used in the analysis—one fuel will be more environmentally sound, one will be more affordable, another might be more reliable or secure, yet another might be more available, and another might be determined to be safer. These preferences are beyond the intention of the Program and are a matter of national energy policy. Of particular significance is the fact that the consumer has no control over upstream costs of producing energy or the physical characteristics of fuels. They cannot control the transmission and distribution losses incurred in bringing electricity to the home. They cannot control the energy required to bring LNG into the country or pressurize it into the pipeline system. They cannot account for the cost of oil drilling or storing nuclear waste. They can only control the amount of energy used within their home—site energy. Factoring in the upstream costs would create a disservice to consumers and could thwart the intent of the Program. Were consumers to switch fuels based on incomplete analysis, costs of conversion could be very great and energy savings might not occur at all. In addition, supplies of the preferred fuel could become constrained, prices could soar, and industries could relocate abroad in order to stay competitive. The nation saw such an example of unintended consequences—constrained supply, sharply increased prices, chemical industries moving abroad—when natural gas, a clean-burning fuel, was popularly used in turbines to generate electricity. DOE/EERE should continue using site measurements to set appliance efficiency standards.

  1. The problem with using the label as a vehicle for societal goals as measured by full-fuel-cycle energy analysis. Informing the public of environmental consequences of energy use is an important goal. The government has an obligation to conduct such educational campaigns. As worthy as this goal is, the appliance labeling program is not the appropriate vehicle. Over the past 30 years, energy efficiency standards have helped consumers in very important ways which can be negatively impacted by the recommendations. Adding information on environmental impacts would confuse the decision process. The existing site-based labels provide clear and understandable cost and consumption information that is relevant to consumers’ purchases. Consumers can easily compare the annual operating costs of different appliances while they compare the purchase prices of the appliances. The cost and energy consumption information on the label equips the consumer to make an informed economic decision—a decision which is fully within the consumer’s control. Importantly, a unit of energy saved by the purchase of an efficient appliance—regardless of the fuel used—means one less unit of energy that we need to produce from domestic sources or import from unstable foreign countries. That helps the environment through reduced air emissions and has important national security implications.

In 2006, the Consumer Energy Council of America convened leading energy experts to examine the costs and benefits of each fuel used for stationary energy needs. The consensus forum examined the characteristics of each fuel through the prism of national consumer priorities, including cost, environmental impacts, availability, national security, public health, safety, and other factors. The report of the forum, Fueling the Future: Better Ways to Use America’s Fuel Options, determined that over the next 20 years we need to use every fuel in the nation’s portfolio—but we need national policy and new technology to improve the characteristics of each fuel. The Appliance Efficiency Program is not the proper vehicle for setting national fuels policy—and fuels policy would be the unintended consequence. Site based standards are uncomplicated, non-political, provide valuable cost and consumption information for consumers, result in significant national energy and environmental savings, and best serve the goals of the Program.

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