On November 19, APGA submitted comments to Council on Environmental Quality (CEQ) in response to the U.S. Department of Energy’s (DOE) proposed climate adaptation plan in coordination with the American Gas Association (AGA). Through these joint comments, APGA and AGA urged DOE to utilize natural gas and its existing infrastructure and workforce to help the agency provide energy resilience to its facilities, such as through the incorporation of combined heat and power (CHP) and the use of renewable fuels. A copy of the comments is available here.
Also in November, APGA staff, joined by Spire, Inc. staff and their outside counsel, met with the DOE’s General Counsel, Samuel Walsh, and the Deputy General Counsel for Litigation and Enforcement, Emily Hammond, last month to discuss our legal concerns with the agency’s proposed revocation of the separate product classes interpretive rule. Recall that the final interpretive rule, issued early this year, would have required the creation of separate product classes in energy conservation standard rulemakings to ensure that non-condensing appliances - whose venting is incompatible with condensing technology and would consequently require costly structural renovations in homes or businesses (if even possible) to replace with the newer technology – cannot be banned from the market if the agency desired to increase the efficiency standard for certain technologies. A copy of the ex parte letter and associated presentation slides is available here.
Finally, APGA submitted a brief comment letter to DOE in response to its proposed energy conservation standards for manufactured housing. While the proposed standards did not directly impact gas use in factory-made homes, they did consider the social cost of greenhouse gases (SC-GHG). APGA’s letter referenced coalition comments APGA had joined earlier this year that identified several concerns with how the preliminary SC-GHG values were derived and urged DOE to not use these values in any rulemaking moving forward until the concerns had been addressed. A copy of the comment letter is available here.
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.