DOE incorporates NAFEM feedback re: comparative analysis

In a recently released final rule that outlines the process for determining whether a new or proposed energy-efficiency standard is economically justified, DOE has revised certain policies for implementing the Energy Policy and Conservation Act (EPCA), and the results are consistent with NAFEM’s long-standing recommendations. Effective Oct. 19, DOE will only draft new or amended standards that result in significant energy conservation that are technologically feasible and cost effective. In March, NAFEM reiterated this point in comments submitted to DOE, which supported the agency’s proposal that it use a comparative analysis of the relative costs and benefits of different technologies before establishing or amending a standard.

NAFEM has long been an advocate for revising DOE’s procedures related to energy-efficiency rulemaking and related waiver requests. DOE recognized NAFEM’s advocacy in several of its proposed and final rulemakings. “NAFEM believes that the improved procedures are fairer, recognize the complexities of constantly pursuing energy-efficiency technologies, and provide a balance that new standards are not always economically achievable for the industry,” said Jeff Longsworth, NAFEM legal counsel, Barnes & Thornburg. “This is a necessary and welcome maturation of the EPCA regulatory process.”

“It’s good to see our multi-year effort pay off with these improvements to the Process Rule. DOE agreeing with NAFEM that using a comparative approach is a positive step toward evaluating the total costs and benefits of energy-efficient equipment,” said NAFEM President Rob Connelly, CFSP, CEO, Henny Penny Corporation, Eaton, Ohio.