Letter Response from the Plumbing Manufacturers Institute (PMI), Docket No. EERE-2010-BT-NOA-0016 - Notice of Availability of Interpretive Rule on the Applicability of Current Water Conservation Standards for Showerheads.
This is the cover letter to additional comments submitted by PMI after alerting the DOE to its belief that the Interpretive Rule should be subject to APA Notice and Comment procedures. The comments concern the economic impacts of the Interpretive Rule's definition of "showerheads." PMI believes that the economic impacts of the Rule outweigh the environmental benefits, and accordingly requests that the Rule is withdrawn. Should the DOE proceed, PMI requests that they follow APA procedure, coordinating with the industry to assess the true economic costs of the Rule.