On July 12, APGA submitted comments in response to a Request for Information (RFI) on reducing regulation and controlling regulatory costs of the Department of Energy (DOE). The RFI is a result of an Executive Order signed by President Trump that requires DOE to “review all existing regulations, orders, guidance documents, policies, and any other similar agency actions (collectively, agency actions) that potentially burden the development or use of domestically produced energy resources, with particular attention to oil, natural gas, coal, and nuclear energy resources.”
APGA’s comments address a number of issues that have come out of the challenges we have faced in recent DOE appliance efficiency rulemakings, such as the furnace rule. Among other things, APGA’s comments communicate that the Office of Energy Efficiency and Renewable Energy’s orientation has created a bias against natural gas appliances and therefore appliance standard outcomes would be improved if there was a separation of the appliance standards obligations of DOE into its own office. APGA’s comments also address a number of process reforms we have communicated in the past, such as the need for greater transparency and that test procedures must be completed prior to DOE moving forward with a new efficiency standard. The comments also raise the issue of DOE modeling, communicating that the models created by DOE to justify efficiency standards have grown excessively complex, impenetrable, as well as costly. APGA urges DOE to utilize a more simplified approach to evaluating existing minimum efficiency standards and for setting new ones. A more simplified and straightforward approach would lower the cost of DOE’s regulations as well as the burden on industry and consumers.
A copy of APGA’s comments is available on the APGA website. For questions on this article, please contact Dave Schryver of APGA staff by phone at 202-464-2742 or by email at
dschryver@apga.org.