Comment Letter Calling for Rescission of DOE Categorical Exclusion Rule for LNG Exports
In response to the Department of Energy’s recent request for information on its categorical exclusions, we submitted a comment letter recommending that the Department rescind its 2020 regulation establishing categorical exclusion B5.7 for discretionary authorizations to export liquefied natural gas. As our comment letter explains, long-term expansion of export capacity may lock in fossil-fuel usage over the long term and thereby impede global decarbonization efforts. Yet when promulgating its categorical exclusion rule, the Department erroneously argued that indirect climate effects are not relevant to its assessment of applications for export authorization, and based its sweeping categorical exclusion on that improper legal conclusion. Our comment letter provides a proper understanding of the Department’s broad authority, which compels the agency to robustly consider impacts on climate change as part of its authorization process.
Comments to DOE on Grid Resilience and Innovation Partnerships Program
We submitted comments urging DOE to clarify how it will distribute Infrastructure Investment and Jobs Act (IIJA) project funding and to enhance program transparency. We encourage DOE to more specifically detail how it will evaluate applications and to offer a more precise definition of what "community benefits" it hopes to achieve. We also suggest that DOE require project applicants to submit cost-benefit analyses so that the agency can better compare projects when making funding decisions.
Joint SC-GHG Comments on Proposed DOE Standards for Room Air Conditioners and Pool Heaters
Together with partner groups, we submitted joint comments to the Department of Energy (DOE) on its proposed rule to strengthen energy conservation standards for room air conditioners and pool heaters. Our comments applaud the agency for appropriately applying the social cost of greenhouse gases to estimate the climate benefits of the proposed standards, even though the standards would be cost-benefit justified without considering any climate benefits. We also encourage DOE to expand upon its rationale for adopting a global damages valuation and for the range of discount rates it applies to climate effects.
Comments to DOE on Manufactured Housing Energy Conservation Standards
Policy Integrity submitted joint comments to the Department of Energy’s Supplemental Notice of Proposed Rulemaking for its Manufactured Housing Energy Conservation Standards. Our comments recommend that DOE provide additional rationale for applying the Working Group’s numbers, including by explaining why it is appropriate to focus on a global perspective of climate damages and exclude a 7% discount rate from its analysis of these damages.
Comments to DOE on Conservation Standards for Furnaces and Water Heaters
In August 2021, DOE proposed to return to holding less-efficient gas furnaces to the same standard as other gas furnaces. We filed comments supporting the proposal, while cautioning DOE against making unnecessary statements that might hinder its ability in the future to set standards that would encourage consumers to switch from gas-fired appliances to electric appliances.
Comments to DOE on Process Rule for New Energy Conservation Standards
The Department of Energy proposed revisions to its procedures and policies for considering new energy conservation standards across a range of consumer products and commercial equipment. We submitted comments offering support for the proposed revisions and making additional recommendations. Our recommendations include weighing a full range of environmental and consumer effects, incorporating the consideration of distributional justice, and reviewing the selection of discount rates.
Comments to DOE on Energy Conservation Standards for General Service Lamps
The Department of Energy (DOE) requested input on how it should conduct analysis of the efficiency, economic impact, and emissions of general service fluorescent lamps and incandescent reflector lamps. We submitted comments encouraging DOE to monetize the full benefits of emissions reductions using the social cost of greenhouse gases.
Comments to DOE on Energy Conservation Standards for Refrigerators and Freezers
The Department of Energy requested input on its analysis of energy conservation standards for consumer refrigerators, refrigerator-freezers, and freezers. We submitted comments encouraging DOE to, as it has in the past, monetize the full climate benefits of greenhouse gas emission reductions.
Comments to DOE on Energy Conservation Standards for Fluorescent Lamps
The Department of Energy proposed to not increase the efficiency of fluorescent lamp ballasts. We submitted comments noting that DOE fails to analyze the forgone emissions reductions of its proposed determination.
Comments to DOE on Grid Resilience
The Department of Energy requested input on how it can enhance the resilience of electric infrastructure systems against severe weather events. We submitted comments, attaching our report on grid resilience and highlighting key takeways that may support DOE efforts to improve the power system.
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