Supplemental Comments of the Plumbing Manufacturers Instititute Regarding the Economic Impacts of the Proposed Definition of "Showerhead," Docket No. EERE-2010-BT-NOA-0016.
The Plumbing Manufacturers Institute submits supplemental comments regarding the definition of showerheads in interpetive rule 10 C.F.R. Section 430.2. Comment alleges that the interpretive rule violates the APA and the EPA, but focuses on the economic impact of the rule, claiming that it should be central to the determination of the rule. Ultimately, the evidence offered is claimed to support a finding that the economic costs of the rule outweigh its benefits.