Category Archives: Checking in on the Federal Register

Similar to the “Development in Energy Policy” series, this series of articles will shine a spotlight onto the incremental process of federal energy policy. Specifically, when there are notices in the Federal Register—the daily government journal where official agency rules, proposed rules, and public notices are published—relevant to the energy topics of this blog, I will read, summarize, and comment on those postings so you don’t have to do so yourself.

Proposed Changes to Energy Conservation Standards Program for Appliances

When the Trump administration took office almost a year ago, one oft repeated promise was to remove and reduce regulations across the board– though environmental and energy regulations were frequently called out specifically. Whether it was in an attempt to boost American oil and coal industries or make complying with environmental regulations for facilities in the United States cheaper, the stated goal was always to prop up a situation that would put ‘America first.’

In recent weeks, the U.S. Department of Energy (DOE) has started down a new path of cutting on regulation in the same intended vein. Specifically, DOE has signaled changes to come to the energy conservation standards program for appliances and other commercial and industrial products (otherwise known as the Appliance and Equipment Standards Program). What is the energy conservation program for appliances? What changes are being discussed? And how are energy advocacy groups responding? Keep reading to find out.



Background of Appliance and Equipment Standards Program

In its current form, the Appliance and Equipment Standards Program is mandated by the Energy Policy Conservation Act (EPCA), which requires DOE to set minimum energy conservation standards for over 60 consumer, commercial, and industrial products. Based on the standards that are set, companies must use the official test procedures (also established by DOE through formal rulemaking process) to test and certify that their products meet the minimum efficiency standards, while facing monetary punishments for every product knowingly shipped in violation of requirements. Not only that, but EPCA requires DOE to review the energy conservation standards and testing procedures for each of the applicable products every six years, surveying if and how the technology and market has changed, to determine if more stringent energy efficiency requirements are warranted (through its anti-backsliding provision, EPCA prevents DOE from walking back a future efficiency standard to be less stringent than one previously established). Also note that through this six-year review process, one of DOE’s possible (and not entirely uncommon) outcomes can be that the review is completed and the analysis dictates that more stringent standards are not feasible (whether it be because of an undue burden it would place on manufacturers, the lack of technological feasibility, the failure of potential standards to help consumers, etc.).

Source

These appliance and equipment energy standards were a hallmark of the Obama administration’s energy policy, having successfully implemented over 50 standards to save American household’s energy and also as a means towards reducing carbon emissions by at least 3 billion metric tons by 2030. Overall, the program as a whole has accounted for nearly $2 trillion in savings on American utility bills since inception in 1987. However as a part of the Trump administration’s efforts to roll back regulations across the board, energy efficiency standards have found themselves in the cross-hairs. Such efforts began early in the Trump presidency as several conservation standards that were pushed to completion in the last days of the Obama administration were subsequently put on hold and not published after Trump took office, while the DOE Secretary has identified the energy conservation program as ‘overly burdensome’ and ripe for reconsideration.

Impending changes

Starting at the end of November 2017, DOE began publicly weighing a complete overhaul of its Appliance and Equipment Standards Program. These changes would be the first significant reexamination of the DOE energy conservation standards program since the modern version of the law came to be in 1987, with the main stated goal of these changes being to allow for more flexibility.

Requests for Information

The first signal of these changes came in a Request for Information (RFI), wherein DOE proposed making these appliance standards more similar to corporate average fuel efficiency (CAFE) standards for motor vehicles. In these CAFE standards, car manufacturers can produce cars that fail to meet the set efficiency standards as long as the manufacturer also sells enough products that exceed the standards such that the average efficiency of the fleet meets the standards. Such a system is in contrast to the existing Appliance and Equipment Standards Program that requires all products to meet the mandatory levels. The RFI text states that ‘market-based policy mechanisms are potentially less burdensome alternatives as they use markets, price and other economic variables to provide incentives for regulated entities to reduce or eliminate negative environmental externalities in a least cost way.’ In addition to the option to average out product efficiency, this RFI also suggests such approaches as efficiency credit trading between manufacturers and ‘feebates’ that reward energy-efficient practices and penalize the failure to adhere to such practices.

As this first step in the rulemaking process (read about how the entire federal rulemaking process works here), DOE is soliciting feedback on how previously described market-oriented mechanisms, in contrast to the long-standing existing structure of the standards program, might be applied to the energy appliance standards program and how such programs have been successful elsewhere.

DOE also issued a second RFI later the same week as the first RFI to request feedback on its ongoing efforts to redesign the energy conservation standards program, specifically regarding the test procedures used to assess compliance with standards and the process used to establish standards. The proposed changes in this second RFI would be to allow establishing energy conservation standards through a quicker process of a negotiated rulemaking (which brings stakeholders in to essentially hammer out the standards with DOE, as opposed to the more extensive public back and forth from the existing rulemaking process), to establish additional means to solicit manufacturer feedback before a rulemaking process formally begins, using established industry standards for compliance testing (instead of continuing to set them through federal regulatory process), and requiring test procedures to be issued prior to the issuance of energy conservation standards.

Deferred action

In addition to the two RFIs, the Trump administration indefinitely deferred action on 20 appliance and equipment standards for household products (e.g., washing machines, refrigerators, and pool heaters) that are by law overdue for their updated review. While not subject to specific fanfare and announcement from the administration, this deferred action was signaled through changes to the Regulatory Agenda, removing the final action time for these 20 standards and placing them under the ‘long-term action’ label, meaning there is no expected regulatory action for these products over the next year.

Source

As an example, energy efficiency standards for commercial water heaters were proposed in 2016, with the legal deadline for a final rule (declaring whether more stringent standards for this product were warranted and, if so, what those standards would be) coming two years after the proposal. However those two years would pass as of May 2018, and since they are under the ‘long-term action’ umbrella, no action on them would occur at least until 2019 and the legal and statutory deadlines will be missed. This situation is similar for all 20 of the appliance and equipment standards that were placed under such deferred action, despite them all being marked as ‘under review’ during the regulatory agenda this past spring.

What is noteworthy about such a move is that, as previously stated, the six-year review for all standards can (and sometimes do) result in an analytical decision that more stringent energy efficiency standards are not warranted at a particular time. However, such decisions are rooted in extensive technological and market analysis, feedback from manufacturers and advocacy groups, and multiple series of proposals and reviews before a final decision is made (as is customary in the federal rulemaking process). But by choosing instead to not open up these standards for review, the measured analysis and thorough debate are prevented from even taking place on potential standards.

Response from energy advocates

In response to these proposed and impending alterations to how the appliance efficiency standards are set and regulated, a number of energy and environmental advocacy groups have made public statements about the effect they would have on future policy and American consumers.

Requests for information

An energy policy advocate at the Natural Resources Defense Council (NRDC) speculated that the proposed change to a CAFE-like standards program could lead to a dramatic reduction in American energy savings, while noting that the efficiency standards program must ‘be considered from the perspective of the consumers’ and that the ‘trading mechanisms DOE has proposed could lead to market confusion.’ A key difference between appliances and the automobile industry is that there are only a handful of very sophisticated car makers, whereas appliances have hundreds of manufacturers of all sizes and levels of energy expertise. The minimum efficiencies serve to protect consumers in situations where two products might look similar from the outside, but the energy use is vastly different due to the difference in manufacturer priorities and abilities. Further, the law behind the appliance standards mandates that standards are set at the ‘highest level that is technologically feasible and economically justified,’ not averaged across a suite of products. Adding in discussion of changing the process to set standards, NRDC also notes that the existing standards program is working well and has been for the 30 years of its existence. The desire to change it now, when nothing is broken, could ultimately do more harm than good and take away from the program that is currently working due to it being ‘straightforward, transparent, and easy for consumers to understand.’

Source

With regard to a shift to a CAFE-like system, a representative of the Appliance Standards Awareness Project (ASAP) expressed concern that such a switch would make the program more complex and difficult to follow, while ultimately opening it up for companies to game the system instead of the current system that puts the onus on the manufacturer to help the consumer save energy. The ASAP representative did, however, commend DOE for looking for ways to improve the Appliance and Equipment Standards Program instead of scrapping it completely and was reassured that the anti-backsliding provision would be effective in making sure existing standards never get weakened.

Deferred action

In its year-end review of energy policy, the NRDC identified the deferred action on the appliance standards as illegal based on the established statutory law, lamenting that in the end it is the American consumers who suffer. NRDC points out how essential such standards are and how important it is that they are reviewed and updated, as many products appear identical from the outside and standards ensure that consumers are getting a minimal level of efficiency. Looking at it economically, NRDC notes that standards implemented through 2016 save the average household $500 per year, while the continued implementation of the legally required standards (and improvements upon those standards) stand to save the country a cumulative $43 billion by 2035– but those savings are threatened if the deferred action continues. NRDC’s position is that all regulations are required by statute to be updated, and the “Trump DOE doesn’t get to pick and choose when to follow the law.”

Similarly, ASAP has noted that this deferred action is DOE indicating its intent to not follow the law, saying “I’ve never seen this before. They’re publishing a plan that flaunts the law. It’s a public plan basically thumbing its nose at congressional deadlines.” ASAP noted that while previous administrations, such as under George W. Bush, missed certain efficiency standard review deadlines, those administrations always appeared to be trying to complete its review and never punted on doing them at all as the Trump administration appears to be.

Lastly, ASAP and the American Council for an Energy-Efficient Economy (ACEEE) put out a joint statement in response to the deferred action, noting that by “deciding not to honor statutory deadlines for these standards, DOE is jeopardizing billions of dollars in savings for American families and businesses, while also creating uncertainty for manufacturers and markets.” ASAP and ACEEE urge DOE to fulfill their statutory and legal obligations in continuing to review and update energy efficiency standards at the regulatory mandated six year intervals.

Next steps

With respect to deferred action, if these standards continue to be shelved against the legal requirements of EPCA, then organizations like NRDC will likely sue, as they’ve already done for several standards that were completed during the Obama administration but the Trump administration has failed to make official by publication in the Federal Register.

Regarding the two RFIs, comments are being accepted through February 16, 2018. While the previously noted press releases from advocacy groups will surely be repeated by those groups in public comment on record to the RFI docket, as well as additional comments from other groups and manufacturers, if these issues are important to you then be sure to submit a comment expressing your viewpoint as a concerned citizen (and consult this post on advice on how to make sure your public comment is read seriously and creates as much influence and impact as possible). In addition, DOE is hosting a public meeting for discussion of these RFIs with all interested stakeholders on January 9, 2018. These public meetings are opportunities for manufacturers, energy advocates, or any other interested parties to give feedback to DOE on the topics discussed in the RFIs. For more information on how to submit comments and about the public meeting, see the official RFI publication in the Federal Register.

Sources and additional reading

Agency floats overhaul of energy efficiency standards: EE News

Changes to the Standards Program: More Harm than Good? NRDC

Current Regulatory Plan and the Unified Agenda of Regulatory and Deregulatory Actions: Executive Office of the President

Department of Energy Issues Second Request for Information (RFI) on Proposed Changes to its Appliance Standards Program: Lexology

Department of Energy Solicits Comments on a Major Rest of its Appliance Standards Program: Lexology

Defending Efficiency Standards: 2017 In Review: NRDC

DOE mulls changes to appliance efficiency program: Utility Dive

Procedures, Interpretations, and Policies for Consideration of New or Revised Energy Conservation Standards for Consumer Products: Federal Register

Statement of ACEEE and ASAP on Federal Plans to Put Updates to Appliance Standards on Ice: ACEEE

The $2 Trillion Success Story: Energy Efficiency Standards: NRDC

Trump administration ignores legal mandates to update appliance efficiency standards: ThinkProgress

About the author: Matt Chester is an energy analyst in Washington DC, studied engineering and science & technology policy at the University of Virginia, and operates this blog and website to share news, insights, and advice in the fields of energy policy, energy technology, and more. For more quick hits in addition to posts on this blog, follow him on Twitter @ChesterEnergy.  

Federal Register Notice: Test Procedure for Distribution Transformers: Request for Information

The Department of Energy (DOE) published a Notice of Request for Information (RFI) in the September 22, 2017 issue of the Federal Register (82 FR 44347) on the test procedure for distribution transformers. This article intended to break down what exactly is being requested by the DOE, the steps that have come before and will come after this, and what it might mean for you.

What is this notice?

I’ve covered what an RFI entails my article on the DOE’s RFI for its net metering analysis, as well as the overall federal rulemaking process in the Policy Rulemaking Process for Dummies article—so click on those links to get the background information on those aspects of this process. However I have not had a chance to detail the DOE’s dealing with test procedures.



As detailed in the ‘Authority and Background’ section of the RFI, the Energy Policy and Conservation Act of 1975 (EPCA) authorizes DOE to regulate the energy efficiency of a wide array of covered consumer products and industrial equipment. Among that list of equipment is distribution transformers. As such, DOE first established regulatory standards for distribution transformers in 2007, and most recently completed full rulemaking process to update to the energy conservation standards for distribution transformers in 2013, which took effect in 2016. These standards set minimum energy efficiency standards for the equipment based on the type of distribution transformer, the applicable kVA rating, and BIL rating, and those final standards can be found here.

The authority of EPCA calls on DOE to not just set the minimum energy efficiency standards for distribution transformers (and other equipment), though. DOE is also responsible for setting the testing requirements, which manufacturers must use as a basis to 1) certify to DOE that their equipment complies with standards, and 2) make representations of the efficiency of their equipment to the public (e.g., through in manufacturer catalogs). In other words, the official DOE test procedure dictates the testing setup and methods in which the efficiency of the equipment is measured.

DOE currently has test procedures for distribution transformers, which can be found here. These test procedures were published in 2006 when the first efficiency standards for the equipment were published as well. As noted in this RFI, “EPCA requires that, at least once every 7 years, DOE evaluate test procedures for each type of covered equipment, including distribution transformers, to determine whether amended test procedures would more accurately or fully comply with the requirements for test procedures to not be unduly burdensome to conduct and be reasonably designed to produce test results that reflect energy efficiency, energy use, and estimated operating costs during a representative average use cycle.” In fact, during the 2013 update to the energy conservation standards for distribution transformers, DOE did just that and determined that the current test procedures were satisfactory and did not require an amendment. However during that rulemaking process, certain stakeholders took advantage of the opportunity to make a public comment and noted that the requirements for ‘percent of nameplate-rated load’, or PUL, of the test procedure might not be appropriate and should be addressed in a future test procedure rulemaking. This RFI published by DOE is the beginning of that promised future test procedure rulemaking on distribution transformers, set to give consideration to the test PUL requirements.

Background of Distribution Transformers

As detailed in the RFI, a transformer is “a device consisting of 2 or more coils of insulated wire that transfers alternating current by electromagnetic induction from 1 coil to another to change the original voltage or current value.” 10 CFR 431.192  Distribution transformers, according to the DOE definition, are specifically identified based on their input and output voltage and other electrical characteristics. Put simply, distribution transformers are the pieces of equipment that take the high-voltage power from transmission lines and step that power down to its safe, final voltage before it is sent to the customers (in their homes, commercial buildings, etc.). These distribution transformers can be found either on a utility pole or in a locked box on the ground. Depending on the area, a single distribution transformer might serve one customer (in a remote rural area) or it might serve many customers (in a dense urban area). Further, a single large industrial facility might require multiple distribution transformers of its own.

On the left is a utility-pole distribution transformer, while the right is a pad-mount distribution transformer. I can’t be the only one who has nostalgia looking at the one on the right and of using it as a base in kickball or as home base in capture the flag until my mom yelled at us to stop playing on it, right?

The full current test procedure for distribution transformers can be found here, which specifies the test system accuracy required; the methods for measuring resistance, losses, and efficiency value of the transformer; and the test equipment calibration and certification.

What is being requested

This RFI is the beginning of a full rulemaking cycle on the test procedures for distributed transformers, so this is the opportunity for stakeholders to make an early and strong impact on the direction of the rulemaking.

The main issue that was brought up during the 2013 energy conservation standards rulemaking with regard to the test procedure was the appropriateness of the PUL specification. The discussion of this issue centered on the idea that the PUL on which the transformers were tested, and thus the PUL on which the resultant declared efficiencies were based, are potentially not representative of the PUL at which the transformers would operate during actual use. If this is the case, then customers seeking out the transformer that would use the least energy might be misled, and transformers that actually save more energy than others in use might be found non-compliant with regulations. To address this issue, DOE is requesting comment on the following:

  • Issue 1: Any data or information on the PUL used during the first year of service for distributed transformers;
  • Issue 2: Typical PUL values used in the population of distributed transformers;
  • Issue 3: Whether data provided by manufacturers represents first year of service or full lifetime;
  • Issue 4: Whether transformer loads increase over time; and
  • Issue 5: How much the efficiency of a transformer effects the purchasing decision of customers.

DOE is also going to investigate the issue of temperature correction and if the current practice of calculating losses by assuming the temperature inside the transformer is equal to an outside ‘reference’ temperature. The concern is that the temperature inside the transformer is surely higher than an outside temperature, meaning the energy losses in practice would be higher than what is being calculated. To address this, DOE is requesting comment on the following:

  • Issue 6: Any data or information about whether calculating losses at ambient temperature or internal temperature is more representative of real transformer performance; and
  • Issue 7: Whether temperature varies with PUL.

The current test procedure specifies efficiency by a single tested PUL. DOE has engaged in some discussion on whether this is appropriate, if a different reference PUL should be used, or if transformers should be tested at multiple PULs. To this end, DOE is requesting comment on:

  • Issue 8: Any data or information on the continued use of a single PUL test requirement compared with the alternatives;
  • Issue 9: How accurate would testing at multiple PULs be to the distribution of real-use transformer operations and how much would that increase testing costs;
  • Issue 10: How many PULs would be appropriate at which to test in a scenario of testing multiple PULs; and
  • Issue 11: Whether there are alternative metrics that should be considered to determine transformer efficiency.

Lastly, DOE also seeks comment on the sampling process and calculation methods used in the test procedure. The specific types of comments DOE seeks are the following:

  • Issue 12: Whether the sampling requirements of units to be tested should be adjusted;
  • Issue 13: Whether the efficiencies advertised by manufacturers typically represent the minimum efficiency standard, the maximum represented efficiency they are allowed to use, or some other metric;
  • Issue 14: Comment on DOE’s requirements related to alternative methods for determining energy efficiency (AEDMs); and
  • Issue 15: Whether the AEDM provisions are useful and if manufacturers use them.

Again this RFI is just the beginning of the rulemaking process for the distributed transformer test procedure, but it also represents the best time to get involved if these test procedures affect you. The above issues are just the ones that DOE specifically is looking to hear about, but stakeholders are more than welcome to address any other topics they find important. As mentioned in the Policy Rulemaking Process for Dummies article, comment periods such as this one represent the best opportunities to directly impact potential regulations that could have real impacts on you or your business.

Note: I have in the works a post on how to submit the most effective public comments, so if there appears to be interest on this post regarding the net metering RFI then I’ll make sure to move up publication of that subsequent post to be helpful for commenting on this Notice in advance of the comment submission deadline. Update: See here for my post on how to make the most effective public comment on a public rulemaking.

Summary of RFI details

  • DOE published RFI asking for comments on development of the technical and economic analyses regarding whether the existing test procedures for distributed transformers should be amended (82 FR 44347).
  • Some key specific topics DOE is interested in receiving comments on include:
    • Ways to streamline and simplify testing requirements;
    • Measures DOE could take to lower the cost of testing requirements;
    • The relation between PUL being tested and PUL actually used in the field for distribution transformers;
    • Whether current temperature correction in the test procedure is flawed;
    • How testing based on a single PUL affects the final posted efficiency of equipment; and
    • The appropriateness of the sampling and calculation methods currently used.
  • Comments are to be submitted by October 23, 2017.
  • Further information is available at the Notice’s online docket, and questions can be directed to Jeremy Dommu at the DOE Office of Energy Policy and Systems Analysis or Mary Green at the DOE Office of the General Counsel.
  • As always, feel free to contact me through the Contact page or commenting below if you have any questions you think I could answer as well.

 

Updated on October 10, 2017

 

About the author: Matt Chester is an energy analyst in Washington DC, studied engineering and science & technology policy at the University of Virginia, and operates this blog and website to share news, insights, and advice in the fields of energy policy, energy technology, and more. For more quick hits in addition to posts on this blog, follow him on Twitter @ChesterEnergy.  

Federal Register Notice: Costs and Benefits of Net Energy Metering: Request for Information

I’ve been excited to write a first post in the ‘Checking in on the Federal Register’ article series, but have been waiting for the right Notice to be posted in the Federal Register. Today is finally that day, as the Department of Energy (DOE) published a Notice of request for information (RFI) in the September 15, 2017 issue of the Federal Register (82 FR 43345). This Notice is a rather brief one, so I would encourage you to read it yourself, in addition to reading this post where I’ll summarize the important details and pre-emptively answer any questions you may have.

What is an RFI?

If you’ve already read my Policy Rulemaking Process for Dummies article, you might be confused—RFIs don’t appear anywhere in that summary of the typical rulemaking process. However, an RFI falls into the category of situations where a Notice of Proposed Rulemaking (NOPR) is not the first Federal Register notice. An RFI is issued, such as in this case, when a topic is particularly complex or contentious, and so the agency solicits public feedback earlier in the process to ensure it has all the best and most up-to-date data and information available before beginning its analysis.



In this instance, DOE indicates they are preparing a cost/benefit study on net metering as a part of the Grid Modernization Initiative. DOE is likely seeking out all possible resources and data sets from stakeholders because net metering is a very contentious issue and it is crucial to have all possible information before digging into the study.

Background of Net Metering

According to DOE, net metering, or net energy metering (NEM), is the “the practice of using a single meter to measure consumption and generation of electricity by a small generation facility (such as a house with a wind or solar photovoltaic system). The net energy produced or consumed is purchased from or sold to the power provider, respectively.” Thus, when these customers who generate their own electricity have generated more power than they are using, they are able to sell back their excess electricity to the utility who controls the transmission and distribution system to which they are connected.

The debate on net metering often pits companies and customers installing rooftop solar panels against utilities. The main crux of the debate surrounds rate design and the issue of whether customers whose excess solar power gets sold back into the larger utility grid system should be credited at the retail rate of electricity or if that unfairly results in these solar customers not paying their fair share of the grid upkeep costs.

These disputes have been commonly going to courts in states with frequent residential solar power installations. For a quick rundown of where each state stood on laws regarding net metering (as of late 2016), see this summary by the National Conference of State Legislatures. For a summary of the most contentious net metering legal battles going on in 2017, see this write up by Utility Dive. However since this is such a common and frequent debate across many different states, the best way to see the latest news is a quick Google search—the most recent development coming from just approved rules and regulations for net metering in Nevada.

What is being requested

In short, this RFI is requesting that stakeholders submit any relevant data, studies, or information they have in regards to the costs and benefits of net metering. DOE specifically requests information from the perspectives of the utilities’ business interests, the rate-paying consumers, and those tasked with addressing the technical and operational challenges of net metering.

As such, this RFI casts a rather wide net as to who prospective stakeholders would be—not only will the expected utilities and energy advocates likely submit comments, but the door is open for any private citizen or group of citizens to express their thoughts and concerns. As mentioned in the Policy Rulemaking Process for Dummies article, comment periods such as this one represent the best opportunities for you, either as a private citizen or a member of an organization, to directly impact potential regulations that could have real impacts on your life.

While there are numerous public studies available that DOE can, and certainly already has, referenced for their information gathering process, the key to this comment request is that they would like those with deep knowledge and experience with the topic to provide comment and context on those existing studies (specifically citing studies done since the beginning of 2012). DOE is hoping to hear if stakeholders find there to be any flaws in commonly cited studies on the topic, information that is not discussed in those studies, or data/information that stakeholders may have internally that have not yet been made public. In essence, this RFI from DOE is indicating they are studying the costs and benefits of net metering, and if you have any information you think is important to be included in that study then now is the time to raise your hand. The analysis generated from the information in this RFI will ultimately be presented to Congress.

Note: I have in the works a post on how to submit the most effective public comments, so if there appears to be interest on this post regarding the net metering RFI then I’ll make sure to move up publication of that subsequent post to be helpful for commenting on this Notice in advance of the comment submission deadline.

UPDATE: See this blog post for advice on making an effective public comment

Summary of RFI details

  • DOE published RFI asking for comments on the costs and benefits of net energy metering (82 FR 43345).
  • Specific topics DOE is interested in receiving comments on include:
    • Motivations and policy context of cost-benefit analyses of net metering;
    • Types of costs and benefits that should be considered for net metering;
    • Methodology issues typically encountered in net metering studies;
    • Context for what drives differing costs or benefits in different net metering studies; and
    • Any emerging issues that should be considered in future net metering studies that may not have been relevant to studies in the past.
  • Comments are to be submitted by October 30, 2017.
  • Further information is available at the Notice’s online docket, and questions can be directed to Kate Marks at the DOE Office of Energy Policy and Systems Analysis.
  • Feel free to contact me, through the Contact page or commenting below, if you have any questions you think I could answer as well.

 

 

 

Updated on October 10, 2017

About the author: Matt Chester is an energy analyst in Washington DC, studied engineering and science & technology policy at the University of Virginia, and operates this blog and website to share news, insights, and advice in the fields of energy policy, energy technology, and more. For more quick hits in addition to posts on this blog, follow him on Twitter @ChesterEnergy.