Setting the Record Straight on CEA's Letter to the Secretary of Energy
The Consumer Electronics Association (CEA) has long opposed minimum energy efficiency standards for their products and has launched numerous campaigns over the years to support their position. Their most recent effort includes a letter to Secretary of Energy Dr. Ernest Moniz that contains so many misleading statements that it’s important to set the record straight.
DOE’s energy efficiency standards program really works. The Department of Energy (DOE) has a 30-plus-year track record of setting the test methods for measuring the energy use of a particular product, and minimum energy efficiency standards that covered products must meet. In fact, the Appliance Standards Awareness Project (ASAP) estimates efficiency standards set during the Obama administration, alone, will save consumers and businesses about $380 billion over the life of the products and reduce carbon dioxide emissions by 1.9 billion metric tons through 2030. Covered products range from refrigerators, motors, and lighting products to external powers supplies -- the little black boxes that power most of the consumer electronics products in our homes. Given that consumer electronics consume 10 to 15% of total residential electricity use, DOE is working to include more of these products in their program as a means to further cut household energy bills and reduce national emissions of carbon dioxide, the main pollutant responsible for climate change, and other harmful pollutants caused by electricity generation.
CEA has repeatedly fought mandatory efficiency standards at the state and federal level. During the California Energy Commission’s standard setting process for big screen TVs in 2008, CEA helped create the “Californians for Smart Energy” group that alleged the TV standards would result in the loss of 4,600 jobs and $50 million in tax revenues for the state of California. Fast forward to 2014 and everyone can see the California standards were wildly successful as new TVs today use less than half the energy they did when the CEC proceeding began. In addition, today’s TVs cost 60% less for an equivalent-sized model and CEA’s alarmist predictions of massive job and tax revenue losses due to the standards never materialized.
DOE’s standards-setting process is transparent and open to all. DOE has an open process in which all stakeholders are invited and welcome to participate. To its credit, DOE closely evaluates test procedures that industry has developed and incorporates as much of the existing materials as appropriate and makes modifications and additions where necessary. Most recently DOE cut and pasted almost the entire test method for TVs that the CEA subcommittee worked hard to develop and then added, for example, some additional language to make sure the test method properly addressed the standby power of new internet ready, or “smart TVs,” as some models have consumed up to 24 watts of power continuously even when turned “off.” While DOE may decide to utilize all or portions of international testing procedures, they must retain the ability to establish their own test methods as the international standards-setting organizations take many years to finalize test methods and may not be nimble enough to update their test methods in a timely basis when new energy-using features are added or loopholes are identified.
CEA’s version of harmonization is a race to the bottom, not the top. In their letter, CEA called into question recent labelling requirements and standards set in Mexico and Canada and their lack of consistency with US policies. In their letter, CEA incorrectly characterized Mexico’s laws as “creating unreasonable testing and labelling requirements while providing no discernible energy savings or guidance to consumers.” As I was unaware of Mexico’s regulations, I immediately searched for them and found they require manufacturers to include a label that shows a device’s standby power usage (the amount of power a device uses when left plugged in and turned off) . Performance of these tests is very simple and inexpensive. Mexico also established maximum allowable standby power levels for many products. These levels were often identical to those set in the United States and in a few instances were more stringent. It seems disingenuous for CEA to state that labeling and standby power limits don’t benefit consumers or result in energy savings.
CEA also claimed the Canadian Provincial standards “unnecessarily mandated energy use limits for televisions” when in reality the Canadian standards set in the Province of British Columbia simply copied the California standards and added TVs greater than 58 inches to their regulations. California included the larger TVs in their initial standards proposals, but dropped them as a concession to CEA. Canada was wise to retain them as they are now a fast-growing part of the market.
The CEA letter also highlights the recent Voluntary Agreement (VA) on cable and satellite set-top boxes. Interestingly enough, CEA and the U.S. pay TV industry failed to harmonize with the levels contained in the existing European set top box VA, as it argued many of their levels were too stringent. More information on the U.S. agreement can be found here.
The bottom line - While harmonization may indeed make sense in many cases, harmonization that results in a race to the bottom or stifles the opportunity for regulatory innovation is simply bad policy and must be avoided. We urge Secretary Moniz and the California Energy Commission to continue their agencies’ leadership in setting meaningful efficiency standards because they save consumers money, reduce the amount of pollution caused by electricity generation, and help stimulate manufacturer innovation.