A Free-Market Energy Blog

Update: ‘Is DOE Leading Us Astray?’ (A 1999 analysis revisited)

By -- April 5, 2018

“In DOE’s ostensible energy efficiency zealousness, it assumes ‘command and control’ of a portion of the economy. Such political markets inevitably displace free markets, as vested interests organize and mobilize resources to protect and enlarge their abilities, against less powerful stakeholders, to determine regulatory outcomes.”

In 1999, “Is DOE Leading Us Astray?” was published in a business trade journal. That journal no longer exists, but my article’s message can be revisited to assess how the current situation.

The original is indented and in red, followed by my responses: [1]

When you do the math, properly ac­counting for the delivered efficiency of the two energy forms, one sees that elec­tricity is delivered at an overall efficiency of 27% and natural gas is delivered at an overall efficiency of 91% (using the above illustrative EFs). Thus, natural gas pro­vides twice as much hot water compared to electricity for the same amount of fuel as shown below:

  • Electric: (88% efficient water heater) x (27% efficient site-to-source delivery) = 24% efficient.

  • Gas: (54% efficient water heater) x (91% efficient site-to-source delivery) = 49% efficient.

Update: The point here is that the official metric for energy efficiency goes back to the original Energy Policy and Conservation Act of 1975 (EPCA). This hasn’t changed and remains controversial. What has changed within EPCA is that the current debate has eclipsed the decades-old “site versus source” argument to one focused on emissions; especially carbon dioxide.

Along with open-ended terms like “as the Secretary determines,” this focus has flourished; first, in the war against coal, which has more recently been extended to all fossil fuels; including natural gas. This is accompanied with considerable mission creep to promote “clean energy,” which is now the theme of DOE’s Office of Energy Efficiency and Renewable Energy’s mission statement. [2]


“Black box” analytical procedures. For example, the following computer programs (at a minimum) are involved for “National Appliance Energy Conservation Act” (NAECA) end-use modeling: NEMS: the Energy Information Administration “National Energy Modeling System”; REM: the “Residential Energy Model”; COMMEND: the “COMMercial sector END-use planning system”; REEPS: the “Residential End-use Energy Planning System”; ARC/Info and Earth Resources Data Analysis System (ERDAS). If you can get the source code, operating these programs usually requires expensive hardware (such as mainframes) and full-time programming staffs. Consequently, DOE models effectively preclude independent analyses. Additionally, skewing inconspicuous input assumptions buried in DOE’s model(s) can significantly alter results.

Update:  This situation has continued to deteriorate. EERE’s analytical procedures have continued to increase in mass, complexity and trickery; all of which works to force rule benefit. The evidence for this is overwhelming and voluminous but ignored. And not just by DOE.  The Department of Justice (DOJ) and the Whitehouse Office of Management & Budget (OMB) have also neglected their oversight authorities.


In short, definitional loopholes let DOE manipulate consensus processes and transparent and robust analytical methods called for by law that, in DOE’s words, should be “as sound and well-accepted as possible, fully documented for the public, and produce results that can be explained and reproduced.”

Update: The good news here is that Daniel Simmons, ex-IER Vice President for Policy and now EERE’s Principal Deputy Assistant Secretary, recently initiated an Request for Information (RFI) about this problem. It is Docket EERE-2017-BT-STD-0062, titled Procedures, Interpretations, and Policies for Consideration of New or Revised Energy Conservation Standards for Consumer Products.  At issue here is EERE’s “Process Rule.” The Process Rule,[3] as reiterated in the Code of Federal Regulations, is an actual binding rule.  However, because the Process Rule is exempt from judicial review, EERE treats the rule as a mere collection of guidelines that it has discretion to follow. This can be rectified by eliminating the following text at the Section 14 (c) of the Process Rule which states:

(c) Judicial review. The procedures, interpretations, and policies stated in this Appendix are not intended to establish any new cause of action or right to judicial review.

“Industry” comments for this docket are generally aligned on this enforceability issue.  This includes electric utility trade associations.


A recent EPRI conference reported that their goal is now to “increase electrification 50 percent over the next 10 to 15 years.” Bob Galvin, chair of Motorola’s Executive Committee, who headed DOE’s “Task Force on Alternative Futures for the National Laboratories” (a.k.a. the” Galvin Task Force” that permitted DOE’s national labs to work directly for “industry”), expressed sentiments at this conference that made EPRI’s predictions look meek.

According to Galvin: “To me, 50 percent seems overly conservative. I would look for multiples. The opportunity to enhance the service to society with energy ought to be multiplied three to five times in the course of 15 years.”

Update: These electrification goals from 1996[4] have not been realized. But they haven’t given up.  In fact, they have expanded to attain a monopoly on energy.  For more details, see the recent MasterResource article titled Warring Against Natural Gas: Joint EEI/NRDC Statement to NARUC (crony environmentalism at work).

This concludes my update. The original article can be viewed by clicking here.


Mark Krebs, an engineer by training, 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 Mark, please see Mark Krebs: Digging Down on Energy Efficiency Claims (an interview).


[1] The original article can be viewed by clicking here

[2] https://www.energy.gov/eere/mission

[3] https://www.gpo.gov/fdsys/pkg/FR-1996-08-27/pdf/FR-1996-08-27.pdf

[4] Technology and the Transformation of the Electricity Industry, Brent Barker http://www.epri.com/EPRI_Journal/nov_dec96/techtrans.html (link no longer working)


  1. Ed Reid  


    “Illegitimi non carborundum.”


  2. Mark  


    A Bay Area resident just went through a home improvement process that likely used some of the assumptions in the models noted in your post to justify some of the benefits when finding out “What Does It Take to Electrify Everything in Your Home”


    Do you know if the homeowner is required to pay some exiting service fee to PG&E for their allocated costs for infrastructure improvements that were required by the CPUC over the years?



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