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DOE Relies on Private Benefits to Justify $3 Billion Energy Efficiency Rule Open Access

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According to DOE’s proposed rule, furnace fans achieving these energy efficiency levels “are already commercially available for at least some, if not most, product classes covered by this proposal.” That is, in many cases, consumers already have the option to purchase a higher-cost, higher-efficiency product. The fact that consumers are not already availing themselves of this option indicates that consumers either are uninformed about the costs savings associated with purchasing the higher-efficiency products or they do not value future energy savings as much as DOE thinks they should. Neither of these constraints would be addressed by the Department’s proposed rule, which would instead set a blanket efficiency standard applicable to all consumers, regardless of preferences.

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