Dear Principal Deputy Assistant Secretary Speakes-Backman: We, the undersigned Associations, submit the following comments in response to the proposed rule Energy Conservation Program: Energy Conservation Standards for Commercial Water Heating Equipment, 87 Fed. Reg. 30610 (May 19, 2022) (“Proposed Rule”). These comments center on the Proposed Rule’s use of the social cost of greenhouse gas (“SC-GHG”) estimates.1 The Associations appreciate the opportunity to share our feedback and extend an offer to engage with the Department of Energy (“Department”) in addressing these comments.
Combating climate change requires citizens, governments, and businesses to work together. The Associations continue to leverage the innovation and the strength of American business to find durable solutions that improve our environment, grow our economy, and leave the world better for generations to come. We offer these comments to respectfully raise vulnerabilities in the Proposed Rule associated with the use of the SC-GHG estimates along with actionable suggestions for the Department.