The American Public Power Association on June 2 filed comments in response to a Department of Energy Request for Information aimed at assisting the DOE in identifying potential modifications to its procedures, interpretations, and policies for considering new or revised energy conservation standards and test procedures for consumer products and certain commercial and industrial equipment.
In its comments, APPA said that DOE should make sure that revised standards do not exacerbate supply chain challenges nor negatively impact consumer choice among higher-efficiency products.
APPA noted by way of example that a proposed 2022 rule regarding energy efficiency standards for distribution transformers would have potentially eliminated over 95 percent of products from the marketplace and thus have made already high lead times for distribution transformers even worse.
APPA also encouraged DOE to ensure that it accounted properly for stakeholder input during the review process and to consider broader system impacts when evaluating specific products.
