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Comments to DOE on Proposed Efficiency Standards for Fans and Blowers

In January, the Department of Energy proposed to strengthen its energy efficiency standards for fans and blowers, which would save consumers in energy costs and reduce pollution that harms public health and exacerbates climate change. Our comment offered several suggestions to improve the rule and accompanying analysis. Specifically, we suggested that DOE:

  • Increase the efficiency level for individual equipment classes to the maximum efficiency improvements that are technologically feasible and economically justified. In particular, we noted that more ambitious standards radial housed fans would yield substantial benefits at relatively modest costs. 
  • Monetize climate benefits using updated damage values from the Environmental Protection Agency (EPA). EPA’s climate-damage values, published in 2023, are the best estimates available and respond to several limitations in the Interagency Working Group’s prior estimates that DOE flags in the Proposed Rule. 
  • Discount all regulatory impacts using the 2% discount rate from the updated Circular A-4, rather than the 3% and 7% rates from the former version.