On September 27, APGA joined a coalition of trade associations responding to the Department of Energy’s (DOE) notice of data availability (NODA) concerning the Energy Conservation Standards for Commercial Refrigerators, Freezers, and Refrigerator-Freezers.
The coalition included the American Coke and Coal Chemicals Institute, American Gas Association, Interstate National Gas Association of America, National Automatic Merchandising Association, National Rural Electric Cooperative Association, North American Association of Food Equipment Manufacturers, and the U.S. Chamber of Commerce.
Joint commenters urged DOE to not adopt the Environmental Protection Agency’s (EPA) December 2023 social cost of greenhouse gases (SC-GHG) updates to the Interagency Working Group’s (IWG) 2021 SC-GHG estimates in a potential Final Rule. Joint commenters highlight the significant flaws in the process and scientific analysis, lack of transparency and stakeholder engagement during the rulemaking development process, and legal vulnerabilities.
In June of 2021, APGA engaged when the IWG was tasked with developing interim SC-GHG values, which were released in February 2021, and then finalizing them – which the IWG never did. Instead, EPA finalized values for SC-GHG in December 2023 in an Oil and Natural Gas (ONG) emissions rulemaking.
While joint commenters still have concerns with the IWG’s SC-GHG preliminary estimates, applying those estimates instead of EPA’s estimates would avoid some of the process concerns that arise with applying EPA’s estimates.
Read the filed comments here.
APGA will continue to work on this issue and will inform members of any future actions by DOE concerning the SC-GHG.
For questions on this article, please contact Sydney Novoa of APGA by phone at 202-464-0834 or email at snovoa@apga.org.