Regulatory Submissions

On May 26, APGA submitted comments in response to the Department of Energy’s (DOE) request for information (RFI) pertaining to energy conservation standards (ECS) for consumer boilers. Although not appliance manufacturers, APGA members do provide the energy needed to fuel the appliances in question; consequently, public natural gas utilities are a critical stakeholder in this work. In response to the RFI, APGA – with the American Gas Association (AGA) and Spire – supported the implementation of separate product classes for condensing and non-condensing technology, in line with the recently finalized interpretive rule. In addition to noting that a new ECS for consumer boilers would not be economically justified, the joint comments also requested that DOE improve its methodologies to allow for more reliable underlying data in future rulemakings.

Additionally, on May 27, APGA submitted comments in response to DOE’s notice of proposed rulemaking (NOPR) for the Process Rule – the rule that dictates the procedures the agency must follow in developing its minimum appliance efficiency rulemakings. In the comments, APGA – joined by AGA and Spire – called for DOE to maintain the enforceable nature of the rule, a new feature that was only finalized in 2020. Additionally, the joint comments also opposed most of DOE’s proposed changes, as they will likely minimize transparency and consistency in DOE’s appliance efficiency rulemakings.