Mr. John Cymbalsky
DOE engaged with the National Academy of Sciences to review DOE’s analytical methodologies to ascertain whether modifications are needed to improve the Department’s analyses. That review process is still ongoing. (86 FR 35677, and 86 FR 70924).
Now that the Committee’s report is publicly available, we request that it be included in the record of EERE–2021–BT–STD–0003 (RIN 1904–AF13), “Energy Conservation Program for Appliance Standards: Procedures, Interpretations, and Policies for Consideration in New or Revised Energy Conservation Standards and Test Procedures for Consumer Products and Commercial/Industrial Equipment.”
While the issues addressed in the report will be relevant for multiple future rulemakings, they are most applicable to the Department’s cross-cutting process rule. Therefore, we also request that DOE reopen the comment period for the second rule (initially proposed in July 2021) in light of the new information provided by the Committee’s analysis, findings, and recommendations.
LINDA COHEN, University of California, Irvine, Chair
CHARLES CULP, Texas A&M University
SUSAN DUDLEY, George Washington University
CLARK GELLINGS, NAE,3 Electric Power Research Institute (Ret)
W. MICHAEL HANEMANN, NAS,4 Arizona State University
DALIA PATINO-ECHEVERRI, Duke University
ANAND PATWARDHAN, University of Maryland
JAMES SALLEE, University of California, Berkeley
1 https://www.nap.edu/catalog/25992/review-of-methods-used-by-the-us-department-of-energy-in-setting- appliance-and-equipment-standards
2 We write in our capacities as individual peer reviewers who comprise the committee convened by the National Academies. This letter is not intended as an official NAS communication.
3 Member, National Academy of Engineering.
4 Member, National Academy of Sciences.