Dear EERE: Past Time to Debate “Deep Decarbonization” (Obama program inconsistent with America First energy policy)

By Mark Krebs and Tom Tanton -- February 14, 2019

“With a clean electricity system comes opportunities to reduce fossil fuel usage in these sectors: for example, electric vehicles displace petroleum use and electric heat pumps avoid the use of natural gas and oil for space and water heating in buildings.”

–  The While House, United States Mid-Century Strategy for Deep Decarbonization, (November 2016)

“Assuming we all want to avoid an American repeat of the French “Mouvement des gilets jaunes” (yellow vest movement) the economic realities of ‘deep decarbonization’ through ‘electrification’ must be a priority for public debate and discussion.” (below)

As Senator Everett Dirksen is credited with saying: “A million here, a million there, and pretty soon we’re talking real money.” Not much has changed, except for inflation. Now it’s more like $40 million here and $50 million there. Such it is with DOE’s Office of Energy Efficiency and Renewable Energy (EERE) and their opaque and hiding in plain sight funding for a “transition to a global clean energy economy.”

The most recent examples of which are:

• Energy Department Announces Request for Information Concerning Efficient and Flexible Building Loads
• DOE Announces Notice of Intent to Issue a Funding Opportunity Establishing a Cybersecurity Institute for Energy Efficient Manufacturing.

While it looks transparent and comprehensive, it isn’t. EERE’s thread-bare “global mission [creep]” remains anchored to an Obama-era strategic plan. Despite the election of President Trump and his pledge to extricate the U.S. from the “Paris Agreement,” EERE’s strategic plan has not evolved. Rather, it continues as an enabler of the “Paris Agreement” and President Obama’s intent to fulfill it via his “United States Mid-Century Strategy for Deep Decarbonization.” The following was published November 2016; awaiting implementation by Obama’s heir apparent, Hillary Clinton:

With a clean electricity system comes opportunities to reduce fossil fuel usage in these sectors: for example, electric vehicles displace petroleum use and electric heat pumps avoid the use of natural gas and oil for space and water heating in buildings.

For there to be a transition to something, there must be a transition from something. The from, as evidenced by the above excerpt, is the forced but subliminal transition away from natural gas and other diverse fuels. Those diverse fuels are freely chosen by informed consumers for affordability, reliability and resiliency under pressure.

Total “EERE taxpayer investment” of $1.2 Billion expenditures for this politically driven “transition to a global clean energy economy” are shown here. Recent expenditures are shown here.  Both of which contradict promises made by the President and reinforced by DOE Secretary Rick Perry during an interview last summer. As Perry stated:

We’re not going to pursue policies that tell businesses and consumers to choose one energy source over another. Each region of the United States has its own unique energy needs, and we realize businesses and consumers must be able to choose from a wide range of energy portfolio options. At the Department of Energy, we’re focused on the science and technology that will maximize the development and potential of all of our energy resources, including natural gas. The American people should be able to use the type of energy that they think is best for their businesses, their lives and their families.

The complete Perry interview is available here. Perhaps EERE’s “career professionals,” the National Labs and their legions of contractors just haven’t caught up with the new policy. We will go with that assumption for now in hopes of correcting this miscommunication from the boss.

EERE continues pushing policy and out-of-proportion funding to electrify everything. However, EERE’s funding of electrification ‘science’ is relatively minor in comparison to what it would cost to implement this hackneyed old policy. We’re talking about “real money” that, at a minimum, roughly equals the National debt ($22 Trillion) or the GDP ($19.39 Trillion) according to most comprehensive analyses. We think the total amount will end up being more like $30 Trillion ± $10 Trillion; depending in part on the speed and technology within this transition.

Assuming $30 Trillion and a present US population of 328 million, the amount of this forced transition would cost each man, woman and child over $91,000. Further, it would reduce diversity and hence reliability, while increasing consumer costs in the face of such events as the recent polar vortex. And don’t forget, the National debt adds to this burden another $67,000 per person. How’s that for “social justice?”

Given the potential for such massive and adverse economic impacts, DOE/EERE needs to be totally up front and transparent with American taxpayers about what its mission is and what the ostensible costs and benefits are. Most importantly what is DOE/EERE rationale behind electrifying everything.

Specifically, what good will it do, other than enriching electric utility investors with a complete monopoly over energy and making them “too big to fail?” Relying on the same consultants to regurgitate the tired policies of bygone years and relying on favored electricity technologies just doesn’t cut it. Neither does EERE’s approach to “peer review” do anything other than belie Secretary Perry’s previously referenced public statements.

By limiting debate, the current approach limits choice. By limiting choice, the current strategy economically harms hard working American consumers. By forcing this “clean energy” nirvana upon consumers, it could kill them, considering what it would take to displace traditional heating fuels during the recent polar vortex events.

We urge the Whitehouse and/or DOE/EERE appointees to exert leadership by broadly and objectively framing this debate and publishing it in the Federal Register. One simple yet far reaching action would be to more fairly include alternatives TO electricity as well as alternatives FOR electricity.

We further urge DOE/EERE to collect and disseminate public comments and ideas via regulations.gov, in the interest of transparency and completeness. However, if DOE/EERE has a better way, we’re “all ears.”

Here is another consideration: According to US law, regulatory proposals that have the potential of exceeding $100 million of economic impacts are considered to constitute a “Major Rule,” as follows:

A major rule, as defined by 5 U.S.C. § 801 (Pub. L. 104-121) is a rule resulting in, or is likely to result in, an annual effect on the economy of $100 million or more or meets other criteria specified in that Act. The classification as a major rule is ultimately made by the Administrator of the Office of Information and Regulatory Affairs (OIRA). Major rules are subject to review by OIRA before they can be published as proposed or final rules in the Federal Register.

The strategy for universal electrification is made up of many ‘little’ rules that, individually, may not technically qualify as “major rules.” However, combined, their cumulative effect certainly does. Just as with cumulative effects in environmental analysis under the National Environmental Policy Act (NEPA), the combined effect needs transparency for stakeholders. If the American public deserve to understand rules that cost $100 million, they deserve to understand a strategy that could potentially cost $30 Trillion in total.

Another way of addressing this of course is through litigation. Given the virtually unlimited resources of the Federal government with which to litigate, this is something we would prefer to avoid, and the Federal government is supposed to avoid per Executive Order 12988 titled Civil Justice Reform.

The Takings Clause of the Fifth Amendment to the United States Constitution reads as follows: “Nor shall private property be taken for public use, without just compensation.” The last time we checked, DOE/EERE was not authorized to initiate such actions.

But that is exactly what DOE/EERE is doing; especially through it’s National Labs and contractors as evidenced by the following excerpts:

• National Renewable Energy Laboratory (NREL) is spearheading the Electrification Futures Study, a research collaboration to explore the impacts of widespread electrification in all U.S. economic sectors—commercial and residential buildings, transportation, and industry.
• For more information on the Electrification Futures Study and data sets, visit nrel.gov/efs.
• NREL is the U.S. Department of Energy’s primary national laboratory for renewable energy and energy efficiency research and development.

Absent an honest and open public debate, DOE/EERE’s present strategy of funding an ill-conceived wholesale transformation of our energy infrastructure will continue to be a few tens of millions here and a few tens of millions there and is yet another example of the same on-going “stealth policy” that we discussed at MasterResource when the Trump Administration was just getting started:

• Federal Energy Efficiency Mandates: DOE’s End Run vs. the Public Interest (Part I)
• Federal Energy Efficiency Mandates: DOE’s End Run vs. the Public Interest (Part II)

Assuming we all want to avoid an American repeat of the French “Mouvement des gilets jaunes” (yellow vest movement) the economic realities of “deep decarbonization” through “electrification” must be a priority for public debate and discussion. At the same time however, we should expect at the rate that rational energy and environmental policy discussions are devolving (e.g., the “Green New Deal” Resolution), stocking up on yellow vests might be a smart investment.

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Mark Krebs, a degreed engineer, has been involved with energy efficiency design and program evaluation for more than thirty years. He has served as an expert witness in dozens of energy-efficiency filings, which he summarized in a Public Utilities Fortnightly article, “It’s a War Out There: A Gas Man Questions Electric Efficiency” (December 1996). For more about the author, please see Mark Krebs: Digging Down on Energy Efficiency Claims (an interview).

Tom Tanton, Director with Energy and Environmental Legal Institute, has worked 44 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 and later as General Manager at the Electric Power Research Institute (EPRI).