On July 2, the Department of Energy (DOE) announced a Notice of Proposed Rulemaking to overhaul the Process Rule, the framework it uses to develop energy conservation standards for home appliances and HVAC equipment. The text of the proposed rule repeatedly cites the comments ACCA submitted in 2025, and several of its overarching themes respond to issues ACCA raised, including:
- Procedural safeguards for consumer choice and product availability
- Earlier stakeholder input
- Longer public comment periods
The proposal largely restores the 2020 Process Rule, committing DOE to weighing affordability, product availability, performance characteristics, and consumer choice alongside energy savings when it writes future standards. Those standards flow from the Energy Policy and Conservation Act (EPCA), the federal law behind DOE’s appliance efficiency authority. ACCA has called on Congress to modernize EPCA and write that balance into the statute itself, rather than leaving it to each administration’s Process Rule.
“That’s a needed and welcome shift, and one consistent with ACCA’s call for EPCA modernization legislation that ensures the Process Rule can’t be watered down with each new administration,” Sean Robertson, ACCA’s vice president of government relations, shared with ACHR News. “This proposed rule also sets the stage for a more balanced process when, hopefully, the D.C. Circuit Court of Appeals allows DOE to rewrite the furnace rule in the wake of last month’s Supreme Court victory.”
As Robertson notes, regulatory progress only lasts as long as the administration behind it. Making a balanced standards process permanent takes action from Congress. Sign ACCA’s ACTion Alert and tell your elected officials to finish the job on energy policy reform.
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Key changes in the DOE Process Rule proposal
Among the changes, the proposal would:
- Add preserving product availability and consumer choice to the Process Rule’s objectives
- Reinstate a formal early assessment stage so stakeholders can weigh in before rulemakings begin
- Extend minimum public comment periods to 75 days
- Set numerical thresholds for what counts as “significant energy savings,” so standards delivering trivial savings don’t keep imposing real compliance costs
DOE also issued a companion Request for Information on the analytic methodologies behind its standards. ACCA has long argued that efficiency standards should reflect how equipment performs in the field, not just in a lab that assumes a perfect installation. The RFI gives contractors another opening to make that case.
Process Rule comment deadlines for HVAC contractors
Comments on the proposed rule are due 30 days after publication in the Federal Register, and the analytic methodologies RFI carries a 60-day window. ACCA is still reviewing the details with partners and will share additional analysis in advance of the comment deadline.
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