On October 13, APGA submitted joint comments with Spire, Inc., the American Gas Association (AGA), and the National Propane Gas Association (NPGA) in response to the Department of Energy’s (DOE) notice of proposed rulemaking (NOPR) concerning energy conservation standards (ECS) for clothes washers and dryers. Through the comments, APGA addressed its concerns with DOE’s rationale for establishing separate product classes for the appliances at question.
In the NOPR, DOE provided its rationale for why clothes washers and dryers required separate product classes; however, that rationale is contrary to previous agency explanations, including those used to support the need for separate product classes for condensing/non-condensing combustion technology in certain gas-fired appliances. APGA felt it was important to note the inappropriateness of this inconsistency, as we have been significantly involved in other appliance efficiency rulemakings that require separate product classes, such as the Furnace Rule.
A copy of APGA’s comments to DOE in response to the NOPR can be found here
. For questions on this article or APGA’s engagement with DOE’s appliance efficiency rulemakings, please contact Renée Lani of APGA staff by phone at 202-464-0836 or by email at firstname.lastname@example.org