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On June 24, APGA submitted comments in response to the Department of Energy’s (DOE) request for information (RFI) pertaining to test procedures for consumer water heaters and residential-duty water heaters. Similarly, on June 4, APGA also submitted comments in response to DOE’s RFI pertaining to test procedures for commercial warm air furnaces (CWAFs).

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. The RFIs for both sets of test procedures posed a number of complex questions, ranging from current market and technology trends to an engineering analysis of the current products and potential advances in energy efficiency. Consequently, APGA’s comments supported those of the Air-Conditioning, Heating, and Refrigeration Institute (AHRI), who we closely coordinated with, echoing AHRI’s comments as they pertain to gas-fired appliances. Furthermore, through our comments, APGA reiterated the need for DOE to appropriately implement its recently update Process Rule through these rulemakings.

A copy of APGA’s comments to DOE in response to the RFI on water heater test procedures can be found here, and APGA’s comments in response to the RFI on CWAF test procedures can be found here. For questions on this article or APGA’s efforts to respond to DOE’s RFIs for appliance test procedures, please contact Renée Lani of APGA staff by phone at 202-464-0836 or by email at rlani@apga.org.