AHAM supports modernizing the Energy Policy and Conservation Act (EPCA) provisions that apply to home appliances. Although innovative technology has touched all aspects of our lives, including the products in our homes and how we work together, important provisions of EPCA have not been updated since the end of the Cold War.
Updates to the law should preserve certain time-tested requirements in EPCA. EPCA is intended to produce achievable energy conservation standards that are grounded in real-world data and design solutions developed in a transparent and timely manner. It balances the goal of energy efficiency with the understanding that savings are best achieved when the most valued features, performance, and capacities are preserved. EPCA’s mandates also include protecting product affordability, which is reflected in its requirement that standards be economically justified.
Critically, the appliance standards program EPCA created is a national one, which ensures manufacturers are able to design and build products for a national market rather than for individual states, providing economy of scale savings for consumers.
AHAM supports the following common-sense improvements to EPCA including:
- DOE should not be allowed to set new standards levels that are harmful to consumers or the economy, or that remove valuable products and features from the market.
- Thoughtful consideration of the impact on consumer welfare and cumulative regulatory burden should inform every standard-setting process.
- Transparency and public engagement with consumers, manufacturers and other stakeholders is key to developing standards that are achievable, that meet consumer needs, and that achieve cost-effective efficiency goals.
- Test procedures should be finalized before issuing a proposed rule for minimum levels that relies on those test procedures. In addition, when there is a need to quickly update a test procedure in a way that will not alter measured energy or efficiency (for example, if required test materials become unavailable) DOE should be allowed to update the test procedure quickly and efficiently.
- When there is broad consensus support for particular test procedure amendments, DOE should be able to act upon a joint statement from parties representative of varying points of view through the same process it currently uses for jointly recommended energy conservation standards
- AHAM supports an approach that allows regulators to focus on the most cost-effective opportunity to conserve energy and water while preserving consumer choice. AHAM supports a process that allows implementation of a new standard before beginning revisions.
Many of the challenges in the appliance standards program originate from EPCA’s outdated requirement that DOE must re-evaluate standard levels without regard to innovation but solely based on the passage of time. This results in an endless loop of regulatory process without public benefit or thoughtful, timely analysis justifying new standards. For example, clothes washers have been subject to eight revisions since the program began. Because some energy and water will always be needed to wash and clean clothes effectively, the opportunity to save additional water and energy is inevitably declining.
AHAM will continue to urge members of Congress to pass legislation that will modernize EPCA in a meaningful way.
On September 13, AHAM testified before the House Energy & Commerce Subcommittee of the US House of Representatives. AHAM's testimony can be read here.