NAFEM offers ideas to DOE for improving energy conservation standards program

As the Department of Energy (DOE) continues to evaluate how to best reduce companies’ costs for complying with energy conservation standards, while also increasing consumers’ choices, NAFEM provided comments outlining the industry’s perspective. NAFEM reiterated earlier recommendations and re-addressed previous concerns about the ineffective practice of establishing energy-efficiency standards based on theoretical models, as well as ongoing challenges with the DOE’s waiver process. NAFEM also again asserted that DOE can gain significant efficiencies by better integrating its standards with the ENERGY STAR program.

NAFEM also provided further insights into potential market-based approaches like the auto industry’s café standards that specify average fuel efficiencies across a manufacturer’s entire portfolio. NAFEM explained that a shift to this approach would be extremely problematic for the industry given the high rate of product customization. Finally, NAFEM called for broad stakeholder engagement in structuring any future program.

“Our thanks to all members who provided input that helped develop NAFEM’s comments to DOE,” said Jeff Longsworth, from NAFEM’s legal firm Barnes & Thornburg. “Our next step is to secure an in-person meeting with DOE to continue our ongoing dialogue, making sure they fully understand the industry’s perspective.”