On July 9, APGA filed comments with the Department of Energy (DOE) on its National Energy Rating Program for Homes.  APGA collaborated with GTI, Laclede Gas and the National Propane Gas Association in preparing comments but each organization filed separately.  APGA stated that it was encouraged by the DOE’s statement “that the Department plans to use source energy as the basic metric for the program.”  DOE’s supportive words include “…a source energy metric would allow consumers to more equitably consider all fuel types. Furthermore, depending on the conversion factors used, as well as how renewable energy is counted, source energy can more effectively reflect the environmental consequences of energy generation, transmission, and use.” 

APGA gave further support to source energy stating, “Site-based metrics most often lead consumers to wrongly believe that electricity is more efficient and less environmentally degrading than the direct use of natural gas. That said, APGA recognizes the direct use of natural gas will not always come out ahead of electricity given more rigorous full fuel-cycle analysis.  This is as it should be as it provides an environmental dimension to free-market competition based upon the empowerment of knowledgeable consumers.” 

As part of its comments, APGA provided DOE with the new Source Energy and Emissions Analysis Tool (SEEAT) developed by the Gas Technology Institute that allows calculation of the source energy and GHG emissions related to appliance site energy consumption by fuel type for each energy-consuming device and for the whole building.  SEEAT includes a source energy and carbon emission calculation methodology that accounts for primary energy consumption and related emissions for the full-fuel-cycle of extraction, processing, transportation, conversion, distribution, and consumption of energy. This tool available to the public at www.cmictools.com, was developed with support from the APGA Research Foundation and others.

DOE is also now exploring the first steps toward using estimates of full-fuel cycle energy savings and greenhouse gas (GHG) emissions as the basis for evaluating appliance energy conservation standards and determining, with the Federal Trade Commission, the best way to provide consumers with more complete information about the energy efficiency of the appliances they buy.

APGA sees a light at the end of the tunnel.  DOE is moving in the right direction, as is the Environment Protective Agency (EPA), in recognizing the scientific and equity arguments in favor of full-fuel cycle analysis.  You can view the APGA comments at www.apga.org.  

For further information, please contact Bob Beauregard at 202-464-2742 or bbeauregard@apga.org.

Return to Archives