Washington, DC (February 12, 2013) – In comments filed yesterday with the Department of Energy (DOE), the National Propane Gas Association (NPGA) called on DOE to include a Full-Fuel Cycle (FFC) analysis in its new water heater test procedure and the new universal energy descriptor. Additionally, the propane industry urged DOE to include FFC information on any label recommendation to the Federal Trade Commission (FTC).
NPGA argues in its filing with DOE that of the two types of possible energy consumption measures:
The FFC analysis is the most accurate way to calculate energy use and environmental emissions because it accounts for (1) Energy consumed in the extraction, processing and transport of primary fuels; (2) Energy losses in electric power-generation or gas processing plants; (3) Energy losses associated with transmission and distribution of fuel to the end user; and (4) Greenhouse gas (GHG) emissions associated with each step within this process.
The current standard, called site or point-of-use consumption, reflects only the energy use by an appliance or vehicle at the site where the appliance or vehicle is operated. This type of measurement does not give a realistic portrayal of the energy consumed by a product, such as a water heater, because it fails to take into account energy losses occurring from the generation, transmission, and distribution of the fuel to the product.
For example, under the site consumption standard, an electric storage water heater might operate with 95 percent efficiency and a propane gas heater with 70 percent efficiency. However, when the full scope of energy consumed is accounted for in the FFC method, the electric water heater operates at about 24 percent efficiency compared to the propane heater’s 62 percent efficiency.
Rick Roldan, President and CEO of NPGA stated, “It’s incumbent on the Department of Energy to inform consumers of the entire energy consumption portfolio of a product, not just the end use. Water heaters are a great example of how utilizing the FFC method can help consumers make a better informed decision when shopping for energy efficient and environmentally friendly products.”
The National Academy of Sciences (NAS) also supports this concept. Stating in its final report on a study authorized by the Energy Policy Act of 2005, the NAS concluded, “DOE should consider moving over time to the use of a full-fuel cycle measure of energy consumption for assessment of national and environmental impacts, especially levels of greenhouse gas emissions, and to providing more comprehensive information to the public through labels and other means, such as an enhanced website.”
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