Energy Efficiency Issue Brief (PDF)
Summary
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Energy efficiency is one of the most important, cost-saving tools available to utilities to meet energy demand, defer generation investment, reduce greenhouse gas and other emissions, and lower customers’ utility bills. |
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The federal government creates incentives for energy efficiency through legislation, regulations, the tax code, and executive orders. The American Public Power Association (APPA) is generally supportive of federal efforts to encourage and support energy efficiency if they are cost-effective for consumers and have a reasonable payback period. |
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Given that many energy efficiency improvements require changes in customer behavior that are beyond a utility’s control, APPA believes Congress should continue to provide incentives, grants, rebates, and federal support for energy efficiency research and development to encourage, but not mandate, achieving greater energy efficiency. |
Background
Energy efficiency is the ability to maximize energy use via more efficient technologies throughout the electric utility system, as well as for electric customers to minimize their energy use via a variety of tools, technologies, and behaviors. In other words, energy efficiency means using less energy to get the same task or function accomplished. Beginning with the Energy Policy and Conservation Act of 1975 (EPCA), Congress has passed several laws to promote energy efficiency standards for consumer products and equipment. Today, the Department of Energy’s (DOE) Building Technologies Office implements minimum energy conservation standards for more than 65 categories of products. The standard setting process, which includes the publication of a proposed rule in the Federal Register, allows for public and stakeholder feedback. DOE is required to set standards that are “technically feasible and economically justified.” In 2007, Congress passed the Energy Independence and Security Act, which required DOE to create a schedule for the regular review and updating of energy efficiency standards. DOE, along with the Environmental Protection Agency, administers the voluntary ENERGY STAR labeling program to identify products and building materials that go beyond federal energy efficiency standards
While many of the energy efficiency standards set by DOE regulate consumer products, including appliances, lighting, heating, ventilation, and air conditioning, and smart home energy technologies, some directly impact public power utilities, notably the energy efficiency standards for distribution transformers. Public power utilities, especially smaller ones, are often distribution-only asset owners and operators. A significant portion of their capital costs are for the transformers and wires that bring electricity to end- use customers.
APPA believes that any energy efficiency regulations on distribution transformers must not constrain market production and be economically justified to ensure that end-use customers recoup the costs for any increases in capital investments required through such regulations. Complex electric system equipment, like a distribution transformer, requires an especially flexible and thoughtful approach to energy efficiency regulations, as there are often situations where efficiency gains can come at the cost of broader optimal system operability.
Congressional Action
Several energy efficiency provisions were included in the Energy Act of 2020, which was enacted into law as part of the Consolidated Appropriations Act of 2021 (P.L. 116-260). Specifically, the law reauthorized the Weatherization Assistance Program (WAP), a DOE program that funds energy efficiency upgrades for low-income households. The Energy Act of 2020 also directed DOE to establish rebate programs to encourage the replacement of inefficient electric motors and transformers, which APPA supports.
The Infrastructure Investment and Jobs Act (IIJA/P.L. 117-58) appropriated an additional $2.5 billion for the WAP. It also appropriated $550 million for the DOE Energy Efficiency and Conservation Block Grant program, which provides block grants to cities, states, and Indian tribes for energy efficiency and conservation projects. Additionally, the law created a grant program for energy efficiency improvements and renewable energy deployment at public schools.
The Inflation Reduction Act (P.L. 117-169) extended or created several new tax incentives for residential energy efficiency improvements, including increasing the credit for residential energy efficiency home improvements, energy efficient home appliances, creating a rebate program for residential energy saving retrofits, and new grants for states to support energy efficiency training for contractors.
In December 2022, DOE issued a notice of proposed rulemaking (NOPR) to increase conservation standards for distribution transformers. APPA and a coalition of impacted industries advocated against the proposed rule as it would have exacerbated the ongoing transformer shortage and only provide minimal energy efficiency savings. Bipartisan legislation in the House and Senate was introduced to prohibit DOE from moving forward on the NOPR for five years and similar language was added to appropriations bills, though nothing was ultimately enacted into law. Responding to industry and congressional concerns, DOE in April 2024 released a final rule that scales back the required efficiency improvements and allows for five years for implementation rather than three years, as was in the proposed rule.
In June 2025, APPA filed comments in response to a DOE request for information seeking assistance in identifying potential modifications to its procedures, interpretations, and policies for considering new or revised energy conservation standards and test procedures for consumer products and certain industrial equipment. In its comments, APPA replied that DOE should make sure that revised standards do not exacerbate supply chain challenges, nor negatively impact consumer choice among higher-efficiency products. APPA used the 2022 NOPR on distribution transformer energy efficiency standards as an example, noting that if implemented as originally envisioned, it could have eliminated over 95 percent of products from the marketplace and thus have made already high lead times for distribution transformers even worse. APPA also encouraged DOE to ensure that it accounted properly for stakeholder input during the review process and to consider broader system impacts when evaluating specific products.
APPA Contact
Steve Medved, Government Relations Manager, 202-467-2928 / smedved@publicpower.org