Regulatory Submissions

On February 17, APGA and the American Gas Association (AGA) sent a letter to the U.S. Department of Energy (DOE), raising concerns with its proposal to promulgate test procedures for certain gas-fired cooking products that lacked sufficiently repeatable efficiency testing results.

In a notice of proposed rulemaking (NOPR) issued in November 2021, DOE proposed a new test procedure to measure the energy efficiency of certain cooking products, both gas-fired and electric.  The efficiency test procedures developed by the agency are a key element in establishing minimum efficiency standards for appliances covered by federal law.  Accordingly, test procedures must be developed in an open and transparent manner, based on technically-supported data that results in methods that provide reliable and repeatable results.  Without such a test procedure underlying the appliance efficiency requirements, manufacturers may have difficulty bringing these gas-fired products to market and maintaining compliance with the applicable statute.