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Comments to DOE on Manufactured Housing Energy Conservation Standards

Policy Integrity submitted joint comments to the Department of Energy’s Office of Energy Efficiency and Renewable Energy  on a Supplemental Notice of Proposed Rulemaking for its Manufactured Housing Energy Conservation Standards. In the Supplemental Proposal, DOE applied the social cost of greenhouse gases to monetize the climate benefits of the proposed standards and then cited our 2016 joint comments in explaining why using the Interagency Working Group’s estimates was appropriate. Our new 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. Our comments also rebutted common criticisms of the Working Group’s social cost estimates.