APGA Provides Feedback on DOE Zero Emissions Building Definition

By Sydney Novoa posted 20 days ago


On February 5, APGA provided feedback to the Department of Energy (DOE) on a draft National Definition for a Zero Emissions Building (ZEB). APGA believes that the energy public gas utilities deliver can and should play an integral role in net zero emissions buildings. Unfortunately, in this request for information (RFI) from DOE’s Building Technologies Office (BTO), the draft definition of a ZEB did not take a fuel-neutral approach. 

In our comments, APGA noted that the definition focuses on on-site emissions from energy use and doesn’t account for off-site emissions. APGA commented that any ZEB definition should account for full-fuel cycle energy and emissions, incorporating a fuel-neutral approach. As well, given their potential for decreased emissions, APGA also argued that any ZEB definition should permit biofuels, as well as other low-carbon fuels, to be consumed on-site.  

This part 1 of a draft National Definition for a ZEB was focused on operating emissions. More information is available here. Future proposed parts of this definition are likely to impact embodied carbon, refrigerant, and other key elements. 

Responses to this RFI and others from BTO will equip DOE with insights on the definition and, hopefully, assist in developing a final, fuel-neutral version of the National Definition for a ZEB. A widely accepted definition, as well as a pathway for verification, is foundational in decreasing emissions, but it should also ensure America’s buildings continue to have access to affordable and reliable energy. These are goals that all policymakers can agree on.

APGA will continue to work on this issue and will inform members of any future actions by DOE. For questions on this article, please contact Sydney Novoa of APGA by phone at 202-464-0834 or email at