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HPBA Files Comments in Response to DOE RFI

HPBA Files Comments in Response to DOE RFI

On December 5, 2011, the Department of Energy (DOE) published a Request for Information (RFI) in the Federal Register seeking comments and information from interested parties in an effort to determine the need for changes to any of their existing rules. DOE stated that it was seeking comments as part of its implementation of Executive Order 13563, "Improving Regulation and Regulatory Review," issued by President Obama on January 18, 2011.

As part of the Executive Order, all agencies were directed to conduct periodic retrospective reviews of regulations "that may be outmoded, ineffective, insufficient, or excessively burdensome, and to modify, streamline, expand, or repeal them in accordance with what has been learned."

In response to the RFI, HPBA submitted comments to DOE on Wednesday, January 4, 2012, urging DOE to abandon the agency's overly-burdensome and unnecessary regulation classifying both decorative vented gas fireplaces and vented gas log sets as "direct heating equipment" (DHE). In addition to the improper classification of decorative vented gas fireplaces and vented gas log sets as DHE, HPBA also commented on the improper imposition of heating standards on non-heating products, a lack of justification for the alternative requirements imposed under the new final rule, and the procedural irregularities in the rulemaking.

  • A copy of these comments can be found here.
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