Jay L. Witkin replaces Jerome Feit, who retired, as the Federal Energy Regulatory Commission's solicitor. Also at the FERC, Judith Ann Dowd will serve as an administrative law judge. Dowd joins...
then it's this type of efficiency, but for a coal plant, it's this type" and so on. Furthermore, Rosenstock argues, in a deregulated market the consumer can continually switch suppliers, making source efficiency analysis virtually impossible. In sum, the picture Rosenstock wants to paint is one depicting the DOE opening a can of worms with the mere mention of the word source.
The gas industry concedes the complexity of the issue, but still feels the calculations can be done. Bill Ryan, GRI's team leader for space conditioning and appliances, urges the DOE to "take a shot at it."
Charlie Fritts, vice president for government relations at the American Gas Association, agrees. The gas industry, in fact, has come up with its own calculations for adding source to the efficiency equation. "Before a single electron hits your water heater, 73 percent of the energy that came out of the ground [i.e., fossil fuels] is lost." In comparison, says Fritts, natural gas loses only 9 percent from the wellhead to your house.
Currently, the DOE's 54 percent efficiency requirement for gas water heaters falls well short of the score (in the mid-eighties) posted by electric water heaters. Yet, according to the calculations by the A.G.A., that 54 percent-efficient gas water heater is actually more efficient - when you take the fuel source into account. The A.G.A. numbers also put electric water heaters as polluting, on average, three times as much as their gas counterparts, when using source analysis. That, Fritts says, "is our beef with the Department of Energy."
And they run across the same issue everywhere. "We have the same problem with furnaces, the same problem with the home energy rating system," he says, referring to the five-star system for home efficiency. Fritts speaks of situations where a four-star electric home actually generated more pollution than a gas home that was awarded only three stars, according to A.G.A.'s account. "It was a classic, 'I'm from the government; I'm here to help you,'" he says.
But using source would just get too complicated, argues EEI's Rosenstock. If you're going to look at source, then where do you stop? What about the cost of oil drilling or transporting crude from the Middle East? What about the U.S. military budget for the Gulf War?
And, Rosenstock argues, the Department of Energy already takes source into account in other ways.
"They're [already] using [source] to set priorities in terms of how many quadrillion British thermal units can be saved," he says, referring to the DOE's means of picking and choosing which appliances to go after based on the amount of energy savings they would achieve. "We have no problem with that."
Emissions: What's At Stake
The A.G.A. still believes that gas gets the short shrift. Fritts cites water heaters as an example: "The DOE sees the 86 percent rating and says 'we can't do much more with that.' Then, it sees the 54 percent for gas and says, 'Man, we could get that up a little higher.'"
Moreover, if you reduce the emissions from the gas water