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Comments on Proposed Process Changes for Setting Energy Conservation Standards

May 6, 2019

The Department of Energy (DOE) recently proposed changes to its process for prescribing energy conservation standards for consumer products and commercial/industrial equipment. We submitted comments explaining how DOE’s proposed energy savings thresholds and consumer test are unjustified and will reduce important consumer and environmental benefits.

In its changes, the Department attempts to draw lines that classify what energy savings are significant enough to be implemented. Setting such thresholds makes no economic sense, ultimately preventing cost-savings for consumers and benefits to the environment. The proposed process also includes a new “Rational Consumer” test, which is meant to account for consumer preferences in determining whether a standard is justified. DOE, however, does not provide details on the economic theory behind the approach or on how it would define a rational consumer. Additionally, our comments discuss the Social Cost of Greenhouse Gases, and we encourage DOE to continue monetizing the cost of carbon pollution using the federal Interagency Working Group’s 2016 estimates.

Filed under Climate Change and Energy Policy, Public Comments, Jobs and Regulation