Comments to DOE on Energy Conservation Standards for Small Motors
The Department of Energy called for input on developing and analyzing energy conservation standards for small electric motors. We submitted comments encouraging DOE to account for the monetized climate benefits of greenhouse gas emissions using social cost of carbon estimates.
DOE asked for information on kinds of analysis it can undertake to identify a maximum economically-justified efficiency level, including national impact analysis and emissions analysis. We pointed to past DOE energy conservation programs that have used social cost of carbon (SCC) estimates as a primary consideration in selecting the standards. Our comments recommend the Department continue applying the federal Interagency Working Group’s SCC estimates, which reflect the best available data and methodologies. The Department should not rely on any “interim” values that have been developed recently by two government agencies. They ignore global climate impacts and use discount rate assumptions that are inconsistent with accepted economic literature.