by Tom Tanton, E&E Legal Director of Science and Technology Assessment, and Mark Krebs
As appearing in MasterResource
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).
The issue involves revising a decades-old accounting convention for site-versus-source energy calculations. With the subsidy- and mandate-driven growth in various renewables for electricity, EERE determined that the existing accounting did not fully capture renewables.
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. Today we cover procedural deficiencies; Part 2 tomorrow will cover technical deficiencies.
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. The intent is for all to begin using this new (and highly debatable) “captured energy” metric as a basis when comparing the direct use of fossil fuels with “averaged” Btu of electricity.
This “captured energy” metric further appears to assume that averaged Btu’s in each kWh will continue to decline in some forecasted fashion, primarily due to a widespread shift towards renewable form of electric generation; perhaps attributable to a full implementation of the soon deceased “Clean Power Plan” and greater reliance on renewables for electricity (if that term can be accurately used with unreliable sources.)