Recent Projects

The Department of Energy (DOE) proposed to change the way it selects energy efficiency standards by excluding certain efficiency levels as not "economically justified" on the grounds of effects to small businesses, market competition, or consumer convenience.The change, however, would allow DOE to irrationally and inconsistently give preference to whichever subset of economic impacts the agency wants to focus on in order to deem standards that otherwise achieve net benefits as instead being not economically justified. We submitted comments explaining how the proposal will not ensure consistent consideration of statutory factors.