October 14, 2015 Ms. Brenda Edwards U.S. Department of Energy, Building Technologies Office, Mailstop EE-2J 1000 Independence Avenue, SW. Washington, DC 20585-0121 RE: Docket Number EERE-2014-BT-STD-0031 Dear Ms. Edwards: The American Public Gas Association (APGA) is pleased to submit comments to the U.S. Department of Energy (DOE) in response to the September 14th Notice of Data Availability regarding an analysis of the consumer economics and national impacts of establishing separate standard levels for large and small residential furnaces. APGA is the national association for publicly-owned natural gas distribution systems. There are approximately 1,000 public gas systems in 37 states and over 700 of these systems are APGA members. Publicly-owned gas systems are not-for-profit, retail distribution entities owned by, and accountable to, the citizens they serve. They include municipal gas distribution systems, public utility districts, county districts, and other public agencies that have natural gas distribution facilities. For more information on APGA and its members, please visit www.apga.org. A copy of APGA's comments is attached. Sincerely, Dave Schryver APGA Executive Vice President #DOE #furnace #furnacerule #Regulatory #noticeofdata
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