NAFEM recommends energy conservation standards program improvements

Late this month, NAFEM submitted comments in response to DOE’s request for information to inform its Energy Conservation Standards Program Design. DOE is looking at changes, or “flexibilities,” to the program that could include market-based approaches, “feebate” programs, or other ways to reduce compliance costs and/or increase consumer choices. In its comments, NAFEM pointed out that DOE must first better understand the market forces and challenges with existing energy-efficiency standards, which NAFEM is willing to help explain. Armed with this understanding, NAFEM suggested that DOE look for ways to better integrate energy-efficiency standards and the successful ENERGY STAR program, to eliminate duplication and inconsistent standards.

NAFEM also explained that market-based programs like the auto industry’s café standards that specify average fuel efficiencies across a manufacturers’ portfolio will be a challenge to implement in the foodservice industry because operator needs and specifications are so diverse. Additionally, 60 percent of NAFEM member companies are small businesses with annual revenues of $5 – $10 million. Many may not offer sufficient product classes to meet production-weighted averages. Before proceeding with a plan, NAFEM encouraged DOE to embrace a process that includes broad stakeholder engagement and a collaborative dialogue.

NAFEM Comments: filed March 26, 2018