Attachment H
Minority Opinion of David H. Archer, Committee Member

I regret that I cannot concur with the draft transmittal letter and the final report of the committee.

First, they do not include [what I view as] the most important finding and recommendations that should result from the information presented to the committee:

  • [Archer] Finding: The U. S. DOE/EERE Energy Conservation Program that establishes energy performance standards for residential and commercial building appliances is significant and effective in reducing the energy demand of the nation. It is well conceived and structured. It properly uses site energy to set the standards and source energy to estimate their energy, economic, and environmental cost/benefits to the nation. The Program is appreciated by appliance manufacturers and their customers, the public.

  • [Archer] Recommendation 1: The scope of the program should be broadened to include a wider variety of residential and commercial building appliances and systems. These should be identified by DOE/EERE to cover a broader range of the energy consuming appliances in these buildings. (An illustrative, but not prescriptive, list of such appliances and systems is attached as … [Table H.1].)

  • [Archer] Recommendation 2: The pace of the program should be accelerated to establish and also to revise appliance standards more rapidly.

Second, the report overemphasizes the concept of full fuel cycle energy to the point that it diverts attention from the purpose of the DOE/EERE program: to assure that the available building appliances for all the various functions, energy sources, and building applications are efficient; not to compare the energy use of appliances using different energy sources on the basis of full fuel cycle energy consumption.

Third, I am concerned that the length and complexity of the committee’s “letter” report detracts from its impact.

TABLE H-1 Additions to the Department of Energy/Office of Energy Efficiency and Renewable Energy Appliance Energy Conservation Standards Program

Residential television sets

Lap and desk top computers

Solar photovoltaic power or solar thermal heating units

Commercial air circulation fans for variable and constant air flow

Cooling/heating and ventilation systems

Commercial ventilation air enthalpy recovery units.

Commercial desiccant based air dehumidification units

Commercial absorption chillers

Advanced thermostats, smart meters, and other instrumentation and control hardware to achieve energy reductions in the operation of appliances



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Attachment H Minority Opinion of David H. Archer, Committee Member I regret that I cannot concur with the draft transmittal letter and the final report of the committee. First, they do not include [what I view as] the most important finding and recommendations that should result from the information presented to the committee: [Archer] Finding: The U. S. DOE/EERE Energy Conservation Program that • establishes energy performance standards for residential and commercial building appliances is significant and effective in reducing the energy demand of the nation. It is well conceived and structured. It properly uses site energy to set the standards and source energy to estimate their energy, economic, and environmental cost/benefits to the nation. The Program is appreciated by appliance manufacturers and their customers, the public. [Archer] Recommendation 1: The scope of the program should be broadened to • include a wider variety of residential and commercial building appliances and systems. These should be identified by DOE/EERE to cover a broader range of the energy consuming appliances in these buildings. (An illustrative, but not prescriptive, list of such appliances and systems is attached as . . . [Table H.1].) [Archer] Recommendation 2: The pace of the program should be accelerated to • establish and also to revise appliance standards more rapidly. Second, the report overemphasizes the concept of full fuel cycle energy to the point that it diverts attention from the purpose of the DOE/EERE program: to assure that the available building appliances for all the various functions, energy sources, and building applications are efficient; not to compare the energy use of appliances using different energy sources on the basis of full fuel cycle energy consumption. Third, I am concerned that the length and complexity of the committee’s “letter” report detracts from its impact. TABLE H-1 Additions to the Department of Energy/Office of Energy Efficiency and Renewable Energy Appliance Energy Conservation Standards Program Residential television sets Lap and desk top computers Solar photovoltaic power or solar thermal heating units Commercial air circulation fans for variable and constant air flow Cooling/heating and ventilation systems Commercial ventilation air enthalpy recovery units. Commercial desiccant based air dehumidification units Commercial absorption chillers Advanced thermostats, smart meters, and other instrumentation and control hardware to achieve energy reductions in the operation of appliances 38