2013-02-11 Comment response to the published RFI

February 11, 2013 Ms. Brenda Edwards U.S. Department of Energy Building Technologies Program Mailstop EE-2J 1000 Independence Ave. SW. Washington, DC 20585-0121 RE: Docket No. EERE-2011-BT-TP-0042, Energy Conservation Program: Test Procedures for Residential Water Heaters and Commercial Water Heaters Comments of the National Propane Gas Association The National Propane Gas Association (“NPGA”) submits these comments in response to the January 11, 2013 Request for Information from the Department of Energy regarding, Energy Conservation Program: Test Procedures for Residential Water Heaters and Commercial Water Heaters. NPGA strongly encourages the department to include a Full Fuel Cycle (FFC) analysis in the new test procedure and the new universal energy descriptor, and, DOE should include FFC information on any label recommendations to the Federal Trade Commission (FTC). NPGA is the national trade association of the propane industry having a membership of about 3,000 companies, with 39 state and regional associations representing members in all 50 states. While NPGA’s membership covers a broad cross-section of categories, over 90 percent of our members are retail marketers of propane gas who deliver the fuel to the ultimate end user. Propane represents a small but important part of the U.S. energy sector. According to EIA’s statistics, approximately 7.6 million U.S. households rely on propane for space heating and 5.8 million households use propane for water heating. Full Fuel Cycle There are two types of energy consumption measures. • Site (point-of-use) measure of energy consumption reflects the energy use (and emissions) of propane, electricity, natural gas, and/or fuel oil by an appliance or vehicle at the site where the appliance or vehicle is operated. • Full Fuel Cycle measure of energy consumption includes, in addition to site energy, the energy consumed in the extraction, processing and transport of primary fuels such as coal, oil or natu