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Comments to the Department of Energy on Regulatory Burden

Following an Executive Order on reducing federal regulatory burden, the Department of Energy (DOE) is requesting the public’s suggestions for rules to repeal or reform. In our comments to DOE’s request for information, we argue that regulatory review should consider the public benefits of regulation, not just the costs to regulated industries.

Although eliminating recently issued rules under the guise of “retrospective review” would be premature, many stakeholders are likely to encourage DOE to do exactly that. In comments to the Department of Commerce, for example, manufacturers asked to repeal or rescind four DOE recently issued or proposed energy efficiency standards that contribute a combined $6.5 billion in net benefits to society each year. Rather than repealing these cost-benefit justified rules, DOE should instead prioritize review of older rules for which actual costs and benefits may diverge significantly from predicted costs and benefits.

Additionally, DOE should reaffirm that the benefit estimates used in recent regulatory impact analyses, including the social cost of greenhouse gases, remain the best available estimates for cost-benefit analysis. DOE should also not repeal rules based on comments alleging negative impacts on employment, as evidence shows that regulations have little effect on aggregate employment or unemployment rates.