On May 16, APGA submitted two sets of joint comments to the Department of Energy (DOE) in response to DOE’s request for comments pertaining to both a notice of proposed rulemaking (NOPR) to set test procedures for consumer boilers and its preliminary technical support document (TSD) for consumer water heaters.
APGA’s comments in response to the consumer boilers test procedure NOPR were jointly submitted with the American Gas Association (AGA). DOE must develop test procedures in an open and transparent manner, based on technically-supported data that results in methods that provide reliable and repeatable results. Without such a test procedure underlying the appliance efficiency requirements, manufacturers may have difficulty bringing these gas-fired products to market and maintaining compliance with the applicable statute. Through the comments, APGA and AGA supported several technical comments raised by the Air-Conditioning, Heating, & Refrigeration Institute (AHRI), the trade association that represents the manufacturers of consumer boilers.
APGA’s comments in response to the consumer water heaters TSD were jointly submitted with AGA, the National Propane Gas Association (NPGA), and Spire. The TSD presents the underlying data that DOE will rely on when it proposes any updates to minimum efficiency standards for consumer water heaters (or determines that changes are unsubstantiated). Because consumer water heaters are similarly situated to residential furnaces, in that the associated venting between condensing and non-condensing technology is incompatible when handling appliance replacements, it was important for APGA to weigh in and continue to raise the same economic and other concerns for the potential of DOE setting a condensing-only standard.
APGA weighs in on DOE’s appliance efficiency rulemakings that impact gas-fired appliances, as APGA members provide the energy needed to fuel these appliances, thus making public gas systems critical stakeholders in these rulemakings.
A copy of the comments pertaining to the consumer water heaters TSD, as well as associated attachments, is available here
A copy of the comments pertaining to the consumer boilers test procedures NOPR is available here
For questions regarding this article, please contact Renée Lani of APGA staff by phone at 202-464-0836 or by email at firstname.lastname@example.org