APGA Submits Comments to Process Rule Supplemental Notice

By Stuart Saulters posted 03-19-2020 10:45 AM

On March 16, APGA submitted comments in response to the Supplemental Notice of Proposed Rulemaking (SNOPR) of the Department of Energy (DOE) Office of Energy Efficiency and Renewable Energy (EERE) concerning modification of its Process Rule. Specifically, EERE wanted input on the “walk-down” process. This particular element of the appliance efficiency standards program aims to ensure that there is economic justification for changes to equipment standards, meaning an appropriate comparison of the benefits and burdens.

In the past, the appliance efficiency rulemakings may have simply adopted the max-tech without clear consideration of all the burdens weighed against the benefits. APGA’s comments supported the walk-down process confirming that cost effectiveness is a part of the analytical methodologies moving forward. Given APGA’s members serve many Americans that rely on natural gas for furnaces, water heaters, cooking ranges, and dryers, it is critical to engage EERE as they develop minimum efficiency standards. There is a clear desire for APGA members to help their customers use natural gas efficiently, but it shouldn’t require an undue burden. While it seems this EERE is trying to support a balanced energy approach, it is important that APGA reiterate the need for consumer choice and ensure regulatory processes allow that. To see the comments, click here.

For question on this article, please contact Stuart Saulters of APGA staff by phone at 202-544-1334 or by email at ssaulters@apga.org.