Over the last several months, APGA has been detailing various correspondences with the new Administration. On March 14, APGA, Spire, National Multifamily Housing Council, National Apartment Association, National Leased Housing Association, and Air Conditioning Contractors of America submitted a joint petition to the Department of Energy (DOE) asking them to correct the serious deficiencies in the furnace, boiler and commercial water heater rulemakings. Many of DOE’s appliance minimum efficiency analyses rely on modeling that is invalid due to a basic methodological flaw. This faulty modeling calls into question the Office of Energy Efficiency and Renewable Energy's (EERE) overall claims of what their “energy efficiency” efforts have saved consumers in both their gas and electric utility bills, potentially going back years.
The petition requests DOE to recognize the error in its methodology and asks DOE to:
- Invalidate the current analysis for furnaces, boilers and commercial water heaters through the Federal Register and announce their intention to reevaluate the proposed standards;
- Publish in the Federal Register their intent to reevaluate the proposed standards process and ask for public comment; and,
- Apply the revised methodology to the above list of proposed standards once they have completed their review of the current methodology.
For questions on this article, please contact Dan Lapato of APGA staff by phone at 202-464-2742 or by email at
dlapato@apga.org.