Regulatory Submissions

APGA submitted a brief comment letter to DOE in response to its proposed energy conservation standards for manufactured housing.  While the proposed standards did not directly impact gas use in factory-made homes, it did consider the social cost of greenhouse gases (SC-GHG).  APGA’s letter referenced coalition comments APGA had joined earlier this year that identified several concerns with how the preliminary SC-GHG values were derived and urged DOE to not use these values in any rulemaking moving forward until the concerns had been addressed.