The undersigned free market and consumer organizations have a longstanding interest in bringing to light the deleterious consequences of federal regulations, which are often neglected by agencies in their attempts to adopt a regulatory agenda. For over 20 years, we have participated in rulemakings conducted by the Department of Energy (DOE) as well as litigation regarding energy and water conservation standards for home appliances. This includes agency actions impacting dishwashers, air conditioners, clothes washers and dryers, showerheads, and light bulbs.
Our particular focus has been on ensuring that the consumer protections built into the law are given full weight in the rulemaking process. In our view, these protections have often been downplayed or ignored by the agency when setting excessively stringent efficiency standards that raise overall costs and/or reduce product quality and choice.
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