Regulatory Submissions

On May 15, APGA submitted comments in response to the Department of Energy’s (DOE) Draft Zero Energy Ready Home (ZERH) Multifamily Program Version 2 (V2).  The program provides criteria for multifamily residential buildings to meet in order to qualify for ZERH certification and the 45L tax credit, as recently amended by the Inflation Reduction Act (IRA).

Through the comments, APGA urged DOE to maintain fuel neutrality throughout the ZERH Multifamily Program V2.  APGA reiterated its support of reducing emissions but reminded the agency that such efforts must be balanced with ensuring continued access to resilient and affordable energy for American consumers.  The comment letter also encouraged DOE to leverage existing pipeline infrastructure for less carbon-intensive fuels, like renewable natural gas and hydrogen, and be cautious when requiring compliance with voluntary programs like ENERGY STAR®, as some of its certifications have taken a misguided approach and excluded natural gas end uses.

APGA members play a critical role in delivering clean, reliable, and affordable energy to Americans.  APGA will continue to engage in similar rulemakings to advocate for “all-of-the-above” energy solutions that help move our country towards our emissions reduction goals while ensuring consumers have access to the energy source that best fits their needs and budgets.