Download this Public Interest Comment (PDF)
Introduction
We served as members of the National Academy of Sciences Committee on Review of Methods for Setting Building and Equipment Performance Standards, and offer these comments based on the peer review we conducted between the fall of 2019 and spring of 2021. The Committee’s Consensus Report, which we are placing on the docket, recommends that by organizing its analysis of new and amended standards according to the longstanding Regulatory Impact Analysis (RIA) framework, DOE could better examine and present the social welfare implications of its rules. The Report also offers specific recommendations for presenting and addressing uncertainty and variability in ex-ante estimates; for quantifying different impacts; and for gathering data ex-post to improve future analyses. It encourages DOE to consider the role of standards in a changing environment and to avoid methods or standards that would impede innovation that could further DOE’s statutory goals.
Read our full Public Interest Comment and Consensus Report.
Co-Authors:
-
Linda Cohen, University of California, Irvine, Chair
-
Charles Culp, Texas A&M University
-
Susan Dudley, The George Washington University
-
Clark Gellings, Electric Power Research Institute
-
W. Michael Hanemann, Arizona State University
-
Dalia Patino-Echeverri, Duke University
-
Anand Patwardhan, University of Maryland
-
James Sallee, University of California, Berkeley
The National Academies of Sciences, Engineering, and Medicine provide independent, objective analysis and advice to the nation and conduct other activities to solve complex problems and inform public policy decisions. The National Academies also encourage education and research, recognize outstanding contributions to knowledge, and increase public understanding in matters of science, engineering, and medicine.
The National Academies appointed the Committee on Review of Methods for Setting Building and Equipment Performance Standards to peer review the analytical methods employed by the U.S. Department of Energy in setting “standards regulations” for the performance of buildings and associated equipment and products.