CFA joined on 2 different sets of comments to the Department of Energy on its prioritization process for energy conservation standards.

CFA joined the Appliance Standards Awareness Project and others in comments addressing the Department’s statutory obligations to review standards and test procedures, DOE’s growing backlog and recent increases in regulatory work. The comments then point out the rulemakings which DOE must actively work on given statutory deadlines and go on to discuss DOE’s discretionary rulemaking activity identifying several rulemakings that DOE should cease because they do not advance the statute’s purposes and, if finalized, could be challenged legally and, finally, a description of other work that would further the energy conservation purposes of the law is provided.

The second set of comments submitted with Earth Justice and other groups stress the fact that DOE has a legal obligation to complete all mandatory actions and that it should defer the many discretionary rulemakings through which this administration has sought to undermine the energy conservation standards program, until the Department has come into compliance with the schedule prescribed by Congress.