CFA joined fellow advocates urging DOE to enact higher efficiency standards for dishwashers. We support DOE’s efforts to understand the relationship between energy and water consumption and consumer satisfaction metrics. However, we believe DOE may be overestimating the incremental costs to meet intermediate efficiency levels for standard-sized dishwashers and that DOE’s assumptions regarding water heater efficiencies are underestimating the energy use associated with water heating. We also encourage DOE to evaluate an additional efficiency level for compact dishwashers.