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Illinois Attorney General Kwame Raoul
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October 18, 2019


Chicago — Attorney General Kwame Raoul, as part of a coalition of 13 attorneys general and the City of New York, filed a comment letter calling on the Department of Energy (DOE) to withdraw its proposed rule to undermine current energy efficiency standards for residential dishwashers.

The proposed rule, issued at the request of the Competitive Enterprise Institute, attempts to carve out a class of dishwashers from energy efficiency standards by creating a new category of dishwashers defined only by shorter cycle times.

“This proposal is unlawful and not supported by any factual need,” Raoul said. “It will do nothing but harm consumers and the environment. I urge the DOE to put the interests of the public first and abandon this proposed rule.”

The Energy Policy and Conservation Act (EPCA) directs the DOE to establish energy conservation standards covering most major household products, including dishwashers. Dishwashers have been subject to energy efficiency standards since 1988 and are currently required to use no more than 307kWh/year and 5.0 gallons per cycle, a requirement which saves energy and helps households save money. The DOE’s energy efficiency program has resulted in substantial economic and environmental benefits: by 2030, the DOE projects the program will have resulted in more than $2 trillion dollars in cumulative utility bill savings for consumers and 2.6 billion tons in avoided carbon dioxide emissions. However, the DOE continues to put the interest of industry over the American people by failing to undertake mandatory rulemakings and instead pursuing legally and technologically unsound actions that would undermine the program.

Raoul and the coalition urge the DOE to withdraw its unlawful proposal on the basis that it:

  • Violates the EPCA’s anti-backsliding provision prohibiting the DOE from enacting a standard that increases energy use of a covered product. The current classes of dishwashers under the law are not limited according to cycle time, and DOE is not authorized to add a class simply to bypass the law.
  • Attempts to improperly avoid review of the environmental impacts of the proposed rule as required by the National Environmental Policy Act; and
  • Fails to provide sufficient justification or reasoning as required by the EPCA and the Administrative Procedure Act that different energy efficiency standards are necessary to maintain a shorter cycle in dishwashers and that this function would be a performance-enhancing feature. In fact, the proposal’s correlation between cycle time and energy use is contradicted by evidence, with longer wash cycles being driven by other factors including changes in detergent formula and consumer preference for quieter machines.

Joining Raoul in the comments are the attorneys general of California, Connecticut, Maine, Maryland, Massachusetts, Minnesota, New Jersey, New York, Oregon, Vermont, and Washington, as well as the City of New York.


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