2013-04-22 Comment response to the published NOPR

April 22, 2013 Kathleen B. Hogan Office of Energy Efficiency and Renewable Energy U.S. Department of Energy 1000 Independence Avenue, SW Washington, DC 20585 RE: Docket No. EERE-2013-BT-TP-0008-000, RIN 1904-AC96 Dear Ms. Hogan: The American Public Gas Association (APGA) is pleased to submit comments in response the to notice of proposed rulemaking regarding test procedures for two-stage and modulating condensing furnaces and boilers issued by the U.S. Department of Energy (DOE), Office of Energy Efficiency and Renewable Energy (EERE), in the Federal on February 4, 2013. APGA is the national association for publicly-owned natural gas distribution systems. There are approximately 1,000 public gas systems in 36 states and over 700 of these systems are APGA members. Publicly-owned gas systems are not-for-profit, retail distribution entities owned by, and accountable to, the citizens they serve. They include municipal gas distribution systems, public utility districts, county districts, and other public agencies that have natural gas distribution facilities. For more information, please visit www.apga.org. The Energy Policy and Conservation Act, 42 U.S.C, § 6293, sets forth criteria and procedures that DOE must follow when prescribing or amending test procedures for covered products, including natural gas furnaces. The Act provides that test procedures must be reasonably designed to produce test results which measure energy efficiency, energy use, or estimated annual operating cost of a covered product during a representative average use cycle or period of use, and must not be unduly burdensome to conduct. APGA believes that energy descriptors should reflect full-fuel-cycle energy metrics that allow for the comparison of products for which there is a choice of fuels. A source or full-fuel-cycle analysis examines all impacts associated with energy use, including those from extraction/production, conversion/generation, transmission, distribution, and ul