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On February 28, APGA, joined by the American Gas Association (AGA) and Spire, submitted comments in response to the Department of Energy’s (DOE) request for information pertaining to energy conservation standards (ECS) for weatherized gas furnaces (WGF). The comments reiterated earlier concerns regarding DOE’s underlying analyses that must be addressed before proceeding with any appliance rulemaking.

In previous submissions to DOE, APGA, AGA, and Spire have raised concerns with how DOE models future natural gas prices and marginal natural gas prices, both of which are important in DOE’s analyses of whether a more stringent ECS is economically justified. Additionally, the comments reiterated earlier concerns with additional economic modeling used by DOE, such as how consumers decide what type of appliance to purchase. It is important that DOE address these concerns, as they underlie many of DOE’s appliance rulemakings, and can impact whether a more stringent efficiency standard for any given appliance is justified.

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.