ALASKA CALIFORNIA FLORIDA MID-PACIFIC NORTHEAST NORTHERN ROCKIES 

NORTHWEST ROCKY MOUNTAIN WASHINGTON, DC INTERNATIONAL 

1625 MASSACHUSETTS AVENUE NW SUITE 702 WASHINGTON, DC 20036 

T: 202.667.4500 F: 202.667.2356 E: dcoffi ce@earthjustice.org W: www.earthjustice.org 

August 20, 2010

Kathleen Hogan

Deputy Assistant Secretary for Energy Efficiency

U.S. Department of Energy

1000 Independence Avenue, SW Washington, DC 20585

Dear Deputy Assistant Secretary Hogan:

As you are aware, several energy efficiency organizations and the Association of Home

Appliance Manufacturers (AHAM) recently reached an agreement concerning five products

subject to the Department of Energy’s appliance efficiency standards program.  The agreement,

which covers refrigerators and freezers, clothes washers, clothes dryers, dishwashers, and room

air conditioners, includes a number of recommendations related to new energy and water

efficiency standards and test procedures, smart appliances, and incentives to manufacture

highly efficient appliances.   

Although Earthjustice was not a signatory to the agreement, I write separately to express

Earthjustice’s support for the agreement and Department’s implementation of the

recommended standards and test procedure changes it includes.  Our absence from the list of

signatories should not be construed as an indication of Earthjustice’s opposition to any of its

provisions.  On the contrary, Earthjustice participated in the negotiations that led to the

agreement and believes the agreement provides a sound set of policy recommendations with

regard to all three of its primary elements: energy and water efficiency standards, incentives for

smart appliances, and tax credits for the production of highly efficient appliances.  Our

decision not to sign the agreement merely reflects that Earthjustice’s internal process for

signing onto agreements that entail a commitment to take a position on legislative proposals

would have conflicted with the shared interests of all parties to submit the agreement to DOE as

expeditiously as possible.    

   

In sum, Earthjustice supports the agreement and we encourage DOE to adopt the

standards and test procedure recommendations that it includes.  As detailed in the initial

communications from AHAM and the American Council for an Energy Efficiency Economy

informing the Department of the success of our negotiations, the agreement’s

recommendations, once adopted, will provide significant benefits.  Among other things, the

agreement will reduce CO2 emissions by more than 550 million metric tons and save more than

9 Quads of energy over 30 years, while also saving households money and helping to retain

U.S. manufacturing jobs.  Moreover, the standards recommended in the agreement meet the

Energy Policy and Conservation Act’s statutory criteria.      

EERE-2008-BT-STD-0019 COMMENT 32
I look forward to working with the Department to advance the recommendations

contained in this agreement. Please do not hesitate to contact me if you have any questions

or need any further information.

Sincerely,

__________________________

Timothy D. Ballo

Earthjustice

1625 Massachusetts Ave., NW

Suite 702

Washington, DC 20036

(202) 667‐4500

tballo@earthjustice.org

CC:   Roland Risser, Program Manager, Office of the Building Technologies Program;  

Michael McCabe, General Engineer, Office of the Building Technologies Program

2

EERE-2008-BT-STD-0019 COMMENT 32