Policy Integrity submitted a comment letter on the Department of Energy’s (DOE) request for information on its methodology for assessing the affordability and cost-effectiveness of building energy codes, which governs the analysis DOE uses to evaluate updates to the national model codes and to set energy standards for federal buildings. The comment letter addresses three of DOE’s questions: how the agency plans to incorporate full fuel cycle (FFC) energy into its analysis, which discount rates it should apply, and how long an evaluation period it should use.
The letter recommends that DOE explain whether and how the FFC energy metric used in the appliance context requires modification for the building context. It also recommends that DOE calculate locationally and temporally specific FFC metrics and model multiple grid-mix scenarios to account for the underestimation of renewable generation in the projections underlying DOE’s FFC multipliers. It further recommends that DOE eliminate the 3% floor on discount rates in federal building analysis because the floor is based on outdated interest-rate data, and that DOE distinguish between private and social discount rates. Finally, the letter recommends longer evaluation periods for building energy code analysis, as the current 30- and 40-year horizons understate efficiency benefits that continue accruing to future occupants past these time horizons.