Public Comments Submitted to the U.S. Department of Energy Office of Energy Efficiency and Renewable Energy

Proposed New Rule for Energy Conservation Standards for Residential Dishwashers

Docket Number EERE-2018-BT-STD-0005

RIN 1904-AE35

Submitted by Bonner R. Cohen, Ph. D.

Committee for a Constructive Tomorrow

October 14, 2019

The Committee for a Constructive Tomorrow (CFACT), a 501 (c)(3) nonprofit organization based in Washington, D,C., welcomes the decision by the Department of Energy to accept the petition of the Competitive Enterprise Institute, and propose a dishwasher product class with a cycle time for normal cycle (wash and dry) of less than one hour.

Despite impressive advances in technology in recent decades, American households are now saddled with dishwashers that are substantially inferior to those available 20 or even 30 years ago. Today’s dishwashers require on average two hours and 20 minutes to complete a normal wash-dry cycle, over twice as long as it used to take. A recent GE survey of 11,000 dishwasher owners reports that having to wait for hours for dishes to be done is a major consumer annoyance. In addition, these machines fail to perform their designated task of cleaning dishes so that they are safe for people to use.

This state of affairs has arisen as a result of energy efficiency standards designed to reduce the use of both electricity and water. But those standards have had the exact opposite effect. So poorly do today’s dishwashers perform that they actually lead to higher use of electricity and water because people must sometimes run the machines twice in order to get clean dishes.

Furthermore, the current standards are clearly regressive, because they result in higher power and water bills, which disproportionately affect the disposable income of lower-earning families.

During the previous administration, the push for energy efficiency was incorporated into the Obama administration’s policies to combat climate change. Such was the focus on reducing manmade emissions of greenhouse gases that dishwasher standards even included consideration of the “social cost of carbon.” But the social cost of carbon is an amorphous term that can mean whatever someone wants it to mean; it has no business being used to goad manufacturers into producing “climate friendly” dishwashers. Indeed, the harmful effects of the current standards speak for themselves.

American manufacturers are perfectly capable of producing world-class dishwashers, once the self-defeating straightjacket of the current efficiency standards have been revised to allow for the manufacture of dishwashers that actually serve the needs of the nation’s consumers. Some manufacturers may balk at the prospect of revised standards because they – at government direction – invested considerable capital in producing today’s “energy-efficient” dishwashers. But we now know that these appliances serve no useful purpose, and it is time that corrective measures to be taken.


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  • Bonner Cohen, Ph. D.

    Bonner R. Cohen, Ph. D., is a senior policy analyst with CFACT, where he focuses on natural resources, energy, property rights, and geopolitical developments. Articles by Dr. Cohen have appeared in The Wall Street Journal, Forbes, Investor’s Busines Daily, The New York Post, The Washington Examiner, The Washington Times, The Hill, The Epoch Times, The Philadelphia Inquirer, The Atlanta Journal-Constitution, The Miami Herald, and dozens of other newspapers around the country. He has been interviewed on Fox News, Fox Business Network, CNN, NBC News, NPR, BBC, BBC Worldwide Television, N24 (German-language news network), and scores of radio stations in the U.S. and Canada. He has testified before the U.S. Senate Energy and Natural Resources Committee, the U.S. Senate Environment and Public Works Committee, the U.S. House Judiciary Committee, and the U.S. House Natural Resources Committee. Dr. Cohen has addressed conferences in the United States, United Kingdom, Germany, and Bangladesh. He has a B.A. from the University of Georgia and a Ph. D. – summa cum laude – from the University of Munich.