New legislation would tackle the most difficult problem (em low load factors for small-volume customers.
We commend the Natural Gas Competition and Deregulation Act, SB 215, passed by...
heater by 10 percent and shift that 10 percent over to electric resistance water heater, "you've made the world worse," says Fritts. "That's the problem, and DOE doesn't get that," he says. By the A.G.A.'s count, a 10 percent market shift in the other direction, to gas water heaters, would reduce CO2 emissions by 1.1 million tons per year.
Fritts also complains about the DOE's handling of the electric heat pump (as opposed to the electric resistance water heater). Referring to the department's decision not to increase the efficiency standard for the relatively new product, Fritts says, "DOE failed to raise the bar for electric heat pumps because they said it wasn't on the market yet, but we feel they just keep coming back to us because they see a target."
Consumer Cost: The Ultimate Standard
David Goldstein, the appliance efficiency standards expert for the Natural Resources Defense Council (NRDC), believes that both the electric and gas industries are missing the point.
"We're not excited about either site or source," Goldstein says of NRDC's position, "because [source] relates to something people cared about in the '70s and don't particularly care about anymore, and [site] doesn't relate to anything at all that I can understand. If you think all energy forms are equivalent and you're mainly concerned about how much we're importing, then source energy matters to you. I don't know anyone who cares about that."
And regarding site energy, Goldstein says, "That's sort of like going in a bar and pricing drinks by the ounce."
To Goldstein, the debate was current in the 1970s but has now played out: "I don't understand why either side cares about it that much now."
On what equitable basis, then, do you create standards? This time, the environmental side sees economics as a productive force.
"The much more useful way to measure energy is in cost," Goldstein says. That obviously works well for consumers, but, as Goldstein notes, the green camp also likes cost measurement "because the pollution impact, coincidentally track the costs pretty well." So, he says, if you're comparing kilowatts and therms, "the easiest and most straightforward and least controversial way to do it is also the most technically correct. The current national average costs track very closely the green house pollution emissions and reasonably closely other pollution emissions."
As for the DOE's neutrality in general, the man on the sidelines of the electric-gas fight says the department for the most part has been fair. "I think DOE has made a strong effort in the standards program to not favor any fuel unfairly."
But Goldstein returns to his preference for cost analysis when he suggests a different bias on the part of the DOE's policies. "There are some constraints within the labeling program that the gas industry objects to, and I think the gas industry's position has merit." The DOE's labeling program, he says, potentially can make a gas appliance appear less efficient than an electric appliance "that actually would cost a lot more to operate and cause a lot more pollution."