Comment on FR Doc # 2026-10729
Environmental Defense Fund, Conservation Law Foundation, Natural Resources Defense CouncilOpposeAdvocacy
Summary: The Conservation Law Foundation, Environmental Defense Fund, and Natural Resources Defense Council submitted joint comments opposing the "Zero-Based Regulating" proposed rule. They argue that the rule is unlawful because it fails to provide adequate notice and comment for the mass sunsetting of regulations, lacks statutory authority, and is arbitrary and capricious.
To Whom It May Concern:
Please find attached joint comments from the Conservation Law Foundation, Environmental
Defense Fund and Natural Resources Defense Council on the proposed rule entitled “Zero-Based Regulating.”
As detailed below, the Proposed Rule is unlawful in multiple, independent respects; DOE should withdraw it and the accompanying direct final rule. Because the Department has presented this proposed rule in a notice separate from the direct final rule, we submit distinct versions of our comments for the respective notices. The comments’ content (other than the initial page) is the same. If there are any questions about these comments, please feel free to contact the representatives indicated on the first page of the commetns.