On August 6, APGA submitted joint comments with the American Gas Association in response to the Department of Housing and Urban Development (HUD) and Department of Agriculture's (USDA) review of Energy Independence and Security Act of 2007 (EISA) program requirements. The comments highlight concerns with the April 2024 Final Determination adopting the 2021 IECC and ASHRAE 90.1-2019 energy codes, and emphasize balancing energy efficiency with affordability to keep homeownership accessible and utility costs manageable.