Energy Department’s Proposed Standards Leave Republican AGs Boiling

Cozen O'Connor
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Cozen O'Connor

  • A group of 21 Republican AGs filed a public comment letter criticizing the Department of Energy’s (DOE) proposed Energy Policy and Conservation Act efficiency standards for consumer boilers—appliances that supply steam or hot water for residential space-heating—arguing that the standards would impose significant hardships.
  • In the letter, the AGs assert that the more stringent efficiency standards for gas-fired and oil-fired boilers rely on misguided estimates of the social costs of carbon, methane, and nitrous oxide; discount federalism concerns; ignore constitutional issues regarding the regulation of intrastate activity; and fail to adequately consider important rulemaking factors including providing time for meaningful review, economic hardship, and strain on energy infrastructure.
  • We have previously reported on Republican AGs’ public comments addressing DOE efficiency standards for other household appliances.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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