“Perhaps most important is the self-fulfilling prophesy: if renewables are made to look more attractive, they’ll increase in actual use. As they increase in use, according to the EERE Guidance document but not reality, they look more favorable. Rinse and repeat.”
“The net effect of the “guidance” is to artificially discriminate against one of America’s most abundant and cleanest energy forms, natural gas.”
“… we believe DOE should rescind this report and any applications of it within Federal policies and regulations.”
Part 2 identifies some of the more egregious technical flaws in EERE’s “Accounting Conventions for Non-Combustible Renewable Energy Use.” Part I yesterday discussed process deficiencies.
Despite the innocuous appearance of an RFI, what EERE ultimately did was to issue a “Technical Report” which, in fact, is more far-reaching than just “guidance” and would impact a multitude of state and federal programs.…
“EERE inappropriately colluded with NRDC, and some in the electric industry, to its predetermined and self-serving conclusions. Clearly, EERE’s mission is to promote energy efficiency and renewable energy. This fact makes them biased, consciously or unconsciously. They are an inappropriate custodian of such metrics.”
“Originally limited to technology development, assessment and promotion, some offices in DOE are now using the cudgel of regulation and ‘guidance’ to ensure their favored technologies ‘win’ regardless of the national interest.”
“Taking the form of an RFI, the proposed change is both procedurally and technically deficient, resulting in regulatory guidance that is discriminatory and lacks basis.”
This is Part 1 in a two-part article about an abuse of the Request for Information (RFI) process at the Department of Energy’s Office of Energy Efficient and Renewable Energy (EERE).…