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Comments to DOE on Energy Conservation Standards for Direct Heating Equipment

The Department of Energy (DOE) recently issued a request for information on the energy conservation standards for direct heating equipment. We submitted comments that advise the Department to monetize climate benefits from greenhouse gas emissions reductions and discuss market-based approaches to energy conservation standards.

DOE is seeking input on conducting national impact analysis and correcting market failures, among other elements, before it decides to propose energy conservation standards for direct heating equipment. Our comments recommend that DOE continue, as it has in numerous past energy conservation standard rulemakings, monetizing the full climate benefits of emissions reductions associated with energy savings. Specifically, the Department should use the best estimates of the social costs of greenhouse gases from the Interagency Working Group and it should use global estimates in selecting conservation standards, rather than focusing on domestic-only numbers. We also resubmitted our comments on adding market-based approaches, where we discuss how these approaches can be implemented to effectively lower compliance costs, incentivize innovation, and achieve energy conservation policy objectives.