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Comments to DOE on Energy Conservation Analysis for Air Conditioners

The Department of Energy (DOE) requested input on the analytical framework, models, and tools that it is using to evaluate potential standards for room air conditioners. In the technical support document, DOE departs from recent practice by proposing to focus on the domestic-only “interim” social cost of greenhouse gases estimates. We submitted joint comments recommending that DOE should, as it has in the past, continue to monetize the full climate benefits of greenhouse gas emissions reductions, using the best available estimates, which were derived by the Interagency Working Group on the Social Cost of Greenhouse Gases.