Comments submitted in response to the Department’s proposed standards for Refrigerators, Refrigerator-Freezers, and Freezers, as appearing in 88 Federal Register 12452 (Feb. 27, 2023). They are jointly supported by a broad range of consumer, environmental and low-income advocacy organizations: National Consumer Law Center, on behalf of its low-income clients; Texas Utility Law Project; Association for Energy Affordability; Public Citizen; The Utility Reform Network; Virginia Citizens Consumer Council; Preserve Montgomery County VA; Friends of Buckingham (FOB); Pennsylvania Utility Law Project, on behalf of its low-income clients; National Community Action Foundation; and Americans for Financial Reform Education Fund.
These groups offer their strong support for DOE’s proposed refrigerator standards. As explained more fully below, DOE’s analytic approach may understate the benefits to low-income households, which underscores the importance of DOE moving ahead with the standards as proposed.