Attorney General Rayfield along with a coalition of 6 state attorneys general and the City of New York in submitting two comment letters to the United States Department of Energy (DOE) — urging the department to allow energy efficiency standards for gas-fired instantaneous water heaters and walk-in coolers and freezers to take effect.
Last month, DOE issued rules delaying the effective date of these standards and signaled that it is considering following its initial delay with further delays of the Biden Administration’s energy efficiency standards for these products. In today’s comment letters, the coalition highlights how the delays are not only unlawful, but would have harmful consequences for consumers, businesses, and the environment.
“Oregon has always been committed to cleaner, more efficient energy use,” Rayfield said. “Moving forward with these standards will not only help protect our environment, but it will also save people money in the long run. It’s time to act – the benefits are clear, and the opportunity is now.”
On January 20, 2025, President Trump issued the “Regulatory Freeze Pending Review” memorandum. This ordered all federal departments and agencies to consider postponing for 60 days the effective date of certain rules published in the Federal Register for the purpose of reviewing any questions of fact, law, and policy that the rules may raise.
Citing that memorandum, on February 20, 2025, DOE published two rules that delayed the effective dates of energy efficiency standards for gas-fired instantaneous water heaters and walk-in coolers and freezers. The two delay rules push back the effective dates for both rules from March 11, 2025, and February 21, 2025, respectively, to March 21, 2025.
In the comment letters, the coalition highlights that:
- Without efficiency improvements, businesses and consumers will continue using outdated, energy-wasting equipment, leading to higher electricity and gas costs over time. DOE has projected that the energy efficiency standards will provide nearly $1 trillion in consumer savings over 30 years, and $3.1 billion (gas-fired instantaneous water heaters) and $6.5 billion (walk-in coolers and freezers) over 30 years of product sales.
- Inefficient walk-in coolers and water heaters burn more fossil fuels, contributing to climate change and worsening air quality. DOE estimated that the energy efficiency standards will reduce greenhouse gas emissions by 2.5 billion metric tons or more—an amount roughly equivalent to the emissions of 18 million gas-powered cars, 22 coal-fired power plants, or 10.5 million homes over 30 years.
- The delays for the two-consumer product energy efficiency standards are in violation of the Energy Policy Conservation Act, and the Administrative Procedure Act.
Joining Attorney General Rayfield in sending the comment letters are the attorneys general of California, Connecticut, Illinois, Minnesota, Washington, and the City of New York.
A copy of the comment letters can be found here.