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On March 2, APGA submitted comments in response to the Environmental Protection Agency’s (EPA) new ENERGY STAR program proposal: NextGen Certification for Commercial Buildings.  As with other voluntary ENERGY STAR programs, the NextGen certification is intended to encourage increased energy efficiency; however, as proposed, the program is likely to limit innovation, risk energy resiliency, and squander existing energy infrastructure efficiencies.

The NextGen proposal included numerous flaws, such as promoting full electrification, no matter the building needs or local electricity generation make-up.  Furthermore, the program would not consider full-fuel cycle emissions and instead only look at site emissions.  If the EPA were to finalize a program that promulgates such policies, it could actually have impacts contrary to our country’s decarbonization goals. APGA has submitted similar comments in response to other EPA ENERGY STAR proposals, such as removing all gas-fired appliances from the program’s “Most Efficient” list.  Through its comments to EPA on the NextGen proposal, APGA also supported the comments submitted by the American Gas Association (AGA).

A copy of APGA’s comment letter is available here.

For questions on this article, please contact Stuart Saulters of APGA staff by phone at 202-802-0493 or by email at ssaulters@apga.org.