Regulatory Submissions

On June 14, APGA submitted joint comments to the Department of Energy (DOE) in response to the agency’s request for comments pertaining to its notice of proposed rulemaking (NOPR) for consumer pool heaters minimum efficiency standards.

APGA’s comments in response to the consumer pool heaters NOPR were jointly submitted with the American Gas Association (AGA) and the National Propane Gas Association (NPGA). Through the comments, the associations raised concerns about the proposed minimum efficiency standards, as the new level could lead to product safety concerns if implemented. As with other appliance rulemaking comments, APGA also asked DOE to implement several of the recommendations from a recent peer-reviewed report that evaluated the agency’s rulemaking procedures.

APGA weighs in on DOE’s appliance efficiency rulemakings that impact gas-fired appliances, as APGA members provide the energy needed to fuel these appliances, thus making public gas systems critical stakeholders in these rulemakings.