Abusive DOE Energy Efficiency Policy Archives (60+ articles)

By Mark Krebs and Tom Tanton -- December 3, 2024

“It is our sincere hope that the incoming Trump Administration, the Department of Energy, the newly formed National Energy Council  and/or its Department of Government Efficiency (DOGE) make use of these resources in considering what to overhaul and what to scrap.”

The incoming Trump Administration, committed to tame inflation and the Deep (Administrative) State, recognizes energy as the master resource. This blogsite by the same name was established in 2007 to demonstrate the importance of energy exceptionalism free-market style.

Politicized “energy efficiency” policies increase costs and limit choice for consumers, thus the need for government mandates and subsidies. The failed history of government in this area–and why–are cross-referenced here by author and subject. These resources are freely available to anyone interested in the evolution of energy policy.

It is our sincere hope that the incoming Trump Administration, the Department of Energy, the newly formed National Energy Council  and/or its Department of Government Efficiency (DOGE) make use of these resources in considering what to overhaul and what to scrap.

Of particular interest to us is the Department of Energy (DOE) Office of Energy Efficiency and Renewable Energy (EERE).  Simply put, EERE is obsolete and counterproductive to a free-market economy. Structural reformation of EERE is overdue for improving consumer choice and prosperity. And it is a relatively easy budget cut.

The Krebs category uniquely provides the devils-in-the-details of how EERE routinely flouts its own laws and regulations and manipulates “data” to stifle legitimate interests of everyday consumers. Further, the original justification for EERE, dating back to the 1970’s oil embargoes, has long been solved. Some 50-years later, it’s well past time to declare victory and move on.

Beginning in 2013, Mark Krebs (with frequent collaboration from Tom Tanton) has authored 60 articles at MasterResource. It is our hope that these articles (listed below) provide the incoming Trump Administration with ample rationale for eliminating EERE. 

Major Themes

These are the top four re-occurring themes: 

• EERE’s irrational push for societal electrification via renewable generation is Congressionally unauthorized mission creep that overloads already challenged electric grids and will conservatively cost taxpayers $18-29 Trillion. Others estimate “electrifying everything” can’t be done at any cost due to raw material constraints.
• EERE routinely reduces consumer choice and/or increases consumer costs through biased appliance efficiency standards.
• EERE’s renewable energy favoritism further inflates electricity costs and reduces energy security through limiting energy diversity and shifting the market to electric appliances.
• EERE and its beholding minions (e.g., the “National Labs”) routinely “pack the bleachers” and rig the apparatus of so-called “consensus” building energy codes to move the market to electrocentric “net zero” construction.  The added expenses of such homes deters the American Dream of home ownership.

Illustrations

Pictures can be worth a thousand words when it comes to understanding EERE’s self-serving motives.  The most pernicious of which is arguably its self-serving empire building/mission creep of the “Deep State.” Here are pictorial examples:

From Heat Pump Subsidies: Never Enough:

“Transitioning” energy efficiency to carbon efficiency grows the regulation business

Source: “Electrification – What Does It Mean for Energy Efficiency?”

From Warring Against Natural Gas: Joint EEI/NRDC Statement to NARUC (crony environmentalism at work):

From Gas Furnace Rule Part II: Return of the “Scorched Gas” Policy

Comparison of 2011 & 2015 Life Cycle Cost (LCC) Spreadsheet Cost-Saving Inflation Calculations for
 Non‐Weatherized Residential Gas Furnaces

Archive Posts

While several other excellent analyses populate the MasterResource’s energy efficiency category, authors Krebs and Tanton[1] are the most prolific and proficient in documenting and explaining the routine gaming of DOE’s “energy efficiency” policies. The following is a listing of the complete  “Krebs Category:”

1. DOE Efficiency Standards: Consumer Time?
2. Heat Pump Subsidies: Never Enough
3. AI & Data Center Load Growth: On-Site Generation, Not Government Planning
4. “Green” Weaponization in Missouri: Ameren vs. Ratepayers, Taxpayers
5. “Wartime” Climate Policy vs. Natural Gas: Biden Gets Desperate
6. Review of Proposed Minimum Efficiency Standards for “Consumer Boilers”
7. Update: DOE Appliance Minimum Efficiency Standards
8. Did DOE “flip the bird” to the DC Circuit?
9. Energy Appliance Victory! (DC Circuit vs. DOE)
10. DOE vs. Gas Cooking: A Review of Critical Comments
11. The White House State: ‘Regulatory Reform’ in Sheep’s Clothing (OMB Circular A-4)
12. Gas Stoves: The Beloved Blue Flame is Just Better
13. Dangerous ‘Deep Decarbonization’ (Krebs PowerPoint to Cooler Heads Coalition)
14. “Rare Earths,” Electrification Mandates, and Energy Security (Part II)
15. “Rare Earths,” Electrification Mandates, and Energy Security (Part I)
16. Gas Furnaces and Big Brother Revisited
17. Gas Furnaces: Big Brother Says No
18. Environmentalists Petition EPA to Ban Natural Gas Use in Buildings
19. All-Electric Forcing in the “Inflation Reduction Act” (up to $14,000 per home)
20. The Department of Energy’s Intent to Eliminate Non-condensing Furnaces
21. ‘The $287 Million Pipeline No One Needed’: Deconstructing an Anti-Natural Gas Argument
22. Energy Efficiency under Biden’s DOE: An Update
23. Mark Krebs on Energy Efficiency under Biden’s DOE (Part IV of IV: More Issues)
24. Mark Krebs on Energy Efficiency under Biden’s DOE (Part III of IV: Biden’s Bias)
25. Mark Krebs on Energy Efficiency under Biden’s DOE (Part II of IV: EERE Modeling)
26. Mark Krebs on Energy Efficiency under Biden’s DOE (Part I of IV: “Deep Decarbonization” Reigns)
27. Gas Furnaces vs. DOE’s EERE (Trump trumps Obama, but Biden is Next)
28. Energy Efficiency Policy Under Trump (Part III: Litigation)
29. Energy Efficiency Policy Under Trump (Part II: EERE’s Process Rule & Overhaul)
30. Energy Efficiency Policy Under Trump (Part I: A Mixed Bag in the Swamp)
31. Gas Industry to DOE: Don’t Ban Non-condensing Gas Appliances
32. Stimulus IV: Last Chance for the Green New Deal?
33. Problems of Industrial Electrification (forced decarbonization on the firing line)
34. EERE Reform: Brouillette’s Turn (‘deep decarbonization’ threat still alive)
35. DOE Revisits Forced Electrification (Decarbonization) Rules re Non-condensing Furnaces, Water Heaters
36. Costing the Green New Deal and “Deep Decarbonization”: Some Clarifications
37. Hearing Summary: “Wasted Energy: DOE’s Inaction on Efficiency Standards & Its Impact on Consumers and the Climate”
38. Dear EERE: Past Time to Debate “Deep Decarbonization” (Obama program inconsistent with America First energy policy)
39. Behind the IPCC Curtain: the Costs of Climate Mitigation Policy
40. Paris Lives! “Deep Decarbonization” at DOE
41. Estimating Costs of Deep Decarbonization (California and beyond)
42. Update: ‘Is DOE Leading Us Astray?’ (A 1999 analysis revisited)
43. Warring Against Natural Gas: Joint EEI/NRDC Statement to NARUC (crony environmentalism at work)
44. Secretary Perry’s Hearing (Part II)
45. The “Powering America” Hearings (Part I)
46. Direct Use of Natural Gas: Unshackle Efficiency from Obama’s ‘Deep Decarbonization’ (Part II)
47. Direct Use of Natural Gas: Unshackle Efficiency from Obama’s ‘Deep Decarbonization’ (Part 1)
48. DOE’s EERE: Reform Ideas for Secretary Perry
49. Federal Energy Efficiency Mandates: DOE’s End Run vs. the Public Interest (Part II)
50. Federal Energy Efficiency Mandates: DOE’s End Run vs. the Public Interest (Part I)
51. Direct-Use Natural Gas Needs a Free Market Too (‘deep decarbonization’ easy target for elimination in new policy era)
52. ‘Home Appliance Energy Efficiency Standards’ Hearing: Some Reflections (Part II)
53. ‘Home Appliance Energy Efficiency Standards’ Hearing: Some Reflections (Part I)
54. Mark Krebs: Digging Down on Energy Efficiency Claims (an interview)
55. The Regulatory Assistance Project (RAP): Warring Against Gas
56. “Grid-Enabled” Water Heating: “Deep Decarbonization” as Crony Environmentalism (Part II)
57. “Grid-Enabled” Water Heating: “Deep Decarbonization” as Crony Environmentalism (Part I)
58. Gas Furnace Rule Part II: Return of the “Scorched Gas” Policy
59. Energy Mischief at the Rural Utilities Services (USDA): Climate Hubs, Efficiency Mandates, Fuel Switching Rules
60. Gas Furnace Rule: Beware of “Scorched Gas” Policy

Conclusion

MasterResource has long documented DOE’s abuse of its of energy efficiency authority (predominately through articles by Krebs and Tanton) in the hope that the time would come for someone willing, able, and insightful enough to make significant course corrections. Finally, with the Trump 47 Administration, the time is now to purge the Deep State’s self-serving, empire building/mission creep that permeates EERE. Please feel free to contact us as shown below, if we can be of further assistance.

Addendum

Regarding graphics, here is greater explanation (short of a full explanation in the linked articles:

The first chart titled “Transitioning” energy efficiency to carbon efficiency grows the regulation business, shows a plan to “transition” EERE’s regulatory authority to establish appliance minimum energy efficiency standards into a much larger market for regulating maximum appliance carbon emissions.

The second chart titled Levelized Cost of Energy: 2017 Dollars summarizes a study that compared non-electric alternatives against electric generation alternatives (which is all traditional LCOE studies consider).  By taking this wider perspective of LCOE, it becomes obvious that the societal cost-effectiveness of fossil-fueled appliances can achieve vastly superior results.    The chart is from Levelized Cost of Energy: Expanding the Menu to Include Direct Use of Natural Gas, by Thomas Tanton, published in August 2017 and available at the Energy and Environmental Legal Institute under the heading “TANTON : ELECTRIFICATION REPORT.”

The third and final graphic titled Comparison of 2011 & 2015 Life Cycle Cost (LCC) Spreadsheet Cost-Saving Inflation Calculations for Non‐Weatherized Residential Gas Furnaces gets deep in the weeds to expose EERE’s analytical manipulation buried within their “Technical Support Documentation” (TSD) than typically exceed a thousand pages. 

In this case, (Non‐Weatherized Residential Gas Furnaces) it compared EERE’s analyses conducted for 2011 and 2015, a period in which gas prices declined.  Despite declining gas prices, EERE’s cost-effectiveness “determinations” markedly increased by the percentages shown in the right-most column. Depending on what the furnace AFUE was and where it was located, this percentage increases ranged between a negligible 1.1% and a whopping 2,156.3%. DOE avoided addressing this chart in numerous public meetings and filed comments that I submitted.

Contact Mark Krebs at the email address below for more explanation.

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[1] There is also a category for articles by Tom Tanton at https://www.masterresource.org/category/tanton-tom/ which covers topics beyond energy efficiency and EERE.

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Mark Krebs (markedwardkrebs@gmail.com), 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. His many MasterResource posts on natural gas vs. electricity and “Deep Decarbonization” federal policy can be found here. Mark’s first article was in Public Utilities Fortnightly, titled “It’s a War Out There: A Gas Man Questions Electric Efficiency” (December 1996). Recently retired from Spire Inc., Krebs has formed an energy policy consultancy (Gas Analytic & Advocacy Services) with other veteran energy analysts.

Tom Tanton (tantontwitter@gmail.com) is a Director of the Energy and Environmental Legal Institute. Mr. Tanton has 45 years in energy and environmental policy, focused on enabling technology choice and economic development. Mr. Tanton has testified to numerous state Legislatures and Congress as an expert on energy policy. He formerly served as Principal Policy Advisor at the California Energy Commission.