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Regulatory Reduction RFI, 76 Fed. Reg. 6123, February 3, 2011

Empire Comfort Systems supported the law requiring energy efficiency standards for Direct Heating Equipment (DHE), and when DOE started the rule making process to establish such standards we participated actively and in good faith .During the process we were visited by DOE's consultant Navigant and spent many hours entertaining DOE's consultants answering questions about our company and our products. There was follow-up and as far as I know full cooperation on our part to play within the rules. This process seemed to provide an opportunity to give data, exchange thoughts concerning our business and on the jobs we provide. Whether I liked the results regarding the space heating equipment or the heater rated hearth products is not relevant to this conversation. What is relevant is the idea that there was a process where the manufacturer and the regulator (that would be DOE) got together and exchanged information; That DOE did its due dilligence in the rule making process.