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Plumbing Manufacturers Institute Executive Director Barbara Higgens, along with representatives from Moen, Masco Corp. and Kohler met with DOE general counsel Scott Blake Harris in late August to provide information about adverse economic impacts of the controversial draft interpretive rule setting forth DOE’s views on the definition of a showerhead.
“I thought it was a very productive meeting and very useful to us,” Harris told pme. “It’s good to talk to people face to face instead of talking to people through the press. I shouldn’t characterize (industry’s) thinking, that wouldn’t be fair, but I’m confident our approach will cause less disruption to industry than some people have thought.”
Harris said these types of meetings are common during public comment periods.
“They requested the meeting and we said we would be delighted to meet with them,” he stated. “We encourage others that are interested to come in and meet with us.”
Harris clarified that his opinion of the industry after the meeting hasn’t changed.
“I’ve always had a good opinion of the industry,” he said. “Perhaps people misunderstood what we’re trying to accomplish and how we wanted to accomplish it.”
Harris said a final ruling is still on track to be released in early October. He noted the draft interpretive rule is still in the intra-governmental process and has been sent to the Office of Management and Budget for comments from other government agencies.
“It’s still in the rule-making process,” he said.
Harris also pointed out documents related to the meeting can be found on the DOE General Counsel’s Web site. Included in those extensive documents are the results of an independent third-party study that PMI commissioned regarding the potential economic impact of the draft interpretive rule.
The study, performed by W & W Services, Inc., stated that based on data collected from PMI members, the inventory, capital and training costs that would result from the proposed change would total over $108 million, while the combined one-time costs and recurring costs reported to W & W if the definition change goes through would total $412 million.
To read PMI’s full supplemental comments regarding the economic impacts of the proposed showerhead definition, visit http://www.gc.energy.gov/documents/PlumbingManu_SuppComments_Showerheads.pdf .