Energy Efficiency

As part of the firm’s multi-faceted energy practice, we represent a number of product manufacturers, trade associations, and other clients on policy, regulatory, compliance, enforcement and litigation matters related to energy efficiency.

Our team has substantial experience working in both private practice and in government service on energy efficiency matters including Department of Energy test procedures and efficiency standards for covered products under the Energy Policy and Conservation Act (EPCA), the Federal Trade Commission’s related requirements concerning efficiency labeling under EPCA, and the Energy Star labeling program.

The firm represents the industry in a diverse-range of matters including:

  • Policy and Government Relations. Legislative drafting, advocacy, and strategic advice on influencing Congressional and Executive Branch on energy efficiency policy.
  • Department of Energy Rulemakings. Assisting clients in digesting complex regulatory proposals on efficiency standards and test procedures, preparing written comments on proposed rules and advocating before agency officials.
  • Litigation. Representing clients in litigation concerning rules on efficiency standards.
  • Exception Relief. Working to obtain exception relief from DOE’s Office of Hearings and Appeals concerning energy efficiency standards.
  • Test Procedure Waivers/Interpretations. Assist clients in obtaining test procedure waivers/interpretations for products that cannot be tested under generic or ambiguous DOE test procedures.
  • Enforcement. Provide counsel to manufacturers and importers of covered products on DOE enforcement actions, related notices, and subpoenas, including negotiating settlements of actions.
  • Labeling. Assist clients on compliance issues associated with Energy Guide and Energy Star labeling of products.
  • Energy Star Standards. Counseled clients on building products trade group to advocate before EPA on revised Energy Star standards.
  • Compliance Counseling. Represented clients on EPCA and Energy Star compliance matters.