must  develop   and  implement  energy strategies  that—while  taking
account of differences  in the needs and resources of  states  and regions—
give precedence to the national  good.   In developing  national energy stra-
tegies, the  federal government should spread costs and  benefits  (environ-
mental, social,  economic, health)  as equitably as  possible.   In keeping
with this  criterion,   states and  regions  should  take  steps  to  maximize
conservation  and to  utilize  their indigenous, renewable resources.   There
should be  assistance  for low-income  individuals,  when  changes  would bear
unduly on the poor.

     We certainly agree  that "the government's role is  to establish sound
public policies, based  on economic principles, national  security concerns,
and a due regard for environmental  values,  so that individuals  and firms
in the private sector have the  incentives to produce and  conserve energy
efficiently,  consistent with the national interest."

     "The nation's energy problems will be solved primarily by the American
people themselves—by consumers, workers, managers, inventors  and  investors
in the private sector."  Yes, but these  actions will  be within the frame-
work set  up by the government,  whatever  energy policies are established.
It is also important  to recognize that the government is a major consumer
of energy  and,  as such, must set a  good example and take actions that are
being requested of all other consumers.  The first step  should be  an inven-
tory of  energy consumption and energy conservation measures being taken by
each department  of the federal  government and an analysis of procurement
policies.  This  report  should  be  published  and  steps   taken to conserve
energy on  the basis of the findings.
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     If_ "The government's role is not to select and promote favored sources
of energy,"  then we question  the insistence  on  the Clinch  River Breeder
Reactor project—another $250 million requested  in this budget, eventually
$3 billion or more.  Yet the electricity it  generates will be so expensive
that it  will have  to  be sold  at far  below cost.   (Wall  Street Journal,
7-1781)  In  addition,   spending   for  nuclear  fission  for  FY  1981  totals
$2.1 billion, an extra  $500 million over the proposed budget for the Nucle-
ar Regulatory  Commission for additional  inspection  as a result  of Three
Mile Island.  In  addition,  annual federal government subsidies in support
of routine energy  supplies  totalled  over $6 billion  in 1977,  according to
Robert H.  Williams of  Princeton  University  (see attached table).   Sub-
sidies included  activities  such  as low  interest appropriations  plus tax
exemptions for hydroelectric and  transmission facilities,  uranium enrich-
ment services, liberalized  depreciation for privately-owned utilities, tax
exemption for publicly-owned  utilities, and  depletion allowances for oil
and gas  (Energy  Conservation  Coalition  Bulletin,   June/July 1981).   If
government subsidies are to be withdrawn  for energy conservation programs,
then the other subsidies  should also be eliminated.   Unless federal  subsi-
dies are removed from other sources  of  energy, this experiment of delegat-
ing all  responsibility  and  funding  for energy  conservation  to  state and
local governments is obviously an experiment designed to fall.

     Energy conservation includes  energy  efficiency  or energy productivity
and refers to getting  from the energy  we use, not  to a back-to-the-caves
reduction in amenities.   It means more efficient  and durable automobiles,
buildings and appliances; greater emphasis  by industry on the cogeneration
of electricity and process  steam, and on  the  development  of new,  more
efficent industrial processes;  and a major  focus on  recycling and resource
recovery.  The good news  is that, if  we take energy productivity seriously
we can have a healthy,  expanding  economy  in the  coming decades with energy
growth far below that predicted only a few years ago.  The Harvard Business
School's Energy Future  (1980) points  out that increases  in the productive
efficiency of energy possible with today's technology could allow the U.S.
economy to operate on  30 to 40 percent less energy  than it now  does, and
still enjoy the  same  or an even  higher standard of  living.   "The cost of
conservation energy is  very competitive with other  energy sources,"  said
Harvard's Daniel Yergin.  "Conservation may well be  the  cheapest, safest,
most productive  energy  alternative readily available in  large amounts....
And contrary to the conventional wisdom, conservation can stimulate innova-
tion, employment,  and  economic growth.  Since  the  United  States  uses a
third of all the oil used in the  world  every day, major  reduction in U.S.
demand would have a major impact on the international markets."

     With the cooperation of  all  levels of  government, business,  industry
and an informed public on a  vigorous program of energy conservation,  every-
one will benefit from the wise use of our energy resources.

GENERAL QUESTIONS

     Q. How are private firms,  state governments, and  local agencies pre-
paring to assume their  new responsibilities?


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                                     FIGURE  1
                 Meanwhile, on  the Supply Side

      The following estimate of annual federal government subsidies in support of routine energy
    supplies in 1977  was prepared by Robert H. Williams of Princeton University. It provides a
    useful benchmark for measuring progress, or lack of progress, toward a free energy market.  '  .

    Federal Activities                                                (million 1977 dollars)
    Low interest appropriations plus tax exemptions for hydroelectric and
    transmission facilities             '                .                              290

    Uranium enrichment services   .                                                  180
    Nuclear Regulatory Commission regulatory costs   .                                  146

    Privately-Owned  Utilities
    Liberalized depreciation for Federal tax purposes                                    2000

    Publicly-Owned Utilities
    Exemption from federal income taxes
    • Tennessee Valley Authority (TVA)                                               130
    • State power authorities and municipal utilities                                      80
    • Rural Electric Administration (REA)                             '               294 ..

    Tax-exempt bond subsidies        '                                             260 :

    Loans and loan guarantees provided by REA •           .                             260

    Oil and Gas Industries                                            •.             •'-',
    Percentage depletion allowance on Federal taxes
    • Oil                       •                                                 550
    • Gas                               '                                       1150

    Expensing of intangible exploration and development costs for Federal tax purposes
    •Oil   -..                    '       -.                                        740 .
    • Gas                                                                       460

    TOTAL                                                                     6540 !
From  the  Energy Conservation  Bulletin,  June/July  1981
                                         350,

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     A. Private firms:  Private firms have, of  necessity,  taken  many steps
to conserve energy during the last several years.   Private reserch results
and expertise must be kept in-house rather than shared  with other firms in
order to  keep a  competitive advantage.   While large  firms may  have the
technical staff, small  firms would  need technical assistance,  flany energy
conservation/energy efficiency  measures require  capital  expenditures  and
must compete  in  corporate  budgets  with  other  projects  when  the prime
interest rate hovers around  20%.   Trade associations are  a possibility; I
have no information regarding their activities.

        Utilities:  In some sections of the country, forward-looking utili-
ties have recognized  that increasing costs  of  construction  mean  that new
power plants are more  expensive than  energy conservation/energy efficiency
measures as a means of  meeting  energy needs  (e.g., New England, California).
For example,  "Duke Power will put  even more  emphasis  on  its peak load
management program and  less on financing  power plant  construction.  "The
less they need to finance, the better for the company and the stockholders,'
M. Liu said."  (Wall Street Journal, 2-25-81).

        On the other hand, James McCarroll, manager, Health Effects Program,
Electric Power  Research  Institute,   comments:    "Conservation  and  energy
shortfalls can have tragic results for  the very  old and very young.  Cutting
the thermostat back a relatively few degrees can especially in the elderly,
produce hypothermia." (Science, July 10,  1981,  p.  197)  EPRI, under the new
federal policies,  should look  far  beyond turning  the thermostat  down  if
the private sector is to assume their new responsibilities.

         State governments;   States are expected to play  a  larger role in
energy regulation and in devising energy programs for low-income and elerly
households in  the  next  few years.   Economic  conditions  in the  state  of
Ohio, however,  have resulted  in  a  budget  crunch.   Legislators  passed a
four-month interim budget in July after they  failed to agree on  a budget
for the  biennium.   In  spite of  inflation,  the  new budget  cuts  existing
levels of state  spending by  3  percent  except for schools and welfare  (Kent
Record-Courier, 7-2-81).  There is  no  room in  the budget to pick  up new
programs, such as  energy conservation,  unless existing  programs  are cut or
taxes increased, both  politically difficult  tasks.   In  addition, two bills
have been introduced to eliminate the Ohio Department of Energy and scatter
the functions  among  various other  agencies.   The League  objected to this
because of  the increased need  to coordinate efforts  to  deal with energy
problems and to  promote the efficient  utilization  of energy.   Whether or
not these  bills  are  enacted,  there  is  little leadership  at  the state
level to promote energy conservation.

     The Ohio  Department of Energy has an energy  audit program,  prepares
an annual energy  conservation  plan  (but never  evaluates  its results), and
carries out other  federally mandated  programs,  mostly  with federal funds.
When federal  support of  a   used  oil  recovery  program  was  withdrawn,  it
became a voluntary program in Ohio.  The task force representing a variety
of interests  recommended support  but  no  legislation is  being  introduced
that requires any new funding.
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     Ohio's Energy Credits Program, begun on  a  demonstration basis in 1977
and now permanent, provides  25 to  30  percent discounts on  winter heating
bills for low-income elderly or disabled utility  company customers through
vendor-lines-of-credit or onetime  cash payments  of  $125  for retail  fuel
dealer customers.  Last winter  some 350,000  households  statewide received
benefits from  the  program,   which  is   funded  by  state  appropriation.

     Such programs are an  important  "safety net"  but are a  continuing
expense.  On the  other hand,  weatherization programs,  increasingly effec-
tive, result in  a significant decrease in energy consumption  and increase
the ability of  low-income people and  the  elderly to become self-reliant.
Federal funding  for  weatherization is being  withdrawn, to  be included  in
block grants with less total dollars.   Said Charles Royer, Mayor of Seattle,
"The real point  is that we are going  to  get local  responsibility with  25
percent less money and no practical means to replace it with local revenues."
(Wall Street Journal, 7-16-81).

     Neither Congress nor the market place  has yet  come up  with solutions
to the problem of weatherization of rental housing:  why should the landlord
pay for energy conservation measures when the tenant pays for the utilities?

     Local governments:  flany options  are available  for local governments
to encourage energy conservation, such as building and  zoning codes, audit
and retrofit  of  public  buildings,  public  education, transit investment,
carpool matching, and  demonstation  projects  for  neighborhoods,  businesses
and industry.  Some of the obstacles to carrying out these programs include
lack of funds,  lack  of  expertise,  lack  of  public  awareness, and resist-
ance to change.   A phased rather than  sudden  withdrawal of federal support
and assistance  would  facilitate the turnover  of responsibility  to local
governments.

     Q. Which activities will get  priority  from public and private organi-
zations and what will be the consequence?

     A. If  present trends  continue,  energy  supply activities will  far
overshadow energy activities, on the part of both public  and  private sec-
tors.  The energy supply  industry  is well established and  is  populated  by
many large  firms  capable  of  doing some research  and development.   The
energy efficiency  industry  is  in   an  embryonic  state  of development,  so
that private  sector  research and  development capabilities  are especially
limited.  In the  building construction industry, for example, technological
innovation is  particularly  difficult  because the  industry is  fragmented
and tradition-oriented.  The federal energy  efficiency  research and devel-
opment effort is far from adequate today.  A federal program with anything
more than modest cuts at this  time would have a devastating long-term impact
on U.S. economy.

     The opportunities  for technological  innovation  in  energy conservation
are far greater than in the  area  of  new supply.  The problem  of runaway
energy inflation  can be greatly mitigated  if the opportunities for cost-
effective energy  conservation investments are  exploited.    The  reason for
this is that it  is possible to achieve a high level of fuel  savings through


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energy efficiency  improvements  at  much  less  cost  than  is  required to
provide energy  from  new sources of energy supply.  The high cost for new
energy supplies reflects  the skyrocketing costs  for  the capital needed to
exploit lew  grade energy  resource alternatives  to  low-cost oil  and gas.
Because of these  rising capital costs  and government subsidies for energy
supply expansion,  there "has been  a continuing  dramatic shift of capital
resources in our  economy to the energy supply  sector.   This ongoing shift
in capital resources contributes to the  scarcity of  capital for nonenergy
investments, which  are  needed  for  industrial  renewal.    (NRDC,  Amicus
Journal, Summer 1981, p. 10-12).

     Consequences:   See  "State  and  Local  Conservation  Activities,  #2.

     Q. Have any new initiatives or opportunities been created as a result
of the shift in federal energy conservation programs?

     A. The opportunities have been there all along.   The question of what
gets done depends  in large  measure on the resources devoted to the various
options.  Funding, attention and other  resources are rather unbalanced at
this time and  becoming more so  with abrupt federal  rescission of FY 1981
funds and drastic reductions in FY  1982 conservation programs.

     C> What  is the  federal government's proper role  in this period of
transition?

     A. To set long-term goals and policies;
        to exert leadership;
        to monitor  and evaluate  results, including  costs to  society and
national security;
        to continue  research and development on  energy-efficient technolo-
gies;
        to provide  technical assistance to  state and  local governments,
business, individuals;
        to monitor   interstate  and  international  impacts  and  recommend
actions;
        to revise  federal procurement  policies and other measures to con-
serve energy;
        to regulate and manage wastes from energy production;
        to set mandatory standards  for energy conservation;
        to use  tax  incentives,  tax disincentives  and loan  guarantees to
encourage business,  industry and individual  consumer to  conserve energy;
        to provide  for  and encourage   citizen  participation  in  decision
making.

     Federal standards and  compliance  timetables that protect the environ-
ment should not be relaxed in pursuit of national energy goals.

     Q. How should the  federal  government evaluate and monitor the effects
of its new energy policies and program changes?

     A. Detailed data collection programs, with quality assurance of data,
must be  continued and/or  initiated  on  energy  usage,  energy  supply  and


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costs; import/export data;  research and development by public  and private
sectors; effects on  environment and public health; world  energy usage and
economic conditions.  In addition,  hold public hearings and ask for citi-
zens to corrtnent at regular intervals.

     It will be  important  to be able to compare the  effect of the changed
policies on  national security  and  international  tensions and  in meeting
the needs of the country  and its  citizens  in an  equitable manner.  When
does the  Reagan  administration plan  to  addres  the issue  of renewable
resources?

STATE AND LOCAL CONSERVATION ACTIVITIES

     !_. Which  of the  functions  formerly  performed  by   federally  funded
programs are likely to be picked up by the state energy offices?  By cities
and counties?  By the private sector?

     A. Energy Impact Assistance;   The  impact  of  strip mining  of coal is a
continuing problem in  Ohio, .not a  sudden new development.  The state law
was superseded by the  federal law  for  restoration and  reclamation.   It is
extremely important  that  reclamation  be firmly  enforced as  strip mining
proceeds in  order to  prevent the  devastation,  erosion  and  sedimentation
and acid mine drainage of the abandoned  lands  in the state.   Other than
that, local governments will be left to cope as best they can.

        Schools and hospitals program:  We support continuance of this pro-
gram, as budgeted.   The  emphasis in Ohio  is to keep  schools  open.  State
Senator Marcus  Roberto  reports  that,   without additional revenue,  more
than 250 of  Ohio's  615 school districts will  likely  be unable  to complete
their calendar year  in the black.  There is only so much that can be cut
out of a school program before it becomes substandard.  (Kent Record Cour-
ier, 6-27-81).   Under  these  circumstances  even important maintenance and
energy conservation projects will be deferred by schools.

        Weatherization Assistance Program:   In view of tight state finances,
any weatherization  programs  will  be  left  to local  governments  to find
funds out of reduced block grants.  See page 3.

        State Energy Conservation Program;   Although dedicated Ohio  Depart-
ment of Energy (ODOE)  staff members have tried to follow state  and  federal
laws  for State Energy Conservation Programs,  the lack  of support  and  leader-
ship by top  state political leaders has rendered efforts largely  ineffect-
ive.  Although  several public hearings wee  scheduled  in  April on the 1981
proposed state  energy  conservation plan,  I  was unable  to get a copy in
order to  prepare comments.  The  public,  reflecting such  attitudes, has
greeted these  efforts  with a  large ho-hum.   Coordination with  other  state
agencies has been  limited and measures  required  under  state  and  federal
laws have  been  neglected,  such as  changes  in procurement  policies and
evaluation of utility  rate structure.

        On the other hand,  ODOE's request  for  proposals under  the federally
funded energy conservation program for innovative public  education,  trans-

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portation, industry,  local  government and  other  projects has  met  with
enthusiastic response.  At the public meeting in Cleveland on July  7, 43
people were present to get  information on how to apply; two other meetings
were held  (Cincinnati,  Columbus);  deadline  for proposals  is August  21,
1981.  If federal funding is dropped, the state is not expected to continue
this program.   Local  governments  and the private  sector  would focus on
their own short-term needs, as limited resources permit.

        Energy Extension Service;  Although  personalized  information  and
technical assistance to individuals, small businesses and local governments
can pay big  dividends  in  terms of  energy and dollar savings,  I  would not
expect this  program to  receive state  or  local government  funding.   As an
example, I have been a member  of the task force for two years for the Kent
Solar Project, funded by  Argonne National Laboratory.  The project's  basic
goal is to develop a plan for  conservation of energy and  use of alternate
energy sources in Kent.   The project has  been completed and the task  force
is continuing to meet on  a voluntary basis to try to implement recommenda-
tions.  One  important recommendation,  to  establish  a Kent Energy Office, a
focal point  to continue efforts,  may not survive,  a  result of the effects
of inflation and dwindling tax base on the city budget.

        Emergency Energy Conservation Planning;  I  would expect  the  state
to maintain a minimum effort.

        Residential Conservation Service;   Under the  National  Energy  Con-
servation Act approved by Congress in 1979, all large and some small utili-
ty companies are required to help  customers  decide  what improvements  could
help customers have energy and money.  While Ohio utilities  have  had two
years to make plans for  the startup of this program on July 1, 1981, they
have requested  and  received  extensions   for mailing  notices  of  avail-
ability of audits.  Ohio  Edison Co. plans to start a pilot program in late
August.  Notices to all  customers  should be  completed by the end of the
year, according to a  company  spokesman.   East Ohio Gas  Co.  also received
a 60-day extension; customers  are  to be  sent  notices about the project in
monthly cycles until  all  customers are served.   Both plan  to charge $15.
(Akron Beacon-Journal, 7-17-81).

     _2. What will be the effects if a state decides to phase out its energy
office?  Which activities will be discontinued?

     A. Effects would include fragmentation of energy conservation efforts,
lack of coordination,  lack of  public  education and  technical assistance,
continued unemployment, increased  energy  expenditures  by state  and  local
governments and  the  private  sector,  preempting   capital  investment  and
operating funds  for  other,  more productive,  uses; reduction  in economic
vitality.

        I would expect  that discontinued activities  would include all of
these listed  above  except for  a  minimal  effort  on  emergency  planning.

     ^. How can local governments transfer the state experience and resour-
ces to" the development and implementation of local programs?

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     A. In general, the energy  audit program has  been very useful.  Imple-
mentation will depend  on local  budgets,  priorities  set in  block grants,
and citizen initiatives, all at short notice.

     ^. How will the 21 states  that have  biennial budgets adapt to the new
federal priorities?  What is the consequence of their operating on a bien-
nial budget likely to have on this ajustment?

     A. Ohio has a biennial budget but  was unable to agree on a budget for
this Tiscal year.  Therefore the General  Assembly passed an interim budget
for four  months.   Legislators  will  meet again  in September.   Thus,  the
problem will not be  the timing but revenue  shortfall,  because of economic
conditions.

     5_. How can information, experience and  resources  be shared regionally
after~~the discontinuation of the DOE Regional Offices?

     A. Can agreement  be worked out  before discontinuation  for an annual
get-together of representatives from the states in each region?  Otherwise,
newsletters, computer  information  systems,  circulating  libraries,  circuit
riders and liaison personnel, regional or  national conferences and meetings.

     6_. Can alternative funding  sources be  found  for  conservation activi-
ties?"

     A. The private  sector  presents the most  opportunities.   Carefully
design~ed federal and state tax  incentives, disincentives,  and loan guaran-
tees would encourage business, industry and individual consumers  to conserve
energy and to shift toward the development and use of renewable resources.
With leadership, planning  and  technical  assistance  from the  federal and
state government, the private sector, especially  utilities, can make long-
range plans to  meet real  energy needs  (not inflated demand)  in the most
cost-effective way.  Energy  conservation has  been repeatedly  shown  to be
the most cost-effective means to meet needs  if_ life-cycle costing is consi-
dered and  rf  federal   subsidies  and  other  distortions  (e.g., declining
block ratesfor  electricity)  are  removed.   The  marketplace  could  then
bring economically efficient decisions.

ISSUES FOR THE 1981 SECTION 11 REVIEW

     1. Funding mechanisms and structural issues

        a.   In light of the proposed changes,  how can the nation maintain
an effective low-income weatherization program?

             A.   The League strongly  advocates  weatherization as a means
of cutting energy costs.  Alternatives:    funds from a very small percentage
of the Windfall Profits Tax; mandatory federal standards for energy conser-
vation; possible local  mandatory requirements for energy conservation, as
part of  a comprehensive energy  plan;  strongly encourage public utilities
to set up their own loan programs for weatherization,  repaid in the custo-
mer's regular bill and in reduced capital requirements for expensive facil-

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ities that won't have to be built.  Encourage formation of local  weatheri-
zation coops,  with members contributing  labor,  materials or  money.   Fund
the Solar and Conservation Bank as approved by Congress.

        b.   If weatherization is transferred into HUD Community Development
Block Grant,  what agencies would be  effective  sponsors at  the community
level?

             A.   Community Action Agencies, local groups.

        c.   How can problems involved in transferring the program from one
agency to another be minimized?

             A.   Provide transition funding so that personnel from the new
agency may work with the  existing  agency  before transfer of the program;
training programs  for   personnel in  the new  agency,   including hands-on
training; transfers of a  few  key personnel from the old to the new agency.

     2. Implementation issues

        a.   If a state decides to phase out Community Action Agencies, how
can their resources and experience be transferred to the new weatherization
sponsor?

             A.   Same as I.e.

        b.   Should LIEAP funds be utilized for weatherization? How can the
LIEAP program coordinate  its  activities with the weatherization program at
the state and/or local level?

             A.   LIEAP funds could be used for weatherization. However, if
totals are  to be  cut  by 25%,  this  will not  be a  significant  source.

        c.   What is the most  equitable and cost-effective  weatherization
program?  Should  the federal  government  continue  to provide substantial
assistance ($1000-200/unit) to a  relative  small number  of  houses?   Or,
should the program be restructured  to provide minimal weatherization  ($200
-300) to a larger number of units?

             A.   Public education  on  energy  conservation must  be on an
essential element of any program.  Criteria  for  selection of houses should
be evaluated.  I  believe that  substantial assistance  should be provided
to a relatively  small number  of houses,  calculating pay-back.  A rotary
fund should be set up;  recipients of  this assistance would pay  what they
were able, knowing that  all funds  in this account would be  used  to help
more people.  Public participation is  essential;  people  for  whom community
action programs are designed should  be involved  in the planning and imple-
mentation of those programs.

        d.   How can CETA workers be retained in the  weatherization indus-
try?


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             A.   A  strong  energy  conservation  program  is  labor  inten-
sive.  Employment would increase, with job openings for those who have skills
in weatherization.

SUNSET PROVISIONS

     1. What  information  is  necessary to enable the  federal  government to
monitor and evaluate the  effects of changes in energy policy and conserva-
tion programs?   For example,  should DOE monitor  whether  state  and local
agencies continue important conservation activities?  Whether private firms
continue conservation  R&D?   Whether  homeowners  continue  to  invest  in
conservation improvements?

        A.   Yes, those items listed.  Also, information should be compiled
on energy  consumption  by  category  (residential,  commercial,  industry,
transportation, etc.), and per  capita  energy consumption.  Detailed infor-
mation should also  be  compiled on the energy  consumed  by the federal gov-
ernment, by category,  for several  years.   As  a major  consumer of energy,
the federal  government  should  set and  meet energy  conservation  goals.

     2. What types of  regular monitoring and special studies would be most
appropriate for obtaining this information? —

     3. How can this information be gathered without placing a major paper-
work burden on respondent organizations?

        A.   Much of this information is probably already collected but may
not be in a form compatible with  the system used.  Quality assurance of data
and compatibility would reduce paperwork.

     4. Regarding the Sunset review, what  are the most important questions
in the  Sunset Provisions?   What  would constitute  adequate  responses  to
these questions?   What  types  of  analyses  should  the response  contain?
What types of data should be  included?  What level of detail  is needed?

        A.   All of the  questions are useful.  In my opinion, the most im-
portant are:

             2)  an identification  of the  objectives intended for the pro-
gram and  the  problem or  need  which the program was intended  to address;

                  — Ihe purpose must be clear.

             4)  an assessment of alternative methods of achieving the pur-
poses of the program;

                  — Often a weak link, with serious omissions in identify-
ing alternatives.   Nonstructural  alternatives  sometimes  are  much  less
costly than structural alternatives.

             6)   an assessment of the degree to which  the original object-
ives of the program have been achieved ...


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                  — To measure results.

             10)  an assessment of the impact of  the program on the nation's
health and safety;

                  — Include  social,  economic,   energy  and  environmental
effects, including  secondary  impacts.  I  would  also  suggest  evaluating
effects on employment.

             13)  an analysis  of the services which  could  be provided and
performance which  could be  achieved  if  the program  were continued  at a
level less than, equal to, or greater than the existing level;

                  — Useful for the budget process.

     I see this  review  as a broad overview  and  assessment, very important
on a periodic basis.  It  should  not  get bogged down in detail.  The answer
to each  Sunset question  could  be limited  to two  pieces  of paper,  with
details in  appendices.   I  recommend  adding question  #15:  Findings and
conclusions based on the above review.

     Thank you for this opportunity to express our views.

      *************

ALBERT B. CSONKA
President
Micro-Carburetor Corporation
25 Rano Street
Buffalo, New York  14207

     The Micro-Carburetor  Corporation is a  pure research  and  development
organization, dealing only with fuel-saving and pollution-reducing carbure-
tors.  The company owns the patent rights  of the Micro-Carburetor.  Upon a
small DOE contract  and  a still  smaller N.Y. State contract,  we developed
two Micro-Carburetor prototypes  for  two large 8-cylinder  engines,  as pre-
scribed by the contracts.

     The Jet  Propulsion  Laboratory,  Pasadena,  CA  performed  a  year-long
testing program  with the  Micro-Carburetor.   According  to their  interim
report, prepared for the Energy Department, our caburetor saves 12 percent
fuel and increases the car's mileage by 13 percent. Their final report will
be sent to DOE in July 1981.  This report will confirm the mentioned excel-
lent savings.  We are convinced that with some  more experiments we could
increase the fuel-saving to at least 15  percent  and  further  reduce  the
emission figures.

     If Micro-Carburetors were in general use, our crude-oil imports could
be reduced by over one-million barrels daily.  This  means  that  with  the
present oilprices,our trade-deficit would be reduced by 12-billion dol-
lars yearly.  This savings would greatly reduce the inflation.

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     During our development  work, U.S.  carmakers had  to change  to  small
cars that use  four-cylinder engines.   It  is in the  country's  roost urgent
interest to  make  these  cars  as fuel-efficient  as  possible.   Properly
developed Micro-Carburetors can help do that.

     In 1980, all  U.S.  carmakers had  huge  losses  thus,  we cannot expect
them to invest money  in developing  Micro-Caruretors for  their  small  cars,
because the Micro-Carburetor was not invented by them.

     For this reason, it  is  very important that the  Government grants the
necessary amount for  the  development  of  Micro-Carburetor prototypes  for
all American made cars as scon  as possible.

     We also have a second invention that further increases the fuel-saving
of the Micro-Carburetor by an additonal ten percent  and reduces  the NOx
emissions by an additional 30 percent.   We were just informed by our patent
attorneys that the  U.S.  patent office authorized a patent for this invention,
that will be issued soon.

     During the last  four years  we  experienced very little interest  from
DOE to assist  the  development  of our  fuel-saving carburetors.   We expect
that the  present  Government will  urgently  remedy  this fault  and  will
grant the  necessary  assistance  for performing  our  development  program
which is of vital interest to the country.

     If this were  denied, we  would be forced  to  sell our inventions to
the foreign  carmakers.   This would   represent  a fatal blow,  from  which we
would like to spare the U.S.  auto-industry.
MIKE DEKAIB
Energy Planner, Lincoln City -
Lancaster County Planning Department
555 South 10th Street
Lincoln, Nebraska  68508

     In reference to the staff working paper  for the third  national Energy
Plan-Parts I, II and III appear to be well done.

PART IV  New Views of Energy

     Policy (Page 10 & 11) Deserves some comment.

     -  The second principle  states that energy policy should  be based on
        "economic principles, national security concerns,  and a due regard
        for environmental  values".   This  is  far too  narrow  a base  for
        national energy.

     -  The third principle  states that "government is not  to select and
        promote favored  sources  of energy".  This should apply equally to
        all energy  sources and  technology  regardless of expenses.   Also,

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        some technologies  have received  substantial  government subsidies
        and under-writing  over  time  -  those which have  not  shall  be
        equalized for balanced economics to work.

     -  The fifth principle states "public spending  should  not  be used to
        subsidize domestic  energy production  and diverts  capital..."  As
        noted above  some subsidies  only  equalize previous actions  built
        in to  some  technologies.   Conservation  has been  documented  as
        having the  biggest  impact per dollar  spent  in the short  run.
        Provisions should  be  made to  assist  conversion to  more  energy
        efficient end uses  as  front-end cost and adequate public knowledge
        represent substantial  barriers to  improved  efficiency.   Specific
        attention should  be   given  to  non-biased  information  sources.

     -  The sixth principle states "...eliminating  controls  on  oil  which
        discourages the private sector from dealing with disruptions effect-
        ively..." while  an accurate  statement  as far  as  it goes,  what
        protection remains to  ensure  the harvest  comes in or public safety
        vehicles have fuel to run?

     The "New Views of Energy Policy" presents many valid points - however,
they should be expanded and tailored to  present  a  comprehensive and more
balanced approach to national energy policy.
MARY DURHAM
County Energy Resources Coordinator
The Legislature of Rockland County
Office of the Chairman
County Office Building
New York, New York  10956

     Various agencies  in  the  Country  administrator different  energy  -
related programs.  They  have been  contacted to reply directly concerning
their specific projects.

     The Energy  Department  has been  mainly  involved in  promoting energy
efficiency in building operations.  This has included participation in the
DOE program for  Schools  and  Hospitals.   The County matched  federal  funds
for a $200,000 technical assistance program of in-depth  energy studies of
59 of its  buildings.  The  studies pointed up ways in  which the County
could save money on operations and recommended energy conservation measures
including expected savings  and  paybacks.  $40,000 has been  awarded in the
second phase to  be  matched with  County funds to  implement some of the
recommended procedures at  the  Community College  and the Health  Complex.

     Signficant savings have  already  been  realized,  and  implementation is
expected to show further savings  or cost avoidance  in  energy consumption.
Monitoring of the last 3 years  of energy use data  shows  savings of from 3%
to 33% in County buildings.  Expected annual  savings after implementation
are forecast to  be in excess  of  the total  cost  of the program.   If this

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program could be  expanded to  include  monies for implementation  of energy
conservation measures for buildings  owned by local  governments  and public
care institutions as well as schools and hospitals, it would be  even more
effective in  promoting  energy conservation.   The  Energy Department  has
offered help  to villages  and town  and  public care  institutions  in  the
County, but there is  no money available  for them to be  able  to implement
the energy  conservation measures  recommended  in the  technical  assistance
studies.

     The Energy  Department,   together   with the  Construction  Office,  is
drawing up a  3-year budget  for County  legislative  approval.  Vfork will be
done based  on cost,  estimated savings,  and payback for  each  recommended
energy conservation measure.   Those measures  requiring  little money  will
be implemented year by  year.   Consumption data monitored  and tied in with
weather data to see if  savings are actually being realized.   If so, energy
measures with greater than  3-year paybacks will also  be considered  for
capital funding.

     The Energy Office  and the Construction Office work closely together
to promote energy  efficiency  in  building retrofits and  in the  design of
new buildings.  IVfost older .County buildings were constructed with construc-
tion costs as the paramount  concern.   New buildings  will be  constructed
with an eye to operating costs as well.

     The County has also participated in the New York State program regard-
ing lighting  standards  for  public buildings.  Buildings  are  in  compliance
with the recommended  standard, and part of the savings realized  so far is
because of reduced  lighting loads.  In this lighting  program,  as  well as
in the School's and Hospitals program,  the County Energy Office has enjoyed
great cooperation with the State Energy Office.

     Itockland County has an  annual energy budget in excess of  two million
dollars.  Participation  in  the   above-mentioned programs has  helped  us
lower the cost of the  government to the  taxpayer.  The costs of the programs
are recouped  in savings  or  cost avoidance  in a  relatively short time.
Conservation still  remains  the   lowest-cost method  of  promoting  energy
savings.  It  is  the  main  thrust  of the Energy Department's  program.
JOHN V. FASHING
Executive Assistant
 to the General Manager
Department of Water and Power
111 North Flope Street
Box 111
Los Angeles, California  90051

     The Los Angeles  Department of  Water and Power  (DWP) is  the largest
municipally owned  utility  in the  country,  serving  more than  1,500,000
electric and 600,000  water customers.  DWP is a locally regulated utility
governed by a  Board of Water and Power Conmissioners,  in accordance with

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the Los Angeles City Charter.  As a locally regulated utility in the state
of California,  our Board exercises full authority  over all DWP activities
including its conservation programs.

     DWP is  pleased to  provide input to  the Federal  Energy Conservation
Program because we  believe  Los  Angeles is  an  excellent  example  of  how
nonmandatory conservation programs  (tailored  to local needs) combined with
appropriate pricing  mechanisms  have significantly reduced the use of elec-
trical energy on our system.

     During the 1950s  and  1960s, the annual  electrical  growth rate in Los
Angeles averaged 7%.   Today,  we are projecting an average annual growth of
1.5% through 1990.

     The DWP load  forecast for  1980 projected total system sales of 17,704
gigawatt hours;  actual  sales  were 17,556.  This  represents  an almost 2%
reduction in energy  usage from  1979.  During the same period, the estimated
real gross regional  product  increased by 4.1% and the estimated gross pri-
vate investment for the region  increased  by  9.2% (see attached  chart).
These estimated figures are in  contrast to the 1980 economic growth in Cal-
ifornia and illustrate that  there has been substantial  growth in the com-
mercial sector of the  economy continues strong and vibrant in Southern Cal-
ifornia, energy sales  are  not locked to the  same rate of growth.  The De-
partment believes  that this diversion  of  trends is  a result of the real
price elasticity of energy and the conservation programs provided  by the DWP.

     As part of the realization  that  energy  should be  priced at its real
cost, the Department,  in 1978,  completely restructured  its  rate schedule
to comply with  the principal of  cost of service.   The new rate structure
eliminated volume discounts  and declining block  rates,  both  of which, in
effect, promoted excessive  use of  electrical energy.   The Department  was
one of the nations first utilities  to establish cost  of service rate sche-
dules.

     The residential sector  comprises  less than 30% of  our total load  and
the most productive  energy  conservation programs  are aimed  primarily at
all-electric customers.  There are two types of programs in the residential
sector.  The first is  the  RCS  program mandated by the  federal  government
which will save approximately 51 gigawatt hours  over  its 5-year duration.
The cost of this program will be 13 cent per kwh saved.  This is substan-
tially higher than the  current cost  of energy  which is  approximately  6
cent per kwh.  The PCS program is not cost-effective for the DWP.

     Other programs  in the  residential  area  are geared toward apartment
buildings which  are  master-metered,   toward  large  residential  electric
users, and for  those people who request energy audits, the Department will
provide Class "A" home energy audits.   These programs will cost the Depart-
ment approximately 1.7 cent per kwh saved,  and  will save 91 gigawatt hours
over the next five years.  Additionally, the Department  has  just begun an
extended loan program  which will  provide  financing  to  residential  or
apartment owners  who  will  retrofit   their  buildings  with  conservation
equipment and material.

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                                                Table 1
                                  Los  Angeles  Department of Water and Power
                            Indicators of  Local  Economic Activity &  Energy Sales
Real Gross Regional
Product*
Year Billions of $s % chge
72 43.1
73 44.2 -2.6
74 44.1 - .2
V5 43.6 -1.1
76 43.4 - .5
77 44.1 1.6
78 46.0 4.3
7 'J 50.9 10.7
80 53.0 4.1
01
02
8J
84
8S
or,
07
08
09
90
Gross Private Total Electricity
Investment** Sales
Billions of $s % clige GWII
7.0 17212
7.0 0 17550
6.4 -0.6 15034
4.6 28.1 16009
4.5 -2.2 16670
5.1 13.3 16879
5.0 13.7 17515
7.6 31.0 178/7
8.3 9.2 17556
17526
17750
17855
18119
18325
18623
18942
19449
19855
20408
% chge
2
-14.4
6.1
4.
1.3
3.6
2.1
-1.8
- .2 (Est.)
1.3
.6
1.5
1.2
1.6
1.7
2.7
2.1
3.0
 *This estimate is based on the same types of indicators contained in the Gross State Product.

** Includes New Construction, Durable Goods purchased and Inventory.

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     Keal
     Gross
   Regional
    Product
   (billions)
     52
     'IB
     '10
Annual
Electric
 5ales
 (GWH)
             Table 2
LOG Angeleti  Ucparl ".ont  of Water and  Power
     Comparison of Knoryy Sales Growth

     with  Ue.il Cross  Regional Product*
              1972   73
                          74
                                75
                                     7G
                                          77
                                                78
                                                     79
                                                                81
                                                                     82
                                                                           83
                                                                                     85
                                                                                           86
                                                                                                87
                                                                                                           89
                                                                                                                90
*T)ij.'j \ LJ ,in  estimate based  on  the same  types  of i >id ica toi <; Contained  in the Gross  State Product

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     EWP's cxrnmercial/industrial energy programs  are partially mandated by
the state of  California.   The DWP has developed  a program which has  been
used as a  model by the  California Energy  Commission  and which was  fully
planned and partially  implemented  prior  to the CEC  Conservation mandates.

     Inasmuch as 70% of  the Department's load is  in the commercial/indus-
trial sectors, this  is an  extremely cost-effective program  for both the
Department and its customers.  Over  the  5-year projected life  of  the com-
mercial/industrial program,  the  Department's  customers  will  save  over
1400 gigawatt hours  of energy  annually  at  a cost of .3 cent  kwh saved.
The program is primarily made up of  energy audits of commercial and indus-
trial buildings  which  include  cost-effective  analysis  on  conservation
practices and equipment retrofit.  It also  includes  seminars  for customers
with similar businesses in which a conservation  consultant will provide 1
or 2 days  of  instruction to such  a  group.  These programs have been very
well received   by  our  customers  and  have  been  extremely  successful.

     The third  part  of  our  Conservation  Plan  is  water  conservation.
Although water conservation may be outside the scope of these hearings, it
is considered  a separate  and important  segment  of the DWP  Conservation
Plan, and is  often handled in conjunction with energy conservation audits
(saving water  saves  energy).  The program  components include  audits  for
business and  residential  customers, the  recent dissemination of  water
conservation kits  to  1.2  million residential customers  of  the   City,  a
leak detection program which covers the Department transmission and distri-
bution main lines,  and  continued cooperation with other water  agencies
including the California  Department  of Water .Resources  to develop new and
innovative water conservation plans.

     The fourth  segment  of the Conservation Plan  deals  with  public aware-
ness.  The Department  has  maintained a relatively low profile  in  the news
media as  compared  to  other California utilities inasmuch as  the service
area is  more  confined.   The  Department's public  awareness  emphasis has
been on  direct mail  to all-electric  residential  customers  and   to  com-
mercial/industrial customers  with minimum  use  of  the  electronic media.
This approach has  been very successful  in creating interest and activity
in conservation.  Mditionally, the  Department has used professional trade
magazines and other  similar types of communication to  direct information
to a particular segment of our customer base.

     A major  part  of  our public  awareness program are the programs for
education.  These programs are aimed at all levels of the schools including
primaryf secondary, and college,  and provide student,  teacher, and teacher
training materials on  energy and  water  conservation.    The Department has
licensed an  education distribution   company  to  develop "Aunt Energina"
which has been very well  received by the California schools.  This same
company had  previously  developed a "Captain Hydro"  water  conservation
program for primary  and  secondary  schools.  The  education program also
includes the  funding  of  an  improvisatlonal theater  group   called  "The
Twelfth Night  Repertory  Company", which  creates  and  produces  short plays
to be  performed in  front  of  junior  and  senior high  student audiences.
                                     366

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This program  has  been enthusastically  received  by the  school  districts
and has been recently  broadcast on  national  public television.

     Very briefly,  these  are the highlights  of the Department's  Conserva-
tion Plan.  As  you can see, there are many diverse parts of the plan  which
we have  developed to  specifically  serve  the  various  customer sectors  in
Los Angeles.  The  Department  of  Water and Power is  somewhat different from
other utilities in that 70% of the load serves commercial/industrial custom-
ers.  It  is therefore  in the best  interest  of conservation and DWP's cus-
tomers, to  provide the primary emphasis on that sector.

     It is  our  position that  conservation  goals should  be set very broadly.
Each utility  should then  be  responsible  for developing the detailed pro-
grams which will reach their customers.   In this way,  the various publics
which must  be  served, can  be  provided  with  an  appropriate  program.   By
allowing each" of  the  utilities  to  develop  necessary programs  which  it
feels meets its  system  and  customer requirements,  each  utility  is  then
allowed to  adjust to  the changing environment  and provide the  best and
most economical service to its customers.

     Thank  you  for the opportunity of providing  information  and  input  on
this subject.    If you have  any further questions regarding our  programs,
you may contact Mr. Jack Klein at  (213) 481-5841.

      *************
MARIAN S. FEENEY
Cooperative Extension  Specialist
Energy/Resource  Development
University  of Rhode Island
Kingston, Rhode  Island  02881

     I am Marian Feeney, Associate  Professor, Cooperative Extension-Special-
ist- Energy/Resource Development, University of Rhode Island. (401-792-2464).

     As energy  issues  and concerns intensify during the 80's  a period  of
energy and  political  transition both with  many  unknowns,  mixed  messages
and uncertainty, one philosopher says  uncertainty  is a  time to be  creative.

     In this  written  testimony, I  will  respond to the general  questions
(p.  7) and  some of the Issues for  the 81  Section 11 Review (p.  12, 14 and
16).   I am  also submitting my testimony for the Third  National Energy Plan
and the Special Edition  of the Community  and Rural Development Newsletter
- 1980 Community Energy for  information.   (This material was  reviewed  by
EPA but not included in the transcript due to  its  length).

     In addressing  the "adequacy  of  attention  to conservation"  and the
decentralized nature of  energy conservation,  we must  remember that  there
are many regional  differences, many differences withing regions and within
areas of states.   Thus,  conservation  policies and program developed  on a
national level must be flexible for regions, states and communities  to meet
their specific conservation needs.
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     The Federal  government  should give  more attention  to  national  and
international policies  and give  strong leadership  to initiate  state  and
local cooperative, coordinated and collaborative efforts in energy conserva-
tion.  Such  efforts must foster  real interaction  and communications  to
reach common  conservation  goals   among the  public  and  private  sectors.

     As policies and programs  are  being developed and as  results are moni-
tored and evaluated, more emphasis should be given to  the impacts on people,
communities, and states, with each dimension being considered - the social,
economic, technical,  environmental and  ethical  impacts,  NOT  just energy
impacts.

     The priorities and activities selected  for energy  conservation will
depend upon the planning process.   Because of conservations decentralizaed
nature priorities,  activities and programs may continue to  be fragmented
and uncoordinated.  However,  as resources (dollars) become  limited,  both
the private and public sectors including  government agencies  may be more
willing to  share,  cooperate  and  coordinate  for  greater  efficient  use of
resources which will  make grater  impact results.   But if the public  and
private sectors including government  agencies and PEOPLE are not included
in the planning  process,  expected  results will  be  difficult  to achieve.

     The changes in federal programs presents a tremendous  opportunity for
private firms, state governments,  local agencies and  non-profits to network
on specific conservation  issues for efficient delivery of education, infor-
mation and technical assistance to  the  residential,  small business, indus-
trial, agricultural,  government,   and  transporation  sectors.   This  will
eliminate duplication of  effort, provide a comprehensive approach to energy
conservation issues, and  put  the  talent and  abilities  already in place to
create more effective  results.  The evaluation questions  must be addressed
in the program planning development stage, not as an  appendix.

     From the issue paper, there  still  appears to be selecting what agency
will do what, instead  of identifying the priorities, determining the audi-
ence needs, identifying informational needs and then  strategizing by inven-
toring existing resources - human and material.

     When doing the inventory of resources,  roles,  responsibilities, man-
dates,, and  expertise  must be clearly  described.   Then a  creative frame-
work for a  comprehensive program  to meet  the priorities  can be developed.
This framework must include planning,  implementation, delivery, monitoring,
data collection and reporting results.

     Joint cooperative  efforts must  also be rewarded.   One  issue which
seems to come to  the  forefront in  numerous public meetings is who has the
information, how  to access the  information  and  evaluate the  information,
and we have the information but not the delivery system.

     Such efforts  demand  strong   leadership,  a  focus on priorities  and
goals, and clearly defined roles and responsibilities of each participating
agency, government, and private representative with continuing communica-
tion and cooperative efforts  supported  so each sees hew pieces  fit together


                                     368

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and what  the whole  can produce.   Each must  feel  a commitment  to their
responsibility.

     By combining  the public  and  private  sectors  into  a  comprehensive
approach to energy conservation-existing workers, educators and the private
sector, more thought might  be  given to organizing  cooperatives to provide
low cost  service  to  low income,  elderly  and  handicapped  or  struggling
businesses.  Or  an energy management  service corp might be  organized  to
provide energy conservation  services.  Agencies and educational institutions
could provide  management,  operation  and   service  delivery  seminars  and
support to both cooperatives and corps.

     I feel the opportunities are there but can we put aside those barriers
or what we think are  barriers  to work on a  creative framework to meet the
energy conservation needs of  PEOPLE and  communities which  will have  an
impact on the state, region and the nation.

     Thank you for the opportunity to share my thoughts and recommendations
again this year.   I will be willing to assist in  implementing energy con-
servation and management actions through cooperative efforts.
KELLY FINN
Kansas City Citizen/Labor Energy Coalition
Box 5952
Kansas City, Missouri  64111

     The Department of  Energy under  Secretary of Energy  James Edwards is
narrowing energy options  of the  American people.  Conservation  and Solar
programs are  being  systematically dismantled,  despite  the  fact  that  a
Fall 1980 Gallup poll  found that solar was the  most  popular energy option
for Americans.

     Further, the proposed  elimination of  1)  the Solar Energy and Energy
Conservation Bank, 2) Energy Extension Service, 3) Residential Conservation
Service, 4)  State  Energy  Conservation  Projects,  5) Home  Weatherization
Programs along  with elimination  of  CETA  programs   that  provide much of
the labor needed for these projects,  cutbacks in aid to assist in payment
of skyrocketing  home  energy bills,   combined with  the  deregulation  of
oil, gasolined and natural  gas prices ad up to what  many  see as a vicious
attack on low and moderate income people.  Low income people spend 35 to 50
percent of their income on  energy expenses.   Yet, home heating costs could
be reduced as much as 40%  through  proven, cost  effective home weatherization
techniques.  The Reagan policies  mean that a growing number of Americans
will not be able to  choose from expanding array of solar  and energy effi-
ciency options, but because of outrageous fuel prices and lack of weatheri-
zation assistance they will be limited to a choice of fuel  bills or food.

     It is suggested that private firms  assume new  responsibilities,  but
most solar/conservation firms are small with almost no money for publicity,
education, consumer information or free services.

                                    369

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     If our  energy problem  is  considered a  national  security risk,  we
should want to solve this national problem as  soon as possible.   The speed
at which  we can  solve this  national problem  depends largely  on Federal
assistance, both to  lower energy use in  the  houses of low  income people
and in assisting,  through educational  efforts,  the market penetration of
solar/conservation products and services.

     It is  also  suggested  that  state  and local  governments  assume  new
responsibilities.  However,  severe  limits  are  placed on taxing powers of
state and  local government.   Often  these tax  restrictions  have been promo-
ted by local  Reagan supporters,  even though such  policies  would  make it
impossible to carry out the Reagan  plan for more local control.   State and
local governments  are  facing tight  and  even  dwindling budgets.   Higher
fuel costs, resulting  from deregulation,  in the 39 energy  importing states
means millions more  dollars pupped  out  of these states  economy,  farther
weakening their ability  to respond  to the new challenges dropped  by the
Federal government.  Yet,  the federal  government after breaking promises
to millions of Americans,  is promising now that state and local governments
will somehow be willing and able  to  follow through on Federal commitments.

     Our private non-profit organization has been increasing its skills and
moving more in the direction  of providing energy services (energy audits,
conservation installations,  solar collectors)  for  low and moderate income
people.  Much of the financing for this work has come from federal sources,
and with the Reagan  cutbacks  many of these services will  have to be aban-
doned.  The need is  still there for low  income  energy programs,  and it is
growing.  KG C/LEC plans to  make a continuing  effort to insure  that he
needs of our low and moderate income constituents are met.

     In evaluating  effects  of  Federal  energy policy changes  aggregate
totals of units of coal,  electricity,  natural  gas, etc. are meaningless in
terms of  citizen  impact.   Aggregate  totals  such  as  these  tell  nothing
about the amount of  energy  wasted or the  impact on various  income levels.
The more  accurate  way to  gauge the  effects  of  Federal policy  changes
would be  to compare  the before  and  after percentages of   family income
applied to energy  costs.  Thus success  would be a lowering of the percent-
age, which  would  leave more  family purchasing  power  for food,  clothing,
housing and recreational expenses.  The lowered  percentage  could be achieved
by either more efficient use of energy or lower or stablized energy prices.
The administration's energy  policies, at this  time  of this  writing,  en-
courage neither of these roads to success.

     The administration energy policies offered by Secretary Edwards offers
no hope, no sustainability and no vision of an energy future in which most
American would like to participate.
                                     370

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MARGARET P. GARLAND
Director
State of Vermont
State Energy Office
Montpelier, Vermont  05602

     The major assumption  of the current federal energy policy is that the
market place will solve all problems related to energy both for this country
and the international  cctmiunity as well.  This assumption is predicated on
a completely free  and  unfettered market place where  demand  and supply are
in harmony.  It  is doubtful that such  market conditions can  be obtained
for any major  fuel  source;  it is  certainly not  true for  the petroleum
market where prices are set by a cartel headed by several OPEC nations.  A
lack of recognition  of this fault and  withdrawal of governmental involve-
ment in energy planning will  have adverse  impacts on the  development of
new technologies,  our  economy,  the  environment and,  last  but certainly
not least, the users of the  several energy  forms at all levels.

     The government has a  definite role, in our  judgment,  in dealing with
the imperfections  in  the  energy  marketing and  distribution  systems  and
assuring that an equitable distribution of available resources takes place
especially during  periods  of  shortages.   If  the federal  government does
not act in this fashion on a continuing basis, there is a real possibility
for economic disaster  for  some areas  of the  country.   New  England is
particularly vulnerable to supply disruptions given its unique and continu-
ing dependence on  foreign  oil.  A dependence that seems likely to continue
in the short term and longer.

     Given the decision to continue to  promote petroleum,  natural gas and
nuclear as opposed to the  development  of new technologies,  New England's
dependence on  oil,  and thus Vermont's, is  going to be tied more closely
than ever to dependence on foreign oil,  at least for the foreseeable future.
This recognizes  the time  needed  to bring  new domestic  sources on line
even if they are  found.  A  better policy would be one  that promotes both
the search for more petroleum  and  natural gas and the search for new tech-
nologies backed up with a strong program of conservation.

     In Vermont,  a  strong move  to  conserve  present  energy  sources  has
taken place since Arab oil embargo of 1973-1974.  This has been particular-
ly true in the use of petroleum products.   In addition, there has  been a
strong trend to  convert residences and businesses  to the use  of wood and
solar in the provision of  heat and hot water.   Some industrial firms pro-
vide their heat,  domestic hot water and process heat and hot  water from
these renewable sources.   One of the state's largest banks, the Merchants,
is building all of its new branches with  solar heating.   The Gilman Paper
Company of Gilman,  Vermont is currently heating  exclusively with wood and
intends shortly to  generate its own  electricity  from a boiler fired with
wood chips.

     Much of the  technology used  by Vermont's residential  and commercial
users was  developed  under public programs.   Such programs,   which we feel
are proper areas for governmental actions,  will be lost under the proposed

                                     371

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plan.  Such a loss  will severely  set back the gains made  in these areas,
further promoting  our  dependence  on  expensive  and  uncertain  supplies
of foreign oil.

     It is  clear that,  even with  some reduction  in the  world price  of
crude oil, our balance of  trade deficit will continue at a high level due
to our  importaion of  large amounts  of petroleum.  The  security  of this
oil supply  is constantly   in  question;  as this  is  written, events  are
occurring in  the Middle East  that  could  escalate  into another  conflict
affecting the delivery of oil to the United States.

     Any National Energy Plan  should recognize the  need to  minimize  our
dependence on the  international oil  cartel  and the possibility of supply
restrictions which even the  Strategic Petroleum Reserve may not be able to
deal with.  In  any event,  less dependence of  foreign oil  should improve
our balance of  trade.  The  development of new technologies  would further
reduce our  need  for  foreign oil  and  make the  United  States  preeminent
in the development of such technologies.

     The policies proposed in NEP  III do not  sufficiently deal  with the
contribution which  conservation has made  and  can continue  to make in the
energy needs  of  the country.   Not only does conservation  reduce  the need
for expensive foreign  energy sources, but it continues  to provide employ-
ment for the  unarployed, the development of new  industries  and the expan-
sion of  old  ones,  and increases  the  amount  of capital  available  for
investment now and in the future.

     Conservation has  allowed  users  in all  of  our  economic  sectors  to
deal effectively with the  ever  escalating costs  of  all types  of energy.
But, even with the  effort  made  in Vermont and  throughout the country, our
residential conservation efforts and  programs  for industrial  and commer-
cial efficient energy usage lag far behind many other industrialized coun-
tries in the  free world.  A National Energy Policy must continue to recog-
nize the positive effects  of conservation in dealing with our energy prob-
lems.

     A substantial  government-supported  program  of  energy  conservation
and efficient energy  usage  coupled  with an  aggressive  program to develop
further conventional  energy sources makes more sense and has  more positive
economic aspects for  the future than  a program promoting only the latter.

     A program   to  promote  conservation  should  include  a  strong public
information segment which  deals with the  conservation and  more efficient
use of present or  conventional  energy sources and the commercialization of
efficient alternative  technologies  and energy sources.   Such  a program
should support state  initiatives in  the areas of conservation  and substitu-
tion of renewable resources  for  non-renewable ones.

     In the latter  area, Vermont has  used its  federal funding in  the past
to develop the following:
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     1. The Home  Energy Audit Team which provides on-site  Class A audits
        and information on efficient  energy usage to Vermont householders.
        (Some 7000 households have  received such audits at  $72 per audit.
        A very low cost in relation to the savings achieved by those audit-
        ed).

     2. Ihe  Vermont  Industrial  Energy  Conservation Advisory  Program  -
        Under this program,  energy experts  frrm private  sector companies
        and from State Agencies combined to give advice on energy efficient
        management to  over  150  small  Vermont  companies  which otherwise
        would not  have had  the resources  or  time to  develop  their  own
        program.  Each  company  surveyed will  save  approximately  20%  on
        their heating and 10% on their electrical usage.

     3. Vermont's Vanpool Program  is  rated as the  best  rural  Vanpool Pro-
        gram in the United States.  It  has  been instrumental in increasing
        the number of  vanpools in  Vermont from 23, three years ago, to 109
        as of this writing.   Ridesharing, including both van and carpools,
        has had a marked  impact  in Vermont  where  public transportation is
        virtually non-existent  in most  areas,  and people  must drive  to
        gainful employment and to get the necessities of life.

     Such programs will be  severely  impacted  by  a  national  policy that
reduces direct  federal support of  energy conservation efforts  as  well as
eliminating support of state efforts to promote a conservation ethic  for
energy usage.  Public  information  at all levels is extremely  valuable in
the furtherance of any conservation program.

     The public's hunger  for information of both data-related  and educa-
tional types is reflected in the number  of  requests the  federal government
and the  states  receive through  the  mail,  at public meetings  or through
energy information lines  such  as  that  maintained  by  the  Vermont  State
Energy Office.  Education at all  levels is needed  if  energy consumers  are
to make  wise decisions in  choosing  the proper available energy options.

     A federal-state partnership  is  crucial in the  area  of  conservation
and in other  areas where states have developed  state-specific  programs to
deal with such things  as  converting utilities and  industrial firms to  the
use of wood or  coal,  energy efficient  management for  farms,  the  use of
passive solar in  residential,  farm and  commercial  building  designs, among
others.

     "Formulation of energy  policy  must be  sensitive  to the needs  of  the
poor .....  holding energy prices down  for rich and poor  alike is an
ineffective way to help the  poor."   That's true, but  no effective counter
proposal is discussed.   An  intensive program  of  weatherization  for  the
low-income and elderly,  would produce  immediate results  by reducing  the
percent of  fuel  wasted in dwellings and would more cost  effective than a
subsidy of  the   energy producers  through   fuel  aid  programs.   Such  an
approach will be more productive in reducing the appalling waste of energy
in much of the housing used by low-income families.


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     Some members of the State Energy Office technical staff have commented
that the amount of  carbon dioxide placed into the atmosphere by the direct
combustion of biomass does not  result in a net increase in carbon dioxide.
Biomass, through its  normal  decaying process, releases  carbon dioxide and
water.  Combustion  of it  will  not  and  greater quantities  of gas  to the
atmosphere.  Further, it  seems  fairly short-sighted to  make the statement
that environmental impacts frcm  carbon dioxide are unlikely in this century,
when this century has only twenty years  to run.   This  seems to be glossing
over a potential problem  without any attempt to address the net impact of
emphasizing technology which may contribute to a future problem.

CONCLUSION

     Many of  the energy   problems  of  the  United States,  so  forcefully
brought to light by the 1973-74 energy embargo, are still  with us.   We are
even more  dependent  on foreign energy  sources  than  we were then  as the
possibility of a severe petroleum supply disruption, the SPR to the contrary,
is still a very  real possibility with the attendent  devastating economic,
political and social impacts on the United States and the world.

     It is our  contention, if  the  foregoing is accepted as a given,  that
the federal government can't step back a  completely hands off/free market
appoach.  In  our judgment,  the  federal  government has an  obligation to
provide leadership to the nation  in achieving economic progress by achiev-
ing energy efficiency using affordable and reliable fuels.   This leadership
would involve promotion of increased domestic energy production, the  fur-
therance of  new  energy  technologies  and  a  strong  conservation  program
promoting both the efficient  use of present energy sources and the  substi-
tution of renewable for non-renewable energy resources.
J. JOSEPH GARRAHY
Governor
State of Rhode Island
Executive Chamber
Providence, Rhode Island  02903

     The State  of Rhode  Island welcomes  the opportunity to  express  its
views regarding  the  new directions  of the  Federal  Energy Policy  and  its
impact on our State and local governments.

     We in Rhode Island  are about 80 percent dependent on foreign oil for
our energy needs.  A disruption in oil  supply from abroad may occur at any
time and the ever increasing price of energy is exacerbating the unhealthy
state of our  economy.   Rhode  Island has no significant  indigenous energy
resources to turn to and it is clear that  any new energy tehnologies will
not be developed in the 1980's.   Rhode Island has  strongly  supported the
administration's efforts to  expedite  offshore oil and gas development,  but
this too will take  7-8 years before  any discovery can reach the production
stage.  As a  result,   Rhode  Island has concluded that the cleanest, least
expensive, and  least  vulnerable  energy option  today  is to  use  less  by


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being more efficient.  Our efforts in the conservation  of energy speak for
themselves and largely through Federal  Funds we have created an awareness
that has reduced  our oil consumption nearly 20 percent  over the past few
years.

     Ihe Administration's dramatic shift  away  from any meaningful  role
for the Federal government in energy conservation is a giant step backwards
for both Rhode Island and the Nation.   It is my  firm belief that the cur-
rent Federal administration has gravely underestimated  the value of energy
efficiency.  Energy Conservation can be of major economic, military, envir-
onmental, and  social value to the United  States.   Numerous  studies have
shown that increased energy efficiency  will provide more energy at a lower
cost and sooner than any other option over  the next twenty years.  There-
fore, Government  has an essential  role in  achieving the  nation's energy
conservation potential and cannot  let the market  place  assume full respon-
sibility for what is a key factor in  our economic  well-being  and our na-
tional security.

     It is with  the above concerns in mind that the  enclosure addresses
those issues posed by EPA for their review  of Federal energy conservation.
     With warm regards.
                                  J. Joseph Garrahy
                                  Governor
WRITTEN TESTIMONY, STATE OF RHODE ISLAND

     Many studies and  numerous articles  have been  written  regarding  the
substantial barriers which exist to  implementing price - responsive energy
conservation.  The Journal of the Federation of  American Scientists in its
April 1981 issue  examined  the  proposed budget cuts  in energy conservation
in detail  and  concluded  they   "lack  economic  and  security  rationale".
There are three points that should be  emphasized regarding the theory that
market prices  will  achieve  the energy  conservation  objectives that  are
vital to Rhode Island's economy.  They are as follows:

     (1) Rhode Island businesses, schools,  state and local governments and
         homeowners simply cannot afford the cost of conservation measures.
         Our businesses are  already  struggling  to remain  competitive  be-
         cause of rising  energy costs combined  with their older and less
         efficient plants and buildings.  Sufficient capital  is not avail-
         able in  most  small  businesses,  local  governments  and  moderate
         income families  to analyze  their  energy  problems  and  finance
         conservation measures   at  current  interest  rates.   The  consumer
         cannot respond  to rising  costs  and must   choose  between  bank-
         ruptcy, food,   clothing,  or  heat.    Federal loans at lower  than
         market interest rates,  grants,  or tax credits are  necessary  to
         enable consumers to  convert high  energy  costs  into conservation
         actions.   Failure to meet this need  will  result in more unemploy-
         ment, increased need  for fuel  assistance  and  federal  funds  for
         consumption vice conservation.

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     (2) Private businesses,  local governments  and the  average  homeowner
         require impartial and accurate  information regarding conservation
         and assistance  to financing  energy conservation  and making the
         correct response  to  higher energy  prices.   Such  information has
         been an  important contribution of  the  Rhode  Island  Governor's
         Energy Office and is essential  in a period of rapid price change
         and new  technology.   Training  and  education  programs  sponsored
         by the energy office will also be  curtailed resulting  in a less
         "energy skilled"  public  and  work  force.  Furthermore,  institu-
         tional, legal  and economic  barriers  which  slow progress  will
         become greater  roadblocks to  conservation  action because  their
         removal by  governmental   action  will  no  longer  be  feasible.

     (3) Rhode Island has many old raulti-family dwellings which are rented
         to the poor and  elderly.  The owners  of these  buildings  have
         no incentives to  save energy and merely  pass  the  rising energy
         costs to building tenants.  As  long  as the availability  of rental
         space is limited, tenants  are  forced to pay the increased costs.
         This is another example where institutional or market place barri-
         ers prevent higher prices from working.   This  is an area  where
         mandatory efficiency standards  or conservation measures  should be
         instituted.

Responses to the general questions posed by EPA are as follows:

     (1) How are private firms,  state governments,  and local  agencies pre-
         paring to assume their new responsibilities?

         Rhode Island's energy  office is  totally Federally  funded except
         for the  required administrative  matching  grant  for Title  III.
         If Congress does  not  modify the  Administration's  proposal  for
         energy conservation,   funding  by  state  appropriations  will  be
         required to continue all energy programs except Title III.   Pre-
         sent austere State and local budgets will be hard  pressed to come
         up with substitute funding.  At best Rhode Island  would be forced
         to reduce its  energy programming and  staff by 50  percent.   The
         extent that private,  state,  or  local  agencies will assume new
         responsibilities cannot be determined  and new initiatives cannot
         be planned until actual funding decisions are completed.

     (2) Which activities will get priority from public and private organi-
         zations and what  will be the consequences if some activities are
         discontinued?

         Long term goals will have to be sacrificed  for  short-term needs.
         Programs which  respond   to the more  immediate  needs are  those
         which are most likely to  receive priority.  In  Rhode Island these
         programs are low  income  heating energy assistance and low income
         weatherization.   These  programs  respond  to  the  need  to  help
         people survive  the   impending  heating season.    The  low  income
         heating energy  assistance program  pays  heating  bills  but  does
         little to save energy.  Programs  aimed at businesses, the average


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    citizen, public  buildings,  and  improving  the  conservation  and
    renewable resource  industry will  be  secondary  even though  the
    energy consumed in the low  income  sector is miniscule  in compar-
    ison.  Expected  cuts in  the  energy  conservation  program  would
    eliminated on-going  information  programs  in  Rhode  Island  that
    have greatly  benefited the public  in  providing  impartial  and
    accurate information about energy efficiency  in  equipment,  build-
    ings and motor vehicles.

(3) Have any new  initiatives, opportunities, or  efficiencies energy
    conservation programs?

    Current programs are already operating under severe  funding  con-
    straints and have been designed  to  take advantage of any initia-
    tives, opportunities  or   efficiencies  available.   For  instance,
    the programs have never provided  direct assistance to local levels
    of government, under  the  schools and  hospitals  retrofit program
    (Title III, NECPA).   States receive more applications  than there
    are funds  available.  Building   code  enforcement  programs  are
    severely lacking in manpower and sufficient funding  is available
    to provide energy conservation services  to only  10 percent of the
    state's businesses.

    Rhode Island has initiated a Community Energy Task Force to better
    analyze the energy requirements  at the local  communities and more
    effectively respond to their problems.  This program will likely
    be terminated   unless costs  are  assumed   by  the  communities.

(4) How can the  federal  government   assist in  this   period of  tran-
    sition?

    If the  Reagan administration program  recommendations for  energy
    conservation materialize  then the transition in Rhode Island  will
    be a rapid  phase out  of  all  conservation  programs  except  Title
    III.  The Federal role during  this  period must be to provide the
    states with block grants  which allow greater  flexibility in deal-
    ing with their priority programs and adapting to  local  conditions
    and needs.

    The most prudent  way that  a  transition  could  be effected would
    be to allow a phased  reduction of  federal  assistance  with  an
    increasing local  match requirement.   This will permit states  that
    choose to rely solely on the "market price"  theory of conservation
    to phase  out  programs while  those  that do  not adhere to  this
    theory could seek state  resources to  meet  their priority  energy
    conservation needs.    §1166,  sponsored  by  Senator   Weicker  and
    Hatfield encompassed this  approach and is supported by the  State
    of Rhode Island.

(5) How should the federal governmnt  evaluate and monitor the effects
    of its new energy policies and  program changes?


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         Evaluations should be carefully structured to include an analysis
         of regional  impacts,  the  performance  of the  conservation/solar
         industry, and the effects  of the market  price  theory on barriers
         to conservation  such  as rentals and lack of capital.  Complaints
         to consumer agencies of government,  the progress of small business,
         governments and  non-profit  organizations, rental costs,  sales of
         energy materials  and  prices,   energy   conservation   loan  volume,
         and consumer attitudes  and  reactions are  important  and  should be
         monitored.  In addition, a  continuing analysis of alternate fuel
         consumption and prices will help determine program success.  Tech-
         nical assistance  and more  emphasis on  information-sharing  would
         be helpful.  Studies ought to be initiated to monitor and evaluate
         the impact of  the current  Federal  energy policy to determine if
         the results warrant  a continuation  of the market-price principle.
MICHAEL GERMAN
Policy Evaluation & Analysis Group
American Gas Association
1515 Wilson Blvd.
Arlington, Virginia  22209

     The American  Gas Association  (A.G.A. )  welcomes this  opportunity  to
provide its  comments  on the  Environmental Protection  Agency (EPA) Notice
of Public  Hearings on  the  Federal Energy Conservation  Program.   46  Fed.
Reg. 29752 (June 3, 1981).   A.G.A.  is  a national  trade association comprised
of nearly  300  natual  gas  transmission  and  distribution  companies which
provide natural  gas  to approximately  160  million  consumers  in  all  50
states.  These  A.G.A. member  companies  account  for nearly  85%  of the  na-
tion's annual gas utility sales.

     EPA's 1981  Section 11 review program is  focusing  upon the  changing
federal energy  conservation policy which  is  now tending  to favor  a decen-
tralized thrust  for energy conservation.  EPA's focus is apparently based
upon the  assumption that  the  federal government  will  withdraw  from  its
active pursuit  of  comprehensive  energy  programs such as  the  Residential
Conservation Service  (RCS)  Program I/ at  the Department  of  Energy.  While
it  is  apparent that the present  Administration plans a  more limited  role
for the  federal government in energy conservation matters  — as has  been
exhibited by the Administration's budget proposals for FY 1981  and FY  1982
— A.G. A.  is  not convinced that the  result of  such budgetary changes  will
be of  great  consequence  for  our member  companies.   Our  belief  is based
upon the  fact that, regardless of whether monies are  removed  from the FY
1981 and  FY  1982 budgets for  such  programs  as the RCS Program, the statu-
tory obligations  for  governments  and covered  utilities will  remain.  _2/
 I/  10  C.F.R.  Part  456

 2/  Furthermore,  substantial civil penalties for noncompliance  will remain
 as substantial impediments  to the  development of locally-tailored conserva-
 tion programs.   See;  Section 219(d) of  the National Energy  Conservation
 Policy  Act  (NECPA7~92 Stat.  3206;   42 U. S.C.  Section 8201).
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     Since the passage of NECPA  in 1978,  most utility conservation efforts
reflect the stringent requirements  of  the RCS Program to  some extent.   In
order to get  an idea,  then, as  to  what role utilities  will  play assuming
federal mandatory  programs  are  abolished,  we  believe that  EPA  should
focus its attention on what was being done prior to the enactment of NECPA.
In the gas  industry,  an A.G.A.  survey  in August,  1978, canvassed  213  gas
distribution member  companies.   168 of these companies responded  to  the
survey.  Of the 168  respondents,   87   (52%) already provided home  energy
audits, with  74 (44%) providing audits at  no cost  and 7  (4%)  providing
them at some  cost.  Attic insulation was marketed by 47  (28%) of  the  re-
spondents, and  26  (15%) of the respondents sold  wall insulation.   Nine
(5%) of the respondents marketed storm doors  and  windows.  Nearly  all  of
these programs  were  initiated without  any  direct  federal, state or local
mandate.

     Some specific actions  taken  by our  member  companies  include a  gas
utility in  the Chicago-Detroit  area,  which  marketed   ceiling  insulation
and offered a  variety  of financing options for its  customers.   By March,
1979, the  company  estimated that  approximately  140,000 homes  had  been
insulated.  Another gas utility  in the  Northwest also was  operating  an
ambitious energy conservation program  at the  time NECPA was  enacted.   In
addition to offering  financing arrangements  for its customers,  they off-
ered ceiling insulation, side-wall  insulation, night set-back thermostats,
storm windows,  furnace  ignition devices  (eliminating  pilot  lights)  and
new furnace and water  heaters  which  met  self-imposed stringent  energy
conservation standards.   One of  our west coast combination  companies,  at
the time NECPA was enacted, had  a program aimed  at  encouraging  consumers
to add insulation  to their  buildings by  offering  zero  interest  loans  for
the purchase of insulation.  In  the commercial sector,  another gas  utility
on the west  coast had  a   conservation program which   offered  consulting
advice on energy conservation measures and practices to owners of commercial
buildings.

     If the mandatory  aspects of the RCS program are eliminated, EPA  can
expect to see  various  states electing  to retain the existing  RCS  Program
in some form.   Furthermore, it  is  likely that  many states will elect  to
develop conservation programs  more closely  suited to the unique climatic
and economic situations  in  their states.   Ihis conclusion is  borne  out  by
the fact that prior to the enactment of NECPA, gas utilities in two  states,
Wisconsin and   Oregon,  were  implementing  state-mandated conservation pro-
grams.  These mandatory  programs existed  at the same time as  those volun-
tary utility  efforts described  above.   In  Wisconsin, the  state  public
utility commission  mandated a program which  was  similar to the RCS  Program
in that utilities  were  required to  contact  and  offer  energy audits  to
their customers.   To date,  experience  in Wisconsin  has been that,  while
initial reaction to the program was satisfactory,  there  has been  no signi-
ficant participation in  the program in the last  two years.  The lack  of
interest on the part of Wisconsin  consumers at this time  is  particularly
surprising considering  the  fact  that   most  utilities  in  that state have
been aggressively marketing the state program.  The Oregon program,  adopted
in 1977 by  the state legislature,  is  also  similar to  the RCS Program  in
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its provisions for  home energy audits  and utility arranging  services for
installation and financing of conservation measures.

     In terms of  the energy savings  which can be expected  as a result of
shifting the conservation initiative from the federal level to  the state and
local level, EPA should again consider the type of energy conservation sav-
ings which occurred prior to the enactment of  NECPA.   A. G. A. has conducted
a recent survey  of the  natural gas  utility  industry aimed at discerning
changes in energy consumption during  the period  from 1973 to  1979.  During
this period, the  RCS Program was  not in effect and therefore had not yet
had any  impact  on energy  conservation.   The A.G. A. member  company survey
strongly indicates  that substantial  conservation  has already taken place
in the  residential  and  commercial sectors —  without mandatory federal
programs.  For example,  in the residential sector, gas use declined at a
rate of  2. 7% per year,  resulting  in a 15% decline  in per user gas consump-
tion during  the  survey  period.    Furthermore,  commercial  sector  energy
consumption declined  at an  annual rate of  2. 2%  per  year,  resulting in
12.4% less  gas  consumption  per user during  the  1973-1979  survey period.
Obviously, A.G. A. has  filed  extensive comment with  DOE  stating that there
is no  necessity  for a  federally  mandated  conservation  program  such as
the RCS  Program.   Given the substantial amount  of price-induced conserva-
tion which already has  taken place, such a program will add an  unnecessary
burden to utility.

     It  is our  understanding that DOE  is  in  the  process of  revising its
RCS rule, with  the  goal of  making the  rule reflect more  strictly the re-
quirements of NECPA,  thereby eliminating many of  the  questionable  inter-
pretive aspects  of the  RCS Program  added  to the  existing  rule  by  DOE.
Since this proposed revised RCS Program  rule would give EPA  and  the natural
gas industry a  better idea as  to  what the federal  role will be in resi-
dential energy  conservation,  A.G. A.  hereby reserves the  right to supple-
ment its comments to  EPA at  such  time as the proposed  revised RCS rule has
been issued.  We believe that  this rule will be relevant to  the focus of
EPA's Section 11 inquiry.
SARA HMRIC
Associate Director, Energy
American Paper Institute, Inc.
260 Madison Avenue
New York, New York  10016

     The American  Paper  Institute is  pleased  to  submit  comments to  the
Environmental Protection  Agency on  the  future  of  various federal energy
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conservation programs discussed in EPA's Issue Paper,  "A Review of Federal
Energy Conservation Programs."

     The American Paper  Institute (API) is the  national trade association
of the pulp, paper and paperboard manufacturers  in the United States.  API
consists of approximately  175 manufacturers which produce about 90% of the
nation's pulp, paper and paperboard output.   In  1980, the entire paper and
allied products  industry  output was  valued at  approximately  $59 billion.
This industry, which operates in all states of the union, employs more than
700,000 people.

     As an  energy-intensive  industry,  substantial  efforts have  been made
to voluntarily  increase  our  energy  efficiency,  and  reduce  our use  of
fossil fuel and purchased  energy.    The  paper  industry has  improved  its
energy efficiency since 1972 by reducing its 1980 fossil fuel and purchased
energy use per  ton  by  26.3%.  During this  time,  the paper industy reduced
its total  use  of fuel oil in barrels  by 27.5%.  The  industry's  fuel and
energy consumption in 1980 consisted  of 48.1% self-generated hydroelectric
power.  By  burning  its non-fossil  and renewable residues  (spent pulping
liquors, bark and  hogged  wood),  the industry increased its  energy  self-
sufficiency from 40.5% in 1972 to 48.1% in 1980.

     The paper  industry has  consistently supported the  use  of free market
forces to encourage energy conservation.  The industry applauds the efforts
of this Administration to move the country away  from  government directed
conservation efforts.  The Department  of  Energy's  initiatives to  reduce
the FY 1982 budget  funds  for federal  conservation programs, referred to in
the EPA  Issue  Paper,  is  one of these efforts  which the paper  industry
supports.

     The wastepaper recycling  segment of  the paper industry would like to
take this  opportunity to  comment on  federal, state and local conservation
activities in relation to the construction and  operation of  waste energy
facilities.

     To the extent  that  governments  develop programs  for the burning  of
urban waste to  recover its energy value,  the paper  industry believes that
the free market should be allowed to determine the destination of recyclable
waste paper.  Federal, state  and local  governments should not enact legis-
lation that precludes or  interferes  with the collection of  wastepaper for
recycling.  There are current laws and  programs  which do so.  Allowing the
market to  determine  the  most  economical  use of recyclable wastepaper  is
consistent with the  Reagan Administration's philosophy  of  not interfering
with free market choices.

     The American Paper Institute  appreciates this opportunity to express
its views to the Environmental Protection Agency on this matter.
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RALPH B. HIRSCH
National Legislative Director
League of American Wheelmen
112 South Ifith Street
Philadelphia, Pennsylvania

      At least in the short  run,  energy conservation in several sectors  is
likely to be  a  highly economical form  of  energy production.   Although,  as
the just-released National  Energy Policy  Plan  (July  1^81)  observes,  some
conservation measures  require considerable  investment for  long-term  sav-
ings, some  require  little investment.   The enhancement  of bicycle  trans-
portation is  one of  these  low-cost  measures.   Already  a  significant and
growing part  of  the transportation sector in  the  United  States, the  bicy-
cle has the  added  advantage  of  being an instantly  recognizable symbol  of
energy conservation.

      The energy  conservation activities  of  the  Department  of Energy  as
they bear on bicycle transportation  are discussed  below under four  head-
ings.  A  brief  review  of current status  under each  headinq  is  followed
by recommendations  for future action.

(1)   Leadership and coordination of  federal agencies'  efforts

      In July 1980, DOE was  assigned  the role  of developing guidelines for
energy management  in  the  federal government and evaluating the compliance
by agencies with those guidelines  (see  appendix  1).   So-called "two-wheeled
vehicle programs",  to  include the encouragement  of bicycle use  for commut-
ing and operational purposes, are  among the measures  that  must be  consi-
dered in each agency's energy plan.

      We urge specific attention by  DOE to these two-wheeled vehicle pro-
grams in the  evaluation of the  first year's reports  from the  federal agen-
cies, for purposes  both of  creating a  baseline  for  gauging progress in fu-
ture years  and  of  identifying  measures  that  may  be readily  transferable
to other agencies.

      DOE should  also take a strong position at  its own facilities,  such
as Fermilab  and  Hanford,  to  foster  bicycle  use among  employees.   Care
should  be  taken  to avoid policies that  tend to discourage  or  interfere
with bicycle  use,   such as  a ban on bicycle  use  (proposed in  spring 1QR1
but now apparently averted)  on  some  roads  at Hanford,  and incidents last
year in  which enforcement personnel at  Fermilab  reportedly  tried to dis-
courage bicycle  commuting by staff members.

 (2)   State  and  local conservation activities

      State  energy  conservation  programs in several  states include a bicy-
cle transportation  component,  However, many  state highway agencies  still
are  inclined to give  bicycle transportation  measures a low  priority.   An
expanded concern by  state  energy offices for  inclusion of  such  measures
may serve to raise  these projects to a priority  level where they could suc-
cessfully compete  for  funding by state or local  governments.

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      The April 1980 Department of Transportation report  "Bicycle  transpor-
tation for enerqy  conservation"  (required  by Section  682 of the  National
Energy Conservation Policy Act of 1978,  Public Law  95-619)  recommended that
bicycle transportation  be  integrated in   "appropriate  federally  required
state and  local  planning activities" by DOE and  several other  agencies.
(See appendix 2).   As information is lacking to gauge how well this has been
done so  far,  DOE should  evaluate state and  local  planning done  under its
requirements to obtain that information.

      Energy contingency plannina at  the state and regional level should in-
clude the contribution that  bicycle  use could make  in  various energy emer-
gencies.  Although this  is  being done in a few metropolitan  regional plan-
ning agencies  (e.g.  Delaware Valley)  it  needs to be  considered in all of
them.

(3)   Grants programs

      We are aware  of only  a few bicycle-related  grants made by  DOE.  So
far as  we  know,  they have  been  relatively small in  size and high  in the
quality of the projects.   These  include the  significant and  valuable sup-
port by  DOE to  the first  national  conference for bicycle  professionals
(Pro-Bike 80)  in  Asheville,  North  Carolina in November  1980, and the  re-
cent award of  an  Appropriate Technology small  grant to a bicycle  group in
Atlanta, Georgia, for  a  project  to foster  bicycle  commuting.   It  would be
helpful if  DOE were to  prepare  and  collate information  to  publicize  all
these projects, and to encourage  agency officials to consider favorably any
future applications for similar projects of high quality.

(4)   Public information activities

      Scattered efforts  of  uneven quality  have been  undertaken by  TOE in
promoting bicycling  as an  energy conservation  measure.    On the  positive
side, a listing last year in the Energy Consumer  of state bicycle coordi-
nators and other  contact persons was helpful, and should  be  repeated in an
updated version.

      On the  other hand,  some efforts  are of dubious benefit.   Newsweek
(6 April  1981)  showed, under the slogan "Keep it  up, America.    Leave  the
car at  home once  in a while" a  man  and a  woman  riding double on  a  single
bicycle and violating many safety rules.  An  important  message was undercut
by being  inappropriately conveyed.    The opportunity  that the bicycle  can
provide as  a  potent and  instantly  recognizable  symbol  of conservation
should be capitalized upon by DOE.  Advance consultation  with the  organized
bicycling community will  enable  TOE  to take  full  advantage of  this  poten-
tial.

      A particularly promising  opportunity will be offered  by the  DOE's
participation in the  1982 World's Fair  in  Knoxville, Tennessee.   The  role
of energy  conservation generally, and of bicycle transportation's contri-
bution specifically,  should  be  presented  to  the  anticipated millions of
fairgoers.
                                   383

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Summary

      Large cuts in funding for conservation-related activities in the DOE's
1982 budget suggest a general retreat  from conservation as an  important com-
ponent of  departmental policy.  Tfe  think that conservation  ought to have
more emphasis among DOE's objectives.   However, even under a regimen of re-
duced funding the bicycle offers  an outstandingly  efficient vehicle for pro-
moting energy conservation.  As the national  organization of bicyclists we
are prepared to work with the department to get the maximum of mileage from
that vehicle.

Appendix 1

10 CFR Part 436, Federal Energy Management and Planning Programs; Guidelines
for Energy  Mangement  in  General   Operations  of the   Federal  Government

Final rule.  (45 Federal Register 44558, 1 July 1980)

436.104  Energy conservation measures and standards.

(a)  Each agency shall consider for inclusion in its plan the measures iden-
tified in appendix C of this subpart.

Appendix C - General Operations Energy Conservation Measures

(a)  'Hie following individual measures or set of measures must be considered
for inclusion in each agency's 10-year energy management plan:
      (10)  Two-Wheeled Vehicle Programs — Includes activities  to encourage
the substitution of bicycles,  mopeds,  etc.  for automobiles for commuting and
operational purposes.  These may  include the establishment of  weather-pro-
tected secure storage facilities,  shower and locker facilities,  and restric-
ted routes  for these vehicles  on Federal  property.   Cooperative programs
with local civil authorities may also be included.

APPENDIX 2

Office of the  Secretary,  Department of Transportation, Bicycle transporta-
tion for energy conservation, April 1980  (Report of the Secretary of Trans-
portation to the President and the Congress, pursuant to  Section  682 of the
National Energy  Conservation  Policy  Act  of  1978,   Public Law Q5-619).

DOT bicycle program activities  (page  38):
      2.  Implementing public information/awareness programs.
          The  Department will work with the Department of Energy to insure
          that federally sponsored energy conservation media cmapaigns call
          attention to the benefits of  cycling.
          DOT will request that all appropriate Federal agencies  (DOI, DOE,
          HUD, EPA) require  full  consideration of bicyclist's  needs in ap-
          propriate federally required  state and local planning activities.

                                    384

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MAKE L. HOFFMAN
313 1/2 S. 9th Avenue
Yakima, Washington  98902

     I would  like to  join the public hearing on federal  energy program
changes, but  D.C.  is too  far from  Washington  (state)  for me  to attend.
Still I would like to add my comments to those you will receive.

     I feel that this administration has really missed the boat on energy.
By putting all our eggs into the oil companies baskets,  we're bound to end up
facing the last drop of oil or the last chunk of coal with few alternatives
and at  the cost  of ruining  our  environment.   Fission  nuclear expansion
will find  us  surrounded by  an ever  growing pile of plutonium.   Both of
these should take a back seat as far as our future goals are concerned, I
feel.

     I was disappointed to hear  Pres.  Reagan  cut back most of  the solar,
geothermal, tidal,  wind,   etc. research budgets.   This  is indeed a  step
backwards.  These  "unconventional" energy  forms  are  our  only long  term
hopes, except  for fusion  nuclear and  hydro  power.   Fusion  seems to be
safer and should be researched further.

     Hydro is a whole separate can of worms.  I agree that dams are neces-
sary in  some  areas for irrigation, city  water supplies  and  flood control
and where a dam exists I feel a generator should too, BUT I also like wild,
free rivers for my own selfish  recreational desires, for  beauty,  and for
wildlife.  We need healthy rivers for healthy ecosystems to  continue.  So
hydro power should only be  part of the answer,  unlike what the Army Corps of
Engineers seems to think.

     Conservation and simpler life-styles  could also  be  encouraged by the
federal government.  This  doesn't seem  to  be the case  with  our present
administration, unfortunately.

     I know the problems are very complex,  but  the direction in  which we
seem to be heading has me  very worried.   The year  2000 is  very close.  We
have little time  to correct  our  ways and  no time for  mistakes.   PLEASE
HELP!!
AVIS E. HOLMES, President
Detroit Energy Corporation Consortium
State of Michigan Plaza
1200 Sixth Street
Suite 404
Detroit, Michigan  48226

RESPONSE TO ISSUES AND DISCUSSION TOPICS RAISED ON PAGES 4 & 5

    Analysis of the rationale, asumptions,  state and local programs budget
information, etc., clearly indicates substantial  conflict between the stated


                                     385

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national goals on  "energy  conservation"  and the means by  which to achieve
the goals, namely funding.

    *  Quote, "The Nation's energy problems will be solved primarily by the
       American people themselves — by consumers, workers, managers, inven-
       tors and investors in the private sector —  not by the government."

       Response:  Prior to  sweeping Wholesale changes, previously establish-
       ed and planned  programs should be  evaluated and  closely monitored
       over a three  (3)  to five (5) year  period.   Over the past  four (4)
       years appreciable money as invested in these programs.  To eliminate
       these programs without properly  determining their effect is extremely
       wasteful.

     * Quote, "The Government's role is to establish sound public policies,
       based on economic principles, national  security concerns, and a due
       regard for environmental values, so  that individuals and firms in the
       private sector have  the incentives  to  produce and conserve energy
       efficiently, consistent with the national interest."

       Response:  The Government's role is  to guide and promote "Alternative
       energy sources"  in order to efficiently utilize the nation's avail-
       able resources.

     * Quote, "The Government's role  is not to select  and promote favored
       sources of energy.  Doing  so risks wasting  the Nation's resources.

       Response:  The Government's role is  to guide and promote "Alternative
       energy sources"  in order to efficiently utilize the Nation's avail-
       able resources.

     *  Quote,  "Formulation of energy  policy must be  sensitive to the
        needs of the poor.   But,   energy policy should not  be used  as an
        income transfer program.   For  example, holding  energy prices down
        for rich and poor  alike is an ineffective way to help the poor."

        Response:  If  energy prices/costs are targeted  to the pocketbooks
        of the rich some subsidy must be available to the poor.  The feder-
        al government must spend  for  energy  purposes because  an adequate
        supply of energy is  our first line of defense and is essential to
        the national interest and security.
                                     386

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*  Quote,  "Federal public  spending  for  energy purposes  should  be
   limited to those areas in which  the private sector is unlikely  to
   invest sufficiently, such as in high cost,  long lead time technolo-
   gies with substantial prospects  of high pay-off.  Public  spending
   should not be  used  to   subsidize  domestic  energy production and
   conservation since  this  buys  us  little additional  security and
   diverts capital, workers  and initiative from more productive  uses
   elsewhere in the economy."

   Response;  Public (federal)  spending, to subsidize domestic energy
   production and  conservation is  an  "appropriate"  and  "necessary"
   federal government  expenditure,  because the  United  States  is not
   energy self-sufficient.   Concurrently, this nation is an excessive
   consumer of  non-renewable  energy.   Residential  usage   comprises
   thirty three percent (33%)   of  energy   consumption  and  therefore
   the public must  spend  to reduce this high percentage.   Moreover,
   energy production and conservation are  integral components linked
   to all  sectors  of  the  economy.   Since most essential  industries
   have been highly developed,  the  track to innovation and  continued
   progress lies in our capability to improve  through  energy conserva-
   tion and energy production.

        Government spending is  a "long term investment"  with an "imme-
   diate result" of  employment and education.   Employment  opportuni-
   ties will  in turn  stimulate the  economy.    It  is essential  that
   government spends its productive areas.

*  Quote,  "The United  States government  should  also take  steps neces-
   sary to  deal with  potential  disruptions  in world  oil  markets.
   These steps  include  increasing  strategic  petroleum stocks  and
   eliminating controls on  oil which discourage  the private  sector
   from dealing with disruptions effectively."

   Response;  The private sector is concerned  with continually increa-
   sing profit for its stockholders and investors.   The private sector
   is not in any way charged  with  the responsibility of meeting the
   needs of  the poor,  nor  is  the private sector charged with the
   responsibility of the general  welfare  of the  public.   To  impose
   such a responsibility on the private  sector  is  to  introduce incon-
   sistency in the concept of  free  and private  enterprise.   It is the
   responsibility of the federal  government to ensure that  the needs
   of the poor are met.

*  Quote,  "The  United  States government should also  take steps  nec-
   essary to deal  with potential disruptions in  world oil  markets.
   These steps  include increasing  strategic  petroleum stocks  and
   eliminating controls on  oil which discourage  the private  sector
   from dealing with disruptions effectively."
                                387

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        Response (Continued):   A first step that the United States govern-
        ment should take  to deal  with potential disruptions  in vrorld oil
        markets is is  to alleviate  the  great dependency  of the  U.S. on
        foreign oil.   This requires  that the  federal  government actively
        participate in the promotion of  energy production, energy conser-
        vation, and alternative fuels.

     *  Quote,  "The level of oil imports per se  is only a rough indicator
        of the Nation's progress in  solving  its  energy problem.  The  wel-
        fare of the  American  people is  inextricably  linked to  that of
        people in  other countries, so the  United States cannot insure its
        own security by a reckless  attempt  to eliminate imports."

        Response;   The  national  security  of  this country  is paramount.
        Thus, domestic energy production and conservation is essential to
        that security.   A weak link in our security is our over-dependency
        on imported energy.   It is impractical to  totally  and dramatically
        eliminate  imports.  However, a  policy must  exist to reduced our
        total dependency on such imports.  Availability of oil imports is
        unreliable and subject to the political whims of despots and  fana-
        tics over  which we have little,  if any, control.  While it is  true
        that our welfare  is linked to that of people  in other countries,
        we cannot  rely on other countries  for  our  own security.  The  U.S.
        can only secure our own security by minimizing reliance  on other
        countries  for essential needs.

     *  Quote,  "Energy is an international  issue  and so the American people
        have an interest  in  seeing  that  other  countries  establish sound
        energy policies."

        Response;   The United  States must  first  establish  and implement
        its own sound  energy   policy/policies,  then monitor  and  evaluate
        those policies on a  consistent  basis, determine  the success and
        short-comings of  those policies   to  eventually  demonstrate  and
        share these policies  with  other  countries.   In so doing,  the  U.S.
        must be ever mindful that  other  countries  that we are  influencing
        are nations that  have  governments  that  guide,  promote and imple-
        ment national policies and goals imposed on their private sector.

RESPONSE TO GENERAL QUESTIONS  IN EPA ISSUE  PAPER, PAGE  SEVEN

     *  How are private firms, state governments,  and local  agencies prepar-
        ing to assume their new responsibilities?

        Response;   Given the  new  direction  of federal  energy policy and
        the decentralized nature   of energy  conservation,   there  is no
        provision  for direction, support or authorization of private firms,
        state governments and  local agencies  to assume  the  responsibilities
        eluded to  herein.  The new  policy does  not  offer a plan  or the
        funds for   the  these   agencies   to  assume the responsibilities.
                                    388

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*  Which activities will get priority from public and private organiza-
   tions and what will be  consequences if some activities are discon-
   tinued?

   Response;  It appears that  public/private organizations will  give
   priorities to those activities which serve  their  own self-interest
   because there will  be  no national  priority.   It further  appears
   that activities  that  attempt to meet  the essential  needs  for the
   poor will be  placed  in  secondary  or  tertiary levels of  concern,
   if not  totally  discontinued.   Current  energy  conservation   and
   energy assistance activities  are inadequate to meet the needs  of
   the poor  and  the general public  and  should  have been  expanded.
   Additional elimination  and   decentralization  of  these  activities
   will have an  adverse  ^effect  on  the national  energy goals of  the
   1977 Act and will adversely impact  upon the economy and the nation-
   al security.  Adversely  upon the  economy because the public  will
   continue to over consume  and a large segment of  the poor will  be
   unable to pay the cost  of such heavy  consumption.   Adversely  upon
   the national security because consumption will be at a  rapid  rate
   while conservation  and   domestic  production  will  be  curtailed.
   Consequently,  we will  be vulnerable to international forces  over
   which we lack direct control.

*  Have any new initiatives or  opportunities been created as a result
   of the shift in Federal  energy conservation programs?

   Response:  There has been a notable decrease in initiatives because
   the opportunities and incentives have  effectively been  removed.   A
   good example is  the federal  government's reneging on a  commitment
   to alcohol  fuels projects.    Elimination  of financing  in  alcohol
   fuels projects and other  alternatives  to  imported fuels  has killed
   internal control of an  extremely viable means  of production which
   itself could generate a  series of new initiatives and opportunities
   that would  create  vast  employment opportunities  and  in so doing
   stimulate the  economy.   The  elimination  of  the initiatives  and
   opportunities that were created through  the weatherization program
   and the  industry that sprang  from it  have been  lost.   Moreover,
   the CETA workers who were trained  out  of weatherization funds  will
   now be  out  of  jobs.    That  constitutes  a waste of  governmental
   funds because the jobs  are now  unavailable.   The second waste  is
   the loss of available "trained" manpower  to the ranks  of the unem-
   ployed, while the public need for weatherization services escalates
   with the ever-rising cost of energy.

*  What is the  Federal government's proper role in this period of tran-
   sition?
                               389

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       Response;   The proper role of  the  federal government is  to postpone
       the hasty  elimination  of programs already in place until such time
       as the new programs have been drafted and potential benefit deter-
       mined.   As previously stated the assumption that lead to the sweep-
       ing eliminations of programs are  untested.   Thus,  the proper role
       of the  federal  government  is  to  insure that  there  is no  gap  in
       services,  benefits or progress in the  transition  of ideologies  or
       approaches to  a very  serious matter  of  national  concern.   The
       hardship that will inure to individual  citizens as well as to our
       conservation and security needs does not  justify  such  an untested
       course of  action.

            Under the Department of Energy  (DOE) Act the federal govern-
       ment has mandated  that  a study should be held  to assess  the govern-
       ment's energy program.   The federal government should properly and
       fairly postpone any massive changes until such time as the mandated
       study has   been completed.    Changes  should  then  be made  on the
       basis of the  findings  of that study which  is to  be completed  no
       later than January 15,  1982.

    *  How should the Federal government evaluate and monitor  the effects
       of its new energy  policies and program  changes?

       Response;   In order to  monitor the effects  of new policies it  is
       first necessary to  monitor,  assess  and evaluate  existing energy
       policies and programs  in order to provide for an  "objective stan-
       dard" of  reference.   New  policies  and programs  should  then  be
       measured or  compared  to that  reference standard  and  to national
       needs and  goals.

STATE  AND LOCAL   CONSERVATION  ACTIVITIES,   EPA ISSUE   PAPER, PAGE  12

    *  Which  of   the  functions formerly performed  by  Federally funded
       programs are likely to  be  picked up by the  state energy offices?
       By cities  and counties?  By the private sector?

       Response;   The  State of  Michigan, as a point  of reference, relies
       almost exclusively  on  federal government  funding  of  the  State
       Energy Office.  These  funds  have been inadequate  to  permit any
       serious planning or activities by the  State  Energy Administration.
       The current funding priorities of the State of Michigan  are prisons
       and the correction systems,   mental  health,   and.  social  services.
       Thus, it is  extremely unlikely that the State of Michigan  can take
       up the massive slack that will be created by the  sweeping elimina-
       tions in the energy area.

    *  Which  of  the functions formely performed by  Federally  funded  pro-
       grams are  likely  to be picked up by the state energy offices?  By
       cities and counties?  By the private sector?
                                    390

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   No major  cities or  counties have  established  an energy  office,
   and the same are already  short-funded  and  have relied heavily upon
   federal funding in the  past for essential services.   Thus, it  is
   not likely that the  local  entities will  be able  to take up  the
   slack.  The private sector involvement  is limited to the utilities'
   participation in the   Residential  Conservation  Program.   Their
   effectiveness will also be  curtailed  because the  federal  weather-
   ization and fuel  assistance plans  which helped low-income people
   conserve energy and subsidize energy costs  have now been eliminated.

*  What will be the effects if a state decides to phase out its energy
   office?  Which activities will be discontinued?

   Response;  The  State  Energy  Office is  already unfunded  and  had
   only provided  scant   information  and   limited  technical   advice.
   Almost all of their activities were with utilities.   However,  they
   lacked sufficient  staff personnel to effectively monitor the utili-
   ties' residential  conservation activities.  To  eliminate the  state
   office would mean  that the public would be left with no representa-
   tion or means of becoming involved in  the national energy effort.
   Since effective energy  conservation relies primarily on the  human
   element it would be  cost effective to expand upon the  foundation
   that has already been established,  especially if the federal  gov-
   ernment intends to withdraw from  its  role  in the energy  effort.
   It is imperative that the State of Michigan  be funded to take  up
   the slack.

*  How can local governments transfer the  state experience and resour-
   ces to  the  development  and  implementation  of  local programs?

   Response;  The  state  experience  cannot  be  transferred  to  local
   government unless  accomplished   by federal   government fundings,
   support, and progressive monitoring and evaluation.

*  How will the 21 states  that have biennial  budgets  adapt to the new
   Federal priorities?  What is the consequence of their operation  on
   a biennial budget  likely to have on this  adjustment?

   Response;  Michigan  has already  adopted its  "annual" budget, and
   the budget did not adapt to the new federal priorities as there were
   no funds appropriated  to  take up the slack.   Because 21 states  or
   42% of the  states  do  have  biennial budgets  is  a  further  indica-
   tion that the  elimination of  weatherization  and  assistance  pro-
   grams ought to be postponed in order to  allow the  entire 50 states
   the opportunity to reassess their  priorities  so  as  to  minimize
   wholesale hardships and  suffering.
                                391

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     *  How  can  information, experience and resources  be shared regionally
        after the discontinuation of the DOE Regional Offices?

        Response;  If by  elimination the  DOE Regional  Offices  the  system
        of regionalism itself would be destroyed the sharing of information
        by regions  would  cease  to  exist.   Thus, the DOE Central  Office
        would have  the  additional  responsibility previously  held  by the
        Regional Offices.   Information and direction as to the  goals  is a
        federal government function  that cannot  be delegated.  A contact
        person or unit  by state  in  the national  office plus a toll  free
        telephone number might be a pragmatic alternative.

     *  Can alternative funding source be found for conservation activities?

        Response;  Conservation is essential  to  our national  security and
        has been defined as a national goal.   Thus, conservation activities
        and the funding  for such is the federal government's responsibility.
        Perhaps, after  ten  or fifteen years  following  the implementation
        of all of the measures essential to conservation (including  alter-
        native sources)  have  taken root then these activities  themselves
        will lessen  the need  for governmental  funding.   At  the present
        time the federal  government  must take the lead as it is  a  matter
        of national security and  public welfare.

WEATHERIZATION AND DOW INCOME ENERGY ASSISTANCE,  EPA ISSUE PAPER, PAGES 13,
14=15	~

     *  What governmental  department?  (Page 13)

        Response;  On the issue of what governmental department will  admin-
        ister the program is not as essential as the continuation  of serv-
        ices, except that  the federal  government  should adequately  fund
        whichever department is designated as administrator.   There  should
        be no break in the services.

             However, the state block grant approach will not  be effective
        because many of the  states are  not  sufficiently prepared to  deal
        with the subject of energy.  Their  priorities are similar to  Michi-
        gan's which  is  one of the most  advanced  states,  i.e., trying  to
        deal with people who are physical menaces  to society and/or  unable
        to accept the massiveness of the responsibility  that goes  with the
        national goals of energy.  Here again there should be a period  of
        adjustment and preparation before the  states are given  this respon-
        sbility.   To thrust it on the states at  this  point in time would
        be a peril to our national security.  It  should  be remembered  that
        national security  is  a federal  and  not   a  state  responsibility.

     Funding mechanisms  and structural issues

     *  In light of  the proposed  changes,  how can the  nation maintain  an
        effective low income weatherization program?


                                     392

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   Response:  The elements of  a low-income weatherization program are
   "labor", "materials",  "management",  and "training".  All of  which
   cost dollars.  Low-income weatherization by definition means  serv-
   ice to people who do not have money to buy such service themselves.
   The elimination  of  the CETA program  along  with the  reductions
   from current funding levels mean that the nation will  not  be able
   to maintain   an  effective   low-income   weatherization  program.

*  If  weatherization is  transferred into HUD  Community Development
   Block Grant,  what agencies  would  be  effective  sponsors  at  the
   community level?

   Response;  If transferred to HUD Community Development Block  Grant
   then HUD would have  to determine the effectiveness of the  respon-
   sibility.  They should use a criteria and an appropriate monitoring
   and evaluation system  that  would be comparable to the  standards
   they use to  approve,  certify and monitor HUD  approval comprehen-
   sive housing counseling agencies.

*  How  can problems  involved   in  transferring  the program from  one
   agency to another be minimized?

   Response: The problems can  be minimize  in transferring the program
   into one agency to another by incorporating the existing operations
   into the new  agency  for one year.   During the  year the  successor
   agency would establish its own standards as to sponsor  criteria and
   performance levels.  Unqualified sponsors will be given a reasonable
   period of time to phase out their activities.

Implementation issues

*  If  a state decides  to phase out Community Action Agencies,  how
   can their  resources  and  experience  be transferred  to the  new
   weatherization sponsor?

   Response;  Community  Action Agencies that have the proven capabil-
   ities should be allowed to  continue under the new standards estab-
   lished by the successor department.   Where such is impossible the
   Community Action Agency personnel and resources should  be available
   and utilized by the succesor agency.

*  Should LIEAP  funds be utilized  for  weatherization?   How  can  the
   LIEAP program coordinate  its activities  with  the weatherization
   program at the state  and local level?
                                393

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Response;  It would  be a dilution  of the purposes of LIEAP funding
to allow  same to  be used for  wea ther izat ion.   Although  the same
agency might  handle  same,  separate  funding  should be  available
for weatherization,  and  under  no circumstances  should  the level
of funding  be  reduced.   I  would  grant  that  weatherization  and
LIEAP all have  to  do with energy, but more  importantly,  they have
to do  with housing  and  could  be effectively  administered by  a
single entity perhaps reducing  administrative  costs.  This  would
in effect increase the  amount of money  available  for  direct ser-
vices.

     Essential to the success of all of  these pograms is  "counsel-
ing" in order to insure that the gains are not short-termed and to
create an  effective  conservation effort,   because  conserving  by
nature is a human function.

What is the most  equitable  and  cost-effective  weatherization pro-
gram?  Should the  Federal government continue to provide substan-
tial assistance ($l,000-$2-000/unit)  to a relative  small  number of
houses?  Or, should  the program  be restructured to provide minimal
weatherization ($200-$300) to a larger number of units?

Response;   Based  on  our  experience  and observation the  Federal
government should  continue to  weatherize the complete  home.   Com-
plete weatherization  would be  wasteful  because  there would  be no
real energy savings.  It would  be money  thrown away.  The sensible
thing would be  to  provide  sufficient  funding  to weatherize  the
homes.  If given a time-table we should  adopt a plan to weatherize
all of  the  twelve  million low-income  homes  with  five  years,  a
structured approach  must  be  followed.   Hence,  the bandage  on the
gaping hole approach  would  serve no beneficial purpose,  nor would
it lead to the achievement of the state goal.

How can  CETA workers be  retained in the weatherization  industry?

Response;   The program referred  to in the previous  question should
include CETA workers.   A reduction  in  the  cost  to retain  these
workers could be realized through the expansion  of  the  weatheriza-
tion program,  based  on  the scale  and  the amount of  activity that
would be  generated.   Hence,  it  is obvious  that only  through  the
infusion of dollars  into the low-income  weatherization  program can
CETA workers be afforded the  opportunity  to  participate in  the
weatherization industry.   The private sector cannot provide suffi-
cient job opportunities that  would  result  in the assimilation of
the vast number of CETA workers.   Additionally,  the work experience
gained by the CETA workers will  serve to make them more  job ready
if jobs in the  private sector  to come into  being.  The net effect
would be to reduce the level of  requisite support from  the govern-
ment.
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EVALUATION, EPA ISSUE PAPER,  PAGE 16

     *  What information is necessary  to enable the Federal Government  to
        monitor and evaluate the  effects of  changes  in energy policy and
        conservation program?   For  example,   should   DOE monitor whether
        state and local agencies continue important conservation activities?
        Whether private firms continue  conservaton R&D?  Whether homeowners
        continue to invest in conservation improvements?

        Response;  First,  it's  necessary  to  monitor  the  existing  energy
        policies and conservation programs.  Without a knowledge and  under-
        standing of the successes  or  weaknesses  in   the  current program
        the Federal government  will be  able  to determine the effects  of
        the proposed changes in such policies and programs.  The question
        posed as to whether DOE should  continue to monitor  the  continuation
        of various programs is  less  important than whether or not we have
        made an acceptable level  of  progress  toward the national goals  of
        conservation,  service and self-sufficiency.

     *  What types of regular monitoring and special  studies would be most
        appropriate for obtaining this  information?

        Response;  Again,  since the national policies  of energy are  rather
        new it  is important  to determine, assess, monitor  and  evaluate
        what is and what has  been.

     *  How can this information be gathered without placing a major  paper-
        work burden on respondent  organizations?

        Response;  The  results  of  monitoring and  evaluation of current
        programs will  provide a  guide  as to policy needs  for future pro-
        grams.   This is especially critical since the proposed new changes
        will be based primarily on assumptions and such programs have not
        been clearly defined  to the point where a standard for success  or
        failure has been identified.  We should take advantage of informa-
        tion already available through  past activities and use this  infor-
        mation to design the programs and policies  that meet  our national
        goals.   Therefore,  the  nature of information needed will  be  dicta-
        ted to a large degree by identified  needs.

     *  Regarding the  Sunset  review, what are the most important  questions
        in the Sunset  Provisions?  What would  constitute adequate  responses
        to these questions?  What  types  of analyses  should the  responses
        contain?  What types  of data  should  be  include?  What  level   of
        detail  is needed?
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Response:  The  most important   aspects  of the  review are  those
that have to do with the objectives  for which the program is being
established, specifically,  (2) an identification of the objectives
intended for the program and the  problem or need which the program
was intended to address;  (6)  an assessment of the degree  to which
the original objectives of the program have been achieved, expressed
in terms  of  the  perormance,  impact,  or  accomplishments of  the
program and of the problem or need which it was intended to address,
and employing the procedures or methods  of analysis appropriate to
the type  or character  of  the program;   (7)  a  statement  of  the
performance and  accomplishments  of   the program  in  each of  the
previous four  completed fiscal years and  of the  budgetary  costs
incurred in the operation of the program;  (8)  a  statement  of the
number and types of beneficiaries or persons served by the program;
(9) an  assessment of  the effect  of the program on  the  national
economy/ including, but not limited to,  the effects on competition,
economic stability,  employment,  unemployment,  productivity,  and
price inflation,  including costs to consumers and to businesses;
(10) an assessment of the  impact of the program  on  the  Nation's
health and safety;  (13) an  analysis  of the  services which could be
provided and performance  which could be  achieved  if the program
were continued  at a  level less  than,  equal to,  or  greater than
the existing level; and  (14) recommendations for necessary transi-
tional requirements in the  event  that funding for  such program is
discontinued, including proposals  for such executives or legislative
action as may  be  necessary to prevent  such discontinuation from
being unduly disruptive.

     I feel  that  all  of these  items are  important  because they
address essential  criteria  that is  necessary to  determine whether
or not  an energy policy  is needed  and  will show  the success  and
failures of  such policy.   Perhaps,   most  importantly,  they will
advise us as  to whether  or not  the assumptions that lead  to the
proposed changes  possess  the  validity  that  would  warrant such
changes.

     Again, I  would stress that the  four  years of  data already
compiled should be analyzed.  This  information must  be augmented
by survey-interviews of  actual  consumers aivl participants both at
local and state levels.   With  four years of activity  behind us we
will have empirical  data that we can use  to affect  policies  and
program changes that would make it unnecessary to rely upon assump-
tions and its  many many variables about the energy market and the
behavior of firms and individuals within it.
                             396

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BILL HORNE
Deputy Director  for Conservation
State of South Carolina
Office of the Governor
SCN  Center, llth Floor, Suite  1130
1122 Lady Street
Columbia, South  Carolina   29201

     A federal energy policy is most important  in providing direction for
both energy  suppliers and consumers.  We have already experienced seme of
the  potential problems associated  with rapid price  increases  in energy.
Inflationary pricing  policies  have affected almost all  goods and services
produced.  An  effective  energy  policy which  allows time  for development
of U.S.  energy  resources is  needed to help  overcome and  prevent  future
problems such as inflation.

     Expansion of  our  economy,  unstable  conditions  in the  Middle  East,
balance of payments and controlling  inflation  should be addressed in energy
policy development.   We must  also  consider  long term  objectives.   If we
continue to have dramatic  price  increases  in energy then control of infla-
tion and expansion of our  economy will be more difficult to obtain.  Stable
energy prices, however will assist in both controlling inflation and promo-
ting growth.

     An energy policy ought to  seek and encourage  stability in price and
adequate supplies of  energy.

     In the immediate future conservation or  efficient  utilization  of our
energy will help stabilize prices.   As we  expand our  efforts  to produce
more energy, efficient utilization can make otherwise wasted BTU's available
for  growth.  Conservation can  play an important  role as  a source of energy
in the period ahead as we  develop our sources.

     How we  achieve  more  efficient utilization  in the  market place is
important.  Large private firms  such as  IBM have  already demonstrated an
ability to reduce  BTU consumption  and  expand simultaneously through more
effiicient utilizaiton of  energy.

     In our  State the  small  and  medium  size  firms without engineering
staffs do  not have   similar  track  records  in  conservation.   Commercial
consumption of energy in South Carolina  has increased much  faster than
industrial or  residential  in  the   last twenty years.   With  substantial
industrial development occurring we have been able to produce  more  effi-
ciently.   Industrial  firms more  often than not have expertise available in
house.  Just recently, however,  we had  a request  from an independent food
store owner to advise him on how to become more energy efficient.

     Upon examination we  simply find conservation expertise  is  needed in
certain areas of our economy.   Also a  strong conservation  ethic  ought to
be supported.  Without that support we  can expect less  efficiency and an
extrapolation of past consumption trends in some areas.
                                     397

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     Moderating price  increases can  be accomplished  through conservation
as presently  demonstrated  in  gasoline.   Consumption  is  down  about 170
million gallons annually compared to  1978 in South Carolina.  As we expand
energy production  capabilities  stable prices  will assist in  efforts to
expand the GNP and control  inflation.

     Without national  direction it is difficult to determine the various
policies which  may be developed by  states  and local agencies to impact
energy.  One  could expect ednergy producing  states  to view policy differ-
ently from consumption only states.

     In summary, effective  utilization of our energy resources in the  next
few years  should  be  a  national  goals.  The benefits are tremendous and
include:  assistance   in  controlling   inflation,  balance  of  payments are
favorable with less imported oil, wasted BTCJ's may be diverted to expansion
of the  GNP,  our  current supplies  last longer  and provide  valuable  time
for the U.S.  to develop energy resources and government  should be able to
reduce its role in assisting with payments of energy.
J. A. HUNTER
Manager, Conservation Systems
San Diego Gas and Electric
P. O. Box
San Diego, California  92112

     San Diego Gas  and  Electric would like to provide  a written statement
in response to the EPA Hearing on the Federal Energy Conservation Programs.

     First of all, the reduction of the Federal funds for the Energy Conser-
vation Programs, except  for  RCS,  will place a greater  financial burden on
our local community agencies and on our Company.   There are three different
funding programs  for  the low-income and  senior  citizens in the San Diego
area.  These funds cone frcm DOE, our utility company,  and HUD (in the form
of Community Block Grant Money).

     In regard to the RCS Program, the effects of the  reductions would be
felt by the  California  Energy Commission.  The  CEC does  receive Federal
funds for this program.   These funds are used to award contracts for differ-
ent projects,  some administrative costs,  etc.   If the funds are eliminated,
the CEC would either have to pursue  alternative  funding sources, or elimi-
nate the activities which are no longer funded.

     The RCS funding cost would affect the local level  differently.   In a
general sense,  our Company would be able to do an audit for less money with-
out the funding.  The  State Plan  could  then  be modified according to our
community needs.  Therefore,  the audit could be streamlined accordingly and
the rates reduced.

     SDG&E wants these  comments to  become part  of the permanent record.
                                     398

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     Due to high utility rates  in the San Diego area,  we are always pursu-
ing ways to stabilize our rates.
WAYNE JOHNSON, Chairman
Government Relations Committee
Southern Gas Association
4320 LBJ Freeway, Suite 414
Dallas, Texas  75234

     The Southern  Gas  Association,  which  represents  the  interests  of
nealy 100 natural gas,  transmission,  distribution and production firms and
the South and Southwest is pleased to present these comments for considera-
tion by the  Environmental  Protection Agency in its  continuing analysis of
Federal Energy Conservation Programs.

     At its  most recent meeting,  the Board of  Directors of  the Southern
Gas Association  adoptd a  resolution  supportive  of  an emerging  trend in
federal energy policy to decentralize many programs  which were formerly
conducted at the Washington level and  return  authority and responsibility
for these programs  to  various  state  and local  agencies.  The  AGA Board
urged our member transmission and  distribution companies to  work closely
with officials of the various state  agencies  in  developing effective pro-
grams and implementation plans  in such areas  as  energy conservation, wea-
ther ization, low income fuel  subsidy programs  and  other  energy related
programs designed to help citizens use energy more wisely.

     We share a  conviction  frequently expressed by officials of the Reagan
Administration that the price paid for energy is the largest single determ-
inant in controlling it's use.  The supplementary information which accomp-
anied the notice for  this  EPA analysis includes the statement that current
changes in  federal  energy conservation programs  are  based  on projections
that rising  market prices  of energy  commodities  will enhance conservation
efforts and we certainly agree with the determination.

     Inherent in our  support for this posture is  the belief that state and
local agencies  are in  the best  position to  determine effective programs
and policies  for the  citizens of their particular states.  Empirical evi-
dence exists to  confirm our belief that local officials are most responsive
to needs of local taxpayers and  perhaps  most responsive  to the wishes to
local citizens in developing programs which reflect those citizen's desire
for certain  levels of state program funding and activity.

     One example of the critical need  for local authority  and responsibili-
ty can be  seen  in the past winter's  Low Income  Energy Assistance Program
(LIEAP).  Title  III  of the Windfall Profits  Act created  a  Hone Energy
Assistance Program designed  to  provide funds to the states to be distribu-
ted to low income families  to  help offset the  rising cost of fuel.  The
stringent nature of the language in Title  III plus the natue of the regu-
lations promulgated by the  Secretary of Health and Human Services resulted
in program  regulations which  were in direct  contradiction with existing

                                     399

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state laws in at least seven of the states represented by the  Southern Gas
Association.

     As a result,  natural gas utilities  in  those states found  themselves
in a dilemma:  their desire to participate in this low income  subsidy pro-
gram was thwarted by existing state regulatory commission orders or by ex-
isting state laws.  The  single issue  which brought this matter  to  our at-
tention was one of termination of utility service which is a responsibility
of the state utility regulatory authority.  However,  the federal  government
in this example  overrode existing state  standards in favor of  a national
standard on termination  of service.  Had the  new policy of decentralized
control over  federal  programs been  in  effect,  natural  gas  companies in
many of our states could  have participated in  the  program thus insuring
that funds allocated for  fuel subsidy payments  could have gone directly to
the energy  supplier.  This is but one example of an  instance  where strict
federal regulations can work to the detriment of program goals.

     Perhaps a more important reason  for supporting  a decentralization of
federal energy  conservation activities  lies in the  fact  that Americans
are conserving all forms of  energy.   Major oil  companies have reminded us
that nationally  our use  of gasoline is declining.  We have seen evidenced
from major  electric  utilities which suggests that the growth in electric
load is increasing at  a  slower rate  than was experienced  in  the past few
decades and certainly in the first half of the 1970's.

     Customers of natural  gas utilities have reduced their consumption of
America's cleanest burning fossil fuel  also.   Residential   customers, be-
tween between 1970-1980,  have reduced  their  use of natural gas  by some 15
percent.  Industrial customers of natural gas utilities  have reduced their
energy consumption  by  11 percent.   (Source:    American Gas  Association,
1981).

     In conclusion, conservation is occurring in the marketplace in propor-
tions which are  not  directly related  to  level of  federal program activity
urging energy conservation.

     In this  period of  policy review  and  determination,  we suggest the
federal government  can best  serve the American citizenry  -  both private
and corporate  - by  transferring authority  and  responsibility  for energy
conservation programs to the state agencies and to the citizens  themselves.
At most,  federal participation should  be advisory to the  primary  role of
the state  agency.   For  example,  federal programs might  suggest areas for
state consideration in formulating programs  for energy conservation.  Fed-
eral agencies  might  advised private   industry  as  to  the specific  cost
savings inherent in  various conservation activities.  Finally the federal
government  might assist  local governments  -  both  state and municipal -
with advice and counseling  on the best approaches  to  be taken by  local
governments in  urging  energy  conservation by their citizens.  All of  these
programs can  be conducted in an advisory nature and do  not require a vast
bureaucratic  system of rules and  program regulations which must be adhered
to by local governments  and private corporations.


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     Of primary  consideration is  the proposition described  earlier that
rising costs of  energy to  business and to  the individual honeowner  is a
much more effective  energy  conservation promotional device than is all of
the federal, state and local programming.

     Our economic system is based  on the premise that  when goods cost more
people use less and we congratulate and support the Environmental Protection
Agency in its expression of this overriding principal.

     Thank you for the  opportunity to submit  these comments and we stand
ready to assist  the  agency  in any way  we can  to  fulfill your objectives.
SUSAN KELLER
The Community Network for
 Appropriate Technologies
1321 Cleveland Avenue
Santa Rosa, California  95401

     I wish to  urge that  action be taken  to  reinstate and  expand energy
conservation programs.  Facts prove:  1) energy costs  continue to soar;  2)
present energy  consumption habits make us politically  vulnerable to other
nations; 3) conservation  is a  much wiser  investment  than the development
of new power  supply;  and 4)  up to 40% of  energy now  consumed is wasted.

     It is imperative that  conservation programs  receive continued Federal
support.  Education  and community outreach  are essential  if  we  are  to
impact the community.   Grants to the low-income  community as  a means for
getting conservation measures in place is of critical importance.  Studies
prove that not  only  does  the  investment  in  conservation cost much less
than the energy supply offset  by  such  action,  but  such action helps  to
short-circuit the  cash drain  on the local  economy  to  a  great extent.

     From 1973  - 1979 energy  costs increased 171%.  The next several years
will undoubtedly be much  worse.   Local  governments  and communities are
doing a great deal toward  conservation, but federal assistance is needed
to insure a rapid  transition  toward a sustainable energy  future.  Such an
investment in efficiency of all support systems makes  economic good sense
no matter who is talking.

     The Reagan  Administration  Energy  Policy  (supply-side mentality)  is
totally counter to the  economic,  social and political well-being of this
nation.  National  Security rests in our  ability  to  conserve resources.
Please re-evaluate  energy  policy in the interest of the  American people.
                                     401

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PATRICIA KELLY
700 W 17th Street
Pueblo, Colorado  81003

     The changes in the proposed 1982 Reagan budget for energy conservation
programs over recent policy are great.  I  can agree that there is  a need
to allow petroleum-based  energy sources to  seek  a real market level.   We
would not be  a nation  of energy hogs and had  such prices not been arti-
fically controlled.  We would now have sufficient stock of energy  efficient
houses and autos.

     The recent price increases have caused American industry to  lead the
way in  our  country  to  internally  efficient  operations.   However,  the
homeowners do  not have the  engineer  or  architect  readily available  to
advise them as  to cost effective  expenditures for  conservation  measures.
The lower the  income of  the householder the less  likely  that that  person
has technical  expertise in  conservation of energy.   Even  more  puzzling
to them is the  evaluation of  alternate energy  sources.   We just  don't have
long experience in solar retrofit or wood  stoves in city homes.   Yet, many
actions, such as installation of solar window boxes or attached greenhouses
are ideal  for  the low to  middle   income  do-it-yourselfer.   That  person
needs some technical assistance and some confidence that the work and expend-
itures involved are wise and effective.

     There is an important consideration here for  the nation, as well  as
the householder:   the  barrel  of oil thus  saved  for  next winter will  be
saved in 1983 and 84,  as  well  as  1990.  The Energy Extension Service pro-
vides the  needed technical  expertise.   It  would  be a  shame to  phase  it
out.

     I work  closely with  our  local  EES office as chair of  the  advisory
committee.  Our  total budget is $21/700, $19,200 of it federal money.  On
that we  served  3,200  people  in the past  year.   Like  many middle sized
American towns,  we have a high rate  of home ownership.   Many of  these home
owners are  do-it-your-selfers.   With  inflationary pressures,  many  more
people are becoming handimen every day.

     The outreach programs of EES workshops,  its technical printed material,
its onsight  evaluations as  invaluable these people.   This  individualized
service is not available elsewhere.

     I am also  concerned  about what  the program cutbacks and cancellations
will do  to the truly  poor.   Weatherization  and  HEAP must continue  or
frightening hardships will be  experienced by them this winter.  The locally
projected increase  of  25%  in natural gas  costs this  coming  winter added
to the  275% increase  sinced  1975 is  a cruel blow to the low  and fixed
income citizen.  They must have somewhere to turn.

     My town of Pueblo  and state of Colorado  seem to  be fairly  typical of
the rest of  the country.   In  Pueblo this year  we will receive $19,200 for
EES, $2,485,000  foi.  LIEAP,  $11,917,957 for  Weatherization.   With city and
county combined  incomes of  $34,000,000  in  locally generated  funds, there


                                     402

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is little hope that they would absorb such costs and continue their custom-
ary services, particularly  since they will  be faced with  cancellation of
other human service programs.

     The state of Colorado  has an Office of Energy Conservation designated
by the governor.  However the legislature has  never  recognized it in fund-
ing.  So, it has been dependent upon SECP and administers.  I detected no
change in the attitude  of our legislature toward this  activity this year.

     Energy conservation  is an  important national  goal.   It is a ready
source of energy to be  used in other places.   It should  not be lost sight
of in the present budget slicing efforts.
WILLIAM C. KINARD, P.E.
1576 S.W. Dellwood Court
Portland, Oregon  97225

     I certainly  subscribe  to the overall rationale  for  new directions in
our Federal Energy Conservation programs; however, we do  not want to over-
look the merit of some Department of Energy programs, particularly programs
that have  advanced  research  and development  benefits.   I  particularly
subscribe to allowing  market forces  to induce conservation in each end use
sector—not to select and promote favored sources of energy.

     Weatherization of the  homes  of the needy  benefit society  in several
ways—quite effective  as compared  with paying portions  of energy  bills
year after year.   Weatherization grants based  upon  cost-effective actions
by regions probably  should  be limited to  insulating ceilings,  caulking,
weatherstripping and floors over unconditioned spaces.

     Here in the Northwest, investor-owned utilities in general are provid-
ing interest-free  loans  and  rebates  to  encourage  conservation  as  these
programs are less expensive  and  seem to be more acceptable to the consumer
than the development of  new sources of energy  that  are  required to assure
an adequate supply.  My concern is that we may depend too much on conserva-
tion and the lead time required to receive  approval  and  complete construc-
tion of power plants.

     It appears that conservation will continue to get priority from pri-
vate and  public  organizations and  the marketplace  will  continue to  be
effective.  Initiatives and  opportunities  that are created  by the private
sector will  continue,  and  public spending should be limited  to research
and development,  particularly in the  long-term  technologies.    Care  must
be taken not to involve political and sociological problems under a scien-
tific disguise.

     Out of recommendations came the proposals under the Schools and Hospi-
tals Program to include  only  audit  and technical assistance.   This  is an
example of prudent use of funds.  Development  of  less  sophisticated soft-
ware programs  to   audit  commercial  and  small industrial  buildings  will


                                     403

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increase the  ability  of  utilities to  offer  audits that  will  encourage
operation and  maintenance  practices;  investments  and,  where  required,
additional engineering and economic evaluations.

     Research activities—such as  that accomplished  by Lawrence  Berkeley
Laboratories—should continue, but care should be given to not duplicating
research by private enterprises.   Example:  There appears to be a  need for
alternatives to degradation of the indoor air quality of residences because
of weatherization-such as an effective heat exchanger.  Solution:   Research
available products and their impact upon the health and safety, alternative
designs and provide case histories.

     The need to research  the impacts of existing regulation—such  as the
Clean Air Act—as it  also  impacts  the supply and cost  of energy.  We need
to apply research  funds to  enable enterprises to  fully utilize  coal and
nuclear resources in our country.

     It seems as though people are willing to make expenditures for conser-
vation if they  know  enough about  alternatives,  costs and savings.   The
distribution of facts in  case histories by the universities and  utilities
will encourage conservation by all classes of users.

     Local governments are  capable to responding to the needs of  the con-
stituents, whether it be for conservation or a new  fire truck or library.
A private company  initiated the zero-interest loan for conservation mea-
sure measures.   I  hope  workers  will  shift  from government  positions to
positions in research and defense.

     I believe we need  to be concerned about  funding sources for  conserva-
tion activities.  One of the  major problems of  commerce  and industry is
funding sources at  a reasonable rate.   Inflation and  high interest rates
are factors.   Reduced federal spending  should help stabilize the  rates.
Any federal funding should be in the form of block grants for energy assist-
ance to the states.

     New residential  construction  is  virtually nil.  Lower interest rates
will allow  new ideas—passive solar and  daylighting—to  be  incorporated
into the structures.  Pacific Power & Light Company  plans to  monitor pas-
sive solar  homes  in  its promotion of passive solar energy saving  homes.

     The President's  program  has  placed  great  emphasis  on  preserving
social welfare  programs that  serve  the truly needy.  This is a forward
step.

     I appreciate the opportunity to present written testimony.
                                     404

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THOMAS H. D. MAHONEY, Ph.D.
Secretary of the Massachusetts Department
 of Elder Affairs
38 Chauncy Street
Boston, Massachusetts  02111

     I very  much  appreciate  the  opportunity  to offer  testimony  on the
Federal Conservation Program on  behalf of nearly one million older persons
in the  Commonwealth of  Massachusetts.  We know well that the  waste of
energy is  of as much  concern in  other states  and  in other parts  of the
nation, and  for that reason, I am  pleased  to report  on some of the ways in
which Massachusetts has participated in conservation efforts.

     Before outlining some of  those programs,  I believe it  is important to
mention the added  significance which  conservation programs  now hold.  Our
national administration  seeks  to  reduce inflation,  increase productivity,
and enhance  our image abroad.   Preservation of our  energy resources will,
without doubt,  strengthen the  ability of  our  entire  population to  meet a
meaningful standard of  living,  to  improve our economy, and to  reduce our
reliance on  foreign  energy  sources,   improving  our   position  worldwide.

     Massachusetts is a  state  in  which  winter fuel supplies are of major
concern.  For  our  elderly  and  handicapped,   conservation  programs  will
allow us to  expand our  fuel assistance dollars.   Last winter,  many elders
had to use up to  one half of their annual incomes for heating their homes.
The price of a  gallon of heating oil,  a fuel upon which most homes depend,
rose 40 cent to $1.30 per gallon.  By May  30, 1981, 41,000 elderly families
had applied for fuel assistance under the  federal guidelines.

     As one state  which  appropriated its own funds for fuel assistance, we
received 11,000  additional applications  from  those  whose  incomes  were
above the national  guidelines, yet who could still demonstrate  a need for
assistance.  In fact, the numbers  of those who seek help increase yearly.

     If the new philosophy of  federal  budgeting  is adopted, the scope and
focus of  conservation efforts  may  change.  Block  grants,  in which the
energy conservation programs may be included,  could  be among the competing
interests unless the Congressional conference committee resolves the issue.
Last year, $189 million was provided for the Department of Energy Weather-
ization Program.   Of  that $558,000 went  into  energy  conservation  grants
with Massachusetts awarding more than  $225,000  for supplementary conserva-
tion grants.

     One of our programs  featured  an educational component with  a goal of
reducing overall energy consumption by 5%  through five mandatory programs:

                  -  car pools

                  -  thermal and lighting efficiency information

                  -  initiating the "right turn on red"
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                  -  publishing informational materials

                  -  initiating governmental coordination

     Our energy extension services included more than  $417,000  for  special
projects (and,  in  addition,  we.provided $25,000  more  with  "carry  over"
funds) the Massachusetts  Department  of  Energy  has given  our  communities
technical assistance through  self-help and  special "low-income  unit" pro-
grams.

     What is of great  concern at  this particular time  is the  added  loss  of
C.E.T.A. funds and the reduction of public  service employment programs and
the Youth Employment  Service.  Our  program of  weatherizing one  thousand
homes per month has been lost since funds were exhausted on June 30 at the
height of the summer  season,  an ideal  time for weatherization.   Block
grant funds to  renew the effort  would  not be  available until  last  fall,
but were we to attempt to implement the program immediately,  we would still
face competing interests for  a  block grant award  reduced in  effect by 25%
from the preceeding year.

     We all realize  that federal cuts mean  local  reductions, and  we have
already begun to note, with the added restrictions on  state spending which
have been implemented  in Massachusetts,  that  the private sector will, even
if it is of a mind to help,  be unable  to pick up but a small part of the
balance.  We are dealing, for the most  part, with the hard  world of "market
rates", and I do  not believe  that  the private dealers will  find  it  in
their interest to provide for low  income households at this  time.   This  is
particularly upsetting  to our  Massachusetts economy  since  we produce  a
minimum of our  own energy  needs,  diverting expenses  for  oil  and  natural
gas to providers elsewhere.

     Still, our record  of promoting conservation  in Massachusetts  is com-
mendable.  In spite  of  fiscal  restraints,  I believe  we are doing all  we
can.  With the  creation  of the Executive  Office of  Energy  Resources  in
1979, Governor  Edward  J. King  has established an Energy  Bond  Program  to
facilitate conservation  in  state buildings  and public  housing throughout
the Commonwealth.   Some  elderly  housing was designed  with  solar energy
components.  However,  this  agency,  whose  reputation and  credibility  in
Massachusetts and  New England is quite high, will see  a reduction in the
federal share  of its  total  budget from  68% to 32%  by fiscal  year 1982.

      I believe  that  Governor  King's  six point state program  to lower fuel
costs of public utilities is one worthy of mention.  It involved  the follow-
ing components:

      -  Public  investigation  of utility planning  for  conversions to coal.

      -  Mandated utility financing programs designed to offer zero-interest
        loans to  residential heating  customers  for   home  weatherization.
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     -  Restructured residential  rate structures designed  to make utility
        rates more  equitable and  more conducive to conservation  than to
        consumption.

     -  Development of an  agreement  to purchase residual fuel oil directly
        from a Venezuelan Government source.

     -  Increasing  the potential  for construction  of  new high  voltage
        transmission facilities through imports from Canada.

     -  Participation in the  signing of  a contract  with Trans-Canada, Ltd.
        to purchase  185  million  cubic  feet of  natural  gas annually to
        reduce dependency  upon  O.P.E.C.   sources  by three  million barrels
        per year  for  ten years.   This agreement, reached  on October 14,
        1981, involved nine New England  utilities and  five utilities from
        New York and New Jersey.

     I am also  happy to report on steps  in which  our  residential Energy
Consumption Program  has   exceed the  requirements  of  the  Department  of
Energy as to minimum standards:

     -  all utilities are required to participate,

     -  audit services are coordinated among utilities,

     -  by January,  1982,   services  will  be available  in  all  residential
        buildings including large apartment houses,

     -  auditors help customers learn to install some of their own weather-
        ization materials.

     We expect  the "ECS"  program to provide  its  one  hundred  thousandth
home audit this  year,  35,000 more than  predicted.   For this success,  we
must pay tribute to a well developed statewide outreach  program.

     I have established a Winter Assistance Task Force in which representa-
tives of our  23 Area Agencies  on  Aging  meet with my staff at our Boston
office.  This group, which  meets monthly throughout  the year,  recommends a
better pairing of fuel assistance and conservation  measures.   If we are
to show meaningful foresight in this area, the linking of these two compon-
ents must be strengthened  on  a  permanent basis.  At the  same time, we are
putting considerable emphasis  on the  federal income tax credits available to
those whose weatherize.  I urge that the Federal Energy Conservation ini-
tiate strong national  programs  of  public education, as we are  confident
that the effort  will  lead  to more meaningful  steps  on the part of public
and private  sectors,   businessman  and  private  homeowner,  employee  and
tenant.

     These hearings  related to  the  Federal Energy  Conservation  Program
provide an  ideal  forum  for  an airing   of  ideas,  interests,  and  common
efforts.  While I speak for the elders of Massachusetts,  I am sure that we
are all acting on behalf  of more  than 25 million older  Americans  who are

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sure to gain great advantage through a  comprehensive and  renewed conserva-
tion program.
Montana Power Company
40 East Broadway
Butte, Montana  59701

     The following testimony has  been prepared in response to  the request
from E.P.A.  to carry  out its  responsibilities under  Section  11 of  the
Federal Nonnuclear Energy Research and Development Act (Public Law 193-577).
Pursuant to that responsibility,  E.P.A. is asking  comments on the possible
directions of a new  Federal  Energy  Policy based upon the  concept  of  "free
market" economics where  rising prices  will  enhance conservation  efforts
and the private sector and the state/local government will carry out  acti-
vities that were previously supported by the Federal Government.

     In an  attempt  to address  the  changes  in   these  Federal  programs,
comments were requested on the following issues:

     1. How are private firms,  state governments and local  agencies prepar-
        ing to assume their new responsibilities?

        The role of  private  firms,  specifically the investor owned utili-
        ties, will be enhanced under the proposed new directions of federal
        energy policy.   Removal of  the inordinate regulatory  burdens  im-
        posed in the past, will allow those programs that  involve conser-
        vation of energy in the residential sector to be more  cost effect-
        ive.  D.O.E. 's  desire in  the past  to be somewhat  paternalistic in
        treatment of  customers of a utility involved in conservation pro-
        grams, produced many non  cost-effective burdens which were  ulti-
        mately paid for by the customer.

        The new direction of  Federal energy policy  will allow  the utilities
        to develop and implement  cost  effective  conservation  programs.
        These programs  will be assisted by the proper price signals  being
        sent to utility  customers via other  deregulation  programs of  the
        Federal government.   Attempts  in  the  past  using  incentive   con-
        servation programs in  conjunction  with artifically regulated  low
        energy prices,  sent mixed  signals  to customers and  did  not generate
        the amounts  or kinds  of  conservation thought  possible.  Energy
        prices that reflect the true cost of  finding additional resources,
        act as a powerful inducement for  customers to adopt   (when  given
        the proper information)   conservation methods  that   work  best.

        Private utilities have in the past  and will continue  to lead  in
        energy conservation efforts.   In the Northwest,  the Investor  Owned
        Utilities have  led the nation  in implementing  innovative,  cost-
        effective conservation  programs  that  have  been  used  as models
        for government  sponsored  conservation programs.   The  customers
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   of these private utilities  have responded  overwhelmingly  to  the
   programs and the conservation ethic that these efforts have genera-
   ted has been transferred to individual life styles.

   Programs like the R.C.S. program have been in place  in the service
   territories of most of the Northwest Private utilities long before
   it became  fashionable nationwide.   There is no  reason to think
   that such  innovative,  cost  effecive utility  programs  will  not
   continue under  the   new  direction  of  Federal   energy  policy.

2. Which activities will get priority from public and privated organi-
   zations and what will be the consequences if  seme  activities  are
   discontinued?

   The major activities that will get priority from the private sector
   (Investor Owned Utility) will be the continuation of cost-effective
   conservation programs  and the development  of  new programs  that
   will maintain the leadership of the private sector  in energy conser-
   vation.  Things  such  as the  Class A energy audit  for customers,
   informational services geared to the needs of the customers, custo-
   mer protection  in conservation purchases,  development of  energy
   resource technologies that  will serve  to continue  the transition
   from fossil fuel resources to  sources of a renewable  nature  are
   among the many programs that will receive priority.

   Discontinuance of  the research  and development of renewable  re-
   source technologies may  impair the  realization  of  energy  from
   these sources.   For example the wind program was seen as an impor-
   tant tool  to  provide  the nation  with  units  capable of  utility
   sized generation  capacity.   Without  the  funds  available for  re-
   search and  development  on  these  types  of  technologies and  some
   sharing of the risk by the governmental  sector, further delays may
   be caused.   For  this  reason,  adverse impacts from reduced  govern-
   ment expenditures may be felt in the private sector.

3. Have any new initiatives, opportunities or efficiencies been crea-
   ted as a result of the shift in Federal energy conservation programs?

   Possible revisions to NECPA  will potentially allow  the utility to
   become more involved in the marketing of conservation and renewable
   resource measures.  This would provide an opportunity for the utili-
   ty to offer the  customer a  "one-stop" conservation and renewable
   resource service.  The time  to get a customer  to  act  on conserva-
   tion recommendations at the time is high and  experience has indica-
   ted that  following departure  of  the auditor,  interest  usually
   wanes and many customers  do not proceed with the  recommended mea-
   sures.

4. How can the Federal Government assist in this period of transition?
   The best help that the Federal Government can give in this period of
   transition is of a technical and research nature. More work needs to
   be performed on the effects on "indoor-air-quality" following imple-

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        mentation of  various conservation  measures.   Additional  research
        is also needed on the possible conservation benefits for the indus-
        trial and  commercial sectors.   Rising energy prices  will  continue
        to spur such transitions but it would be helpful to be able to plot
        cost-effective conservation scenarios for these respective entities.

        Preparation of  literature- has  also been  a useful  tool  that  the
        Federal Government has provided  in  the past.   These materials have
        been well written and concise.   Continuation of this function would
        be justified.

     5. How should the Federal government  evaluate and monitor the effects
        of its new energy policies and program changes?

        Possibly the  best  way to monitor the effects of  any conservation
        program is to evaluate the consumption of the product in an unregu-
        lated market condition.   As  we  have  found out in the gasoline situa-
        tion, price  elasticity  is  indeed  greater than  what was  thought.
        Rising prices serve to-drive the economic equation in the direction
        of substitution or conservation.  Given  the proper information  and
        data from  the private sector  and  government,  the individual will
        choose the proper  mix of  strategies to insure the  protection  of
        lifestyle as much as is possible.

     6. What will be the effects if  a state decides to phase out its energy
        office?

        The state  energy office, while at  times helpful to  the private
        sector, has attempted to develop activities  far removed from what
        is generally  perceived  as  its mission.    In  several cases,  there
        were attempts to develop load  forecasting abilities, etc.,  which
        were going to be used to  justify manipulation  of  consumption  of
        those forms of energy that  were perceived as of the "hard" nature
        while espousing the  "soft"  technologies.  These attempts  were  not
        based upon any  recognized  cost-effective measurement  but  rather
        upon an idea  of  social direction for  society in  general.   Rather
        than provide assistance to the  private sector, adversarial relation-
        ships existed.  This was  not conducive to the octnmon goal of provid-
        ing the citizens  of the nation with the tools necessary to formulate
        their own decisions  about the  type  and quantity of  any particular
        fuel to use.   Advocacy of particular favored types of energy sources
        by these bodies only  added to the bewilderment of the general public
        on the serious issue of  providing  adequate supplies  of  energy  for
        our nation.

In summary then,  we  fully support  the goals of the new  energy direction
of the  Federal  government and  will  continue our efforts  to  assist  our
customers in the conservation of  energy.   This best can be  done,  however,
through the mechanism of the free market where the government's role is to
establish rational public policies  which take into consideration  national
security ineterests and  environmental  values but  leaves the citizens  and
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private sector  with sufficient  incentive to  produce and  conserve energy
in a cost-effective manner which  is  consistent with the national interest.

                             Section 11
                     Federal Nonnuclear Energy
                    Research and Development Act
          Weatherization and Low Income Energy Assistance

The following statement responds  to  questions  asked in the issue paper for
use in preparing testimony.

1.   Funding mechanisms and structural issues

     a.  In light of the  proposed changes, how can the  nation maintain an
         effective low income weatherization program?

     o   A key strategy for maintaining an effective low income weatheriza-
         tion program includes the  structuring of a  diverse funding based
         combining federal, state and possibly local government monies with
         private funds  stimulated with tax  incentives —  perhaps  special
         tax incentives for energy-oriented companies.

     o   The proposed change of typing weatherization in with the Community
         Development Block  Grant funding  could  have serious  detrimental
         effects.  The effects would be felt because the Community Develop-
         ment Grant Program has been an ongoing program  with existing pro-
         jects and programs.   This  fund,  by   itself,  is  being cut  25%.
         People will want  to  save the ongoing programs  and possibly build
         them with the added  weatherization monies — not  sacrifice their
         program for weatherization.  Different people have been involved.

     o   In Montana,  no state monies have been allocated for weatherization
         programs as they have  in other states.   Time is  needed to allow
         the political  process to   survive  cutbacks  at  all  levels  than
         accept new areas to allocate state monies.

     o   There is an understanding of the importance of weatherization as a
         long-term solution among various sectors of  the population.   A
         Citizens Task  Force  comprised of former  state government  offi-
         cials,  fixed and  low income representatives,  a Community Action
         Agency representative and the president  of the  Montana Power Com-
         pany researched the issue of the  energy  problems of fixed  and low
         income people.   They submitted a report emphasizing weatherization
         as a top priority.

     o   But,  to  bring in the  sectors to  form a diverse base, an  initial
         solid funding base is needed to secure support.

     b.  If weatherization is  transferred  into the HUD  Community Develop-
         ment Block  Grant, what  agencies  vould  be  effective sponsors
         at the community level?
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     o   In Montana,  the  number of  agencies  capable of administering the
         effective program  is few.  The Human Resource Development Councils
         (HRDC's)  or  the Community Action Agencies  for  Montana have been
         operating some type of weatherization program since  1975.  Longe-
         vity in development and  administration of social programs such as
         weatherization is  a strong element for effectiveness.  The HRDC's
         are  private  nonprofit  corporations that would be the  best agencies
         for  establishing a contract arrangement for  administering the pro-
         gram in Montana.   Other agencies, such as  local county governments
         are  not experienced in this effort in Montana.   They are experi-
         enced in  eligibility certification such as  AFDC,  but they do not
         administer service programs.  They mostly purchase services through
         private nonprof its.  Many wasted dollars would be spent in unneces-
         sary start-up time.  Private contractors specializing in the insu-
         lation business have special  interests in mind and would not pro-
         mise the  type of coordination and objectivity needed  to administer
         the  program.   Being a private nonprofit corporation, the HRDC's can
         hire various types of labor based on  funding levels and require-
         ments.  They could design a cost-effective labor mix of volunteers,
         union or  CETA's based  on what is available.  Community Development
         Block Grant  procedures allow  for contracting with community agen-
         cies to do the weatherization work. Administrative costs are mini-
         mized.

     o   Without Community  Action  Agencies in  Montana,  the  program might
         die  or fade  away.

     c.   How   can  problems  involved in transferring  the program  from one
         agency to another  be minimized?

     o   If the programs  have  to be  transferred  (which is not advisable),
         impacts are  minimized  by:

         Hiring some  of the higher qualified employees of  the previous agen-
         cies who  have experience with the program.

         Allowing  an  adequate time for transition  from  one program to the
         other.  Allow time for employees  to spend  time together.  Most pro-
         blems occur  when  a desk is emptied  one day and  filled the next.
         Time is needed to  educate the public.  Clients are frequently lost
         in changeovers.

2.    Implementation Issues

     a.   If a state decides to  phase out Community  Action Agencies, how can
         their resources and experience be transferred to the  new weatheri-
         zition sponsor?

     o   Again,  some  of the best  employees could be hired by the new agency.
         They are  the ones  with the experience.
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    At least,  the Community  Action Agency  employees  should provide
    training or be contracted as a transitional team.

o   The CETA trained labor could be  hired by  the new  weatherization
    sponsor.  The purpose of  the  CETA training is to provide the base
    for advancement into other jobs.

b.  Should LIEAP  funds be utilized  for weatherization?  How can the
    LIEAP program  coordinate  its activities  with the  weatherization
    program at the state and/or local level?

o   LIEAP funds should be  allowed for  weatherization.   States should
    be able to authorize up to 30% of  LIEAP funds for weatherization.
    Again/ a large  starting  base is  needed.   Weatherization  is the
    long-term solution.  Larger amounts are needed  for  its implement-
    ation — not smaller.

c.  What is the most  equitable and  cost-effective weatherization pro-
    gram? Should the Federal government continue to provide substantial
    assistance ($1,000-$2,000 per unit) to a relative small  number of
    houses?  Or, should the program be restructured to provide minimal
    weatherization ($200-$300) to a larger number of units?

o   To equitably service low income people, programs need to be desig-
    ned for both low income homeowners  and renters. In Montana, approx-
    imately 50% of the low income families are renters.

o   To design the most  cost-effective  weatherization  program,  more
    money per unit is  necessary,  not less.  Current limits  have only
    allowed a band-aid approach  toward efficient retrofitting.   Cur-
    rent rules have allowed  $500 for materials  and  $500 for  labor.
    Since many  low  income  people live  in  older housing,   $500  has
    covered a superficial amount  of storm windows, caulking and per-
    haps insulation when the  roof leaks and the  furnace  is  operating
    at 30% efficiency.  The Citizens Task  Force on Energy problems of
    Fixed and Low Income Consumers,  an independent group brought to-
    gether by Montana  Power  Company,  states  in  their  final  report:

         "Conservation offers   the most  readily  available  long-term
         solution to  the energy  problems  of fixed  and low  income
         people.  At the present  time, energy assistance funding  to
         provide weatherization for  fixed and low  income housing  is
         limited to $1,000 per unit,  with only  $500 of that  amount
         allowed for weatherization  materials.

         In order to  expand  weatherization to  address  sufficiently
         the problem of  housing  inadequate  to  conserve energy,  the
         Citizens Task Force recommends that the  Legislature  appropri-
         ate Coal Tax  or other funds  available to  supplement  weatheri-
         zation and energy  conservation programs for  fixed and  low
         income dwellings, to  be invested  in retroffitting residences
         with adequate and/or  other  energy conserving  improvements..."

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         More funds   to  support  weatherization   are  needed,  not less.

   d.    How can CETA workers be retained in the weatherization  industry?

   o     Tax  incentives  tied with a  strong information campaign   selling
         the skills of  the  CETA workers may be the  key way of  integrating
         trained CETA  workers  in  the  private sector.   The  potential is
         not bright  given  the  large  amount  of unemployed  union labor
         currently available  in  the  economy.   Union labor, however, raises
         the costs of the program to unnecessary heights.

   o     The most effective way may be to  form  other  private  nonprofit
         organizations built  with  trained CETA  labor and  available to do
         contract work  with  the  local  agency administering  the program.
CHRIS PALMER
Director of Energy and Environment
National Audubon Society
645 Pennsylvania Avenue, SE
Washington, D.C.  20003

     I very much regret that I am unable to testify at your Section  11 hear-
ings because of previous commitments but  I  would be very  grateful if you
could enter  into the record the  Audubon Energy Plan,  a copy  of which  is
attached.   This study reflects our views on what the nation's energy policy
should look like.   As you  can  see we  support a major  emphasis on energy
efficiency.

    (Following is an extract of the Audubon Energy Plan, which was  reviewed
    in its entirety but is not included in the Transcript  due to its  length).

     Energy is  a major factor  in determining the quality of our  lives.   It
furthers the production  of  goods and services, and  its  production and use
seriously impact on the quality of our environment.

     The Audubon Energy  Plan is a practical plan  for our country to obtain
adequate energy while protecting the environment.  It is based  on the convic-
tion that by using energy more efficiently our economy can continue to grow
and prosper, providing an increased level  of  goods  and services  for all  at
least until the  year 2000  without consuming  any more  energy  than  is being
used today.  The Audubon Plan  envisions  a steady  increase in  the use  of
solar energy (25 percent by  the year 2000) which will cause a steady  decrease
in environmental pressures  from traditional energy  sources.   The Plan is  a
low-cost energy strategy and provides the most rapid route to national energy
security.

Audubon's Role in the Energy Debate

     Audubon's concern  is with  life  — plant, animal, and human  — and the
air, water, and  land so essential to life.   This broad interest which has

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evolved over  the  past eighty  years  began with  the  successful fight  by a
group of highly motivated activists to  stop  the  slaughter of plumed birds.
Continued activity in the conservation of wildlife resulted in an awareness
of the  inter-connnetedness  of life —  ecology — and  led Audubon men and
women to become environmentalists dedicated  to protecting the life-support
systems of our planet.

     The production and use  of  energy have a major impact on our environment.
Pollution of the air stems primarily from the burning of fossil fuels in our
factories and powerplants, automobiles,  and homes. It is the major cause of
the acid rain which falls throughout much of  the world,  destroying fish life
and plant life and corroding buildings.  Oil spills contaminate beaches ev-
erywhere.  Hydroelectric projects flood valuable wildlife habitat.  The ac-
cumulation of radioactive waste threatens life  for  millenia.   (Because  of
Audubon's special concern with  wildlife  and the habitat  on which it depends,
a detailed catalog of the impact of energy facilities on wildlife and wild-
life habitat has been prepared and will soon be released.)

     On the other hand, the production and use of energy are essential to a
modern style of life.   Audubon is convinced  that we can have enough energy
to continue  the  growth of  production of goods  and  services while  at the
same time protecting the environment.

     One reason will  be a marked increase in the efficiency with which we
use energy;   in  other words,  an increase in  the productivity of energy.
Because the  Audubon Plan requires much  less coal,  oil,  and  nuclear power
than are envisioned  in the  plans of the energy  industries and the federal
government, it will dramatically curtail environmental environmental damage
from strip-mining, air pollution, acid  rain, and the production of nuclear
wastes.  Sulfur oxide air pollution and  rain  acidity will  actually drop well
below current levels.  The Audubon Plan will also ensure that environmental
safety is built into the new energy-conservation and renewable energy tech-
nologies at early  stages rather than added  to them  half-heartedly decades
later.

Audubon's Expertise in Energy Matters

     Traditionally, Audubon's expertise has been concentrated in the biolo-
gical and ecological  sciences.   Awareness  of the serious ecological impact
of energy activities  has led  the Society to  expand its  staff to include
scientists with backgrounds in  chemistry,  physics,  and  the  agricultural
sciences.

     A new environmental policy research department has  been formed to carry
out policy studies in a number of areas of interest to the  Society,  including
energy.

     Preparing an Energy Plan as detailed and specific as this one requires
that difficult choices be made — about nuclear power,  the use of coal, and
the use of land for bioenergy, and so on.  These choices have been made by
Audubon staff members, using inputs from many ccrnprehensive studies prepared
by a variety of prestigious  private and governmental institutions throughout


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the world.  Additionally,  a draft of  the report  was examined  by  outside
reviewers.  In this regard, we are particularly indebted to Alvin Aim (Har-
vard University), Paul Bente  (Bioenergy Council), Lester  R.  Brown  (World-
watch Institute),  William U.  Chandler  (Environmental Policy  Institute),
Frank von Hippel  (Princeton University),  Roger Sant  (Carnegie-Mellon Uni-
versity), Gordon Thompson (Union of Concerned  Scientists),  Robert Williams
(Princeton University), and Daniel Yergin  (Harvard  University).  Most  of
the criticisms and suggestions made by these reviewers have been incorpora-
ted in the Plan.   The major quantitative changes that have been made include:
1) an increase in the projection for natural gas  availability  in the year
2000 (from  11.5  quads per year  to 15 quads per  year);   2)  a  decrease in
the projection for industrial  use of solar collectors  (from 3 quads per year
to 1.7 quads per  year); and 3)  an incerease in the capital  investments in
energy efficiency from $500 billion to $700 billion).

     The Audubon  Plan  is  not  to be  considered a  fixed  strategy.  Details
will be  revised  periodically  to take into  account new developments  — in
both technology and governmental policy — that arise.
PATRICIA B. PELKOFER
Vice-President
Group Against Smog and Pollution
P. 0. Box 5165
Pittsburgh, Pennsylvania  15206

    Members of GASP's Energy Committee have reviewed the 17 page issue paper
concerning the 1981 Section  11 public hearings under the Federal Non-nuclear
Energy Research and Development Act.

    We have decided that we do not have access to the necessary records and
information to adequately comment  on the issues and questions presented in
this document.  We sincerely hope that directors of local and state programs
for energy conservation, and those citizen's organizations that have better
access to these efforts, have submitted factual and documented testimony to
assist in your evaluation.

     Our comments, for instance, on how  efficient or successful the weather-
ization program has been on the local or state levels, or on what might hap-
pen to this important effort when federal funding is eliminated, would be no
more than opinion and guessing on our part without a great deal of informa-
tion we do not have.

     However, we "guess": that many energy conservation efforts on the state
and local levels will be discontinued without federal funding and guidance,
as priorities for local and state tax dollars are set.

     We have special  concern  for the poorest and the elderly among us who
can neither afford to make their homes more energy efficient, nor the funds
to pay  the higher cost  of  fuel wated  in inefficient or  non-weatherized
dwellings.  Many of these persons  may live  in  rented homes where theirs is

                                     416

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not the decision or option to weatherize ... and should the landlord decide
to make such  improvements,  the rental fee, as well,  may become burdensome
to the poorer tenant.

     As an incentive for energy conservation, GASP's policy supports decon-
trol of oil  and natural gas  pricing, so that energy used reflects actual
replacement cost.  However, we  believe this measure must be accompanied by
provision for those  with low  income  through  a minimum  energy "life line"
basic rate or some  such program as "energy  stamps".   The practice of pay-
ing heating bills for  the disadvantaged,  which may be dollars for precious
energy resources escaping through  walls and windows rather than providing
heat for the elderly or poor  person,  is not acceptable nor in the interest
of energy conservation.

     Finally, we call  your attention to a  recent study  conducted  by the
State of Pennsylvania, Office of Planning and Development,  entitled "Choices
for Pennsylvanians".  Nearly three dozen public meetings were held through-
out the state in an effort to identify the economic, social, health, etc. ,
priorities of Commonwealth elected officials and citizens.  Several threads
became a pattern emerging at these sessions: -

     1)   Pennsylvania  citizens desire a balanced  growth approach to econo-
          mic development, with about  as much concern for  their communities
          and for the  environment  as  for business expansion.   Little will-
          ingness exists to lower  pollution standards as  a way to keep or
          attract industry, and  economic growth without regard to its im-
          pact on communities and resources was strongly opposed.

     2)   Other  options  ranking in  the  top ten  concerns were conserving
          energy in  industry, conserving energy in homes and development of
          alternative energy  sources.   Conservation  of  energy in industry
          and homes  were listed as more  important  by most  citizens than ef-
          forts to develop new energy sources.

Enclosed for the record is an article  from the Sunday Patriot-News, Harris-
burg, PA. , July 19,  1981 by Bruce Cutler summarizes  the  study.  We hope you
can obtain a copy of the report in  its entirety for your  evaluation and con-
sideration.

     The right kind  of  approach, with a careful plan and good public educa-
tion on the part of our state  and local elected officials  (and the employees
who carry  it  out)  could translate the type of public thinking expressed  in
this report into positive and funded programs for energy conservation on the
state and local levels  as federal dollars continue to evaporate.

     Thank you for the  opportunity to comment.
                                    417

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GERALD ROCCAPRIORE, President
Solar Power Institute
P. 0. Box 450
46 Meriden Avenue
Meriden, Connecticut  06450

     The United States is putting, its domestic economy and future existence
on the line to  bring oil into this country.  The Reagan  Administration is
spending $160 billion on defense to protect the flow of  crude oil from the
Middle East.  The Middle East brings in 21 million barrels of oil a day and
uses only 2 million barrels of oil daily.   Eight million of this foreign oil
is shipped into the United  States daily.   The United States  and  other non-
Communist countries produce 31 million barrels of oil  daily  and  consume 51
million barrels of oil  a  day.   The United States  instead  should  put  its
energy house in order and  stop being  at  the mercy of non-renewable sources
of energy, such as the Mid-Eastern oil cartel.

     The effect of such  dependence not only hurts the international stabili-
ty of the world,  but also jeopardizes the American economy  which sends so
many dollars  outside the  country  to pay for  its addiction to  foreign
non-renewable energy supplies.

     The Reagan Administration need only look upward — at  the sun — to find
the answer to its economic and defense woes.  The sun, which  is man's oldest
companion, can be its best  teacher now in leading the way out of this econo-
mic and political shambles.

     The sun provides the  source of energy that can,  for free,  bring more
energy than all the tea in China — or all the oil in the Mid-East, all the
coal in Pennsylvania, and all the uranium in Africa.

     Instead of making  enemies  with the Mid-East and  the world  over non-
renewable energy  supplies,  let us  make friends with nature  and  its gifts.
Let's harness the power of the natural  rays of  the sun  to  heat homes and
bring international peace to this troubled world.

     The Solar Power Institute of Meriden,  Connecticut is dedicated to real-
izing the dream  of natural energy that  can  be found by  looking  up in the
morning —  instead of spending  billions of dollars digging downwards  for
crude oil or  coal.   Let's  channel man's energies that have  brought us the
elimination of many of mankind's ills and  the creation of so many wonders,
and use  it  to radiate warmth  to a troubled  world by using the  sun.

     While we're  looking up, let's  look at the atmosphere which  is so ad-
versely affected  by  man's  use of non-renewable  forms of energy that have
made some men rich but our American people so poor from inflation.  Govern-
ment surveys project a drastic increase  in carbon dioxide, nitrogen oxides
and ash and sludge because of coal burning  and oil use.  Also, we still face
incredible dangers from problems with radiation if  we look to more nuclear
plants as our answer.
                                     418

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                Figure  1  Annual per capita energy consumption and gross national product, 1970 and 1978,
                as  compared with the potential for 2000 A.D.  energy and GNP for the U.S.  from the Sawhill

                study.  Source:  Tables 1583 and 1594,  U.S.  Bureau of the Census, Statistical Abstract  of

                the United States; 1980 (101st edition),  Washington, D.C., 1980.

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     Now, the  United  States  Department  of  Environmental  Protection  is
considering ways and means  to monitor and evaluate  the  effects of changes
in energy policy.

     That agency must  consider a  special study on  the  quality  of air in
this country.

     This Institute is recommending  a strong commission to monitor the air
quality and  solar  radiation  that  is  being  defused and  deflected because
of the effects of  oil,  coal, and nuclear powers.   The air that gives us
and sustains  life  shouldn't  be jeopardized by  being  suffocated by our
dependence on non-renewable sources of energy.

     Already, Canada is  complaining  about the acid rain that  falls over
our borders  into its land,  affecting its  food growth.  Must we wait  until
more of this happens and hurts our food growth.

     Gentlemen, the  Institute heartily  urges such  a commission to  study
our air quality.  And  we strongly urge that this be a blue ribbon commis-
sion with no taint of  interest in  this same  oil and coal industry that has
already almost brought us to  our knees internationally over its  greediness
for foreign  oil  and insatiable  appetite  for  big  bucks at the expense of
domestic tranquility and international peace.

     This commission  should  be a  group  of  concern and  honorable persons
that can honestly and truly tell us of our future air  supply.
ARTHUR H. ROSENFELD
Energy Efficient Buildings Program
Lawrence Berkeley Laboratory
Berkeley, California  94720

JEFFREY P. HARRIS
Buildings Energy Data Analysis
 and Demonstrations Group
Energy Efficient Buildings Program
Lawrence Berkeley Laboratory
Berkeley, California  94720

     Although we were  unable to attend EPA's  Section  11  hearings  in person
this year,  we appreciate  the opportunity  to submit  written comments  re-
flecting our  own personal views  on several  of  the issues  raised  in  your
pre-hearing announcement.   These include:    (1)   the  degree  to which  the
private market can  be  expected to move toward greater energy efficiency in
response to rising  energy prices; (2)  additional steps needed at  the Fede-
ral level  to  speed  the market's response and  help assure  its  full  (and
equitable) coverage; and (3) an  important role  for the Federal government
in monitoring the  effects of both  market behavior and  public policies  on
the rate of progress toward more  efficient energy use.


                                     420

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                             * Based on LBL analysis of NAHB data on 300,000 houses constructed 1976 1979

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     Along with this letter, we are submitting for the record two documents
for inclusion with  the  Section 11 hearing records.   They were prepared as
testimony for recent hearings  by the House  Subcommittee on Energy Conser-
vation and  Power  (5/20/81) and  the House Interior  Appropriations Subcom-
mittee (4/8/81) (These documents were reviewed  but are not included in the
Transcript due to  their length).   The  two  papers  summarize the potential
for improved energy efficiency in buildings, and offer examples of barriers
and time  lags  in the market's response to  higher prices.   These examples
draw upon several years of research on energy  efficient buildings,  at LBL
and elsewhere, and illustrate the need for a continued but selective Federal
role that complements and strengthens market forces.  A few additional com-
ments will  introduce the enclosed documents, and their relationship to the
issues raised in this year's Section 11 hearings.

     Market response to higher energy prices.    Historically low  energy
prices have left the U.S.  market with a stock  of  buildings and appliances
which are far  less  efficient  than  is  optimal at  current energy prices —
let alone at the higher energy  prices which  can  be  expected  in  coming
years.   Other  advanced  industrial  countries,  with  historically  higher
energy costs and  heavy dependence  on  imported oil,  have already adjusted
their economics,  in part,  to new  energy realities, achieving  levels of
energy use  per  capita  (or per dollar  of GNP)  that  are  considerably lower
than those  in the U.S.   (See Figure 1. )

     Evidence that  we have  seen suggests  that the  current  directions of
Federal energy policy will cause the market's lag in  achieving economically
optimal levels of efficiency to increase, at least in the near term, rather
than decrease.    In  simple terms,  this  is  because energy  economics are
continuing  to change  faster than the  normal rate of  turnover in the build-
ing stock  — even  if  one  assumes very optimistic  rates of  adoption of
energy-saving techniques  in new  buildings.   The major  hope  for  reversing
this trend  in market  lag is to make even  more rapid progress in  improving
the energy  efficiency of the existing stock, through  physical modifications
("retrofits") and  more  care~fuloperating  practices.   Efficiency  gains
in new  buildings  can also  be accelerated,  through  government and utility
actions to  improve  the  flow of  technical information  to  industry and
consumers.

     For new residential construction, one approach  to measuring the market
lag is  underway at  LBL;  some preliminary results are  shown in  Figures  2
and 3.  These  two figures, one for gas-heated  and the other for  electric-
heated residences,  compare  space conditioning energy use in homes actually
built in  1973,  1976, and  1979 with the amount of  energy that would  have
been used  if the  same  new homes  hctd  been designed more  efficiently to
minimize  life-cycle energy costs.

     The difference  between the actual homes  and  the economically optimum
design  is on the order of 30-40%  in annual  energy savings.  Consumption
of actual  new homes was calculated using the  DOE-2 computer model,  based
on a survey by the  National Association of Home Builders of new home  char-
                                     422

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acteristics in  each  of those  years.   The  characteristics  and estimated
energy use of the "life-cycle-minimum" house  for each year  were based on
LBL research,  again  using  the DOE-2  model to  calculate  expected energy
use.

     The data  show that the market,  on average,  is improving,  but so is
the economic  optimum.   Even  under the  improbable  assumption  that  real
energy costs  remain  at their current levels, and that no new energy-saving
technologies are  introduced,  we now estimate the market lag  in new homes
at roughly 6 to 25 years.  (The range depends on  housing type and  location. )

     These market  lag estimates apply  only  to new  homes;   comparable ef-
forts are  needed to  identify  and  assess  trends in  retrofitting existing
homes for  energy efficiency.   This analysis  should  include the rates of
retrofitting for various measures  and  for different parts  of the country,
the actual energy savings  and costs  involved,  and  analysis of how much
these decisions  have  probably  been  influenced by  rising  energy prices vs.
information or incentive programs.

     Initial data  compiled  by  LBL  suggest that some home retrofit programs
are achieving measured  energy  savings of  20-25%,  at costs  of under $2000
per household  (or  roughly  $19/barrel-of-oil equivalent  saved).   However,
this is based  on a limited  sample, and results show quite  a range around
the average:   a  few very successful retrofits have saved  40-50% or more,
while energy use in other homes was reduced  by only about 10-15% (although
in some of the  latter cases the retrofit  investments were  also  very low).
These data are  presented and  discussed in  the  recent SERI/LBL  report on
"Building A Sustainable Energy Future", printed by  the  House Committee on
Energy and  Commerce  (Committee Print  97-K,  April,  1981;  Table  2.1 and
Figure 2.12).

     These preliminary  results demonstrate  the  importance  of   continuing
serious efforts  to track and  analyze  both  the  successes and  failures of
conservation programs and market forces.

     Federal actions to reinforce the market.  As the enclosed  papers sug-
gest, some of the most important  federal roles in  complementing market-
induced energy conservation are:

     o   Continued support  for basic  research in building energy science,
         including researchonindoorairquality,health effects,and
         other indirect  consequences  of  some  energy-saving  strategies.
         Private firms may  benefit from much  of this basic  research,  but
         are unlikely to support  it at a significant level,  since many of
         the results can be considered "public goods" (i.e., they represent
         information that,   once developed,  is relatively easy  for others
         to obtain).    Since no one organization can  capture  the  entire
         benefit of  such research,  none is likely to pay  for  the work.

     o   Information, feedback, and quality control.   A critically import-
                                    424

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         accurate, timely,  understandable  information to  both  producers
         and consumers.   The Federal  government can  assist  in  providing
         reliable analytical  tools  for measuring  and  communicating  the
         energy performance  of  individual  products  or  technologies  and
         of whole  buildings.   One  approach to  "labelling" buildings  for
         their energy  performance  is  outlined  in the  enclosed  papers.
         These analytical tools and  energy  labels must be in turn be based
         on an ongoing research program, one that includes  a full range of
         performance modelling, laboratory measurements,  and field monitor-
         ing of real buildings.

     o   Participation  in high-risk/high-leverage  demonstrations.  In any
         industry, there are  only a  few genuine innovators,  but a larger
         number of firms  willing to follow another company's  lead,  especial-
         ly where  the  innovative  project is made visible  and accessible.
         Government participation  in innovative  technology demonstrations
         is all the more important  in  many sub-sectors related  to build-
         ings, where markets  may  be  characterized  by  a limited  number of
         well-established suppliers  or  purchasers,  where (conversely)  the
         firms are small  and  poorly capitalized, or where  there  are other
         sources of institutional inertia  or constraints.   The case study
         of the introduction  of high-frequency  electronic fluorescent bal-
         lasts (4/8/81 testimony)  offers an instructive example.

     o   Market failures   from misplaced incentives.   This  final   category
         calling for a  government  role  involves instances  where  normal
         market incentives do  not operate, or  operate only within narrow
         limits.  One clear  example is the lack of incentives for either
         building owners  or tenants in rental housing (or leased commercial
         space) to invest in  energy efficiency.   Another  example of  an
         obvious source of  market failure  is  that wherever energy prices
         to consumers  are  significantly  lower  than   actual   replacement
         costs for energy  supply  (as  is  almost  universally the  case),
         private decisions  on energy use  will  be  based on inappropriate
         market signals.

         The solutions in cases such as these are not yet clear.   Nor is it
         obvious that the Federal government represents the most  appropri-
         ate — or the only appropriate — level for public  sector involve-
         ment.  But in the case of  both rented/leased  buildings and energy
         pricing policies, the Federal government  can still provide  an impor-
         tant source of general financial  and  technical  support to innova-
         tive new approaches developed  by  others, at the local government
         level, in community and  non-profit organizations,  and by industry
         itself.

     Monitoring progress  in conservation.   We  have  already suggested  the
need for a much more attentive monitoring  of trends in energy  conservation
and efficiency in buildings  (and  in other  sectors).  Looking  at  aggregate
trends in energy  use is  important,  but not sufficient.   Also of interest
are:
                                     425

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     o   the range of conservation  results achieved (including  variations
         in energy saved and in the costs of conservation);

     o   identifying reasons for this range (what factors seem to separate
         successes from failures?); and

     o   trying to  untangle the  impact of  market forces  (energy prices)
         from that  of  specific  conservation  programs,  regulations,  and
         policies.

     Gaining this more  detailed level  of insight  into  what  is  happening
with energy  conservation,  and  why,  will  not be  a  simple or  short-term
process.  Nor is is one that the Federal government should expect to pursue
alone.  But  once again, DOE  and other  Federal  agencies can help  to  set
directions and serve as  an  example to other levels of government,  utilities,
and private industry by pursuing two types of activities:

     o   Establish a  framework for  technical  guidance and  support  for
         the conservation  data   collection  and  analysis done  by  others.
         This would  include periodic  nationwide  or regional  statistical
         surveys of  the  energy-using   stock  (as   the  Energy  Information
         Agency has begun  doing),  compilation and  comparative analysis  of
         energy conservation  data  from  a  variety of  sources,  and  the
         dissemination of  guidelines to help  standardize and improve  the
         technical quality  of  these diverse  data-collection  activities.

     o   Maintaining,  for  the  Federal  government's  own   conservation
         programs and tax  incentives,  the  highest  professional  standards
         in monitoring and  evaluating  results, and use of  the findings to
         improve or terminate programs.

     In conclusion,  we   would  emphasize  that  the  Federal roles  we  are
recommending do represent  a change in past emphases  (although much of  the
time Federal energy  conservation policies in the past have  been character-
ized more  by confusion  than  by adherence  to any  clear set  of goals  or
strategies).  The  direction of  this change  is  clearly  toward a  greater
reliance — but not a blind dependence — on the market.

     The challenge  for  Federal policy-makers  and  managers will  be three-
fold.  First, to  gain accurate  insights  into where market  forces  are  and
are not leading toward  economically  preferred  outcomes.   Second, to under-
stand why  this  happens, and  to devise and diligently pursue intervention
strategies that  are no  more  (and  no  less)  intrusive  than needed.   The
final challenge  is  to be  as ready  to  address inequities  in  the market's
solutions as to deal with its inefficiencies.

     Thank you for the opportunity to present these views.
                                    426

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MR. RICHARD O. SILVA
Energy Detectives, Inc.
Executive Offices
549 Gulfview Drive
Gulfstream, Florida  33444

     In January  of  1980,  Dr. Gautam  Dutt of the  Center for Environmental
Studies of  Princeton  University  reported to  Congress  that 1.6  million
barrels of oil per day could be saved if every residential property in the
United States was audited for energy efficiency and retrofitted.

     Intrigued by this  and  other information,  I set out in August of 1980
on a four month  tour of the country,  from Philadelphia to Los Angeles and
then to Florida.  I visited countless cities and towns, evaluated over one
hundred private  homes,  met  with numerous  electric  company  officials and
principals of energy saving enterprises.  The results of this trip revealed
to me that very  little  was  being done to implement residential energy sav-
ings throughout the country.  It also became apparent that water conserva-
tion was just as important as energy conservation.

     In November, 1980,  I  formed  a company  in Philadelphia, Pennsylvania
under the name of Energy Detectives,  Inc., employing eight persons,  two of
which were trained by Princeton University in  proper  residential auditing
procedures.  During the first three months of operation, Energy Detectives
preformed only audits,  however,  many homeowners  desired that  it perform
the retrofit  work as  well.  Numerous  homes were also re-audited  at the
homeowner's request after other  firms had performed the retrofit work.  We
found much of the work of the retrofitters to be shoddy and not to specifi-
cations.  Today,  Energy Detectives is a full service,  energy conservation
enterprise.

     Energy Detectives  has  performed 1037  audits of  which 86%  have been
retrofitted by us.   94%  of the audits  performed were  to homes  owned by
upper income, professional  persons,  even though  advertising expenditures,
which exceeded $30,000.00, were directed to a middle-class audience.   Based
on these  results,  it  is  apparent that middle-class  homeowners are  not
taking advantage of the service offered.

     A recent survey  of fifty homes previously audited and retrofitted by
Energy Detectives revealed  an average of 27% energy savings  and a feeling
by the  respondents  that  they  were conserving  water  due to hotter water
reaching the  faucet  faster,  low  flow  shower heads and baffles in water
closets.  A  number  of middle-class  homeowners were  also  surveyed.   The
reason for not having an audit performed were:

     1.  They did not believe  that they  could save energy  without being
         uncanfortable.

     2.  They were not aware of the  need to conserve  water except  during
         drought conditions.
                                     427

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     3.  They believed a  tax  deduction of $300.00  for  energy conservation
         was not enough.   (Most were not even aware of such a tax deduction
         and when made aware,  did not think it was sufficient in any event.)

     4.  They believed solar  energy is not perfected and will  not be cost
         competitive in the foreseeable future.

     The Residential Conservation Service Program has been in effect for two
years.  Some utilities have offered this  service for three years.  While I
am not aware of all of the details,  Princeton University, Philadelphia Elec-
tric Company and Philadelphia Gas Works have admitted that Energy Detectives
has performed  more  audits than any  privately  owned  firm  or  utility.

   I have been told that  certain utilities have performed  thousands of so-
called audits which are,  in fact,  not audits  at all.   What they have done
is to have a meter reader measure and  record the outside dimensions of the
building, the number of windows  and  the number  of stories.  This information
is then set into a computer and the consumer is advised of the R factor of
insulation needed to make his or her home energy efficient.  This system is
not only misleading but it cannot be considered to be an audit when compared
to the Princeton system.

     Further, the homeowners  following of mere insulation recommendations
neither makes his  or her home  energy efficient nor advances the  cause of
energy conservation with  this cursory  audit method.  It is also my opinion
based on  numerous  discussions  with homeowners and  the public  in general
that there  exists a  total lack of  confidence  in the gas and electric
utilities.  To the contrary, the American public believes that these compa-
nies are  monopolies  that care  little  about their  customers and  are only
interested in  rate  increases and  surcharges.  It  is  difficult  for the
public to  swallow that a  company  which makes its  profits on  the  sale of
energy is  seriously  interested  in  energy conservation.   It  appears to me
then that  energy  conservation has  become a mass of inefficiency; of large
utilities seeking  computerized  answers  with  minimal   data  input  and the
continuing waste of millions  of dollars  spent creating  complexities out of
simple on-site problems.   Only when one  stops and  considers the thousands
of different  home  builders  and commercial  and  construction firms  who
have built the homes,  office buildings  and commercial  structures in this
country, each using a different construction technique, materials, specifi-
cations, and  taking  short  cuts, does one  realize  the absolute necessity
for an  in-depth audit of the  type developed  by Princeton  University and
used exclusively by Energy Detectives.

     What  is  needed  to motivate the American people  including low income
persons and businessmen to act  to conserve energy and water?

     First, it must  be recognized that the  public-at-large  will not  incur
increased debt  for what  it considers to be  a  savings  of a few dollars per
month.  It must also be recognized that most people believe energy conserva-
tion means  being  uncomfortable.   Therefore,   I  propose  the   following:
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     1.  Provide tax  credits (not deductions)  for the full amount spent by
         the property owner in the year the audit and retrofit are comple-
         ted.  The  property deed should then  be noted accordingly so that
         future owners and  local or  state governments  are aware  of the
         building's energy  efficiency.

     2.  There  should be provided three or  five year  low interest loans
         from state government funded by the Federal  government, if neces-
         sary, to pay for the cost of the retrofit.  Checks should be made
         payable to the  property owner  and to  the  retrofit  company.   A
         Certificate  of  Compliance and Completion  should be signed by the
         property owner  and  the  retrofit  company  and these  loans  should
         be made quickly  and without red tape, in other words, as short as
         three days.

     3.  Any person or business  entity  selling a retrofitted property and
         purchasing another property which  has not  been audited and retro-
         fitted should have  the  opportunity  to qualify for  another  low
         interest loan which should  bring  the newly  acquired property up
         to energy  efficient standards.

     4.  Within  five  years  from  a  predetermined  date,  any  property  not
         retrofitted, with  certain  exceptions,  should  not be  sold until
         retrofitted,  thereby insuring  that  energy   inefficiency  is  not
         passed over or passed on.

     5.  At  such  time as is determined  there  exists  or  will  exist a free
         enterprise system  of independent enterprises in the energy conser-
         vation business,  a  massive  advertising  campaign sponsored  and
         funded by  the Federal government should be aired on the television
         and radio.  This campaign should be regionalized as to its content
         but the objective  should be the  same,  to substantially increase
         public awareness of what is available and  what Government will do
         to assist  property owners in saving energy.

     Needless to say,  there will be  both unscrupulous property owners  and
retrofit companies  who will attempt  to take  advantage of  this program,
however, I am  sure that retrofit  guidelines  and material specifications
suitably enforced can be implemented and monitored through state or local
inspection and by  random analysis together with appropriate penalties  for
fraud or misrepresentation.

     A recent study by the Department of Energy's Oak Ridge National Labor-
atory concluded:

     "Energy conservation saves  energy  and money,  reduces the  amount  of
     pollution,  reduces oil imports and our dependence  on foreign sources
     and buys time  during which  to  develop alternative  sources  of  energy
     that are environmentally benign,  abundant and  socially acceptable."

     It is now time for the  rhetoric  to cease and the assault on the misuse
of energy and water to begin.


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     For my  part,  Energy  Detectives  will  begin franchising  energy  and
water conservation audit  companies nationwide  by January of  1982.   These
small, efficient, privately owned and operated  businesses will create jobs
and opportunities for thousands who will,  by their efforts, help to audit
hundreds of  thousands of  homes  and businesses in a relatively short time.
The practical and  actual result  of these audits and  resultant  retrofits
will be to reduce our dependence on foreign oil.

     Our Government has given or  proposes  to give hundreds of millions of
dollars to assist  utility  companies in making a halfHhearted and ineffect-
ive bid at  inducing their  customers to conserve energy.  Obviously,  the
conflict of  interest  suspected  by the  general  public as well  as the lack
of technical excellence  of these programs  has  netted or will  net few, if
any, positive results.

     The current  administration  has  re-emphasized  the  need   for private
enterprise and the American consumer to do  for themselves what Government
has attempted to do unsuccessfully heretofore.  My proposal allows everyone
to enjoy  the long-term  benefits  of home energy and  water  conservation
without a giveaway to any special interest group - no matter how large or
influential  - while promoting jobs in the private sector.  The money alrea-
dy doled out to the utilities  for ineffective programs  could have made a
major contribution to the lower  interest  rates on loans  I have proposed.

     In conclusion, therefore, let  me  re-emphasize  the tremendous need for
intelligently managed and scientifically performed energy and water conser-
vation audits  in this  country.   The  benefits  to  be achieved  by private
industries working to provide jobs and  creating real  savings for Americans
all accomplished not  by  handouts or giveaways  but by sensible and logical
credits and  low  interest loans so  that we, as  in  the American tradition,
can do it ourselves.
PETER M. STERN
Vice President
Corporate and Environmental Planning
Northeast Utilities
107 Selden Street
Berlin, Connecticut

(This statement  and  the additional  information  submitted  with  it,  was
excerpted from testimony presented by Mr.  Stern in June  1981,  before the
State of  Connecticut,  Department of  Public Utility  Control,  Docket No.
810602 - Application of  the Connecticut Light and Power Company, and Docket
No. 810604 - Application of the Hartford Electric Light Company.)

INTRODUCTION

     My name  is  Peter M. Stern.   My business address is 107 Selden Street,
Berlin, Connecticut.   I  am  Vice President,  Corporate and Environmental
Planning of  Northeast Utilities.  Among  my responsibilities  are the load


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forecast, rate research and consumer  research functions.   In January 1981,
I was given  the  additional responsibility  of insuring that  the Northeast
Utilities Conservation  Program for  the  1980s  and  1990s  (NU 80s/90s)  is
carried out in keeping with its objectives.

OVERVIEW

     NU 80s/90s  is  a comprehensive plan  for improvement  in the economics
of supplying electric power to customers of  Northeast Utilities (NU).   It
shows how within six years the percent reliance on oil for  47  percent of
energy used  for  electric  generation for NU customers can  be reduced to 10
percent by:

     o   completion of Millstone Unit 3 and retention of substantial
         ownership

     o   conversion of 850 MW of presently oil-fired generating capacity
         to coal

     o   limiting growth in electricity ocnsumption to 1.5 percent or
         less annually  (in contrast  to  the  2.8 percent average  annual
         growth experienced from 1975 to 1980)

     o   addition of hydro and refuse-derived energy.

     The successful  completion of  this  first  six  year   stage  of  the  NU
80s/90s program  will  benefit  customers  by minimizing   the  inflationary
effect of rising  oil prices and by greatly improving security  of supply.
From the measures taken between 1981  and 1986 alone  (completion  of Mill-
stone Unit 3,  coal  conversion, and  the  addition of other non-oil capacity)
customers will save some $6.3  billion  (nominal  dollars  in the years  the
savings occur) between  1981 and 1993  compared to what they would have paid
should reliance  on  oil for generation  continue  as  at the  present.  This
amounts to about  a  $1,600 savings  for the customer with a 500 kWh monthly
bill, and hundreds  of thousands of dollars  for our  larger  commercial  and
industrial customers.

     With the  completion of  Millstone  Unit  3  in 1986,  there will be  no
need for additional base  load  capacity  on the NU system until near the end
of the century,  greatly reducing  capital  requirements for the construction
program.  There  will thus be adequate time to  assess  and  test  emerging
electric generation technologies before making  a  commitment.  This flexi-
bility in planning  for  electric power generation and the  reduction in  the
capital construction  program  will  be important  and valuable outcomes  of
the completion of the 1981-1986 phase of NU 80s/90s.

     A more  secure  and  less inflation-prone electric energy supply such as
we have planned  in  NU 80s/90s will also  make a vital contribution to  the
economic health of  the  region and  state in the  1980s and 1990s by assuring
businesses of  a  reliable and  economic  supply of electric power,  one that
can also  accommodate a  surge of demand  as  could occur  if there  were a
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major disruption of  the world oil  supply or price system.  NU 80s/90s is
an action plan  in  consonance with  the emphasis in the  Connecticut Energy
Advisory Board's (CEAB) 1981 report on diversity of  fuels in the Connecti-
cut economy,  conservation of energy,  and the  availability of  energy for
economic development.

     The oil displacement as part of NU  80s/90s is  substantial and has re-
gional significance.   In  1987 alone coal conversion  and the  addition of
Millstone Unit  3  (with a 65  percent  NU  share) will replace  14.5 million
barrels of  oil  (8.5 million barrels from coal conversion  and 6.0 million
barrels from  Millstone Unit 3).  Electric power  from currently operating
nuclear plants  in  1987  will displace 21.3 million barrels  of  oil.   To
place this  in perspective,  the  total  oil replacement of  35.8  million bar-
rels in 1987  is nearly  one-half the  78 million barrels of  residual oil
used for electric  power in New England  in 1980.   In addition,  oil use in
the region  will be  reduced  at  the point of use  because  of  conservation
measures taken by customers.

     The economic  benefits from NU 80s/90s  are extensive.  Let me summar-
ize them in general terms:

     o   Direct benefits to families and businesses equal to the value
         of the energy saved through conservation.

     o   Benefits to the state's economy in the form of:

                reduced oil dependency

                retention of more  dollars in the state's  economy  because
                energy conservation  expenditures  involve spending  within
                the state.   This will  represent  increased   state  income
                over the  alternative  of  not installing  conservation mea-
                sures and continuing to buy oil  from out-of-state producers.
                The savings  in  energy  expenditure  effectively  increase
                income and  spending within  the  state  with  a multiplier
                effect on the Connecticut economy.

            -   narrowing  of   inter-regional  energy  cost  differentials
                which now  exist by  substituting  coal/nuclear for  oil in
                the generation  of electricity, particularly  as  the price
                of natural gas  (used much more widely outside of New Eng-
                land) increases with deregulation.

NU 80s/90s  should  have a broad  impact on nearly  all major categories of
oil used in the state.  It will  reduce the use of  12 distillate oil for
home heating,  heavier  oils  used  in  apartments  and  businesses,  and the
residual oil  used  by  manufacturing   industries  and  electric  generating
plants.  In each category the program should make an impact.

     In order to maintain the targeted 1.5 percent or lower electric load
growth, we  are  adding substantially  to  the number  of   energy management
assistance  services being offered to customers.  Reinforcing the successful

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CONN SAVE home energy audit program, which NU has sponsored from the outset
(including the 1979 pilot program which enabled Connecticut to  become the
first state in  the nation  to place the  Residential Conservation  Service
(RCS) program in operation),  are aerial  thermography and  interpretative
workshops showing heat  loss in buildings  (available to  customers in  our
more densely-populated  municipalities),  a  service  to  wrap water  heaters
and turn down their thermostats, incentive  payments for certain conservation
measures, audits  for  commercial/industrial  customers  and other  programs
designed to encourage customers to use energy more efficiently.

     Our objective is to reduce energy consumption  of  all types.   Because
of the prevalence of oil used  in the region for space heating and industrial
processing, and important result of NU 80s/90s will be to reduce the direct
use of oil, in addition to  maintaining growth in the use of electricity at
1.5 percent or less.

     The purpose of my testimony is to give a report on the current status
of the principal elements of NU 80s/90s.  After describing the background
of the program  I will  discuss the  customer assistance programs in  some
detail, as considerable progress  has  been made, and  then  discuss  the plan
to reduce the use of oil in our generating plants.

     NU has made NU 80s/90s  a central part  of its  institutional  purpose
and future development.  We feel  we have been  responsive  to DPUC concerns
and produced a program whose elements  fit  well  together and will result in
nore economic electricity  supply   being  made available  to customers.   We
request the support of the DPUC for the program and its elements.

(Additional information on the Northeast Utilities Conservation Program was
submitted and reviewed  for  the record as  part  of Mr.  Stern's testimony).
ELMER N. STUETZER
5409 Itaska Street
St. Louis, Missouri  63109

     Do our nation's private electric public utilities really want "regula-
tory relief"?  The July 1981 settlement of  the Union Electric Company rate
case demonstrates that this Company has never  had it so  good as it now has
under the  jurisdiction of  the Missouri Public  Service Commission.   From
beginning to end this  entire  case was a farcical charade  intended to fool
the public into believing  that the MPSC is  consumer-oriented when instead
it is really pro-utility.

     On November 26,  1980  U.E. filed  for a rate increase of $91 million,
much more than it knew it really needed.  Such a huge sum  was decided upon
so that the  MPSC could later  cut it  down  to give  the  appearance it  was
protecting consumers.  Then during the period until a public  hearing  was
held on May 28, 1981 the staff of  the  Commission made a  so-called audit of
the exhibits prepared  by the  Company to  justify its request for a rate

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increase.  The hearing gave members of the public an opportunity to express
their opinions of  the U.E. request,  thus making  them feel that  they  had
some part in holding down the amount granted by the MPSC.

     On the very next day after the hearing the Commission  staff  responded
to such public opinions  by  announcing it could only recommend  an increase
of between $22 to $26 million.  However,  a  few days later the  staff disco-
vered, with the help  of  the Company,  that  it had  made a  mistake and  now
recommended an increase  of  between $38 to  $42 million.   On July  13,  1981
the MPSC announced that  it  had decided that effective July 17,  1981 Union
Electric was  entitled  to an increase of  about $50 million  to  be  followed
by an additional increase of about $15 million, possibly as  early as August
15, 1981 after it was determined  what effect  the  recent coal-miners'  wage
increase would have on the company's fuel costs.

     May I suggest a much more practical method of granting rate increases
to public utilities, i.e., THE ALL-AMERICAN WAY!  I use the  term ALL-AMERI-
CAN WAY to emphasize  it  would have to be effective in every state  in  the
union so that one  state  could not offer lower rates than another  in order
to entice  new business  to  its state at  the expense  of  the  residential
customers.  Under the  ALL-AMERICAN,  every  consumer, no matter how  big  or
how little would pay  exactly the  same price  for each  kWhr of  electricity
used, no  matter  what  time  of day or  season of  the  year.  In  addition,
instead of long, drawn-out  rate  cases, smaller amounts could be requested
more frequently as needed.  With  a governing board of  the  utilities peers
whose energy  costs would soar  you can  be  sure they  would not allow  any
utility to charge  too much for  its service.  Had  the ALL-AMERICAN method
of rates been in effect  at Union  Electric  Company  during the year of 1980
residential user's  bills would  have  been  $63 million  less,  commercial
users would have been $29 million less, large industrial users would have
had to pay $72  million more,  $22  million,  and miscellaneous would  pay $3
million less.

     It would have made  no  difference to Union Electric as it  would still
have the $997 million it needed to continue to render  its usual good serv-
ice.  It  is   interesting  to  note that  the recent decision  of  the  MPSC
increases rates to  residential by 8.5%  but to large users only 8.4%.   To
me, that seems to be the Un-American way!

Note:  The attached  schedule showing the derviation of my figures  may be
of interest to you.
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                KWHR        Revenue in     All-American         Difference in
Class of        Sales in    Thousands of   Revenue in           Thousand
Customer        Millions    Dollars        Thousand Dollars     Dollars
Residential     8446          402,160            339,571            (62,589)

Commercial      6913          306,486            277,937            (28,549)

Industrial      7616          233,854            306,201             72,347

Other Electric  1435           35,619             57,694             22,075
 Utilities

Miscellaneous    385           18,774             15,490             (3,284)
              24,795          996,893            996,893
     The above exhibit shows  in the first three columns the  class  of cus-
tomer, kilowatt hour sales in millions,  and  electric operating revenues in
thousands of dollars as shown on page 36 of Union Electric Company's Annual
Report for Year 1980.  The last two columns show what the operating income,
i.e., revenue, would have been and what the difference in such operating
revenue would have been had the All-American Way of Electric  Utility Rates
been in effect in 1980.

     The All-American Way charges all  customers, from the very largest, to
the very smallest, exactly the same price per  kilowatt hour,  no matter how
much or how  little is used,  or what  time of  day  or  night,  or  season of
year, winter or summer.  The  average  KWHR price used in above computations
is .040205, arrived at by dividing $996,893 by 24,795 KWHR.  So residential
customers would have paid $62.5 million less, commercial customers would
have paid $28.5 million less.
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AMY TIMMER
Energy Extension Service Clearinghouse
P. 0. Box 30228
Lansing, Michigan  48909

(This statement was presented  by  Ms.  Timroer to the National  Energy Exten-
sion Service Advisory Board on May 19, 1981.  The title  of this presenta-
tion was Energy Information Services;   Implications for U.S. Energy Policy
(A Study Based on the Michigan Energy Extension Service Clearinghouse)).

     In cutting  federal  funding   for national  energy  conservation  pro-
grams, the  Reagan Administration  believes that  rising energy  prices and
government tax  incentives will adequately encourage  people to conserve.
Unfortunately, recent history  suggests that  this simply  will not  be the
case.  While  it is  true that  energy consumption has declined  as prices
have risen, the decline in consumption has not  kept pace  with  the growth
of prices.   For example,  since  1972,  the price  of  natural  gas  used in
Michigan homes has  risen 194%;  the  price of home heating oil, 437%; and
the price of  electricity,  115%;  yet per  capita  energy consumption in the
residential sector  has  declined   only 5% during  the same  time period.
Citizens have made  up  the difference between their savings and  their con-
sumption simply by devoting more of the household budget to energy, indivi-
duals and families  are  exporting  billions of dollars  each year  to pay for
imported fuels — money that could otherwise be used to purchase goods and
services within this country.  Thus, the  free  market is working  — but
very slowly  and at  an  enormous  cost  to both  consumers  and  businesses.

     In making their decisions about  how conservation should be encouraged,
the free market theorists do not give sufficient consideration to an impor-
tant fact:  rational economic decision-making relies on an  unobstructed flow
of information.  For the price mechanism  to work, people must know how to
respond.  Unfortunately, not all of our responses can be dictated by common
sense.  If the price of hamburger goes up, the response is simple: eat less
or buy  something  else.  But,  if  the price  of  home  heating fuel  goes up,
there are  fewer obvious ways  to  buy less or conserve.   Some  of the most
effective ways  to use  less  energy require  us  to know a  great deal more
about our  homes than most people  know.   In other  words, people are not
managing their energy consumption because  they do not know  how.

     A  state-wide  survey  conducted  in 1978 demonstrates  this  contention.
A majority  of Michigan citizens  polled   cited  turning out  lights  as an
important conservation  action.   A minority  cited insulating  and  a very
small minority  cited weatherstripping as important  conservation actions.
Although all  three  actions will  save energy,  insulating  and weatherstrip-
ping can  save much  more than turning  out  lights.   But, because turning out
lights  is  the most obvious  way to save  energy,  this conservation measure
is widely practiced, despite the  fact that it will not significantly affect
utility bills.   It  is  little  wonder that American  citizens claim  to be
conserving, yet  complain that  their  energy  bills continue to soar.   Thus,
the  need  for energy management information is widespread and strong.  And,
the  Michigan  experience suggests  that it  is an essential  complement  to the
efficient operation of  the free market.

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     The Michigan  Energy Extension Service  Clearinghouse  has been addres-
sing the need for  energy information since  April,  1978 when the Clearing-
house opened  the Energy  Hotline.   The Hotline is  a toll-free information
service established to help homeowners  and  other  small energy users under-
stand energy  use and consumption patterns, and cope with ever-rising energy
prices.  The  Hotline offers  technical assistance  over the  telephone and
provides callers with written materials on a wide variety of energy topics.
Materials developed  by  the  staff are designed  to  address the  broader
aspects of  conservation and  energy management, while supplying both tech-
nical "how-to"  instructions  on  conservation  techniques,  and  financing
information.  Based  on a number of studies of public awareness  of energy
concepts, and factors  which best motivate citizens  to conserve,  more than
200 different publications have  been  developed  and are  now distributed
state-jwide.   This  information  is  used  by  homeowners,  small  businesses,
local governments,  public  school  teachers,  community groups,  students,
professionals in the  energy  field, and other state  and federal agencies.

     The Clearinghouse  operation  in  Michigan collects extensive data  on
each client,  which is  used  to continually monitor the  effectiveness  of
the program,  and to modify  the service so  that  it  is  most appropriately
addressing the  needs  of the  public.   It is important to understand that,
by definition,  an  information service must  be responsible to public need,
since that is its  inherent function.   If use  of  such a  service  falls off
dramatically, it is  an indication that either  the service is not providing
appropriate help,  or that it is  no  longer needed.   If government  is  to
serve public  need  in the area of energy information, then, it is useful to
look at  the  trends  that have  occurred  in the  Michigan  experience.   To
date, over  65,000  Michigan  citizens  have made use  of  the Clearinghouse.
The table below shows that  the demand  for  this  service  continues  to in-
crease in weekly phone contacts  since the  service  was made  available  in
1978.

    Number of Citizens Contacting the Michigan Energy Extension
                 Service Information Clearinghouse

                                   Total       Number Per Week

1978                                5,959          119
1979                               17,019          327
1980                               28,107          541
1981 (through February)             8,410          764

     And the  trend  is expected to  continue.  In a  random survey of over
600 Michigan  households  conducted  in August of 1980, over 80% of  the re-
spondents said they could use more information about one or  more areas  of
energy conservation right now.   These  findings  are  complemented by those
of a nation-wide survey conducted by the Gallup  Organization (1980)  where
it was found  that over half  of the population still does not know about
the federal income tax  credit for residential solar installations  (finan-
cial assistance is often viewed as one of the best  incentives  for under-
taking conservation projects).   It is  thus apparent  that in  order  for
Americans to  make  wise decisions  about energy use,  and to  be  encouraged

                                    437

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to take  advantage of  existing  incentives,  they must  have access  to the
necessary information.

     What, then,  is  the  best channel through which to  offer such informa-
tion? The marketplace has  seen the entry of a confusing  variety of energy
conservation devices, including  gas savers, insulation,  solar panels, and
wind generators  (yet another indication of consumer  interest  in conserva-
tion) .  To  sell their products, many  companies  must first explain energy
terminology (such as R-values, BTU's,  and thermal storage  capacity),  and
then explain how their product  will help  the  consumer  cope with  energy
costs.  Thus, to make an  intelligent decision, the consumer must understand:
new terms  and   concepts;   technicalities  of the  product;   financing in-
formation, including payback periods and  resultant  savings;   objectivity
and reliability of information received;  comparable products; and alterna-
tive options.   While private  interests may eventually  offer all of this
information, it  is the reliability and objectivity of the information that
a consumer  will  most  often  question.  Approximately  one-third  of  the
calls received  by Michigan's  Energy Hotline concern  specific  brand-name
product information, while the great majority (75%) of all calls are from
consumers who are making decisions related to personal conservation invest-
ments.

     To confirm the need for an objective information service and to deter-
mine public preference  for the source  of that  information, Michigan sur-
veyed citizens  and  asked the  open-ended  question of where people thought
they could get the most  believable information about energy.  The combined
"government" responses  (federal,   state,  and local)  were   mentioned  more
frequently than any other  source.   The  next most  frequent response was "no
one" or  "don't  know any."   Moreover,   when the  Gallup Organization asked
who should  "educate  and inform" consumers  about solar energy,  the  single
most often mentioned source was the federal government.   Contrary  to the
assumption of the new  administration,  it seems  the public  is  very  much in
favor of  continued  government involvement  in certain public  is  very much
in favor  of continued  government  involvement  in  certain  public  service
areas —  in this  case,  that  of  energy  information dissemination.   More
importantly, the public seems  willing to  support  such preferences with tax
dollars.  In a  Michigan  survey conducted from late February through early
May of  this  year, 79%  of  respondents agree that  "the  government  should
spend a larger  portion of  its present budget on  energy conservation."  In
contrast, only  31%  agree that "government  should  stay  out  of the picture
and let the  free market find the  best solution  to  our energy problem."

     A criticism  now being  leveled against  the  information  produced and
distributed by  the  U.S.  DOE maintains that  the department is  biased  in
favor of  decentralized  alternative  energy  approaches  and against  more
traditional central  station energy  sources (House Subcommittee  on  Energy
Research and Production report entitled, "The Department of Energy's Public
Information Programs:  Major Changes Needed").  Because of this criticism,
a review  of certain  DOE publications  is  currently  being  conducted,  and
states are unable to obtain quantitites of those materials for distribution
to the public until that review is  complete.  Not only  has this created an


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inconvenience for  state  information  services,  but  the  criticisms  which
led to  this  action are misleading.  Much  of the DOE public information is
distributed to consumers who are making very decentralized  energy decisions.
The criticism that DOE does not adequately  promote  central station energy
sources ignores  the fact that the public  in general has  little to do with
such decisions.  Conservation  and renewable energy options require indivi-
dual-level awareness and information in order to be  implemented.

     The experience  in Michigan provides  the kind  of data upon  which to
base decisions  that will  determine the  scope  of an information service.
It is consumer  demand that should dictate the  types of materials produced
by a government information service.   Below is a  table based on the first
40,000 citizens  requesting information from the EES Clearinghouse between
mid-1978 and mid-1980.

                   Percentage of Citizen Requests
                    For Information by Category

                   Conservation              54%
                   Solar energy              12%
                   Other renwable sources    13%
                     (e.g. wood, wind,  biomass)
                   All electrical generation  3%
                   Nuclear energy             1%
                   Fossil fuels               1%
                   Other Miscellaneous      16%
                                            100%

As the  table  clearly indicates, consumer  preference is overwhelmingly for
conservation and renewable technologies information.   More than ten times
as many requests for solar energy information have  been received than for
either nuclear  or  fossil  fuel  information.   Futhermore,  conservation,
solar, and  other  renewable  energy  sources,   together account  for  over
three quarters of  all  energy information requested.   (Note:  Since August,
1980, where the table above  left  off,  customer  requests have  been even
slightly more in favor of  solar and  conservation.)  The  implications  for
national energy  policy are obvious:   the  public desires,   and  is actively
using, information that  will help them reduce  energy consumption.   If in-
formation services prove to be cost-effective  in helping  keep down energy
expenditures, they  should  be maintained and expanded.   Thus,  the costs of
such services must  be  explored in relation to their impact on energy con-
sumption.

     The Michigan  EES integrates  an  extensive evaluation  component into
every aspect of the program.   Every person  who contacts the Clearinghouse
is surveyed to  determine satisfaction with the service,  and  conservation
actions taken as a result  of information received.   Conservation actions
are translated  into BTU savings  and  then into dollar  savings.   The table
below shows program costs and savings.
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                                                        Dollars Saved
            EES Dollars Spent    Client Dollars Saved    per $ Spent

1978        $ 83,981             $  283,332              $3.37
1979         155,081                866,029               5.58
1980         174,609              1,522,432               8.72

The Information  Clearinghouse has  in effect,  more than  paid for  itself
with energy  savings in  every year  of operation.   In 1980  alone,  almost
$9.00 were saved for every dollar  spent  to operate the program.   This is
of special significance  to the economy of  Michigan,  as 85%  of our energy
must be  imported into  the state.   From  a national perspective, this  kind
of productivity could be invaluable in helping to solve the energy problem.
A balanced  energy  program cannot  afford  to ignore  such  contributions.

     Finally, it  is interesting  to note  that the Michigan  Clearinghouse
has promoted these  savings while maintaining high ratings  from clients in
a variety of service areas.

                       Clearinghouse Patron Feedback

     74.5% of  Clearinghouse materials are rated  as 80-100% of what the
         patron wanted.
     67.1% of  Clearinghouse  patrons take  action to conserve  energy after
         contact with the Clearinghouse.
     79% of Clearinghouse  patrons rate the service  as  completely informa-
         tive
     82.9% of  Clearinghouse clients  are  making their  first  contact  with
         the service.

The program has   consistently maintained  these  ratings  for  three  years.
The national Energy Extension Service program began  as an  experiment in
grass roots energy  conservation — the  intention being to use  government
only as  an  impetus  to helping consumers realize  energy savings in their
personal consumption habits.  Without employing any regulatioins — relying
solely on the  benefits of education and consumer incentives  to save money
— the  Energy Extension  Service program  has done  precisely that.   The
service has not  only helped hundreds of thousands  of Americans  understand
the nature of  our  energy  crisis,  but "has  provided  them with the kind of
information necessary to promote active  conservation of  scarce  resources
and increased use of renewable resources.  But more importantly,  the exper-
ience and accumulated knowledge  offers the Reagan administration  an option
- to avoid government  interference in the marketplace;  to avoid increased
use of fuels that cannot last or are not proven safe  to  our environment;
to avoid  sending billions of dollars out of our country  each year.  That
option is to  educate the  public,  to provide a cost-effective and  highly
needed information  service that  has  proven  its  worth  in our efforts to
combat the energy crisis.
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MARGARET WALKER
Drector, Arizona Energy Office
Office of Economic Planning and Development
1700 West Washington
Phoenix, Arizona  85007

     The EPA Section 11  requirements provide a  good opportunity for impar-
tial review of the U.S.  Department  of  Energy (DOE)  programs.  It is impor-
tant to  remember  that  this is  not  just a  required exercise  but a useful
tool to  allow  constructive comments  for DOE  programs and  policies.   The
ccmments that  resulted  from  the 1980  Section  11  review were thoughtful
and, in  our  view, reflect  the value of  the energy conservation programs
administered by DOE.   It is regrettable that the programs are being aban-
doned at a time when they are just beginning to bear fruit.   In this testi-
mony, I  intend to review the  successes  of the DOE conservation programs in
Arizona, and then respond to  the altered approach  of  this  Administration.

THE ARIZONA ENERGY STORY

     The Arizona Energy  Office has received federal funds since 1974 when
it was  established  with  Federal  encouragement.  Since 1974,  our programs
have expanded as  the  federal  and state role in energy conservation grew.
We administer  federal   funds   for the  State Energy  Conservation Program
(SECP), Energy Extension Service (EES), Emergency  Energy Conservation Act
(EECA), Residential Conservation  Service  (RCS), Institutional Conservation
Program  (ICP),   and  Weatherization  Assistance  Program.   In  all,  direct
federal funds,  excluding  pass throughs, amount  to $700,000 or about 60% of
our budget.  The  Arizona Legislature has  recognized the  needs  in Arizona
and has  supported  the  office with  the  additional  40% of  our  budget.

     It might  be  useful  to  review the extent of  the  energy  problem in
Arizona:

     o   Arizona is particularly vulnerable to oil interruptions since
         we produce and refine very little petroleum.

     o   Arizona households spend $2.7 billion in direct energy costs
         for residential and transportation uses:

         — $1810 per household for gasoline
         — $1257 per household for electricity and gas

     o   Transportation represents 36% of all energy used (against a
         national average  of  25%)  despite a reduction   from  1.41 billion
         gallons in 1979 to 1.36 in 1980.

Arizonans have responded well to calls for conservation.   They are eager
to learn how to go about  saving energy in their homes,  cars  and businesses.
Our programs are  designed to  help Arizonans find reliable information and
complete effective measures.  The following  represents some  of the activi-
ties, successes and potential of the state energy office:
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o   The Governor  appointed a  Building  Standards  Advisory Comnittee
    which produced a  thoughtful  Arizona Guidelines for Energy Conser-
    vation in New Building Construction.   With  an  estimated  43% of
    Arizona's energy consumption used in buildings, a  savings of just
    20% is equal  to  the energy to  be produced annually by the three
    Palo Verde Nuclear units, 3750 megawatts.

o   The  Weatherization Assistance  Program has insulated and improved
    3281 homes in Arizona.   If each of  these averaged  a 35% reduction
    in space heating,  which  it is estimated  to do,  we  would  save
    $143,000 a year in  utility  bills for those low income and elderly
    residents.   As utility  costs continue to  rise,  that  would  save
    millions of dollars over the lifetime of the houses.

o   Driver  Energy  Conservation  Awareness  Training (DECAT) can save
    20% of our  gasoline consumption.   In  the first year  of the pro-
    gram, 3000 Arizonans will be trained with a savings of 1.1 million
    gallons of gasoline  or over one and  a  half million  dollars  for
    those drivers.   Particularly valuable  will be  training  diesel
    fleet drivers and high school driver education classes.

o   Three hundred forty-seven schools, hospitals and local  government
    buildings in Arizona received $1.1  million dollars to improve the
    the energy efficiency under the  Institutional Conservation Program.
    As an example, a hydronic economizer was installed at the Univer-
    sity of Arizona which  can offset 87% of  the  campus cooling load.

o   Conservation  Road  Shows have  been  given to over 1000 Arizonans
    from Williams to Willcox. At even a modest  figure of 5% performing
    some energy conserving measures  as a  result of  these programs,
    the savings will  be equivalent to  all the energy a  family needs
    to power its vehicles for a lifetime.

o   The proposed Residential Conservation Services (RCS) would provide
    on-site energy audits  for  Arizona homeowners.   It is estimated
    that a resident who takes a minimum action on the reccntnendations
    of the RCS audit can reduce energy use by 22%.  If just 6% request
    an audit and half of them take  some action,  the  estimated annual
    energy savings is  43,000 barrels of oil equivalent.   That would
    represent $1.8 million in Arizona alone.

o   One third of Arizona's  cities and  towns are participating in the
    Energy Conscious Community Award program to recognize local ener-
    gy activity and provide  a delivery mechanism for  oior  energy pro-
    grams.  Communities  can  win  a Governor's  Award   of  Excellence,
    Merit or Participation  by demonstrating success  in  a  number  of
    energy conservation and solar projects.

o   As a result of the  Arizona  Energy  Office, at least 23  trillion
    Btus were saved in two years.
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         —       This much energy  in  the  form of gasoline would supply the
                  fuel   for a third of a million small cars for a full year.

         —       This much energy would supply  all of the energy needs of
                  144,000 typical Arizona homes  for a full year.

         —       This much energy  is  equivalent to 3.8  million barrels of
                  oil or $159 million.

It is  clear that  we support  the retention  of  federal  funding  for state
energy offices.   That  expenditure  provides  offices  around  the  country
familiar with  energy solutions and it allows  states to focus on the parti-
cular needs of the citizens in that state.   Arizona is  an especially good
example of the  need  for local  focus.   Among other characteristics,  we have
unique construction with flat roof houses and evaporative coolers, enormous
climate diversity,  and  we  have  carefully guarded  local home  rule.   The
state and local conservation grant program that  funds these 50 state energy
offices was $336 million.  That is only 2% of the DOE budget and one-tenth
of the Strategic Petroleum Reserve.

EFFECTS OF NEP III

     With a total  reliance on the  free market  economics of  the Third Na-
tional Energy  Plan,  most of the  successes Arizona has forged  will be re-
moved.  Useful  cost-effective programs will  not be  offered  because  the
funding will be removed. Although  we recognize the value of a fundamental
review to examine what  works and what doesn't work as a  result of federal
funding, we strongly suggest we have demonstrated the  value of DOE conser-
vation and renewable funding.

     The rising price pressures that  have resulted  from the  free market
economics will give Arizonans the motivation to conserve but not the means.
People need reliable,  available information  to  understand which  measures
are most cost-effective.  Larger corporations with staffs of engineers can
make those calculations  but the average homeowner has great  difficulty in
deciding whether it  is  cost-effective  to  install  R-30 or  R-19 insulation
or which appliance has the most favorable life cycle cost.

     These are  economies of scale  that can  result from  federally funded
appliance labelling  programs,  energy efficient  building code  reccmnenda-
tions, passive  solar building technologies,  and on and  on.  In a  similar
way, it makes sense to have one state energy office to assist local govern-
ment leaders and  energy users make  energy  decisions  based  on  reliable
information.   Economies  of  scale  are being lost  by the  new  approach.

RESPONSES TO SECTION 11 REVIEW QUESTIONS

1.   "How are private firms, state governments and local  agencies preparing
     to assume their new responsibilities?"

     There is little  indication that these  groups  recognize that they must
     assume new responsibilities.   You  make the  assumption that  because

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     the federal  government  is  dropping  its  role  in  conservation  and
     renewable programs,  these groups are expected  to pick  them up.   On
     the contrary, there is a  strong belief that the  intended  dismantling
     of DOE means there is  no energy problem,  therefore no need  to  assume
     new responsibilities.   Leadership and  authoritative sense of  direction
     is needed to assist us in explaining  there is a  critical  role to  be
     played in conservation and renewables.

2.    "Which activities will get priority from  public and private  organiza-
     tions and what will  be the consequences  if some  activities  are discon-
     tinued?"

     Keep in mind that federal budgets which call for no support  for state
     energy offices, will mean the end of a substantial number  of the  suc-
     cesses we enumerated earlier.   Consequences  will  be uninformed  citi-
     zens who pay more than they need to  in energy costs, less  efficient
     buildings and fleets  with reduced productivity, ever increasing  con-
     sumption at higher prices that will fuel not only inflation  in  geome-
     tric proportions, but  bring  greater  declines in  economic output  as
     fossil fuels are harder to retrieve.

3.    "Have any new initiatives or opportunities been  created as  a  result of
     the shift in Federal energy  conservation programs?"

     Those that appear likely will  end  when  state  energy offices  close.
     Private sector conservation  initiatives  can be inconsistent, unreli-
     able, unmonitored and  unenthusiastic.   Because profit-centered  firms
     need to see fast paybacks it  is questionable how  fundamental research
     necessary for renewables  will be continued.

4.    "What is the  Federal  government's proper  role in  this period of tran-
     sition?"

         Leadership.   The Federal  government must explain  that  exponential
         growth of energy consumption is impossible to sustain  and  recognize
         that capital  formation  costs for  expanding production facilities
         is an increasing  drain  on  the economy.   It   must  recognize  and
         support conservation  and  renewables as appropriate  answers in  a
         transition from  fossil fuels.

     -   Equity.   The enormous federal support  for fossil  fuel  exploration
         and production,  for  nuclear  fuel  research and disposal must  be
         balanced with an equal emphasis on  other forms of energy produc-
         tion.  The subsidies for existing  fossil  and nuclear production
         must be recognized and  made part of  the real  cost  of  producing
         these fuels.   If   similar  support  were  given conservation  and
         solar during this  transition,  the  investment  would be  less  and
         the long-term results greater.

         Information.   Americans  need reliable   information on  measures to
         take.  As we make the transition to higher prices, people must  be


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         given the  appropriate  tools  to  protect themselves  from  these
         prices.

5.   "How should the Federal government  evaluate and  monitor the  effects
     of its new energy policies and program changes?"

     For example, U535  would be  extended to  demonstrate Btu  savings.   A
     new tool would be examining numbers of people on low income assistance
     resulting from energy bills.   Numbers of small businesses bankruptcies
     could be calculated.

SLMMARY

Existing DOE  conservation  and renewable programs need a  chance to achieve
their full successes.   A weeding  out process has produced  effective pro-
grams that should be  continued.   True market energy economics  cannot  be
the sole policy since Americans need reliable energy information and assist-
ance.
MR. JETER M. WATSON
The Conservation Council of Virginia
Route 3, Box 647-A
Ashland, Virginia  23005

     The Conservation Council  of Virginia is a  coalition  of 38 membership
groups representing  a broad  spectrum of  environmental interests,  joined
together by  a  common  commitment to  the  conservation  of those  resources
which result in maintenance and improvement of  a  healthy  environment.   As
such, the Council  is extremely interested in energy  use,  particularly the
efficient use of energy through conservation measures,  which we (in agree-
ment with the Harvard  Business School Energy  Project)  consider to  be the
most important and readily available energy source for a continuing healthy
economy.

     The Administration's  emphasis  on  increased  production  seems  to  be
based on two erroneous assumptions  concerning energy conservation:  First,
that conservation means a lowering of personal standards of living (implied
in the  Notice of Public Hearings and Staff Working Raper,  p.  10-11)  and,
second, that market  forces  will bring  about  desired  conservation  goals
regardless of government energy policy (Id., p. 2, 6, 9, 11).

     Where the first assumption is  concerned,   (i.e.,  energy conservation
means lower standards of living) the Administration  seems  to be fixated on
a narrow definition  of conservation  merely as  curtailment  of use  (i.e.,
of "doing without").   But energy conservation  is far more  than  that.   In
the sense that we  are advocating it, energy conservation  means adjustment
of use  (i.e., of  cutting out  waste by improving  efficiency).   Studies of
the energy/GNP relationships of the United States  and a number of European
countries have indicated that, given a serious commitment to energy conser-
vation, this country could reasonably expect to achieve a  30 to 40 percent

                                    445

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energy saving without any  standard  of living loss and,  more probably,  with
a resulting higher  standard of  living, when  the reduction of  energy-use
induced environmental dislocations is considered.  In short, current waste
within the system will permit conservation to do more with less.

     Where the Administration's  second assumption is concerned  (i.e.,  the
inevitability of energy  conservation through  pricing  in the free  market)
it should be  pointed out  that  proposed federal  subsidies for high cost,
high technology  energy  systems  will  inevitably erode  the price  induced
energy conservation  we  have experienced  at  various times  since 1973  by
placing these  high   cost  alternatives  on  a  more favorable  institutional
footing.

     Were the government actually "not  to select and promote favored sour-
ces of energy", as  is proposed  in guiding principle three (Working Paper,
p. 10), then pricing alone might, indeed, bring about the energy  conserva-
tion, in the  form of "not wasting the  Nation's resources" (Working Paper,
p. 10), to which the Administration does not appear  hostile.   Unfortunate-
ly, the Working  Paper  immediately contradicts  guiding  principle three  by
proposing, in guiding principle  five,  to  subsidize high cost,  high  techno-
logy energy systems, subsidies which  will, in a very real way,  "select and
promote (the)  favored  sources  of  energy,"  decried  in guiding  principle
three.

     Such high technology  subsidies  by the Administration will,   in  our
opinion, heighten the energy waste  which renders  our economy  increasingly
non-competitive with those  of  other,  more  efficient countries.   Greater
inefficiency will result  from   the  high intermediate  to  end-use  energy
characteristics of  the  favored,  subsidized   energy  systems and  from  the
erosion of price-induced conservation gained so far, as  these new  techno-
logies use up and replace existing technologies.

     Additional benefits accrue to the energy conservation approach.   Ener-
gy conservation is  a virtually pollution  free energy source.  It does  not
tear up the land, nor create boom and bust economies, nor pollute or other-
wise use up waste quantities of  water, nor affect air quality or climate,
and, most importantly,  it does  not involve the long lead times  and inflexi-
bility of the high cost,  high technology systems.

     The Administration's Working Paper alludes to  these  disadvantages  of
the high technology solutions,but  dismisses them  being  results of  suc-
cesses in other  areas  of  improvement or as  being too  distant in  time  to
worry about.   Far  more attention  should be  paid to these disadvantages.
The combustion products of  increased coal usage  are of concern, both  be-
cause of direct health effects of air  contaminants and  because of the more
indirect problem of acid rain.   The  competition  for water of these  high
cost, high technology energy systems  with  existing  uses of water,  espe-
cially in the  more  arid  west,  may  be severely limiting  both  economically
and environmentally.  The  characterization  of  possible  climatic  effects
as too remote to warrant concern (i.e.  in the next century) is inappropri-
ate on three  counts.   In the first place, it is irresponsible to put  off
such a problem so callously  on  a generation unborn.  In  the second place,

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many of us in this room hope to live well  into  the  next century.  Finally,
there is a body of evidence  stemming from the  climatological  research of
people such  as  Reid Bryson  to suggest  that man induced  climatic effects
are already  being experienced  without  the presence  of  the  large  scale
technologies which the Administration proposes to subsidize.

     We therefore urge  you to consider  and support both  the economic and
the environmental benefits of  strong  government support for energy conser-
vation initiatives  which  will benefit  all  the people,  rather  than  the
economic benefits which will  accrue to only a  few,  while  the economic and
environmental costs are  borne by  many if  the  high cost,  high technology
energy systems are  subsidized  at the  expense of conservation and renewable
energy resource programs.

     Thank you for this opportunity to present our views.

        MEMBER ORGANIZATIONS OF CONSERVATION COUNCIL OF VIRGINIA
   1.  ASSOCIATION FOR THE PRESERVATION OF VIRGINIA ANTIQUITIES

   2.  AUDUBON NATURALIST SOCIETY OF THE CENTRAL AMERICAN STATES

   3.  CANOE CRUISERS ASSOCIATION

   4.  C.A.R.E. CHAPTER OF THE CHESAPEAKE BAY FOUNDATION

   5.  CITIZENS COMMITTEE FOR VIRGINIA STATE PARKS

   6.  CITIZENS ENVIRONMENTAL COUNCIL OF THE ROANOKE AREA

   7.  CITIZENS PROGRAM FOR THE CHESAPEAKE BAY

   8.  COMMITTEE TO PRESERVE ASSATEAGUE ISLAND

   9.  THE GARDEN CLUB OF VIRGINIA

  10.  HANOVER CITIZENS FOR SENSIBLE GROWTH

  11.  IZAAK WALTON LEAGUE OF AMERICA, VIRGINIA DIVISION

  12.  KING GEORGE ENVIRONMENTAL ASSOCIATION

  13.  LEAGUE OF WOMEN VOTERS OF VIRGINIA

  14.  LOWER JAMES RIVER ASSOCIATION

  15.  NORTHERN SHENANDOAH  VALLEY CHAPTER OF THE  NATIONAL AUDUBON SOCIETY

  16.  NORTHERN VIRGINIA CONSERVATION COUNCIL

  17.  OLD DOMINION CHAPTER OF THE SIERRA CLUB


                                     447

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  18.  PIEDMONT ENVIRONMENTAL COUNCIL

  19.  POTOMAC APPALACHIAN TRAIL CLUB

  20.  RAPPAHANNOCK LEAGUE FDR ENVIRONMENTAL  PROTECTION

  21.  RECLAIM THE JMES

  22.  RICHMOND CHAPTER OF THE NATIONAL AUDUBON SOCIETY

  23.  RICHMOND SCENIC JMES COUNCIL

  24.  RURAL POINT CONCERNED CITIZENS ASSOCIATION

  25.  SOCIETY OF AMERICAN FORESTERS, APPALACHIAN SECTION

  26.  TROUT UNLIMITED, VIRGINIA COUNCIL

  27.  VIRGINIA ANGLERS' CLUB

  28.  VIRGINIA B. A. S. S. FEDERATION

  29.  VIRGINIA BEACH CHAPTER OF THE NATIONAL AUDUBON  SOCIETY

  30.  VIRGINIA CHAPTER OF THE AMERICAN SOCIETY OF  LANDSCAPE ARCHITECTS

  31.  VIRGINIA CITIZENS FOR BETTER RECLAMATION

  32.  VIRGINIA FEDERATION OF GARDEN CLUBS

  33.  VIRGINIA FEDERATION OF HUMANE SOCIETIES

  34.  VIRGINIA REGION OF NATIONAL SPELEOLOGICAL SOCIETY

  35.  VIRGINIA SOCIETY OF AMERICAN INSTITUTE OF ARCHITECTS

  36.  VIRGINIA SOCIETY OF ORNITHOLOGY

  37.  VIRGINIA WILDERNESS COMMITTEE

  38.  YORK CHAPTER OF THE CHESAPEAKE BAY FOUNDATION

      *************

JUNE WILLIMS
Manager, State Energy Conservation Plan
Department of Energy and Transportation
Watkins Building, 510 George Street
Jackson, Mississippi  39202

     The following comments should be entered as testimony for the Environ-
mental Protection Agency Section 11 hearings.

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     The Energy Division  of the Mississippi Department of  Energy and Trans-
portation takes  the  stance that  conservation through  high  prices in  the
free market alone  cannot  meet  the  energy conservation goals for Mississippi.
Conservation efforts  of MDET  center  around the  ideas  of not  only reducing
or at  least  stabilizing  energy  demand,  but of  utilizing present  demand in
the most  efficient manner.   Peak  energy efficiency  is  a  major  factor in
leveling off the costs of energy.

     Large businesses and industries  with heavy amounts  of investment capi-
tal have the  flexibility to undertake major retrofitting projects to attain
maximum energy efficiency in  plant operations.   These  firms are  also more
likely to have on  staff a person whose major function it is to seek out and
take advantage of opportunities to conserve energy.

     But what  about  those  businesses and  industries  which  are struggling
to remain  in the  market?   Without encouragement  and technical assistance
from the  governmental  sector,  these  firms  will  take  the alternative  of
continually passing on rising  energy costs to consumers.

     Adoption of  energy  efficient  management  practices  today  will  most
certainly impact upon future  energy  needs.  The  MDET Energy  Division will
continue to  encourage  energy  conservation by  providing energy management
technical assistance and training.
RALPH WILLMER
Somerville, Cambridge Economic
 Opportunity Ccmnittee, Inc.
Somerville, Massachusetts

     My name is  Ralph Willmer, and  I  am the Project Director  of the Energy
Consumer Education Program  at  the Somerville, Cambridge  Economic Opportuni-
ty Committee,  Inc.  (SCEOC).   SCEOC  is  the  local  Community  Action Agency
which serves the  cities and towns of  Somerville,  Cambridge,  Belmont, Water-
town, Arlington  and  Lexington  in Massachusetts  near  Boston.   As part  of
our program, we conduct  workshops on low cost/no  cost  weatherization and
utility rights.  We have also written manuals on these subjects.

     The purpose of  my testimony  is to  express  my concern  over the direc-
tion that  federal  energy conservation programs  are headed.  I will address
several different  issues  including the need  for  the continued federal  role
in weatherization  programs,  the  impact  of  the proposed  federal  policy  in
Massachusetts,  its effect on the  low-income  population and  the  problems  of
shifting programs from one agency to another.

     For the  past  several  years,  the  federal  government  has  sponsored
weatherization programs  which target  low-inccme  neighborhoods.    This  pro-
gram has been  run by  several  different agencies  during this time period.
Programs such as  these provide  vital services,  which should  not be  over-
looked.  The situation  in our  service area is typical of  many  cities within
the New  England  region.    The  city  of  Somerville has   a   relatively  high


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proportion of low-income people.  According to a  recent survey done in the
city (Initial Energy  Inventory Report Citizen's  Energy Advisory Conrnittee)
over 90% of the city's housing stock was built prior to 1939.  Multi-family
structures comprise 90%  of all city  residences.   There is a  2  to 1 ratio
of renters to homeowners in the city.  The survey also showed that 85% of
these homes were  inadequately insulated  and  75%  of  all homes  lacked any
insulation at all,  Furnace efficiencies were also  low  -  the average effi-
ciency for all housing types was only 71%.   Oil is the predominant heating
source.

     The scenario described by these  statistics  is a  particularly dismal
one.  Low  income  people  who are  most vulnerable to the  upsurge  in oil
prices are the  ones who  are living  in homes  that  burn the largest volume
of fuel.   Landlords have no incentive to tighten  up these homes,  whether
they pay the  utilities  or not.  Since  the  housing stock  is so  old, and
poorly insulated,  many  of  these homes are  costing consumers hundreds of
dollars a  year  in  wasted energy.   Weatherization programs,  sponsored by
the federal government,  have  begun to  improve this  situation.   Many of
these people also  receive  some  fuel  assistance money  in  addition to the
weatherization kits.   However,  funding  the   fuel assistance program is
really only a band aid approach to the problem.  Through continued weather-
ization, we can begin to make homes  more  energy  efficient  and therefore
decrease reliance on fuel  assistance  to pull people  through the  winter.

     In general, energy  conservation should be the crux of any sound ra-
tional energy policy.  Throughout the  issue paper  written for the National
Energy Plan III hearings,  the  point was made that America's dependency on
foreign energy supplies leaves us in a vulnerable position.  Energy conser-
vation should play  a vital role in  reducing our dependency on imports.
Since it is economical  and the technology is  already developed,  there  is a
very important  role that the  federal  government  should play.   To ignore
this or pass the responsibility down to the states and localities is short-
sighted at best.

     Massachusetts is  facing  an additional  obstacle  to  maintaining and
expanding its own weatherization programs.   In  November 1980,  the voters
approved a sweeping tax  reform measure known as Proposition 2 1/2;  which
essentially limits the amount  of property and auto excise tax to 2 1/2% of
the value  of the  taxed  item.   In  its  first  year  of  implementation it is
expected to reduce  city  and town revenues by anywhere  from $480-$565 mil-
lion.  The state, in  turn,  has increased its  local aid package to accommo-
date approximately  half  of  that  loss.   All  in all,  it appears  that any
new revenue on either  the state or local level  will  be used  to rehire
laid off police and fire personnel and teachers,  as opposed to developing
new programs.    This is  coupled with  the anticipated  cutback  in  various
federal funds,  including the zero level  budgets  for weatherization and the
State Energy Corservation Program.

     The Administration's  proposal  places more  of the  responsibility for
weatherization services on  local agencies and organizations as well as the
private sector.  I  see  a couple of drawbacks to  this  type of plan.   First
of all, utility companies have thus  far  been reluctant  to enter into the


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conservation business.  The Residential Conservation Service, set up through
legislative efforts, begins to get utilities into conservation.  The utili-
ties offer energy  audits,  appraisals,  contractor referrals and  financial
information.   However,  this  program does  not  really benefit those  who
cannot afford to  insulate  and weatherize  their homes,  nor does  it help
low-income people who may not be  as credit worthy as more affluent people.
Other members of  the private sector also  cannot  fill this void.   Energy
Secretary James Edwards would like  to  see the free market forces encourage
conservation by forcing people to  conserve as prices continue to  rise to
the world  level.   This policy can only  serve to the detriment  of low-
inccme people who cannot bear the brunt of these increases.

     In any case,  efforts should be made to  continue weatherization pro-
grams that will help low-inccme people reduce their heating bills  and the
resulting large utility arrearages  and terminations.   The  most  effective
structure for  operating these programs  have been  through the  Community
Action Agencies.  They have been running a variety of different weatheriza-
tion projects for a  number  of years.  They are equipped with the knowledge
of the local community's  people and their  needs;  much more so than state
wide organizations would.   Over the years they have developed the resources
and expertise to  effectively  manage projects  and educate  citizens about
weatherization.  These  programs have  been  operated  in  conjunction with
many other local organizations, which  service a more  specialized clientele
within the community.   Should the CAA's be phased out by the state govern-
ment, other local agencies would  probably be able to pick up the programs.
In some  cases,  the municipalities have also  established  programs of their
own.  Only with close  coordination between  each  party will  a successful
transfer of  responsibilities  occur.   However,  once  again, Proposition  2
1/2 will hinder the  ability  of the municipalities to play  any major role
in weatherization, even if  some  block grant  money filters down  to them.

     The optimal  weatherization  program would  be a  combination  of home
improvements that would include larger investments in insulation, particu-
larly attic  insulation,  and low cost  weatherization.  This  is  irtportant
because in order  to  maximize the  cost-effectiveness  of the  conservation
improvements, both approaches must  be used.  A house that has been insula-
ted but has not had its doors and  windows weatherized, is  still going to
leak and cost  the occupant  money.   Conversely, a home that lacks insula-
tion will still be  inefficient.   Obviously, it is necessary to do at least
the minimal weatherization,   but  a  combination of that  with  some insul-
ation will produce the best  results.   In addition, some programs have also
included tune ups  of inefficient  furnaces.  This is  important because an
inefficient furnace will cost tremendous  amounts of money and waste energy
even if the home is fully insulated.

     To summarize,  I feel  it  is  imperative  that the federal government
continue to play a major  role in  energy conservation programs.  Our agency
has weatherized several thousand homes and  apartments  over the  last few
years, which has helped many low income families meet their utility obliga-
tions.  A cutback  in federal  funds will place  these  programs  in jeopardy
and due  to the fiscal condition  of Massachusetts, it is uncertain as to
whether or not the state  can pick up weatherization projects.   Agencies on

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the community level are best  equipped to operate the program.  I hope that
they will continue to have the opportunity to do so.  Thank you.
HARRY WUERTENBAECHER, JR.
Vice President - Customer Service
Union Electric Company
1901 Gratiot Street
P. 0. Box 149
St. Louis, Missouri  63166

     Union Electric  Company  is an  investor owned  utility which  supplies
electric service  to approximately  700,000  residential  customers in  the
State of Missouri  and adjacent areas in  the States of  Illinois  and  Iowa.
We are submitting  this  testimony  in an effort to communicate our concerns
over past actions of the federal government in the area of energy conserva-
tion.  We hope that future governmental actions  will rescind past programs
which sleet and promote favored sources of energy (Building Energy Perform-
ance Standards) and mandate  utility provided on-site audits  of customers'
premises (Residential and  Commercial  and  Apartment Conservation  Service
Programs).

GENERAL PHILOSOPHY

     We support  the  President's  Program  for  Economic  Recovery  and  the
broad concepts of  reducing growth  in  Federal spending  and  minimizing the
costly burden of regulation on the private sector.

     The involvement of  the  Federal government  in  energy conservation was
an improper response to its previous erroneous policy of fuel price regula-
tion.  The imposition of price controls on natural gas and oil, which regu-
lated the consumer costs of these  fuels  below  their  true  market  value,
which disrupted the  oost-benefit  balance  between energy  use  and  conserva-
tion.  This in turn led our citizens to choose big and powerful automobiles
rather than small  and  efficient ones.   Similarly,  home  buyers chose  addi-
tional square  footage  in lieu of better  insulation and storm  sash  in the
new home market.

     The proper response to the fuel crisis which became evident in 1973-74
should have been to  remove all price controls.  Instead, government  opted
for a  gradual  removal and  imposed  costly  and ineffective  regulations in
energy conservation  and efficiency standards,  all adding  to  regulatory
burdens, more federal involvement ad increased federal budgets.  To
correct the situation we must change our course to that outlined by present
administrative policy.

PAST AND CURRENT NON-MANDATED CONSERVATION ACTIVITIES OF UNION ELECTRIC
COMPANY

     Our efforts on  behalf of  energy  conservation  in residences  began in
1954 and have  not  ceased in the ensuing 27  years.   Our original construc-

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tion and  insulation standards resulted  in at least  70,000 dwelling units
being constructed  with R-24  insulation  in ceilings,  R-15 insulation  in
walls, with dual glazed windows and storm doors throughout.

     In 1977,  Union Electric  began a program whereby we  stimulated the
installation of ceiling  insulation to a level of  R-30 in  existing resi-
dences of our  customers.   This was accomplished through  the existing mar-
keting structure of insulation suppliers and  installers  with the opportu-
nity for our customers to pay for the installation on their monthly elec-
tric service bill   at  prevailing interest  rates.    Insulation contractors
participating in the program made more than 38,000  installations  of this
type in homes  of our customers in the period between January  24,  1977 and
June 30, 1981.

     We support the National  Energy Watch  Program of  the  Edison Electric
Institute and  more than  1,900 of our customers have improved the thermal
performance of their homes and  as a  result have  become members  of this
activity.

     In 1976 Union Electric initiated a marketing  and advertising program
educating our  customers   on the benefits  of proper  maintenance  of  air
conditioners and the value of purchasing new  equipment with higher Energy
Efficiency Ratios.   We are still actively pursuing this program.

     We also are   actively engaged in tests of active and passive  solar
heating systems,  heat  pumps,  solar water heaters,  super  insulated homes,
solar shielding of  homes  and electric vehicles.    All these hold future
promise in the area of energy conservation.

     Our past  and  present programs were developed  on the basis  of their
cost-effectiveness to our customers and represent  a practical approach to
energy conservation  in our area.

FUTURE  CONSERVATION ACTIVITIES OF UNION ELECTRIC  COMPANY WHICH EXEMPLIFY
HOW A PRIVATE FIRM IS ASSUMING ADDITIONAL RESPONSIBILITIES WHICH WILL ALLOW
FEDERAL GOVERNMENT TO WITHDRAW MANDATED UTILITY PROGRAMS

     As part of our July 17, 1981 rate case settlement, the Missouri Public
Service Commission allowed Union Electric Company  to remove the prevailing
market interest rate requirement  from  its insulation  financing program.
We now will  finance the  installation  of R-30 insulation in the  attics  of
our customers  (and allow caulking, weather stripping, side wall insulation,
storm sash and storm doors to be included along with the  ceiling insula-
tion) at an effective  annual  interest rate of 5%.   These thermal improve-
ment items are the most cost-effective conservation measures our customers
can install in their homes.   The below market interest rate  is  a tremen-
dous incentive to  any customer  who lives  in  a poorly insulated home and
views his rising   natural  gas,  propane  or  oil  heating costs as  an ever
increasing financial burden.
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A SUGGESTION FOR LOW INCOME WEATHER!ZATION PROGRAMS

     Subsidizing energy costs supports the  continuing waste of energy.  If
gasoline stations were to provide  certain people with free gasoline, these
people would make no  effort to  drive less  or to drive fuel efficient auto-
mobiles .

     Admittedly, we are in  an era of rapidly  increasing  energy costs, but
this is  little different  from price changes  in  or  the  availability of
other necessities such  as food, clothing and  shelter.  People have always
adopted to  these  changes by using  less or  switching to  other  items or
other methods.  In  fact,  it is important  that people do  this,  otherwise
the supply  segment of the market  receives  false signals and does not posi-
tion itself for the inevitable  future.

     Efficiency in structures and devices can only be improved to a  limited
point.  After  that, the cost of operation must be  manipulated by the  user
through some  form of  limited use.   Subsidies do not limit use but the  lack
of a subsidy does.

     Making structures  energy  efficient  is  a worthwhile and  necessary
goal.  This  is especially  true where  the  disadvantaged  do  not  own the
structure in  which  they live.  But  improved thermal  efficiency  will  only
delay the need to limit use  ... not prevent it.

     The following table  gives a rough  indication  of annual heating  costs
in St. Louis,  Missouri for  a poorly insulated hone  (60  BTU/sq.ft.) and a
well insulated home   (30  BTU/sq.  ft.)  for the past,  present  and  future.
Future costs  are based  upon the  projections  of  Chase  Econometrics, and
Mellon Institute.

                    1970          1980              1990
                 Poor  Good     Poor  Good     Poor    Good

Natural Gas      $155   $  77     $775  $386     $4,400   $2,200
 Furnace
Add-On H.P.      NA    NA        585    293     2,200   1,100
 to N.G.
Electric Heat   NA    NA        445    223     1,180      590
 Pump

                    1970             1980           1990
                Poor    Good    Poor   Good    Poor    Good

 Electric         280    140      840   418    2,200  1,100
  Furnace

      It is obvious  frcm  the  above that  compounded increases  in  energy
 costs soon outpace the excellent effect of thermal improvement.

      Sooner or later  both  the "advantaged"  and "disadvantaged"  will  be
 looking for ways  to cut their  energy  costs,  even though their  structures

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have been  improved  in thermal efficiency.   Dressing for lower inside temp-
erature settings during the winter  (even lower  at night)  and the zoning of
the house  into smaller  comfort zones  will be practiced by most  of  our
population.  We may see  the use of insulation in interior walls and floors
to make these comfort zones more efficient.

     We suggest  a  new  approach to low  income  weatherization containing
the following three linking elements:

     1.  Provide weatherization for the structure.

     2.  Deny  future energy  use  subsidies for the  weatherized structure.

     3.  Teach energy limiting practices to the occupants of the structure.

     We recognize that  a small percentage  of our population  is incapable
of earning enough money  to cover their basic needs  for  food,  clothing and
shelter, and will still require aid through government assistance programs.

WE URGE THE REPEAL  OF ALL FEDERAL PROGRAMS  WHICH  PROMOTE FAVORED SOURCES
OF ENERGY MID MANDATE UTILITY ACTION

REPEAL BUILDING ENERGY PERFORMANCE STANDARDS

     This program  unfairly burdens an electric  heating  system with an
efficiency calculation unrelated to the building and related  to the effi-
ciency of  electrical  generators.   Union Electric Company generates  99% of
its electricity fron burning coal and using water power.   We are construct-
ing a nuclear plant.   Any law or regulation which  unfairly augers against
electric heating forces the use of fuels which are  either in short supply
or the availability of which  is subject to the political whims of foreign
interests.

REPEAL THE  RESIDENTIAL AND  COMMERCIAL AND  APARTMENT CONSERVATION SERVICE
PROGRAMS

     These programs place  Union Electric  into  the  decision-making process
which heretofore was exclusively between our customers and  their selected
contractor.  It  further  forces us to  give our customers  estimates  of
dollar savings due  to  thermal improvements they may make and forces us to
inspect those  installations.   Inspection  of installations  on  the  custo-
mer's side of the meter  has historically been  the  responsibility of local
governmental inspection authorities which are generally immune from respon-
sibility arising from the inspection of a defective product.

     We believe these  programs are  detrimental to our customer relations
and are non-cost-effective.   Money  spent  on audits  achieves  nothing unless
the customer takes   some  conservation  action.   Actions  taken  by  audited
customers do not exceed  those  taken  by  unaudited  customers.  To begin
these programs, and burden our rate payers with  costs related to unjusti-
fied results is a tremendous mistake.
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WE URGE TOE FEDERAL GOVERNMENT TO REDUCE  ITS INVOLVEMENT IN  ENERGY CONSER-
VATION

     Allowing the  free market  to  work  and  giving  our  citizens  correct
price signals  are resulting in  increased energy  conservation.   Citizens
will continue to  respond to these  signals so  long as the government does
not manipulate one side of supply and demand or one  segment of the energy
marketing industry.

     The cost  of studies,  hearings  and  evaluations  are all part of  the
waste in  federal spending  which  our country  can no  longer  afford.   We
question the need  for the Department of  Energy,  the  Federal Trade Commis-
sion and  the  Environmental  Protection  Agency to  each  conduct  hearings
under federal  laws dealing  essentially  with  the  same subject of  energy
conservation.

     Since none  of  the government's  previous  energy conservation programs
can be shown to have  achieved any  significant  results,  little is  gained by
questioning which programs should be  retained or changed.

WE URGE THE FEDERAL GOVERNMENT TO ESTABLISH A LONG-RANGE CONSISTENT ENERGY
POLICY

     Private industry and private investors cannot develop  energy produc-
tion and  delivery systems under  government policies  which vacillate from
one year, or  from one  administration,  to the next.   Above all, we should
set our  nation on a  long-range consistent energy  course.  Development of
coal mines and  construction of coal or  nuclear power plants require five
to fifteen years  from planning to production.   If the government  is free
to change the  rules  and place such  energy investments  in  jeopardy through
changing policies,  private  investors  cannot  undertake  necessary  energy
projects which are so vital  to our national interest.

     We thank  the Environmental  Protection  Agency  for  this  opportunity
to express  our views regarding energy  conservation and  energy policy in
general.
                                     456     *U.S. GOVERNMENT PRINTING OFFICE: 1982/5S9-092/3398

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