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Kwame Raoul

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ATTORNEY GENERAL RAOUL OPPOSES FEDERAL ROLLBACK OF ENERGY AND WATER EFFICIENCY STANDARDS

July 16, 2025

Proposed Changes Would Cost Americans Millions in Higher Utility Bills by Eliminating Efficiency Requirements for 16 Consumer and Commercial Appliances

Chicago – Attorney General Kwame Raoul today announced he joined a multistate coalition in submitting comments to the U.S. Department of Energy (DOE) opposing its proposals to eliminate energy and water efficiency standards for 16 consumer and commercial appliances.

The proposed changes would remove efficiency standards for appliances ranging from dehumidifiers to microwave ovens. Current standards, established under the Energy Policy and Conservation Act (EPCA), require appliances to meet minimum efficiency levels that save consumers money while reducing energy or water consumption and environmental impact.

“At a time when many families continue to struggle to pay for basic necessities, the Trump administration continues to roll back longstanding policies that will increase the financial burden on households while also undermining the decades of progress our nation has made on conservation,” Raoul said. “The changes proposed by the Department of Energy would increase Americans’ utility costs, and I am proud to join with my fellow attorneys general to urge the agency to rethink this misguided and costly decision.” 

Raoul and the coalition submitted detailed comments challenging the proposed rollbacks, which are part of the DOE’s broader initiative to reduce regulations. These rollbacks would cost consumers millions of dollars annually in higher energy and water bills while undermining decades of progress on conservation.

In their comments, Raoul and the coalition highlight that the DOE’s proposals lack the technical and economic analysis federal law requires for establishing or modifying efficiency standards. When each of the existing standards was originally announced, the DOE conducted thorough studies demonstrating their technological feasibility and economic benefits. However, the current proposals to rescind these standards do not include any such analysis.

Raoul and the coalition also emphasize that eliminating these efficiency standards would result in significant lost savings on energy and water, leading to higher utility bills for consumers nationwide. The standards have historically saved Americans billions of dollars in energy costs while reducing strain on the electrical grid and water systems.

Under the EPCA, the DOE is required to review efficiency standards at least once every six years and must set standards at the highest level of efficiency that is technologically feasible and economically justified. The statute includes anti-backsliding provisions designed to prevent the weakening of existing standards without compelling justification.

Raoul and the coalition further argue that the DOE has failed to comply with several federal requirements, including the Administrative Procedure Act (APA), the National Environmental Policy Act (NEPA), the Regulatory Flexibility Act and Executive Order 13211, which requires the preparation of a Statement of Energy Effects for federal actions that would significantly impact energy supply, distribution or use.

The comments rebut the DOE’s central arguments for removing the standards, including the department’s claims that it lacked authority to originally establish the standards and that the anti-backsliding provisions of the EPCA do not apply. The coalition demonstrates that the DOE’s legal reasoning is flawed and that the agency has ignored the interests of states, manufacturers and consumers who have invested in compliance with existing standards.

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