2009-01-30 Public Submission page with comment

As a homeowner and subsequently utility-paying energy user, I have come to appreciate the value of energy efficient equipment. Not only does it lessen the cost of monthly bills, there is a more qualitative value in the fact that I am actively participating (though on a small scale) in helping to protect and preserve the environment. Since purchasing my home eight years ago, I have upgraded many different aspects of my home, replacing non-energy efficient equipment with its more energy efficient counterpart—ranging from the thermostat, dishwasher, clothes washer, ceiling fans, and light bulbs, to the windows. Yet to be replaced with new energy efficient models are both my furnace and my water heater. As I read through the process involved in amending the current standards for establishing/evaluating energy efficiency in these types of home heating equipment, I see a number of implications that may result from this process. I think the intent behind the action is well-founded. As indicated by the published material in the Federal Register, some of these standards have seen little change since 1987 when the NAECA was first enacted. Since then newer technologies have been invented to bring about greater efficiency, yet only individual states have taken action to regulate the use of improved standards. I believe the Department of Energy should be tasked with the responsibility of maintaining these standards in accord with available technology. Improved Federal standards may assist in alleviating states from enacting similar standards at a lesser level and may help create a more uniform platform for consumers and manufacturers across the nation. At the same time, I caution the DOE against raising the standards too high, especially in times of economic uncertainty. The initial monetary cost (purchase price) of more efficient equipment is certain to increase. Ultimately, the consumer will bear the cost of this increase. While many utility companies (public and private) have come of offer monetary incentives (cash rebates) to consumers to upgrade their present non-efficient equipment. Further, increased purchase price, without increased incentive may push consumers away from purchasing the newer technology. If energy efficient equipment is not purchased and instead, the consumer elects to purchase the cheaper non-efficient model, then the act of amending the efficiency standards has actually had an adverse affect on the environment as there is little or no positive change in conserving energy. For this reason, I think that if the Department of Energy is to consider analyzing the current standard, and/or proposing new standards, I think that is imperative that it seeks and obtains approval from the vast stakeholders that will be affected, from manufacturers, to consumers, to utility companies.