AGA, American Public Gas Association (APGA) & Spire Inc. File Joint Comments on the DOE Notice of Proposed Rulemaking Pertaining to the DOE “Process Rule”.
This past Monday, September 13th, AGA, APGA and Spire, Inc.,  filed timely comments on the  U.S. Department of Energy’s (DOE) July 7, 2021 Federal Register notice proposing revisions to DOE’s “Procedures, Interpretations, and Policies for Consideration of New or Revised Energy Conservation Standards and Test Procedures for Consumer Products and Certain Commercial/Industrial Equipment” (Process Rule) and requested comments on the proposals and any potential alternatives. The joint comments strongly disagree with DOE’s characterization of the proposed Process Rule  revisions in the earlier notice and in this notice that include the following topic areas: coverage determination rulemakings; clarification of EPCA’s rulemaking process for ASHRAE equipment; and clarification of DOE’s analytical methods. The Part One of DOE’s proposed changes to the Process Rule  returns it  to former requirements including what can be described  as “guidance” rather than a DOE requirement, eliminate the minimum energy savings threshold for DOE to set a standard and reinstate the potential for a stakeholder negotiation process. It would also eliminate a  mandatory 180-day waiting period between a test procedure final rule and a proposal for a new standard, a requirement that we believe is a common sense requirement to provide manufacturers time to assess changes on proposed requirements on their covered products. Each of these proposed changes would eliminate changes that many stakeholders including AGA,  APGA and Spire Inc. supported.  We will provide DOE’s response when available.

State Codes Activity Update.
Attached  is a weekly feature of the “Friday Update” covering state code calendar activities as presented by the online utility “Fiscal Note,” which is sponsored by APGA and AGA Code and Standards. Please review the update and determine if there are state code activities that impact your service territory or organization.
Please don’t hesitate to contact us if you have any questions on any of these items.