Comment to the Department of Energy: Energy Conservation Program: Energy Conservation Standards for Consumer Conventional Cooking Products Proposed Rule

The estimates on benefits and costs asserted by the Department of Energy (DoE) in the proposed rule on 'Energy Conservation Standards for Consumer Conventional Cooking Products' demonstrate that it cannot satisfy any plausible benefit/cost test. The maximum annual consumer savings in the DoE lifecycle analysis is for gas cooking tops, asserted by DoE to be $1.51 per year per unit. That number is too small to differ from zero as a matter of statistical significance; the figures for the other cooking technologies are smaller, and in most cases are effectively zero. Accordingly, the savings, whether delineated in dollars or units of energy, are too small to satisfy the legal requirements promulgated under the Energy Policy and Conservation Act (EPCA). Nor does the DoE analysis examine the forgone service quality characteristics to be lost under the proposed rule. If DoE is correct that the savings, again whether delineated in dollars or units of energy, are sufficiently significant to satisfy the requirements of the EPCA, then unless DoE asserts that consumers are irrational--which it does not do--then it must be the case that the forgone service quality characteristics, if monetized, are greater than the asserted savings. A continued pursuit of the specifics of this rule, accordingly, is inconsistent with the central principle underlying support for a market economy, to wit, a definition of economic value as revealed by consumer preferences reflected in market prices. If DoE views consumers as irrational, it should say that explicitly, justify it, and justify as well the implicit premise that DoE officials and staff are more rational. The DoE assertion of climate benefits is preposterous, as a straightforward application of the DoE estimates of the reductions in GHG emissions to the EPA climate model, under assumptions that exaggerate the effects of such reductions, yields a prediction of a temperature decline in 2100 of 0.005[degrees]C, a figure effectively equal to zero, and undetectable in any event given the standard deviation of the surface temperature record. DoE attempts to circumvent this obvious problem by using instead the interim IWG estimates of the social cost of carbon, but those estimates are fatally flawed and heavily politicized, in that they (1) distort the actual economic growth predictions produced by the integrated assessment models, (2) base predictions of future climate phenomena on climate models that cannot predict the past or the present, (3) incorporate 'co-benefits' in the form of a reduction in the emissions of other criteria and hazardous air pollutants already regulated under different provisions of the Clean Air Act, (4) incorporate the asserted benefits of GHG reductions on a global basis, and (5) employ discount rates that are inconsistent and inappropriate. In short, the proposed rule cannot satisfy any basic standard of analytic rigor, a plausible benefit/cost test in particular. It should not be finalized in this form.
RIN 1904-AD15 Docket EERE-2014-BT-STD-0005 Document 2023-00610 Document Citation 88 FR 6818 This comment paper addresses the benefit/cost analysis presented in the rule proposed by the Department of Energy (DoE) on [...]