Regulatory Submissions

On January 29, APGA submitted joint comments in response to the Department of Energy’s (DOE) notice of proposed determination (NOPD) and request for comment pertaining to energy conservation standards (ECS) for weatherized gas furnaces (WGF).  APGA was joined by the American Gas Association (AGA) and National Propane Gas Association (NPGA) in submitting these comments.

Through the comments, APGA supported DOE’s proposal that higher efficiency standards for WGFs are not statutorily justified at this time.  The Energy Policy and Conservation Act (EPCA) requires that new ECSs must be technologically feasible and economically justified, among other factors.  In the NOPD, DOE noted that new ECSs would not be economically justified and proposed that the standards remain unchanged.

As in previous submissions to DOE, APGA reiterated earlier concerns regarding DOE’s underlying analyses that must be addressed before proceeding with any appliance rulemaking.  APGA raised concerns with how the agency models future natural gas prices and marginal natural gas prices, both of which are important in the agency’s analyses of whether a more stringent ECS is economically justified.  Additionally, the comments reiterated earlier concerns with how DOE is implementing recommendations from a peer-reviewed report, as well as those pertaining to the economic modeling used by the agency, such as how consumers decide what type of appliance to purchase.  It is important that DOE address these concerns, as they underlie many of the agency’s appliance rulemakings, and can impact whether a more stringent efficiency standard for any given appliance is justified.