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APGA Comments on New York Building Code Proposal (September 19 2024) 

10-03-2024 11:39 AM

APGA has engaged recently on a proposal put forward by New York policymakers that can negatively impact the use of natural gas in buildings in that state. APGA’s members in New York are focused on providing resilient and affordable energy to their customers through the infrastructure the existing, competent workforce operates. Also, this infrastructure and workforce could be used to deliver renewable natural gas and hydrogen in the future. Given this, it is important for APGA to submit comments to the docket.

The input submitted responds to a proposed rule with amendments to Part 1229 and Part 1240 of Title 19 of the New York Codes, Rules, and Regulations. APGA believes what was put forward aims to eliminate the use of natural gas in many buildings New Yorkers own, inhabit, and utilize. APGA supports responsible climate conscious policies; however, removing the option of natural gas places an unfair economic burden on New York residents and utility providers. It also could have limited, if any, emissions reductions especially considering the high efficiency of the direct use of natural gas.

Instead of eliminating natural gas, the state of New York should consider a revised approach to clean energy goals that maintains the utilization of natural gas, while also integrating renewable natural gas (RNG) and hydrogen. This strategy would enable New York to meet its climate targets while ensuring residents and businesses retain access to affordable and resilient energy. In addition, this path forward continues to utilize the investments of the state in its existing pipeline infrastructure and competent utility workforce.

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2024-0918_NY Building Code Comments - APGA - FINAL.pdf   743 KB   1 version
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