NAFEM comments to DOE on setting energy-savings standards

At the same time it issued the updated Process Rule, DOE also issued a Supplemental Notice of Proposed Rulemaking seeking input on how the agency determines whether new energy-saving standards are needed. NAFEM has long recommended that DOE follow Energy Policy and Conservation Act (EPCA) requirements that a new or amended standard is needed only if it results in significant energy conservation that is technologically feasible and cost effective.

DOE sought input on proposed changes that would require the agency to conduct a comparative analysis of the costs and benefits of all proposed alternative energy-conservation standards before establishing or amending a standard. This approach would help DOE determine if an alternative standard is economically justified. NAFEM agrees with this approach, as reflected in comments submitted March 16.