Arlington, VA – 01/11/2012 – The Consumer Electronics Association®
(CEA) is calling on the California Energy Commission (CEC) to reject a proposed regulation for consumer battery chargers due to a flawed justification and unnecessary duplication of a federal regulation.
The CEC has scheduled a meeting to adopt the proposed regulation on January 12, 2012, in conflict with a long-scheduled industry trade show, the 2012 International CES®, which involves many significant stakeholders in the CEC's battery charger proceeding.
"The CEC's proposal to regulate consumer battery chargers is flawed, unnecessary and duplicative of a federal regulation already underway. Moreover, the process surrounding this proposed regulation has been a concern, with the CEC's most recent public comment period scheduled during the holidays and an adoption hearing scheduled in conflict with the 2012 International CES, a major event for a large number of industry stakeholders interested in the battery charter proceeding,” said Douglas Johnson, CEA's vice president of technology policy. "Worse, the CEC has not provided responses to the previous round of public comments on its proposed regulation, saying that it will provide comments after the regulation is adopted.”
CEA and other major stakeholder groups recently commissioned an in-depth report examining the model the CEC used to justify its proposed regulation for battery chargers. The report was produced by the Berkeley Research Group based in Los Angeles, Calif.
"After extensive review of the model, we discovered the CEC's calculations contain arithmetic errors and are based on outdated data, which overstate product energy savings and understate the incremental costs of compliance,” said C. Paul Wazzan, Ph.D., Berkeley Research Group director. "We corrected these errors and created a new model to reflect a more realistic picture of the effects of the proposed regulation on first-year energy savings realized by California consumers. The corrected CEC approach and our new model both show that the proposed regulation would more often than not negatively impact consumers.”
"As an industry strongly supportive of energy efficiency, we continue to be concerned about how energy efficiency regulation is being justified and pursued in California,” said Johnson. "In each and every CEC rulemaking related to consumer electronics, including the regulation for televisions that took effect in 2011, we have seen flawed analysis that results in misleading claims regarding energy savings for California consumers and ratepayers.”
According to the CEC, the proposed battery charger regulation, once fully implemented, would save California ratepayers approximately $306 million per year. While the CEC purports to calculate cumulative savings "up to the point where compliant products begin replacing noncompliant products,” the CEC's model calculations actually estimate first year savings attributable to the regulation after a complete turnover of the current stock.
The report finds that this simplistic approach is fundamentally flawed and logically unsound as it fails to adequately account for several significant factors, including: product turnover; the time value of money; the potential impact of a pending U.S. Department of Energy regulation for battery chargers; the incremental cost of compliance; and technological improvements due to competition.
"Unjustified or poorly justified regulation is something that California can least afford, given the state's high unemployment and already burdensome regulatory regime, but also given California's important goals and objectives for saving energy and reducing emissions,” said Johnson.