In October and December 2020, DOE established separate product classes for residential dishwashers and residential clothes washers and clothes dryers, respectively, that have a short cycle as the “normal cycle.”

We strongly support DOE’s proposal to revoke these “short cycle” final rules and to reinstate the prior product classes and applicable standards. As DOE describes in the NOPR, in those 2020 final rules, DOE failed to consider the necessary criteria for amending standards.3 In particular, DOE did not analyze whether the amended standards for short-cycle products were designed to achieve the maximum improvement in energy efficiency that is technologically feasible and economically justified as required by the Energy Policy and Conservation Act (EPCA). DOE also did not consider whether the amended standards violated the anti-backsliding provision.