Policy Integrity has submitted comments to the Department of Energy, encouraging DOE to improve its economic justification for a proposed energy efficiency determination. DOE has determined that energy conservation standards for mercury vapor and metal halide high-intensity discharge lamps are not “economically justified” as required by statute, even though such standards could save up to 1.6 quadrillion British thermal units of energy. By reducing electricity demand at and pollution from fossil fuel-fired power plants, such energy savings would generate environmental and health benefits. However, at no point in DOE’s documentation does the agency discuss environmental and health benefits as part of its analysis of “economic justification” and “national impact.”
The failure to consider these benefits is inconsistent with the agency’s practice in prior energy efficiency rulemakings. Given that the agency has a readily available methodology for quantifying and monetizing some of the key environmental and health benefits generated by energy savings, we suggest that the final determination should include such quantified benefits, whether or not they would change DOE’s final determination on whether the standards are cost-benefit justified.
Our full comments are available here.