On August 18, the U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy published in the Federal Register a Statement of Policy that it will use full-fuel cycle measures of energy use and emissions when evaluating energy conservation standards, and will work with the Federal Trade Commission to made readily available to customers information on full-fuel-cycle energy use and emissions to enable customers to make cross-class comparisons of products. See Energy Conservation Program for Consumer Products and Certain Commercial and Industrial Equipment; Statement of Policy for Adopting Full-Fuel-Cycle Analyses Into Energy Conservation Standards Programs, 76 Fed. Reg. 51,281 (Aug. 18, 2011). AGA believes that the use of full-fuel-cycle metrics will enable a more comprehensive analysis of the total energy and emissions impacts of minimum efficiency standards for appliances, and that making such information public will help customers better understand the energy and environmental impacts of their appliance choices. AGA commends DOE for taking this action and believes that the use of full-fuel-cycle metrics will enable a more comprehensive analysis of the total energy and emissions impacts of minimum efficiency standards for appliances, and that making such information public will help customers better understand the energy and environmental impacts of their appliance choices.
By way of background, DOE is required by the Energy Policy and Conservation Act to set conservation standards for specific products and equipment based on energy consumption at the point of use. DOE uses energy measures in performing a national impact analysis and an environmental assessment to estimate the total projected amount of energy savings and emissions likely to result from the imposition of a particular conservation standard. A full-fuel-cycle energy measure would include not only the energy consumed by the appliance but also the energy losses associated with generation, transmission, and distribution of electricity, and the energy consumed in the extracting, processing, and transporting or distributing of primary fuels. DOE must adopt the energy conservation standard that it determines achieves the maximum energy efficiency improvement that is technologically feasible and economically justified. DOE concluded that it will use the Greenhouse Gas, Regulated Emissions, and Energy Use in Transportation (GREET) model to convert energy estimates to their full-fuel-cycle equivalent values.
In its Statement of Policy, DOE stated that it will include in the national impact analysis and environmental assessments estimates of energy use and emissions based on full-fuel-cycle measures. Although DOE did not agree to make side-by-side comparisons of calculated energy savings on a full-fuel-cycle basis for appliances where there is a choice of fuels, DOE did observe that the use of full-fuel-cycle measures would provide an indicator of the impacts of possible fuel switching on total energy savings and emissions. DOE concluded that while it already accounts for potential impacts of fuel switching in its analysis, it will make the methodologies and result of fuel switching more explicit in all rulemakings in which fuel switching may occur.
DOE added that while energy conservation standards should continue to be based in large part on the costs and savings that users experience, consumers should be given ready access to information on the energy resource and environmental impacts of their appliance choices. DOE explained that making such information available in a manner that would enable consumers to make cross-fuel and cross-product comparisons of comparable products could provide consumers with significant new information. Accordingly, DOE will make the full-fuel-cycle energy and emission factors that it generates in its rulemakings available to the FTC and will work collaboratively with the FTC to determine if changes to the Energy Guide labels will benefit consumers.