Summary
Energy “savings” as asserted by DoE in its notional CRE Standards as analyzed in the
Notice of Data Availability and Request for Comment are illegitimate as a benefit of any such
Standards because they shunt aside the CRE performance benefits attendant upon the higher
energy use currently observed. CRE consumers, after all, are not fools. In any event, the energy
savings even as estimated by DoE are trivial: about 2 tenths of one percent (0.0023) of the total
energy consumed in 2023 by the residential, commercial, and industrial sectors.

The reduction in GHG emissions asserted by DoE as impacts of the Standards would be
less than five one-hundredths of 1 percent of U.S. GHG emissions in 2022. The attendant decline
in global temperatures would be about eight one-hundred thousandths of a degree C (0.00008°C)
by 2100. Because the standard deviation of the surface temperature record is about 0.11°C, that
effect would not be detectable.

DoE attempts to circumvent this reality by substituting the social cost of carbon, a
fundamentally flawed parameter. It is driven by Representative Concentration Pathway 8.5, an
assumed future GHG emissions/concentrations scenario so extreme that it is essentially
impossible. RCP8.5 is incorporated into climate models that overstate the actual satellite
temperature measurements by a factor of over 2.3. It incorporates the asserted global effects of
increasing atmospheric concentrations of GHG, despite the fact that most such effects, whether
consistent with the evidence or not, will be borne by individuals not residing with the U.S., and
thus essentially unaffected by U.S. policies. It ignores the uninternalized social benefits of rising
GHG concentrations. Examples are planetary greening, increased agricultural productivity,
increased water use efficiency by plants, and reduced mortality from cold. The calculation of the
SC-GHG is driven primarily by the inclusion of “co-benefits” in the form of reductions in criteria
and hazardous air pollutants already regulated by EPA, a fundamental exercise in double counting.
The SC-GHG employs discount rates artificially low to evaluate the purported future streams of
benefits and costs engendered by GHG policies. Finally, the SC-GHG as estimated by the Biden
administration mischaracterizes the GDP effects of rising GHG concentrations as projected in the
central integrated assessment models.

The proposed CRE Standards are fatally flawed, and should not be finalized.

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