APGA Tells DOE to Preserve Separate Product Classes for Gas-Fired Appliances

By Renée Lani posted 10-14-2021 12:01 PM

On October 12, APGA submitted joint comments to the Department of Energy (DOE), opposing DOE’s proposal to roll-back the final interpretive rule that granted separate product classes for condensing and non-condensing gas-fired technology.

A final interpretive rule was promulgated by the outgoing administration in January 2021, which determined that condensing and non-condensing technologies were considered protected features under the relevant federal law.  Accordingly, no minimum efficiency standard promulgated by DOE could eliminate either technology, meaning that DOE would have to establish separate product classes to ensure that condensing and non-condensing technologies could remain on the market.  In August, DOE proposed to reverse this decision.

Through the comments, APGA again told DOE that its proposal would effectively ban atmospherically vented (i.e., non-condensing) products, which is impermissible, and that its authorizing statute for appliance efficiency rulemakings does not authorize DOE to adopt standards in pursuit of other objectives such as electrification.  Spire, the National Propane Gas Association (NPGA), and the Plumbing-Heating-Cooling Contractors– National Association (PHCC-NA) also signed onto the comments.  A copy of the comments with associated attachments is available here.

Others who submitted comments opposing the reversal of the final interpretive rule are the American Gas Association (AGA), Natural Gas Supply Association (NGSA), U.S. Chamber of Commerce, Air-Conditioning Heating and Refrigeration Institute (AHRI), as well as a handful of individual appliance manufacturers. 

For questions on this article, please contact Renée Lani of APGA staff by phone at 202-464-0836 or by email at rlani@apga.org.