COPAA has filed public comments in response to a U.S. Department of Energy (DOE) notice of proposed rulemaking that proposes to eliminate requirements for accessibility of buildings] under Section 504 of the Rehabilitation Act. While COPAA does not typically comment on policy matters at the DOE, the comments were warranted given the flagrant use of a policy tool known as a “direct final rule” -which bypasses requirements under the Administrative Procedures Act- as well as the intention of the rule to gut federal 504 accessibility requirements.