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In this paper I look at social movement strategy in response to neoliberal environmental policy. Specifically, I look at the strategy of energy efficiency advocates during the development of federal energy efficiency standards for appliances starting with the program’s inception in the late 1970s. I develop a conceptualization of neoliberalism drawing from Adam Peck and Jamie Tickell’s “roll-back” neoliberalism and “roll-out” neoliberalism. In my conceptualization I view roll-back and roll-out neoliberalism as two forms of neoliberalism that can exist simultaneously, as well as occur and reoccur over time. I show how social movement strategy changes in response to each form of neoliberalization. Roll-back neoliberalization is characterized by environmental deregulation; in response, energy efficiency advocates turn to a state based and litigious strategy to ensure the existence of energy efficiency standards. Roll-out neoliberalization is characterized by a weakening of environmental regulation through the increased influence of industry and the development of competing market-based regulatory programs; in response, energy efficiency advocates conduct their own technical analysis in order to counter act industry influence. I collected data for this study through interviews with policy makers, industry members, and social movement members; in addition, I also conducted quantitative analysis of over 150 federal regulations. My research contributes to neoliberal theory by highlighting its effects on environmental regulation. My research also contributes to literature on social movements by identifying strategies that can counter neoliberal environmental policy.