Rulemaking:

Energy Conservation Program for Consumer Products: Clothes Washer Energy Conservation Standards

Stated Purpose:

"Washing Machines to Become More Energy Efficient: Agreement Will Yield Big Savings for Consumers and the Environment"

Summary of RSP Comment:

One observation offered in RSP's November 27, 2000 comment on DOE's clothes washer energy conservation standards was that the rule was based on a recommendation of manufacturers and energy conservation advocates, and the process not conducive to consumer input. While RSP does not believe that all public matters are best decided by polls or referenda, we believe it is a useful exercise to put regulatory decisions into language that the average citizen can understand, and to listen to their views. To this end, Mercatus commissioned a survey of consumers to provide DOE a better understanding of their preferences with respect to washing machine attributes and the standard established in the proposed rule.

The telephone survey, conducted by Rasmussen Research on Tuesday, November 28, 2000, posed five questions related to washing habits and preferences. With a sample size of 2000, and a margin of error of +/- 3 percent with a 95 percent level of confidence, the poll yielded some interesting results.

When faced with the simple question of whether they would favor or oppose a regulation that effectively eliminated top-loading washer models, consumers expressed opposition by a ratio of six to one. Even when informed that the mandated machines would have lower operating costs and greater energy efficiency, respondents still opposed the regulation by a margin of 2.6 to one. When asked whether the savings predicted by DOE would be a "good deal," respondents replied in the negative by a ratio of almost two to one.

DOE bases its estimated operating savings on an assumption that a household will operate a washer 392 times a year, however, less than 15 percent of survey respondents operate their clothes washer that frequently. More than two-thirds of households surveyed wash 5 or fewer loads a week, which DOE's data reveal would not be enough to recoup the higher purchase price of the mandated washing machines.