The Council approved comments on the Department of Energy's proposal for revisions to the federal energy efficiency standards processes at its February meeting.
The DOE has released two requests for information, one on its energy efficiency standards process and one on its design of the federal standards program.
Federal standards have been an important part of the Northwest's success in achieving energy efficiency, which is now the region's second largest resource after hydropower. Federal appliance standards work well in tandem with utility efficiency programs in achieving regional goals. In the past, the Council has been an active participant in the standards-setting process, and its comments reflect a deep base of knowledge and experience in implementing efficiency savings.
The Council's overarching comment to the process rule request for information is that the DOE's work in developing, adopting, and implementing energy efficiency standards is already a success and should not be taken for granted. The comments urge the DOE to be careful in changing its procedures so that value is not lost. That said, the Council also supports, in concept, many of the ideas raised in the rulemaking, and its comments on specific points are summarized in the meeting memo.
The second request for information concerns the idea of shifting toward market-based mechanisms for standards, which the Council advises could be impractical:
"Shifting to a market-based approach represents a significant change to a process that is working quite well. Our perception is that mechanisms like fleet average efficiency and trading mechanisms among regulated products and between product classes are not practical, will be difficult to design and implement, and are not likely to be as effective as the current approach in securing cost-effective savings."
Market-based approaches look at the average efficiency of all appliances entering the market, rather than regulating each appliance.
The Council recommends proceeding by conducting small-scale pilot efforts and rigorously evaluating the results before implementing alternatives.
More on this topic:
Changes to the Standards Program: More harm than good?
As Federal Efforts Lag, States Are Picking Up the Slack on Appliance Standards