Appliance Efficiency: Does the Fuel Cycle Make a Difference?
The electric industry watches contentedly as the DOE ignores the gas industry's strongest arguement.
While the Department of Energy continues to take a fresh look at appliance efficiency standards in committee meetings and rulemaking initiatives, in large part it continues to ignore the gas industry's allegations of a bias toward electricity.
To be sure, the DOE has been active in standard-setting on several fronts, ranging from fluorescent lamp ballasts , to clothes washers , to central air conditioners and heat pumps (see rulemaking issued in November, in . At press time, stakeholders expected new action at any time in the DOE's water heater docket .
No matter the docket, however, the gas industry cries foul, complaining that it loses before a proposed rulemaking even begins.
Define Efficient for Me
What the gas industry primarily wants to talk about - and what the DOE largely has ignored - is the perennial "site vs. source" debate, or whether an appliance's fuel efficiency should be measured only at the site of consumption (site analysis), or whether the entire fuel cycle, including the energy source for the power needed to run an electric appliance (e.g., how much smog does the coal-fired plant emit to power that electric water heater?), should be considered in measuring an appliance's efficiency (source analysis). Naturally, the gas industry's preferred method of measuring appliance efficiency is source analysis.
In fact, back on June 3, 1999, President Clinton issued Executive Order 13123, which called on the federal government to reduce energy use and emissions "as measured at the source. To that end, agencies shall undertake life-cycle cost-effective projects in which source energy decreases, even if site energy use increases. In such cases, agencies will receive credit toward energy reduction goals through guidelines developed by DOE." (See www.eren.doe.gov/ femp/aboutfemp/exec13123.html.)
On the other hand, the preliminary agenda for a scheduled March 28 meeting of the DOE's appliance energy efficiency standards advisory committee, makes no mention of the issue.
So is the DOE biased? That depends on whom you ask.
"[I]n my opinion, the Department of Energy does have a bias," says Bob Hemphill, principal project manager for gas pipelines at GRI. Hemphill is quick to remind that comparing electricity and gas is comparing apples to oranges. "Electricity is an energy form, not an energy source," he says.
Meanwhile, Steven Rosenstock, manager, electric solutions, at the Edison Electric Institute, thinks otherwise. "We've been satisfied with the [DOE's] process. They've taken all of our analyses into account," he says, referring to the various proposed rulemakings on efficiency standards.
Rosenstock employs the traditional argument against using source analysis: It would make calculation entirely too complicated. "They've used site efficiency guidelines because it is a lot easier for the consumer to understand," Rosenstock says. It would be both confusing and perhaps unreliable to make an attempt at incorporating source into the equation, which would result in scenarios that Rosenstock is quick to fabricate. "If you have a windmill, that's one type of efficiency, but if you have a nuclear plant,