FR 2021-03154

The document involves the Department of Energy (DOE) requesting an extension for its information collection activities. The extension seeks approval under the Paperwork Reduction Act for an additional three years. It focuses on gathering data and maintaining records related to energy or water conservation standards for various products and equipment, covering items like refrigerators, air conditioners, and heating equipment. The DOE outlines procedures for information collection, certification, compliance reporting, and recordkeeping for manufacturers.

General Summary

The DOE's proposal entails a comprehensive information collection process designed to ensure compliance with conservation standards, enabling the DOE to regulate efficiently the energy performance of consumer products and commercial equipment. This notice seeks public comment as part of the Office of Management and Budget's (OMB) review process. Critical elements under review include certification reports, compliance statements, recordkeeping, waiver applications and labeling requirements for products subject to federal energy or water conservation standards.

Significant Issues and Concerns

Several concerns arise surrounding the impact of these reporting requirements on manufacturers. Notably, the Air-Conditioning, Heating, and Refrigeration Institute (AHRI) highlighted the burdensome nature of the reporting requirements, citing delays in the release of necessary reporting templates by the DOE. The lateness of these templates can impose additional pressures on companies by compressing timelines and complicating compliance efforts. AHRI also expressed concerns about the breadth of data collection by DOE, which sometimes goes beyond what is essential for compliance, raising apprehensions about confidentiality and data protection.

Moreover, feedback points to overlapping regulatory requirements from different bodies, potentially leading to duplicative reporting efforts and inefficiencies. The stakeholders have urged DOE to streamline its data collection processes to mitigate unnecessary paperwork and costs, emphasizing issues with workflow planning due to unpredictable DOE timelines.

Impact on the Public

The document has broader implications for the general public. By ensuring that manufacturers comply with federal energy conservation standards, the DOE aims to promote energy efficiency, ultimately benefiting consumers through lower energy costs and a reduced environmental footprint. However, if compliance requirements are overly burdensome, it could influence product prices or limit the availability of some models, indirectly affecting consumers.

Impact on Specific Stakeholders

Manufacturers and industry stakeholders such as the AHRI are significantly impacted by these requirements. They face administrative burdens, increased costs, and potential inefficiencies due to the complexity and scope of DOE's data collection processes. The concerns of stakeholders indicate a need for the DOE to re-evaluate its requirements to ensure they are not unduly onerous and align with business cycles for better predictability.

For regulatory bodies, the document suggests a potential avenue for improved collaboration and harmonization of reporting requirements. By aligning reporting mechanisms across agencies, stakeholders could reduce paperwork costs and administrative friction.

Conclusion

In summary, while the DOE's proposal aims to bolster energy conservation efforts, there are pressing concerns regarding the efficiency and practicality of its reporting requirements. Stakeholders contend with significant challenges that, if unaddressed, complicate compliance. The DOE's acknowledgment of these issues is a promising step, though concrete actions to resolve them remain unspecified. Enhanced communication and timely provision of reporting templates are crucial to fostering a collaborative and efficient regulatory environment.

The Federal Register document submitted by the Department of Energy (DOE) includes an important financial aspect related to the implementation and compliance with energy conservation standards. One of the key components discussed is the Annual Estimated Reporting and Recordkeeping Cost Burden, which is projected to be $77,306,000. This represents the anticipated expenses associated with the administrative requirements placed upon manufacturers by DOE's energy efficiency regulations.

The financial burden primarily stems from the significant number of estimated hours needed to comply with reporting requirements. DOE estimates approximately 773,060 hours are necessary annually to fulfill these obligations. The time is spent on activities such as handling certifications, creating supplemental testing instructions, and preparing waiver applications. Each certification alone is estimated to require 35 hours. Additionally, specific tasks related to creating labels and preparing representation extension requests also contribute to the hour tally.

These financial allocations are pertinent to several issues highlighted in the document. Comments from stakeholders, such as the Air-Conditioning, Heating, and Refrigeration Institute (AHRI), emphasize concerns over the complexity and extent of the reporting requirements. The high cost and time burden underscore the need for potentially streamlining processes to make compliance more efficient and less costly for manufacturers. AHRI and other stakeholders have suggested that DOE's reporting requirements might be over-extensive, leading to unnecessary financial burdens.

The document also reveals that DOE utilizes a Compliance and Certification Management System (CCMS) for electronic submissions, which aims to ease the financial load by standardizing reporting tasks. However, despite this aim, stakeholders have raised issues about inconsistencies and delays in releasing the necessary templates, which further complicate planning and potentially inflate costs. This is a critical concern that suggests inefficiencies in the system that could increase the financial burden beyond the estimated figures.

Overall, the financial references in this document reveal a significant monetary commitment required from manufacturers for regulatory compliance. Addressing the issues of complexity, predictability, and potential duplication in reporting processes could help reduce this substantial financial burden, which the DOE and stakeholders are keenly aware of, as reflected in various comments and feedback within the document.