2026-07-07 Comment response to the published Request for information and request for comments

Summary: Michael Ravnitzky opposes the proposed analytic framework for setting energy conservation standards, arguing that it introduces extra-statutory requirements and methodological flaws that would paralyze the DOE's ability to implement the Energy Policy and Conservation Act (EPCA). He contends that the framework creates unworkable mathematical barriers, ignores documented market failures, and risks making future standards legally indefensible under the Administrative Procedure Act.