Regulatory Submissions

On July 6, APGA submitted joint comments with Spire, Inc. (Spire) and the American Gas Association (AGA) in response to the Department of Energy’s (DOE’s) request for information (RFI) pertaining to energy conservation standards (ECSs) for consumer water heaters (CWHs). Although not appliance manufacturers, APGA members do provide the energy needed to fuel CWHs; consequently, public natural gas utilities are a critical stakeholder in this work.

Through its comments, APGA addressed the need for separate product classes for condensing and non-condensing combustion technology in gas-fired CWHs. We also used this opportunity to reiterate APGA’s positions regarding the flawed Furnace Rule, including random assignment issues in modeling, as well as subsequent DOE activity, such as the agency’s delay in finalizing the proposed interpretive rule for separate product classes. As always, APGA reinforced the need for DOE to appropriately implement its recently update Process Rule in any potential appliance efficiency rulemaking.

A copy of APGA’s comments to DOE in response to the RFI on CWH ECSs can be found here. For questions on this article or APGA’s efforts to respond to DOE’s RFIs for appliance ECSs, please contact Renée Lani of APGA staff by phone at 202-464-0836 or by email at rlani@apga.org.