test procedure for product evaluation. Designing to a point-of-use energy requirement allows the manufacturer to wholly manage the energy use of their product and provides incentive for research and development that go above and beyond current regulations.


Furthermore, appliance energy information has become an important factor in purchasing decisions for consumers in the past five years. Through a combination of appliance efficiency standards, Energy Guide labels, Energy Star and other market awareness efforts, including tax incentives to manufacturers to deliver energy savings beyond that required by regulation, consumers are taking steps to further reduce energy consumption of appliances. The product specific information addressed by the abovementioned information programs is critical to this progress and should be maintained.


AHAM requests that the Committee maintain the current DOE procedure for defining appliance energy standards using point-of-use energy as the basis. As noted above, this approach has incentivized manufacturers and results in substantial improvements in product energy efficiency. As mentioned earlier, AHAM believes that consumers are also motivated by point-of-use energy values, as these are values they can control.


AHAM acknowledges that addressing inefficiencies in the fuel cycle, for all fuels, is paramount to further reducing energy inefficiencies and greenhouse gas emissions; however, home appliance manufacturers are not responsible for fuel cycle efficiencies and therefore cannot directly address energy use at this level. Only the utilities can be held accountable for the fuel source in their generating plants. Again, DOE's current approach, where point-of-use energy values are used to set regulations and full fuel cycle energy use is estimated through impact analysis, provides a realistic foundation for addressing both concerns.


We thank you for the opportunity to provide these comments. Please feel free to contact me with any comments or questions that you may have.

Sincerely,

Debra K. Brunk, Ph.D.

Director,

Technical Services



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