DIANNE FEINSTEIN 

CALIFORNIA 

~ntttb ~tatt~ ~tnatt WASHINGTON, DC 20510-0504 

The Honorable Steven Chu 

Secretary 

U.S. Department of Energy 

1000 Independence Ave., SW 

Washington, DC 20585 

Dear Secretary Chu: 

http://leinstein.senate.gov 

October 2, 2012 

SELECT COMMnTEE ON INTELLIGENCE· CHAIRMAN 

COMMITTEE ON APPROPRIATIONS 

COMMITTEE ON THE JUDICIARY 

COMMITIEE ON RUlES AND A.DMINISTRATION 

I am writing to request an explanation of the assumptions, analyses, and cost 

estimates used by Department of Energy (DOE) to develop its proposed minimum 

efficiency standards for consumer product battery chargers. 

Our society is increasingly reliant on battery-powered consumer electronic 

products like cell phones and laptop computers, so I am pleased that DOE has undertaken 

the important task of ensuring battery chargers satisfy minimum efficiency requirements. 

Multiple studies by McKinsey and Company have found that increasing the efficiency of 

consumer electronics is the single most cost effective means of reducing greenhouse gas 

emissions. 

Many of my constituents are concerned that DOE's proposed standards have 

overlooked simple and inexpensive improvements to battery chargers, rely on outdated 

and incomplete information, have an aggressive schedule for implementation, and include 

labeling requirements that may not be flexible enough. In order to better understand how 

DOE developed these proposed efficiency standards, I would appreciate it if you could 

answer the following questions. 

• Consumer electronics technology evolves rapidly, so it is important that the most 

current cost estimates and technical data serve as the basis for developing new 

efficiency standards. The California Energy Commission (CEC) recently developed 

efficiency standards that are more stringent than DOE's proposed requirements. The 

CEC evaluated least-cost technology pathways to achieve compliance and concluded 

that its standards are cost effective for California and the nation. 

According to the CEC, the DOE's cost-effectiveness analysis did not use least-cost 

technology and did not appropriately separate the costs of energy efficiency from 
other quality-enhancement costs. As a result, DOE has concluded that the California 

energy efficiency standards are not cost effective. The CEC estimates that 

implementing the less stringent DOE standards instead of the California standards 

would increase electricity bills $400 million annually in the United States. 

How does DOE plan to ensure that accurate cost-effectiveness analyses, including 

appropriate incremental costs of energy efficiency components, are used to maximize 

energy savings benefits in the United States? Why has DOE relied on technical 

information gathered in 2010 as the basis for its rule when more efficient products and 

cost effective designs have been subsequently introduced? 

• I believe it is important for DOE to move expeditiously to promulgate cost-effective 

standards that maximize energy savings. Finalizing federal standards will preempt the 

California standards. I am also aware that manufacturers of electronic products have 

requested a reasonable time period to make design changes necessary to comply with 

the new requirements. Please explain how the time line for DOE's proposed standards 

will ensure that California's standards are not preempted before a similarly protective 

standard is in place, while providing manufacturers sufficient time to comply with the 

new requirements. 

• I am aware that DOE has received extensive comments regarding the proposed 

efficiency standards. At least one organization has expressed concern that new 

standards require labeling directly on product casings, which may be overly 

cumbersome to implement. Because mandating labeling requirements would 

negatively impact marketing and branding strategies for some companies, does DOE 

intend to allow flexibility for compliance with these labeling provisions? 

I thank you for your efforts to establish minimum energy efficiency standards for 

consumer product battery chargers. I look forward to hearing from you regarding this 

important request. If you have any questions or concerns, please feel free to contact me 

in my Washington office. 

DF/mbn/ba 

Sincerely, 

Dianne Feinstein 

United States Senator