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On August 30, APGA submitted comments to the Department of Energy (DOE) Office of Energy Efficiency and Renewable Energy (EERE) on a request they issued regarding data to be used in setting energy conservation standards for consumer product and commercial and industrial equipment. EERE was hoping to get stakeholder input on what data should be used in carrying out the Process Rule.

Unfortunately, the office believes site energy should be used exclusively for prescribing energy conservation standards, based on their interpretation of the Energy Policy and Conservation Act of 1975 (EPCA). APGA pushed back on this assertion providing that site energy does not fully account for energy demand and costs. Full-fuel-cycle metrics should be used. The National Academy of Sciences (NAS) confirms this in a report they issued, and several other government agencies, such as the Environmental Protection Agency (EPA), use metrics that account for energy loss and cost in all aspects of the supply chain. In the NAS report, there were also a few recommendations to EERE, which have not been completed, so APGA took the opportunity to urge completion of those. To see the comments, click here.

For questions on this article, please contact Stuart Saulters of APGA staff by phone at 202-464-2742 or by email at ssaulters@apga.org.