Comment on FR Doc # 2026-10727
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" direct final rule. They argue the rule is unlawful because it fails to provide adequate notice and comment under the Administrative Procedure Act, lacks statutory authority for mass regulatory sunsetting, 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 direct final rule entitled “Zero-Based Regulating.”
As detailed below, the direct final rule is unlawful in multiple, independent respects, and these comments and those from other commenters are clearly both significant and adverse. DOE should withdraw it and the accompanying proposed rule. Because the Department has presented this direct final rule in a notice separate from the proposed 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 the representatives indicated on the first page of the comments.