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APGA Responds to DOE Proposed Error Correction Rule Amendments

By Renée Lani posted 11-12-2020 12:16 PM

On November 9, APGA submitted a joint letter with Spire in response to the Department of Energy’s (DOE’s) notice of proposed rulemaking (NOPR) and request for comment pertaining to proposed clarifying amendments of the Energy Conservation Program’s Error Correction Rule (ECR). Through the brief comments, APGA notes its general support of DOE’s proposed amendments to the ECR but opposes the agency’s intention to not require the error correction process as part of all energy conservation standard (ECS) rulemakings.

The ECR was intended to allow “public input on possible corrections to pre-publication drafts of [ECS] documents.” The proposed amendments would make clear that the error correction process does not levy a required timeline on DOE to publish a final rule and provides the agency with significant discretion on whether it ultimately establishes or amends an ECS. APGA engages in ECS rulemakings, as they may impact the availability of certain gas-fired appliances on the market, making it important to weigh in on DOE’s procedures for establishing these rules, such as the ECR.

A copy of the letter can be found here. For questions on this article or APGA’s engagement with DOE regarding its appliance efficiency rulemaking procedure, please contact Renée Lani of APGA staff by phone at 202-464-0836 or by email at