Regulatory Submissions

APGA Files Comments on DOE’s Commercial Refrigerators, Freezers, and Refrigerator-Freezers NODA (September 27 2024) 

10-03-2024 01:04 PM

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. 

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Coalition Comments on DOE Commercial Freezers-Refrig NODA....pdf   364 KB   1 version
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