Inefficient Governance? DOE misses Energy Efficiency Deadlines over and over again

As we struggle to Energize America, there are many challenges … from mistaken impressions as to the costs of options, people seeking silver bullet (single point) solutions (X will solve everything … fill in X), priority challenges, and so on.

One of the key challenges, however, might be bureaucratic inertia.

Energy efficiency — saving power (Negawatts) — should be the simpliest portion of the path toward a better energy future. We have the technolgoies and they are (highly) cost effective.

Sadly, the Department of Energy has been systematically sabotaging energy efficiency — having not met a single Congressional deadline for setting energy efficency standards. Ever!

Energize America bumpersticker

The General Accounting Office (GAO) has done many reports on energy efficiencyover the years. While dry reading for many, for those involved in Energize America (particularly, those involved in Home Energy Efficiency), these can make fascinating and valuable works … and windows (even if not the most energy efficient windows) on what is going on inside the US government when it comes to energy efficiency.In January, GAO issued ENERGY EFFICIENCY: Long-standing Problems with DOE’s Program for Setting Efficiency Standards Continue to Result in Forgone Energy Savings (note: pdf). Sadly (as is usually the case with a GAO report), the news isn’t too good.

Let us take a look at the summary:

DOE has missed all 34 congressional deadlines for setting energy efficiency standards for the 20 product categories with statutory deadlines that have passed. DOE’s delays ranged from less than a year to 15 years.

Would anyone have been expected to realize after, I don’t know, 10 or so missed deadlines, that there might be something wrong. And, 15 years … I don’t know what to say …

And, note that over 1/3rd fall into the 10-15 year late category — with none of those completed.

Rulemakings have been completed for only (1) refrigerators, refrigerator-freezers, and freezers; (2) small furnaces; and (3) clothes washers. DOE has yet to finish 17 categories of such consumer products as kitchen ranges and ovens, dishwashers, and water heaters, and such industrial equipment as distribution transformers.

So, energy efficiency is a key tool toward turning the nation toward a better path forward. Every kwh burned equates into, roughly, 1.5 lbs of CO2 into the atmosphere. How many millions of tons of CO2 might we be talking about?

Lawrence Berkeley National Laboratory estimates that delays in setting standards for the four consumer product categories that consume the most energy––refrigerators and freezers, central air conditioners and heat pumps, water heaters, and clothes washers––will cost at least $28 billion in forgone energy savings by 2030.

$28 billion in lost energy savings … how about in terms of kilowatt hours and C02. If we take a high-cost KwH of 10 cents on average, that is 280 billion kilowatt hours … and roughly 420 billion pounds of additional C02 pollution. (And, by the way, there are all the dollars, KwHs, and tons of carbon dioxide into the atmosphere in past years due to failures to simply follow the law and institute energy efficiency standards. In 2004, reportedly, the delays resulted in 53 million tons of carbon dioxide emissions, about the same as 1% of total U.S. carbon dioxide emissions.)

DOE’s January 2006 report to Congress attributes delays to several causes, including an overly ambitious statutory rulemaking schedule and a lengthy internal review process. In interviews, however, DOE officials could not agree on the causes of delays. GAO’s panel of widely recognized, knowledgeable stakeholders said, among other things, that the General Counsel review process was too lengthy and that DOE did not allot sufficient resources or make the standards a priority. However, GAO could not more conclusively determine the root causes of delay because DOE lacks the program management data needed to identify bottlenecks in the rulemaking process.

Hmmm … he said, she said … fingers pointed everywhere … and no one has responsibility?

In January 2006, DOE presented to Congress its plan to bring the standards up to date by 2011. It is unclear whether this plan will effectively clear DOE’s backlog because DOE does not have the necessary program management data to be certain the plan addresses the root causes. The plan also lacks critical elements of an effective project management plan, such as a way to ensure management accountability for meeting the deadlines. Finally, the plan calls for a sixfold increase in workload with only a small increase in resources. DOE plans to manage the workload through improved productivity.

Hmmm … DOE plans to solve the problem by telling staff to do more? Is that what they mean? GAO certianly doesn’t express confidence in this plan.

As the LA Times reported this 3 March with the title Energy Dept.’s missed deadlines on appliance efficiency cost billions, report says:

“I have never seen anything like this,” said GAO analyst Karla Springer, who led the group that prepared the report. “It is nearly 30 years of not meeting a deadline. It is kind of frightening.”

This is about the most egregious case of “dog ate the homework” that I’ve ever heard of. They were unable to make a single deadline in 30 years!!!

Well, let’s go to the cover letter to the report:

Household and commercial products … will account for about 30 percent of estimated total U.S. energy consumed in 2006,

Increasing the energy efficiency of these kinds of products could produce significant energy savings. Not surprisingly, therefore, Congress has long been interested in improving energy efficiency. In 1975, under the Energy Policy and Conservation Act (EPCA), Congress required DOE to set target minimum energy efficiency standards … Minimum efficiency standards for consumer product and industrial equipment categories are designed to eliminate the least efficient products from the market.

Sadly, perhaps the most inefficient part of the system is the DOE’s process for setting efficiency standards.

Sadly, the problem isn’t only in delays for setting standards … Last fall, The New Yorker published Untransformed:

more than fourteen years after Congress mandated transformer standards, the Bush Administration finally got around to proposing them. (The original deadline was missed during the Clinton Administration.) To prepare the proposal, the Department of Energy assessed six possible levels of efficiency, ranging from the highest, known in bureaucratese as Trial Standard Level 6, to the lowest, Trial Standard Level 1. According to the department’s figures, the ideal balance between the up-front costs and the long-term gains was achieved at Level 4. Nevertheless, the department turned around and recommended a much lower transformer standard, Level 2. The decision obviously makes no sense on environmental grounds—in effect, the department is proposing to squander some twelve billion kilowatt hours per year, or roughly enough electricity to power all the households in Iowa—and also no sense on financial ones: the D.O.E.’s own analysis shows that the net cost of the lower standard will actually be higher over the life of the average transformer, which is estimated to be thirty years. The proposal leaves “billions in savings just sitting on the table,” is how Steven Nadel, the executive director of the American Council for an Energy Efficient Economy, put it

What can I say? AHHHHH!!!!

Sticking with The New Yorker, this 2002 Malcolm Gladwell article pointed out that the Bush Administration had changed the requirements for future air conditioner efficiency to increase from Seasonal Energy Efficiency Rating (SEER) 10 not to SEER 13 but to SEER 12. (Note that, later, the minimum was set for SEER 13 starting in 2006.) What were the implications of that ‘miniscule’ difference?

For anyone wanting to make electricity cheaper, then, the crucial issue is not how to reduce average electrical consumption but how to reduce peak consumption. A recent study estimates that moving the SEER standard from 10 to 13 would have the effect of cutting peak demand by the equivalent of more than a hundred and fifty power plants. The Bush Administration’s decision to cut the SEER upgrade by a third means that by 2020 demand will be fourteen thousand megawatts higher than it would have been, and that we’ll have to build about fifty more power plants.

50 more power plants based on that one relatively hidden change. … 50 …

For those seeking to Energize America, a critical part is to pursue a holistic approach: balancing energy efficiency, renewable power, and changed usage patterns.

The first should be the easiest … someone needs to explain that to the Department of Energy.

Energy Smart

PS: When it comes to being Energy Smart, have to wonder whether the Department of Energy is doing its part …


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