Comments Regarding The Energy Conservation Program For Consumer Products And Commercial And Industrial Equipment
The Competitive Enterprise Institute (CEI) is a non-profit public interest organization committed to advancing the principles of free markets and limited government. CEI has a longstanding interest in bringing to light the potentially deleterious consequences of regulations, which are often neglected by federal agencies in their attempts to adopt a regulatory agenda. CEI has previously participated in appliance conservation standards rulemakings, with a particular emphasis on ensuring that the interests of consumers are represented.
Since its enactment in 1987, the National Appliance Energy Conservation Act (NAECA) has been aggressively implemented by DOE. Today, most major energy-using home appliances have been subjected to two or even three rounds of successively tighter standards. Further, with the wave of stringent standards promulgated in the final months of the Clinton administration, this fast regulatory pace will continue for several more years.
The NAECA’s goal, that of providing technologically feasible and economically justified energy conservation standards for major energy-using appliances, has largely been accomplished, if not exceeded. As the comments below elucidate, CEI believes that further standards are likely to be adverse to the interests of American consumers, and that further rulemakings should be undertaken with great caution.