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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.
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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.
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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.
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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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Comments to DOE on Energy Conservation Standards for Air Conditioners
The Department of Energy requested input on impact and emissions analysis for upcoming energy conservation standards. We submitted comments encouraging DOE to continue to monetize the full climate benefits of greenhouse gas emissions reductions.
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Comments to DOE on Process Rule for Prescribing Energy Conservation Standards
The Department of Energy (DOE) proposed changes to the Process Rule for prescribing energy conservation standards. We submitted comments and additional comments explaining how certain proposed changes violate both DOE's statutory mandate and the principles of rational rulemaking. We emphasize that the significance of energy savings must be weighed by considering all important costs and benefits.
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