CFA supports the proposed refrigerator, refrigerator-freezer, and freezer standard; however, we believe that DOE could do more. CFA’s analysis of the proposed rulemaking addresses specific concerns raised by DOE, broadly the associated technology, cost estimation, regulatory burdens, rebound effects, climate change, and other and non-monetizable effects.  Moreover, there are a number of very important fundamental issues, like discount rates and market processes, that we also note influence the decision on where to set standards.

In reviewing the standards for the many product classes of refrigerators, it is clear that the DOE has chosen to set the standard at the lowest life cycle cost.  That may seem reasonable, but it is inconsistent with the statute and sound public policy. A standard at one higher level of efficiency is superior; it is.

• technically feasible
• saves more energy
• takes account of the climate and public health value of higher standards, ensuring consumers get the benefit of capturing externalities
• economically justified
• increases LCC slightly
• yields a benefit-cost ratio of almost 2
• delivers more consumer pocket surplus
• has an acceptable payback period of half the life of the appliance or less while it negatively impacts only about half of consumers