Public Comment on Reforming DOE's "Process Rule" for Energy Efficiency Standards


By Sofie E. Miller

March 02, 2018

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The George Washington University Regulatory Studies Center improves regulatory policy through research, education, and outreach. As part of its mission, the Center conducts careful and independent analyses to assess rulemaking proposals from the perspective of the public interest. This comment on the Department of Energy’s request for information does not represent the views of any particular affected party or special interest, but is designed to evaluate the effect of DOE’s process rule on overall consumer welfare.


The Department of Energy (DOE) is seeking comment on potential modifications to its “Process Rule,” which outlines the Department’s approach to establishing new or revised energy efficiency standards for consumer appliances. The comment provides DOE with a public interest perspective on its Process Rule and potential improvements in the areas of direct final rulemaking, negotiated rulemaking, retrospective review, and the analysis that supports the Department’s rules.

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