DOE’s Process Rule: More Harm Than Good

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By Lauren Urbanek, Natural Resources Defense Council

It will soon be more difficult and cumbersome to set strong standards for the appliances and electronics in our homes and businesses, if the Trump administration’s Department of Energy has its way. At issue is a change in the process to set standards, recently proposed by the U.S. Department of Energy (DOE). By erecting unnecessary hurdles for efficiency standards for products we use every day like clothes dryers, room air conditioners, and refrigerators, DOE’s revised process will lead to more energy waste and pollution.

And, in fact, had the “Process Rule,” which is the subject of a DOE hearing this week, been in effect over the past decade, we would not have seen energy-saving improvements to at least 16 products, leaving homes and businesses with higher electric bills.

The process rule change is part of a two-pronged attack on energy efficiency by the Trump administration. In addition to making it more difficult to put new or updated standards in place, DOE is attempting to roll back light bulb energy efficiency standards set for 2020 by excluding certain types of bulbs, which would increase consumer utility bills by $12 billion—$100 per U.S. household—every year. It will also lead to a lot more pollution from the extra 25 power plants’ worth of electricity that will be needed.

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Meanwhile, DOE has also failed to issue even one new or updated energy efficiency standard over the past two years, as my colleague Kit Kennedy recently noted in testimony before Congress. The agency’s illegal delays and inaction hurt the nation’s energy efficiency standards program just when we need it most to urgently address the emissions that cause climate change. They also threaten to undercut bipartisan-led efficiency standards progress that has delivered $2 trillion in energy savings over the past three decades while boosting American competitiveness by collectively driving manufacturers to make better products.

Rather than spending its time and effort on setting new standards, as it is statutorily obligated to do, DOE has proposed a variety of unnecessary changes to the process rule, which is what DOE uses to create new energy efficiency standards for appliances, electronics, and equipment. Some of the changes, such as adding additional reviews before initiating a standard and allowing industry to develop its own efficiency tests, are transparent efforts to slow down and weaken a regulatory process that has been working smoothly for years.

It’s only upon closer inspection of DOE’s proposal that the potentially devastating impact of this policy becomes clear. It’s likely that the largest efficiency standard ever set, for commercial rooftop air conditioners, heat pumps, and warm air furnaces, would never have been set if the proposed changes were in place. That’s because the updated process rule would defer to efficiency levels for equipment set by the  American Society of Heating, Refrigerating and Air-Conditioning Engineers’ (ASHRAE) Standard 90.1, and not require (or allow) higher efficiency levels in most cases. The fact that DOE could go further than the ASHRAE-set levels enabled the federal agency to set the standard for rooftop units, which will save 15 quadrillion BTUs (quads) of energy: nearly equivalent to the amount of energy in all of the coal burned to generate electricity in the United States in a year.

The proposal also requires a “significant energy savings threshold” that is arbitrary and will be very damaging. The agency would require an efficiency improvement of 0.5 quads, or 10 percent, over 30 years for any new or updated standard.

Such an subjective requirement could have derailed more than 4 quadrillion BTUs (quads) of energy savings from previous standards, which is equivalent to the annual energy use of 44 million homes. Much of those benefits come from standards that fall below both thresholds for “significant energy savings,” yet are delivering precisely that for consumers.

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Take standards for clothes dryers and room air conditioners finalized in 2011, which together are expected to save almost $4.5 billion over about three decades while avoiding 36 million metric tons of carbon dioxide (CO2)—approximately equivalent to the emissions from 7 million cars in a year.

DOE’s ability to set standards like these without the constraint of an artificial requirement of “significance” is one reason why it has long delivered steady, measured progress on energy efficiency. This product-by-product progress, in the aggregate, is not only significant but vital in curbing carbon emissions and saving consumers money. In testimony at DOE Thursday, I’ll urge the agency not to hobble this program with needless rules and nonsensical requirements. Even seemingly modest percentage increases in efficiency deliver huge benefits at scale, given that the national appliance standards cover more than 60 categories of appliances and equipment, many of which can remain in use for several years. With each delayed or denied standard, the United States locks in decades of energy waste and lost savings for consumers.

DOE

What we could have missed

Here’s a full list of the standards that might have been rejected under DOE’s proposed savings thresholds:

Automatic commercial ice makers: Beginning in 2018, more efficient ice makers common in restaurants and hotels began saving 19 billion kilowatt-hours over three decades, equivalent to the annual energy use of 1.7 million American homes.

Residential boilers: Minimum efficiency levels for the units that provide heat and hot water for homes were raised in 2016.

Ceiling fan light kits: Some 80 million households operate one of these fans. Standards announced in 2016 will save consumers $12 billion over three decades.

Clothes dryersStandards finalized in 2011 require dryers to use 5 percent less energy. Even when the standards themselves are modest, they establish a baseline for necessary improvements over the years, since DOE is required periodically to revisit them.

Commercial clothes washers: Though this flawed standard left potential energy savings from top-loading machines on the table, it still improved the water and energy efficiency of the large washers that dominate laundromats and apartment building laundry rooms, and it sets the stage for further needed savings.

Commercial and industrial pumps: Rules finalized at the end of 2015 for these pumps, often used to circulate clean water in large buildings, are projected to save more than $1 billion and avoid 17 million metric tons of carbon pollution over the next 30 years.

Commercial warm air furnaces: Standards for these furnaces, common in small- to medium-size commercial buildings, were updated in 2015 and will help avoid 12 million metric tons of COemissions through 2053.

Dehumidifiers: Standards covering dehumidifiers, established in 2016, go into effect this year and will save the average homeowner between $100 and $140 in energy costs over the life of the product.

Direct heating equipment: Finalized in 2010 and effective as of 2013, these standards ensure a baseline for annual fuel utilization efficiency in floor heaters, gas wall heaters, and room heaters.

Dishwashers: The 2012 standards require units to use about 14 percent less energy and 23 percent less water by 2013.

Metal halide lamps: The dome-shaped lights you see in big-box stores, parking lots, and other large spaces are more efficient thanks to 2014 standards that will save about $1.1 billion by 2046.

Pool heaters: Standards that took effect in 2013 require a minimum thermal efficiency of 82 percent.

Pre-rinse spray valves: These hand-held sprayers, often used in restaurants and commercial kitchens, will cost about $80 less to operate annually starting this year, thanks to standards passed in 2016.

Ranges and ovens: In 2009, DOE prohibited wasteful standing pilot lights on gas-powered ranges and ovens. These appliances still lack energy efficiency performance standards, which were proposed in 2015 and have languished under the current administration.

Room air conditioners: The air conditioning units placed in windows or through walls – now use 10 to 15 percent less energy thanks to standards that took effect in 2014, adding up to $1.5 billion in net energy bill savings.

Single package vertical air conditioners and heat pumps: These units, typically installed externally on modular classrooms and similar buildings, are set to become more efficient this year when standards established in 2015 take effect.

Originally posted here.

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