Docket ID No. EERE-2022-BT-OT-0004
Introduction
DOE requests comment on the assumptions, models, and methodologies it uses in setting energy conservation standards for products and equipment covered under EPCA. The RFI is organized around the findings of the National Academies of Sciences, Engineering, and Medicine (NASEM) Committee on Review of Methods for Setting Building and Equipment Performance Standards, (NASEM 2021), as well as comments received on earlier RFIs. I served on the NASEM committee and coauthored that report. I have published widely on regulatory analysis and regulatory process, including on energy efficiency standards, and I have worked as an economist in several federal agencies, including in the Office of Information and Regulatory Affairs, an office I headed from 2007-2009. I am also a past president and fellow of the Society for Benefit-Cost Analysis.
I fully support DOE’s effort to improve the analysis supporting its efficiency standards. The RFI is generally asking the right questions to refocus DOE’s analysis on the social welfare impacts of its standards and the NASEM report offers invaluable recommendations that DOE should pursue. This comment 1) briefly reviews DOE’s statutory authority in relation to longstanding regulatory impact analysis guidelines, 2) explores the key elements DOE’s analyses should consider in revising energy efficiency standards, 3) identifies current practices toward which DOE should contribute fewer resources, and 4) suggests analytical practices in which DOE should invest more resources to improve its understanding of social welfare impacts.