As we move towards beneficial electrification (BEL) implementation, energy efficiency standards for appliances and buildings are clearly needed. Yet with COVID and other factors, the status of potential legislation has taken a backseat with an indeterminate timeline.
This conundrum also highlights the challenges of incorporating so many different inputs from legislators, lobbyists, and others. The U.S. Department of Energy oversees nearly 100 appliance category efficiency standards. These standards are usually promoted under products carrying the Energy Star label. Every six years, DOE is mandated to review specific appliance efficiency standards, and obviously, many deadlines have been missed due to the above factors and more. Dozens of standards for everything from clothes dryers to freezers to gas furnaces were overdue at the end of 2021, with dozens more reviews to be done before the end of 2024, at least some of which will most likely not be completed by the designated times.
Like BEL, which carries the requirements of improving one of four things without negatively impacting the other three (cost reduction, product improvement, improvement in grid reliability/instability and positive or neutral environmental impact), DOE efficiency standards must be economically justified, lead to significant energy conservation and be technically feasible. The recent Supreme Court ruling effectively removed some of EPA’s critical mandates, and enforcement of power plant greenhouse gas reductions could potentially alter just how much control EPA and DOE have over setting energy efficiency standards for appliances going forward.
This can be challenging in an era of potential energy price volatility (particularly natural gas), which could heavily favor implementation at one level but then not at another.
Another potential drawback is that these standards may limit the buying choices for economically disadvantaged Americans in the interest of prioritizing saving energy.
Two examples below highlight how DOE operates when business as usual does not always go the way it should.
One of the most prominent is the DOE LED Backstop requirement for General Service Lamps (GSLs) that was present in the Energy Policy and Conservation Act, as amended. Because DOE was unable to complete a rulemaking regarding GSLs in accordance with the specified statutory criteria, the minimum efficiency standard for GSLs going forward will be 45 lumens/watt. This final rule amends the previous determination in 2019 that the backstop requirement was indeed not triggered. This ruling assured that when no action had been taken, there was at least a minimum standard that would apply to all devices going forward.
Another slightly more confusing set of rules has been clarified for residential dishwashers with a normal cycle of 60 minutes or less, top-loading residential clothes washers and certain classes of consumer clothes dryers with a cycle time of fewer than 30 minutes and front-loading residential clothes washers with a cycle time of fewer than 45 minutes (short-cycle product classes).
An amended set of conservation standards was announced, but then it was found that this was done without meeting relevant statutory criteria, and now has been revoked, reinstating the prior classes and standards for these products. Confusing, to say the least, but a testament to the difficulty of setting these standards with the myriad interests and constantly shifting priorities of the Department, coupled with currently successful efforts to impede the shift away from fossil fuels to renewable energy in energy production.
As you can see, energy efficiency standards are quite challenging to get everyone to agree on, but we all agree that efficiency and sustainability are two things we need to move forward.