Regulatory Submissions

APGA staff, joined by Spire, Inc. staff and their outside counsel, met with the DOE’s General Counsel, Samuel Walsh, and the Deputy General Counsel for Litigation and Enforcement, Emily Hammond, last month to discuss our legal concerns with the agency’s proposed revocation of the separate product classes interpretive rule.  Recall that the final interpretive rule, issued early this year, would have required the creation of separate product classes in energy conservation standard rulemakings to ensure that non-condensing appliances - whose venting is incompatible with condensing technology and would consequently require costly structural renovations in homes or businesses (if even possible) to replace with the newer technology – cannot be banned from the market if the agency desired to increase the efficiency standard for certain technologies.