No, Joe, There's No Heat Pump Nirvana! You've Been Dreaming. Get Over It!
The social cost of carbon SCC is a prime example of how DOE is using this nebulous authority to impose carbon reduction benefits within its cost/benefit analyses.
“But wait, there’s more” (in the immortal words of Ron Popeil). EPCA also states that DOE can include “any such other factors as the Administrator deems appropriate.” The social cost of carbon SCC is a prime example of how DOE is using this nebulous authority to impose carbon reduction benefits within its cost/benefit analyses. The Competitive Enterprise Institute’s (CEI), Ben Lieberman, explains SCC:
Junk Science Behind Federal Appliance Regs About to Get Junkier
The Biden-Harris administration has embarked on a wave of anti-consumer home appliance regulations over the last several years. Each was justified in part by overblown claims of climate change benefits. And now, the Department of Energy (DOE) has proposed using a new methodology that would further inflate these hypothetical benefits to justify even worse regulations in the years ahead.
DOE is in the process of creating new energy use limits for stoves, dishwashers, furnaces, washing machines, water heaters, ceiling fans, refrigerators, and more. The agency always asserts that consumers experience net gains from these regulations, but CEI has filed comments highly critical of these rosy assumptions. In reality, such rules often raise the up-front costs of appliances more than is likely to be earned back in the form of energy savings. Some rules also compromise appliance choice, performance, and reliability.
But DOE’s fictitious consumer benefits are only part of the problem. CEI has also taken issue with the agency’s assertions that these regulations deliver quantifiable climate change benefits. For example, DOE’s costly 2023 final rule for residential furnaces was estimated by the agency to provide $16.2 billion worth of such benefits.
The agency arrives at this figure by calculating the reduced energy use attributable to the efficiency standards and then estimating the amount of greenhouse gas emissions avoided as a result – mostly carbon dioxide emitted to produce electricity at coal or natural gas-fired power plants. Then it multiplies the tons of emissions avoided by the calculated per unit dollar cost to society of such emissions.
Until now, DOE has relied upon the 2021 Interagency Working Group on the Social Cost of Greenhouse Gases (IWG 2021). IWG 2021 provides the agency with the per ton Social Cost of Greenhouse Gases (SC-GHG) values.
Relying on IWG 2021 was bad enough, but in its most recent proposed rule for commercial refrigeration equipment DOE is switching to an updated 2023 version of SC-GHG provided by the Environmental Protection Agency.
The new methodology takes several already-dubious assumptions in IWG 2021 and stretches them further. For one category of commercial refrigeration equipment covered in the proposed rule, DOE calculates the climate benefits of $48-$320 million dollars under IWG 2021 but a whopping $564-$1,713 million under the new way. That’s around 5-10 times higher.
More Concerns
In May of 2022, I wrote an article published in Real Clear Energy titled Fallacies of Supplying American LNG and Electric Heat Pumps to Europe to Fight Putin and Global Warming. Primarily, it summarized the flawed “energy efficiency” physics behind this Biden administration plan that has since been regurgitated in the Investment Reduction Act a few months later. This article, which I stand by, received 189 comments.
This leads to my overarching concern: What is the fundamental motive behind all of this. It is:
Globalized social control through the establishment of an all-electric energy monoculture.
The transformation and growth of energy efficiency regulations into carbon efficiency regulations.
The following graphic cogently illustrates:
In short: DOE and its minions are running out of stuff to regulate under existing energy efficiency statutes within EPCA. A move to carbon efficiency regulation vastly expands their regulatory empire. The IRA is providing obscene amounts of taxpayer funding to force-feed this anti-consumer agenda. For more information, see Dangerous ‘Deep Decarbonization’ (Krebs PowerPoint to Cooler Heads Coalition). For the record, that presentation identified the $8,000 heat pump tax credit stated at the beginning of this article.
As Travis Fisher testified before the House Energy & Commerce Subcommittee on Energy, Climate, and Grid Security on September 11th, “ The subsidies in the IRA for wind, solar, and batteries alone could cost American taxpayers $3 trillion by 2050.” Fisher also testified: “Between the IRA subsidies and the EPA rules, I would summarize the administration’s power grid policy as this: Green the grid and brace for blackouts.”
The Competitive Enterprise Institute is leading a coalition of free market advocates attempting to organize support to stop the IRA’s obscene and consumer abusive funding. In response, the Biden (mis)Administration is attempting to shovel IRA funding out the door as fast as it can to contractually shield it. For further information, see Dismantling the Inflation Reduction Act green Subsidies Coalition Letter.
Mark Krebs, a mechanical engineer and energy policy consultant, has been involved with energy efficiency design and program evaluation for over thirty years. Mark has served as an expert witness in dozens of State energy efficiency proceedings, has been an advisor to DOE and has submitted scores of Federal energy-efficiency filings.