In May 15 comments, three utility trade associations, including the American Public Power Association, offer recommendations to the Department of Energy regarding its prioritization of new or updated energy conservation standards and test procedures for appliances and equipment.
The groups, which also include the Edison Electric Institute and the National Rural Electric Cooperative Association, responded to the DOE’s Feb. 14, final rule, “Procedures for Use in New or Revised Energy Conservation Standards and Test Procedures for Consumer Products and Commercial/Industrial Equipment.”
The groups recommended that DOE provide a list of the estimated national savings based on the annual site energy to allow stakeholders to review the DOE’s preliminary estimates and compare them with other studies or other technology and market data. It would also allow parties to see which appliances would be able to meet the thresholds established in the Feb. 14 rule.
The groups in their comments also recommend that the DOE analyze the annual estimated site energy savings along with the estimated savings over 10-, 20-, and 30-year periods, to ensure more thorough analysis by all stakeholders.
On a related issue, the groups recommend that the DOE show the savings in typical units related to the product energy source and then convert these savings to site British thermal units (BTUs) using technical conversion factors from kilowatt hours or therms or gallons or other typical energy units associated with the appliance.
Doing so would allow stakeholders to perform “apples to apples” comparisons for products that use different types of energy inputs, the groups wrote.
The groups also recommend that the DOE take into account how many times a product has been through the efficiency review process in order to prioritize rulemakings that would get more “bang for the buck.” Products that have been through the review process multiple times are subject to rising efficiency levels that can push them closer to technological efficiency limits. Under 2010 rules, for instance, small electric motors showed maximum potential energy savings between 12.6% and 32.1%. Under proposed 2020 standards, the maximum energy savings range from 5.1% to 8.6%.
In their final recommendation, the groups recommend that the DOE consider the benefits of grid-interactive “smart” appliances that can save money and provide benefits to the grid even though they might not necessarily correlate to device level electricity consumption reductions.
Smart appliances can shed load, shift loads, and modulate loads in ways that provide benefits to building owners, the environment, and the overall energy grid, they argue, and the DOE should take steps to ensure that future standards do not penalize smart appliances, even if they increase annual site energy usage by a minimal amount compared with non-connected or traditional appliances.
The groups emphasized that they strongly support the DOE’s conservation standards program and noted that it has been “one of the most successful energy efficiency efforts ever created in large part due to its focus on setting standards that are technically feasible and economically justified for a large majority of consumers.”