Regulatory Submissions

On April 17, APGA submitted comments in response to the Department of Energy’s (DOE) supplemental notice of proposed rulemaking (SNOPR) pertaining to energy conservation standards (ECS) for consumer cooking products, including gas-fired ranges and ovens.  Through the comments, APGA identifies several flaws in the rulemaking and its underlying analyses and argues that DOE must withdraw the SNOPR to address these issues before moving forward with setting new standards for these products. 

If implemented, the proposed standards would ban the majority of gas-fired ranges that are currently available on the market.  Specifically, DOE’s proposed standards would violate federal law by banning certain features in gas ranges that consumers find valuable: high input burners and cast iron grates.  Through both its comments to DOE and a letter to the Department of Justice (DOJ), APGA raised its concerns about the anticompetitive nature of this particular rulemaking.  Other significant flaws highlighted in the comments to DOE included the inherent bias in the relevant test procedure against gas-fired appliances, as well as the lack of sufficient economic justification.

APGA will continue to weigh in on DOE’s appliance efficiency rulemakings that impact gas-fired appliances, as APGA members provide the energy needed to fuel these appliances, thus making public gas systems critical stakeholders in these rulemakings.