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Lane Burt’s Blog

New commercial refrigeration standard from DOE a head scratcher

Lane Burt

Posted January 10, 2009

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The Bush administration released new efficiency standards for commercial refrigeration equipment on Friday, finalizing the levels they proposed last October. This standard covers the refrigerated display units used in grocery stores and gas stations. You can find the full document here, if you are brave.

The standard itself is not completely terrible and will save about a quad of energy in 30 years (quadrillion BTUs, and we use about 100 of those in a year), but the way DOE reached their conclusions makes you go hmm...

Oddest of odd comes in the Department's treatment of LED lights. Using LED lights in refrigerated cases is generally a good idea, as they use less energy, give off less heat, and they make the Red Baron and the Gordon's fisherman look delicious. The real perk is they are thought to increase sales via superior lighting. The Department was considering requiring LED lights in all cases (vertical and horizontal, open and closed) as part of this rulemaking.

So in order to make a decision about LEDs for a standard that does not take effect until 2012, DOE had to make an assumption about what LEDs would cost in 2012 and beyond. Luckily, the Department's own Solid State Lighting division has done just that, by creating the most comprehensive projection of LED prices based on historical trends and technologies in development. The conclusion of this report was that LED prices would fall 50% by 2012 (they fell 9% in 2008 alone). Slam dunk.

Not really, because DOE rejected its own findings as too uncertain, saying in the final rule:

"While considerable information is available that suggests LED prices are likely to decline by at least as much as DOE's sensitivity analysis assumed, DOE is not using this information as the basis of its analysis due to a lack of certainty about the timing and success of LED research and product development."

So somehow these projections are too uncertain to use in this analysis. But the projection that, beginning in 2009, LEDs will stay at exactly the same price indefinitely? That is rock solid, iron clad, a done deal.

DOE did update to the most current prices for LEDs to reflect changes that have occurred since the NOPR. And since October the prices have...wait for it...decreased.

"For today's final rule, DOE updated the LED costs to represent the current cost of LEDs. DOE did not receive any data providing a greater level of confidence that LED price reductions would occur. However, LED costs have decreased and the costs used in the NOPR engineering analysis no longer represent the current cost of LEDs."

Sigh. So what does this inexplicable decision mean? Well, according to the NOPR, if LED prices decrease by only 6%, then LEDs make sense across the board and the highest standard level considered is justified. And if the 50% reduction, as projected by DOE, occurs, then the nation hits the jackpot, saving nearly five billion dollars. The energy and carbon savings in moving to the higher standard level are also significant. According to ACEEE,

"The stronger standards which DOE rejected would have saved another 0.26 quads (about 25 billion kilowatt hours), or enough to power another 1.3 million households for a year. DOE's chosen standard will eliminate 52.6 millions tons of carbon dioxide over thirty years (according to DOE, an amount equal to that annually emitted by 332,500 cars); the stronger standard would have cut another 13 million tons (an amount equal to that annually emitted by another 82,000 cars)."

This is a bit depressing, especially considering the irrational basis for making this decision and the apparently light treatment of the additional benefits. But hope springs eternal, as the incoming administration has promised to overhaul the appliance standards process. That's a good thing, because DOE will issue 25 standards over the next four years (pursuant to a consent decree that resulted from a lawsuit filed by NRDC and several states). For comparison, the Bush administration issued 4 standards. Hopefully this is the last time we see such bizarre logic used to determine national energy policy.

 

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Comments

RecycleBill, aka Billy JonesJan 11 2009 09:55 AM

Puzzling, to say the least. Has the government burned itself to the point that government no longer trusts government or have we the people just been burned by government and the energy industry?

Sorry, a lifetime in America has left me a scheptic of anything the government does.

kate reifersJan 12 2009 03:36 AM

We must all remember that government is a very expensive machine, HOWEVER, just now starting out in the LED retrofit and energy efficient lighting industry I can tell you that, especially in the cases of 24 hr gas stations & convenience stores with refrigeration, that much of their energy usage is through lighting. This is good step, although I believe that 2012 is too far ahead.

It's just like doing a highway retrofit to add more lanes. By the time the project is finished, current traffic levels require more lanes upon completion. Make the standards and deadlines for 2010 at the latest.

The earth, nor us humans, can't wait.

lburtJan 12 2009 09:49 AM

I wouldn't say that the government does not trust itself, but I would say that traditional analytical methods often leave much to be desired. Because the prices are uncertain, the analysts will leave them out rather than introduce uncertainty into their analysis, but ignore the fact that this has the same effect as selecting 0 for this factor, which is certain to be wrong.

Moving up the start date for standards is a tricky issue. Manufacturers often have valid concerns on timing, but other times they do not. Allowing DOE the flexibility to set standard start times on a case by case basis is something that has been discussed.

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Switchboard is the staff blog of the Natural Resources Defense Council, the nation’s most effective environmental group. For more about our work, including in-depth policy documents, action alerts and ways you can contribute, visit NRDC.org.

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