Regulatory Submissions

On May 19, APGA submitted comments to the U.S. Department of Energy (DOE) in response to a petition pertaining to the test procedures for gas cooking products that were finalized last year.

Recall that DOE finalized a new test procedure for gas cooking products last year. During the notice and comment period, APGA had raised concerns about the repeatability of the new test procedure. To help address concerns with the final test procedure, the Association of Home Appliance Manufacturers (AHAM), the trade association that represents manufacturers of cooking products, petitioned the agency in January 2023. However, DOE did not publish notice of the petition until after the comment period closed for the agency's rulemaking impacting gas cooking products' minimum efficiency standards, during which APGA also raised concerns about the test procedure for gas-fired appliances.

Through the comments, APGA supported portions of the petition while continuing to raise concerns about how the test procedures seen inherently biased against gas cooking products. APGA engages in test procedure rulemakings, as they are the underpinning for complaince with minimum efficiency standards. APGA jointly submitted the comments with the American Gas Association (AGA), the National Propane Gas Association (NPGA), and Spire.