Blogs

On September 9, APGA submitted comments in response to a Department of Energy (DOE) proposed interpretive rule. The reasoning for DOE even requesting this input was due to a petition from APGA and other gas industry stakeholders last June. That petition asked for legal interpretation whether the Energy Policy and Conservation Act (EPCA) does or does not authorize the adoption of efficiency standards that would limit the appliance market. In the Federal Register notice announcing the interpretive rule, DOE “partially grants the petition by issuing an interpretation that non-condensing operation is a product feature and that no DOE rulemaking may prescribe a standard that would make that feature unavailable.”

DOE’s proposal also states their intention is “not impede energy affordability, particularly for persons with low incomes, by mandating high-cost condensing products and installations.” The feedback given to DOE this week thanked them for their support in ensuring their appliance standards are all encompassing with regards to features. However, DOE was urged to finalize the pending residential furnace and commercial water heater rulemakings accounting for this interpretive rule. APGA was glad to have a diverse set of signatories for these comments, representing several stakeholder groups including gas companies like Spire, but also the building, housing, and contracting community. The National Association of Home Builders (NAHB), the Air Conditioning Contractors of America (ACCA), the Plumbing-Heating-Cooling Contractors—National Association (PHCC-NA), the National Multifamily Housing Council (NMHC), the National Apartment Association, the National Leased Housing Association (NLHA), and the Manufactured Housing Association for Regulatory Reform (MHARR) were all happy to join in APGA’s submittal to DOE. 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.