Regulatory Submissions

APGA, AGA, Spire Comments on DOE's Entitled Energy Conservation Program (May 27 2021) 

07-07-2021 10:20 AM

COMMENTS OF THE AMERICAN GAS ASSOCIATION, THE AMERICAN PUBLIC GAS ASSOCIATION, SPIRE INC., AND SPIRE MISSOURI INC. In response to the Request for Comment Entitled Energy Conservation Program: Procedures, Interpretations, and Policies for Consideration in New or Revised Energy Conservation Standards and Test Procedures for Consumer Products and Commercial/Industrial Equipment 86 Fed. Reg. 18901 (April 12, 2021) Docket No. EERE-2021-BT-STD-0003 RIN 1904-AF13

The American Gas Association (AGA), the American Public Gas Association (APGA), and Spire Inc. (Spire), collectively referred to as “Commenters,” appreciate the opportunity to comment on the above-captioned notice of proposed rulemaking (NOPR) concerning revisions of its “Process Rule.”1 AGA, founded in 1918, represents more than 200 local energy companies that deliver clean natural gas throughout the United States. There are more than 76 million residential, commercial and industrial natural gas customers in the U.S., of which 95 percent — more than 72 million customers — receive their gas from AGA members.

AGA is an advocate for natural gas utility companies and their customers and provides a broad range of programs and services for member natural gas pipelines, marketers, gatherers, international natural gas companies, and industry associates. Today, natural gas meets more than thirty percent of the United States’ energy needs.

APGA is the trade association for approximately 1,000 communities across the U.S. that own and operate their retail natural gas distribution entities. They include municipal gas distribution systems, public utility districts, county districts, and other public agencies, all locally accountable to the citizens they serve. Public gas systems provide safe, reliable, and affordable energy to their customers and support their communities by delivering fuel to be used for cooking, clothes drying, and space and water heating, as well as for various commercial and industrial applications.

Spire Inc. and Spire Missouri Inc. (collectively “Spire”) are in the natural gas utility business. Spire Inc. owns and operates natural gas utilities that distribute natural gas to over 1.7 million residential, commercial, and institutional customers across Missouri, Alabama, and Mississippi, and Spire Missouri Inc. is the largest natural gas utility serving residential, commercial, and institutional customers in Missouri. Natural gas utilities are critical stakeholders in rulemakings concerning standards for products that use natural gas, including the procedures used by DOE to adopt these standards, and support energy efficiency, including cost effective efficiency improvements, for natural gas products. Overall, as a recent study found, natural gas utilities invested $3,800,000 per day in energy efficiency programs in 2018. 2 The study found that, in 2018, natural gas utilities funded 132 natural gas efficiency programs in the U.S. and Canada for a total of $1.47 billion—an eight percent jump from 2016 and a 20 percent rise since 2012.3 These programs help customers install tighter-fitting windows and doors, better insulation and purchase increasingly more efficient natural gas appliances.

Natural gas utilities spent one-quarter of their budget ($365.34 million) on low-income efficiency programs, assisting over 214,581 participants in 2018.5 Additionally, 1 See 10 C.F.R Part 430, Subpart C, Appendix A. 2 Natural Gas Efficiency Programs (2018 Program Year), available at https://www.aga.org/research/reports/naturalgas-efficiency-programs-2018-program-year/. 3 Id. 4 Id. 5 Id. - 3 - more than 66,000 commercial customers, and upwards of 72,000 industrial program customers were enrolled in natural gas efficiency programs in 2018.6 Commenters are especially concerned that such efficiency standards be adopted only after consideration of all relevant points of view, including the distributors of natural gas, whose desire for the efficient use of natural gas is matched only by their commitment to ensure that minimum standards do not have the consequence of eliminating consumers’ choice to use clean and economical natural gas by imposing unjustified costs on consumers or depriving them of gas-fired products that are suitable for their needs. Such standards are not authorized by statute and would be harmful both to natural gas utilities’ interests and those of the consumers they serve.

Commenters have a direct and vital interest in both the minimum efficiency standards and the procedures used by DOE to adopt new minimum efficiency standards and have consistently engaged in efforts to revise the Process Rule, including through its recently finalized changes in 2020. Accordingly, we offer these comments in response to the newly proposed revisions.

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