Regulatory Submissions

Request for additional time for DOE NOPR on separate product classes for certain gas-fired condensing and non-condensing appliances (September 7, 2021) 

09-09-2021 12:15 PM

On September 7, APGA joined others in requesting additional time to respond to the Department of Energy’s (DOE) notice of proposed interpretive rule pertaining to separate product classes for certain gas-fired condensing and non-condensing appliances. DOE’s proposal would roll-back the interpretive rule finalized in January of this year, which would have ensured that new minimum efficiency standards could not be set that would effectively eliminate non-condensing technology from the market, as it determined the technology to be a protected feature.

In 2018, APGA and others from the gas industry submitted a petition to DOE, requesting the establishment of separate product classes for certain gas-fired condensing and non-condensing appliances. APGA and its members have repeatedly expressed concern that previously proposed rules by DOE suggesting the replacement of non-condensing appliances with condensing appliances would ultimately undermine efficiency goals while significantly increasing consumer costs. The previous administration granted the petition on January 15, 2021, but the proposed roll-back of the interpretation revives these concerns. The American Gas Association, Spire, and National Propane Gas Association also co-signed the request for additional time. 

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