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Public Gas News Inside This Issue

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APGA Opposes LNG Export Legislation

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PHMSA Proposes to Adopt Annual Report Changes Suggested by APGA

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APGA Urges EPA to Ease Greenhouse Gas Reporting Burden

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PHMSA Working Group on Public Awareness Meets

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APGA Speaks at Southeast LDC Forum

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APGA Represents Public Gas at PHMSA Class Location Workshop

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APGA Meets with Senator Toomey and Senate Republican Steering Committee

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APGA Submits Comments on DOE’s Request for Input on Residential Conventional Cooking Products

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APGA Joins NGVAmerica to Oppose Kilogram NGV Standards

2014 APGA Annual Conference The 2014 APGA Annual Conference will take place July 20-23 at the Resort at Squaw CreekTM in Lake Tahoe, California. Register to attend or exhibit at www.apga.org/laketahoe.

May 5, 2014 Volume 33 Number 9

In a Victory for APGA, Court Vacates DOE Furnace Rule

On April 24, the U.S. Court of Appeals approved a joint motion to vacate a direct final rule (DFR) concerning 2011 furnace efficiency standards issued by the Department of Energy (DOE) (76 Fed. Reg. 67037). In March, APGA, DOE, and the other parties filed a joint motion for vacatur in the case styled as American Public Gas Ass’n v. Department of Energy, D.C. Cir. No 11-1485. By approving this motion, the court vacated the original rule and remanded the proceeding for notice and comment rulemaking. APGA filed its petition for review with the court in December 2011 to challenge the DFR. By establishing a 90 percent fuel efficiency standard for furnaces in the northern region of the United States, the DFR would have eliminated non-condensing gas furnaces from the northern region and likely driven many consumers

in that region to less efficient electric furnaces. DOE and APGA began meeting in fall 2012 to discuss a possible settlement through a court-supervised mediation process, which resumed in January 2014. As part of the settlement that eventuated from these discussions, DOE agreed to withdraw the DFR and initiate a traditional notice and comment rulemaking for new furnace efficiency standards. Bert Kalisch, APGA’s President & CEO, stated, “Without the courage of APGA’s Board of Directors to proceed with this lawsuit, there would be no settlement today. APGA knew it was important to stand up for the interests of natural gas customers, natural gas utilities and overall efficiency in this litigation. While APGA is not a large association, our members recognized two essential wrongs in this continued on page 3


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May 5, 2014

APGA Opposes LNG Export Legislation

APGA Public Gas News

Publisher: Bert Kalisch Editor: Audrey Anderson Writers: APGA Staff Layout: Marghet Hager For questions and comments: Please contact Audrey Anderson, APGA Marketing & Communications Manager, at 202-464-2742 or by email at aanderson@apga.org Public Gas News is published biweekly by the American Public Gas Association Copyright 2014 American Public Gas Association All rights reserved. This is intended for actual subscriber use only. You may not forward, distribute, copy or republish this newsletter in any manner without the express written consent of the American Public Gas Association.

On April 28, APGA sent a letter to Chairman Upton (R-Mich.) and Ranking Member Waxman (D-Calif.) of the House Energy and Commerce Committee expressing opposition to the Domestic Prosperity and Global Freedom Act (H.R. 6) introduced by Representative Gardner (R-Colo.). APGA testified in opposition to this legislation at a March 25 hearing in the Energy and Power Subcommittee. Rep. Gardner introduced H.R. 6 on March 6 in response to the crisis in Ukraine. This legislation would grant free trade agreement (FTA) status for U.S. natural gas to all 159 members of the World Trade Organization (WTO). In effect, this would do away with the requirement for the Department of Energy (DOE) to do a public interest analysis on the export of LNG to countries that do not have an FTA with the United States. Instead, under this bill, any export to a WTO country would be granted by DOE without modification or delay. In its letter, APGA communicates that “this legislation will fail to achieve its desired purpose of reducing Ukraine and other Eastern European

nations’ dependence on Russian natural gas and will increase the price of our domestic natural gas here at home hurting homeowners’ budgets and businesses’ bottom lines.” The letter also states that the legislation will fail to assist Ukraine as natural gas will be sold by private firms to the highest bidder without any consideration of U.S. geopolitical interests. The letter argues that rather than exporting LNG, the U.S. should be exporting the drilling technology that has enabled producers to tap into huge shale reserves. There are vast shale reserves in Europe, including Ukraine, assuming countries are willing to invest in the technology to access those reserves and also to permit drilling for shale gas reserves. Copies of the letters to Chairman Upton and Ranking Member Waxman are available on the APGA website at www.apga.org/correspondence. If you have any questions on this article or APGA’s efforts to oppose LNG export, please contact Dave Schryver of APGA staff by phone at 202-464-2742 or by email at dschryver@apga.org.

2014 Marketing & Sales Award Now Open

The APGA Marketing & Sales Award is an annual award to recognize APGA public natural gas systems who have worked hard to market natural gas this past year. Systems of all sizes are encouraged to submit their innovative and successful marketing programs, branding initiatives or customer service campaigns for consideration and recognition. The five award categories are: • System Growth Program • CNG Program • Consumer Education Program • Advertising Program • Digital Marketing Program Please note that you must fill out

separate forms for each category you wish to enter. The 2014 Marketing and Sales Award will be open for submissions April 28-June 10, 2014. Winners will be notified in June and the awards will be presented at the 2014 APGA Annual Conference in Lake Tahoe, Calif. Systems may submit entries to any number or variation of categories at www.apga.org/MSaward. If you have any questions on the award, please contact Audrey Anderson of APGA staff by phone at 202-464-2742 or by email at aanderson@apga.org.


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May 5, 2014

In a Victory for APGA, Court Vacates DOE Furnace Rule

continued from page 1 rulemaking: first, trying to implement a change via direct final rule on a contested and complex matter with many stakeholders; and, second, adopting an efficiency standard that benefits a few to the detriment of many. Because of the DFR’s disregard for the inability of many American consumers to afford the significant costs required to retrofit their home’s venting system, today marks an overall energy and emission savings victory for the country. APGA looks forward to working with DOE and other stakeholders on a new furnace efficiency standard that serves the best interests of American consumers, regardless of region or financial wherewithal.” The DFR mandated an increase in annual fuel utilization efficiency (AFUE) from 78 percent to 90 percent for natural gas furnaces installed in 30 northern states. The federal minimum efficiency for natural gas furnaces was

also increased from 78 percent to 80 percent in southern states. Under the DFR process, unless DOE received adverse comments that DOE believed provided a reasonable basis for withdrawing the DFR, the rule and its minimum efficiency standards would stand as the new efficiency standards. Despite receiving comments opposing the standards from over 30 stakeholder groups including APGA, DOE ruled that it did not receive adverse comments warranting withdrawal of the DFR. The furnace rule would have taken effect in May 2013. Instead, DOE will now develop new efficiency standards for gas furnaces. In this new rulemaking, APGA urges DOE to consider regional impacts on consumers when setting appliance efficiency standards. APGA is a long-standing supporter of energy efficiency, and will continue to be. In fact, the direct use of natural gas is one of the most efficient uses

of energy at 90 percent compared to 27 percent for electricity. However, the furnace rule in the DFR, in an attempt to increase energy savings, would have inadvertently deterred consumers from purchasing more efficient direct use natural gas appliances due to the high upfront costs associated with the only furnace type—condensing furnaces—that could meet the DFR-established 90 percent standard. Consequently, consumers would be incented by the DFR to buy electric appliances that are initially cheaper to install, but ultimately less efficient and therefore more costly in the long term. For questions on this article, please contact Dave Schryver of APGA staff by phone at 202-246-2742 or by email at dschryver@apga.org.

PHMSA Proposes to Adopt Annual Report Changes Suggested by APGA

In the April 28 Federal Register, the Pipeline and Hazardous Materials Safety Administration (PHMSA) proposed to modify its Distribution Annual Report to adopt four changes suggested by APGA in written comments filed in 2013. Specifically, PHMSA is proposing to: • Add a section for operators to specify the commodity type transported, “Natural Gas,” “Synthetic Gas,” “Hydrogen Gas,” “Propane Gas,” “Landfill Gas,” and ”Other Gas.” • Add utility ownership definitions aligned with those found in Energy Information Administration (EIA) Form 176: ”Investor Owned,” “Municipally Owned,” ”Privately Owned,” ”Cooperative,” and ”Other Ownership.” • Add “Reconditioned Cast Iron”

as a pipe material and defining it as a cast iron gas distribution pipe that has been lined internally by use of suitable materials that ensure safe operation at a maximum allowable operating pressure (MAOP) not to exceed the previously established MAOP. Reconditioned Cast Iron does not include cast iron pipe inserted with a gas pipe that is, by itself, suitable for gas service under Part 192, (e.g., an ASTM D2513 pipe meeting code requirements for the intended gas service). Such insertions are to be reported as the material used in the insertion. • Revise “Cause of Leak ” categories in Part C to align with the leak causes in the gas distribution annual report with the incident

causes from the gas distribution incident reporting form (PHMSA F 7100.1, Incident Report—Gas Distribution System). • Add a new data collection in “Excavation Damage” to include the four causes from Part I of the “Damage Information Reporting Tool (DIRT)-Field Form.” These changes will not take effect until PHMSA reviews public comments from this notice and gains approval from the Office of Management and Budget for these changes. For questions on this article, please contact John Erickson of APGA staff by phone at 202-464-2742 or by email at jerickson@apga.org.


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May 5, 2014

APGA Urges EPA to Ease Greenhouse Gas Reporting Burden

On April 23, APGA filed written comments with the Environmental Protection Agency (EPA) commending EPA for proposing to ease reporting burdens under EPA’s Greenhouse Gas Reporting rule and suggesting changes to further reduce the burden to report estimated fugitive greenhouse gas (GHG) emissions from distribution systems. On March 10, EPA proposed to amend the reporting requirements under Subpart W that requires certain operators of natural gas distribution systems to annually report estimated fugitive emissions of methane, carbon dioxide and other GHGs. Currently, Subpart W requires that reported GHG emissions be expressed in metric tons of carbon dioxide equivalent (CO2e). Subpart W estimates the leakage from gas distribution systems based on miles of mains, number of services, number of regulator stations and gate station leakage survey data. In this rulemak-

ing, EPA proposed to amend 40 CFR 98.236 to require reporting in metric tons of each reported GHG rather than convert tons of individual GHGs into units of metric tons of CO2e. This requires one less calculation by reporting utilities. APGA’s comments commended EPA for proposing to simplify the reporting. APGA encouraged EPA to even further simplify reporting by limiting reporting to only the minimum data necessary for EPA to calculate estimated GHG emissions. APGA listed 12 specific data elements such as miles of main and number of service lines by material of construction from which EPA could calculate all the other data Subpart W currently requires utilities to report. Reducing the number of calculations EPA requires responders to perform would ease reporting burdens and improve the quality of the data by reducing the potential for calculation errors. APGA noted

that even though EPA is proposing to no longer require natural gas distribution operators to convert metric tons of individual GHGs into CO2e, these operators must still determine if their estimated GHG emissions exceed the reporting threshold of 25,000 metric tons CO2e. This conversion should be performed by EPA’s electronic Greenhouse Gas Reporting Tool (e-GGRT), which should alert the reporting entity if the results of calculations using the 12 data elements entered by a utility result in estimated GHG emissions at or above the reporting. Copies of APGA’s comments can be found at www.apga.org/filings. For questions on this article, please contact John Erickson of APGA staff by phone at 202-464-2742 or by email at jerickson@apga.org.

PHMSA Working Group on Public Awareness Meets

On April 23 and 24, APGA participated in a meeting of the Pipeline and Hazardous Materials Safety Administration (PHMSA) Public Awareness Working Group. Public gas systems are represented on the working group by Bill DeFoor of the Municipal Gas Authority of Georgia and John Erickson, APGA’s Vice President, Operations. The working group was established in 2013 to review and analyze existing data and information from public awareness program inspection summaries, public awareness workshops, breakout groups, the first and second editions of API RP 1162, federal public awareness and related regulations, and other relevant sources. At its April meeting, the working group began assessing the strengths, weaknesses, opportunities, and threats to effective public awareness communications to each of four stakeholder

groups, which are customers and noncustomers living near gas lines, public officials, emergency responders, and excavators. APGA presented the summary results of the APGA GOAL program that over 180 utilities use to measure the level of gas safety knowledge of customers and non-customers. The results show a high level of gas safety awareness even before the new public awareness requirements began in 2006. Bill and John emphasized that there are significant differences in the public awareness challenges between a local distribution system and an interstate pipeline. APGA is pleased that the working group agreed that it should also review the forms and instructions given to state pipeline safety inspectors to conduct public awareness inspections of local utilities to identify anything that

might prevent a utility from utilizing the most effective public education methods. The working group agreed that state and nationwide outreach programs can be very effective, but obviously cannot include utility-specific information. APGA strongly believes the enforcement process must support the overall goal of effective public awareness. APGA hopes that the working group will foster a consistent understanding of the intent and application of RP 1162 among operators and regulators. For questions on this article, please contact John Erickson of APGA staff by phone at 202-464-2742 or by email at jerickson@apga.org.


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May 5, 2014

NAESB Holds Gas-Electric Coordination Meeting

On April 22 and 23, the North American Energy Standards Board’s (NAESB) Gas-Electric Harmonization Committee held a meeting in Houston, Texas to begin discussions regarding the notice of proposed rulemaking (NOPR) approved by the Federal Energy Regulatory Commission on March 20. Among other things, the NOPR would change the start of the gas day from 9 a.m. CST to 4 a.m. CST. This change is proposed to give electric utilities additional time to meet their morning ramp-up demands. APGA has expressed strong concerns with changes to the start of the gas day outside of normal working hours as these would impose additional costs on natural gas systems that receive no benefit from the change. FERC staff communicated at the meeting that they recognize this will impose additional costs but believe the benefits will outweigh the costs. The proposal would also move the timely nomination cycle later and increase the number of intraday nomination opportunities to help shippers adjust their scheduling to reflect changes in demand. The rule does provide a 180-day period to allow continued discussions between the natural gas industry and the electric industry to see

if a proposal supported by both sides can be reached. Comments are due in 240 days. Discussions to see if consensus can be reached on gas-electric coordination issues have begun in NAESB. APGA members Gordon King of the Okaloosa Gas District and Mark Werner of CPS Energy participated in the meeting. After an overview of the voting process, there was a presentation of the timeline for addressing the issue. Specifically, there will be meetings every two weeks until June 2 at which time the goal is to have work completed on alternative consensus proposals, vote, and prepare a recommendation for the June 6 NAESB Board of Directors meeting. After the Board of Directors approves any potential consensus standards, the appropriate gas/electric quadrants and subcommittees will move any potential consensus proposal through their individual bodies with the goal of having a ratification ballot on any potential consensus standards distributed to NAESB membership on August 22. Consensus standards will need to be filed with the commission by September 29. The primary focus of this meeting was to show presentations from inter-

ested parties including the Natural Gas Council, which presented a straw man proposal. APGA has been part of the Natural Gas Council effort to begin internal discussions within the gas community to attempt to see if a consensus could be reached on a proposal that would meet the needs of the electric industry while minimizing disruptions on the gas side. There were a wide variety of views that were presented at the NAESB meeting regarding whether the start of the gas day should be changed and to what time as well as what changes should be made within the electric industry. At the end of the meeting, four specific issues were identified for further discussion. They were whether there should be one or two energy days, the start of the gas day, whether there should be three of four intraday cycles, and the nomination schedules. The next meeting of the NAESB Gas-Electric Harmonization Committee will be May 6 and 7 in Houston. If you have any questions on this article, please contact Dave Schryver of APGA staff by phone at 202-464-2742 or by email at dschryver@apga.org.

APGA Speaks at Southeast LDC Forum

On April 16, APGA’s Executive Vice President, Dave Schryver, served as the keynote speaker at the Southeast LDC Gas Forum held in Atlanta, Ga. The LDC Gas Forum is held regionally to bring people together from the natural gas industry to discuss vital regional and national issues affecting all aspects of the natural gas marketplace. The event is held annually and is very well attended by APGA members and other representatives from the natural gas industry. In his presentation, Dave provided a legislative and regulatory overview of many of the issues affecting public

gas systems and the natural gas industry as a whole. He discussed LNG export both from the regulatory side, as well as recent efforts within Congress to pass legislation that would expedite the permitting process, and communicated the concerns APGA has raised in regard to the impact LNG export would have on price and on efforts to increase U.S. energy independence. He also discussed APGA’s ongoing efforts to pass legislation that amends Section 5 of the Natural Gas Act to provide the Federal Energy Regulatory Commission (FERC) with refund authority in the

same manner that Congress provided to them under the Federal Power Act. Dave also discussed FERC’s efforts to address gas-electric coordination and communicated APGA’s concerns that efforts to improve gas-electric coordination should not result in unintended adverse consequences such as shifting risks and costs among shippers or degrading services to other pipeline shippers. If you have any questions on this article, please contact Dave Schryver of APGA staff by phone at 202-4642742 or by email at dschryver@apga. org.


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May 5, 2014

APGA Represents Public Gas at PHMSA Class Location Workshop

On April 16, David Hraha of the Iowa Association of Municipal Utilities represented APGA on an industry panel on class location sponsored by the Pipeline and Hazardous Materials Safety Administration (PHMSA). The public workshop sought comments on whether applying the integrity management (IM) requirements beyond high consequence areas (HCAs) would eliminate the need for class location requirements in federal pipeline safety regulations. Locations along gas pipelines are divided into classes from one (rural) to four (densely populated) based on the number of buildings or dwellings for human occupancy. Allowable pipe operating stresses—as a percentage of specified minimum yield strength (SMYS)—decrease as class location increases from class one to class four locations. Gas IM plan requirements use a count of dwellings within the pipeline potential impact circle (PIR) to identify areas of higher risk along pipelines. PIR is based on the pipeline’s diameter and pressure. The workshop included presenta-

tions from PHMSA, state representatives, industry and the public. David’s presentation focused on the major differences between interstate gas transmission pipelines and the lines operated by public gas systems that are classified as transmission. About 56 public gas systems operate a total of nearly 3,000 miles of lines classified as transmission, but as David pointed out, most of these lines are less than 8 inches in diameter and many operate below 20 percent of yield stress. David urged PHMSA to consider redefining transmission to only include lines operating greater than 30 percent SMYS. He also pointed out, as did many other panelists, that class location is referenced in many other parts of federal rules as well as in some state regulations. Attempting to eliminate class location would require modification of all these other sections. Transmission operators asked that regulations be amended to allow transmission operators to use IM principles to establish maximum allowable operating pressures for newly constructed pipelines and where popula-

David Hraha (right) of the Iowa Association of Municipal Utilities representing APGA at the PHMSA class location workshop.

tion encroachment has changed the class location of an existing line segment. APGA agreed that this should be an option, but state and public panelists expressed concern that recent accidents have called into question whether the formula for calculating potential impact circles is accurate for large, high pressure transmission lines. PHMSA is expected to propose changes to regulations based on input from the workshop as well as written comments. For questions on this article, please contact John Erickson of APGA staff by phone at 202-464-2742 or by email at jerickson@apga.org.

APGA Files Motion to Intervene in Sabine Pass LNG Export Application

On April 14, APGA filed a motion to intervene in an application filed by Sabine Pass Liquefaction to export approximately 314 Bcf/year of liquefied natural gas (LNG) to non-free trade agreement (FTA) countries from the Sabine Pass LNG Terminal in Cameron Parish, La. The total LNG export capacity applied for to date is 38.51Bcf/day and 35.86 Bcf/day to FTA and non-FTA nations, respectively. When an application is filed—in cases where the application is specific to countries that the U.S. has a free trade agreement with—the application is deemed to be consistent with the public interest and granted without modification or delay. In cases where an application is seeking exportation

of LNG to countries that the U.S. does not have FTAs with, the burden is on those opposed to the application to demonstrate that the application is not consistent with the public interest. In its filing, APGA states that the export application is inconsistent with the public interest and should be denied, communicating that exports will “increase domestic natural gas prices, burdening households and jeopardizing potential growth in the U.S. manufacturing sector, as well as the nation’s transition away from more environmentally damaging fossil fuels.” The filing also expresses concern that if this and other LNG export applications were to be approved, “the resulting increase in natural gas prices

would undermine recent investments to expand natural gas as a transportation fuel.” The issue of LNG export continues to receive attention, most recently in Congress with hearings held in both the House and Senate that examined expediting the LNG permitting process. APGA testified at a March House Energy and Commerce Committee hearing in opposition to expediting the permitting process. A copy of APGA’s filing is available at www. apga.org/filings. If you have any questions on this article, please contact Dave Schryver of APGA staff by phone at 202-4642742 or by email at dschryver@apga. org.


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May 5, 2014

APGA Meets with Senator Toomey and Senate Republican Steering Committee

On April 21, APGA along with AGA and NRECA met with Senator Toomey’s (R-Pa.) office and the Senate Republican Steering Committee to discuss a wide range of legislative initiatives. The primary focus of the discussion was centered on the Hoeven-Manchin amendment embedded in the Shaheen-Portman bill. Both Senator Toomey’s office and the Senate Republican Steering Committee are supportive of the repeal of section 433 but they do have concerns over some other provisions within the Shaheen-Portman bill. Senator Toomey has offered amendments in the past with regard to rolling

back renewable energy mandates. The question remains if this bill will come to the floor for a vote. There is some speculation that this bill may become tied to a decision on the XL pipeline. In addition to the discussion on repealing section 433, revisions to the definition of “waters of the United States” from the Environmental Protection Agency (EPA) and Army Corp of Engineers was also discussed. The revised definition would expand EPA’s and Army Corp of Engineers’ jurisdiction. This will impact the natural gas industry and further hinder the expansion of pipelines. This will also add addi-

tional regulatory impact on the ability of APGA members to replace and expand their distribution systems. The expansion of EPA’s jurisdiction under the Clean Water Act along with their aggressive greenhouse gas initiatives has Senator Toomey’s office and the Senate Republican Steering Committee—as well as many other Congressional members—concerned. As things continue to develop, APGA will keep members informed. For questions on this article, please contact Dan Lapato of APGA staff by phone at 202-464-2742 or by email at dlapato@apga.org.

Upcoming APGA Educational Webinars

Register online at www.apga.org/webinars for APGA educational webinars. Free for APGA members! • HOUZE - May 13 at 3 p.m. EST: David Goswick will discuss the HOUZE project, the first of its kind in America, which introduces affordable homes that produce significantly more electricity than they use through the utilization of natural gas co-generation Power Cells. • APGA Research Foundation - May 15 at 11 a.m. EST: Learn more about how the APGA Research Foundation invests in projects across the innovation cycle, from idea generation to product development through commercialization. The RF guides the development of products that benefit its member systems. • DOE Home Scoring Tool - June 5 at 3 p.m. EST: U.S. Department of Energy (DOE) is partnering with state and local governments and utilities across the country to make the Home Energy Scoring Tool widely available to homeowners. Learn more about how the tool allows homeowners to compare their energy performance nationwide.

APGA Submits Comments on DOE’s Request for Input on Residential Conventional Cooking Products

On April 14, APGA submitted comments to the Department of Energy (DOE) on their request for information and notice of document availability, which sought public input on whether to amend the current energy conservation standards for residential conventional cooking products. The letter highlights three areas of concern. The first area of concern is the need to use source energy analysis. APGA understands that, under the Energy Policy and Conservation Act, DOE is authorized to set energy conservation standards for covered products based on point-of-use. But, DOE itself has recognized the shortcomings of site-based analysis and the need to use full-fuel cycle measures of energy use, greenhouse gas and other emis-

sions in the national impact analyses and environmental assessments for future energy conservation standards rulemakings. The second area of concern is the importance of using a marginal price analysis in gauging the economic impact of a revised energy efficiency standard. A marginal price analysis reflects the rise or decrease in natural gas costs most closely associated with changes in the amount of gas consumed when comparing appliances of different efficiencies. When comparing the life cycle cost of appliances with different efficiencies and the value of the gas consumed, it is appropriate to price the gas on the margin. The final area of concern is DOE’s

reliance on Lawrence Berkeley National Labs (LBNL) for conducting technical analyses for all such minimum efficiency rulemakings. Recently, LBNL issued a report advocating that gas ranges without effective vent hoods should be banned due to indoor air quality concerns based on some flawed testing parameters. This report was given considerable media press coverage throughout the nation. However, APGA believes that DOE has an obligation to convince itself and the public that LBNL’s analyses for this rulemaking will be completely objective. For questions on this article, please contact Dan Lapato of APGA staff by phone at 202-464-2742 or by email at dlapato@apga.org.


PRESORTED FIRST CLASS US POSTAGE PAID DULLES, VA PERMIT NO. 349

AMERICAN PUBLIC GAS ASSOCIATION

201 Massachusetts Ave NE Suite C-4 Washington, DC 20002 Phone: 800-927-4204 · Fax: 202-464-0246 www.apga.org

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May 5, 2014

APGA Joins NGVAmerica to Oppose Kilogram NGV Standards

APGA has signed on to a joint letter with NGVAmerica, American Gas Association, American Trucking Association, America’s Natural Gas Alliance, SIGMA Fuels, Truck Renting and Leasing Association, and National Association of Convenience Stores that was sent to Commerce Secretary Penny Pritzker. The letter is in response to two proposals put forth by the National Conference of Weights and Measures (NCWM). The letter asks that Secretary Pritzker support a proposal by the NCWM to establish a national standard for the sale of compressed natural gas (CNG) and liquefied natural gas (LNG) in diesel gallon equivalent (DGE) form. Currently, standards exist to compare CNG to gasoline through the gasoline gallon equivalent (GGE). However, because most CNG and LNG are

used by vehicles that otherwise would use diesel, it is hard to make a cost comparison between diesel and either CNG or LNG. Creating a DGE would make it easier for municipalities, businesses, and consumers to make cost comparisons when purchasing CNG or LNG. This would greatly promote CNG and LNG as a clean and affordable alternative to diesel. The proposal would be an option for vendors, not a mandate. The joint letter also asks that Secretary Pritzker oppose a NCWM proposal to mandate the sale of CNG and LNG in kilogram units. The United States largely does not use the metric system, and a mandate to force vendors to sell CNG and LNG in kilogram units would cause market disruptions, create confusion for consumers and businesses, and unfairly target

a growing transportation fuel source in the US. Efforts to force the sale of CNG and LNG in kilogram units are discriminatory, and APGA is opposed to them. Along with the joint letter to Secretary Pritzker, APGA has reached out to roughly 120 congressional offices, encouraging them to sign on to a dear colleague letter being circulated by Representatives Terry (R-Neb.) and Larson (D-Conn.). Their letter mirrors the one that APGA signed on to. APGA will continue to keep members posted on any new developments regarding these two proposals. If you have any questions about this article, please contact Dan Horning of APGA staff by phone at 202-464-2742 or by email at dhorning@apga.org.


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