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National Electrical Manufacturers v. United States Department of Energy

ELR Citation: 41 ELR 20267
Nos. No. 10-1533, (4th Cir., 08/16/2011)

The Fourth Circuit denied a petition challenging a DOE rule setting forth energy conservation standards for small electric motors. The motors covered by the rule are electric induction motors ranging in power output from 0.25 to 3 horsepower. In promulgating the rule, the DOE invoked its authority to establish energy conservation standards for "small electric motors," a term defined by the Energy Policy and Conservation Act. An electronics association filed a petition for review, arguing that the statutory definition of a small electric motor unambiguously excludes all electric induction motors exceeding 1 horsepower, as well as certain motors rated at and less than 1 horsepower. But the statutory definition does not unambiguously incorporate such a limitation. Moreover, DOE's interpretation was a reasonable policy choice for the agency to make. Accordingly, the petition for review was denied.