THE SOURCE - Summer 2018 - 13

The comments also cite the concerns
APGA has raised numerous times related
to DOE's analyses and models. For
example, proprietary data that is not
gathered by DOE under confidentiality
agreements should not be used in a
DOE rulemaking unless that data is
made available to the public at no cost
and without limitations as to its use. In
addition, the comments also state that
the energy efficiency modeling that has
been utilized by DOE is too complex
and burdensome and that replacing the
current complex life-cycle cost analysis
with a simple payback analysis based on
"real numbers" is more practical.
Lastly, APGA and AGA believe that the
Process Rule must be mandatory since
only then will DOE be held accountable
to its own procedures. If the Process
Rule is mandatory, it is much more
likely to be followed, which in turn will
increase the confidence the public has
in the transparency and fairness of the
regulatory process.
In somewhat related news, on
February 15, the U.S. District Court
for the Northern District of California
issued a ruling ordering the Department
of Energy to publish four appliance
energy efficiency standards proposed
by the Obama Administration in late
2016. Three of the standards addressed
items such as portable air conditioners,
battery backup systems used to keep
computers and other electronic devices

running when the power goes out, and
air compressors; and as a result, had no
impact upon natural gas systems. However,
the last standard addressed commercial
package boilers. These boilers provide
heat to approximately 25 percent of the
commercial market in the U.S.
In February 2016, APGA and Spire,
Inc., filed an Error Correction Request
and Request for Withdrawal. The basis
for the Error Correction and Request for
Withdrawal was that there were numerous
flaws in the economic modeling utilized
by DOE to justify the rule. Specifically,
the 10,000 trial cases DOE used as its
basis for analysis were not constructed
to reflect the reality that - in the absence
of regulation - purchasers generally
choose high-efficiency commercial gas
boilers in installation scenarios in which an
investment in such equipment would make
economic sense for the purchaser. Instead,
the 10,000 trial cases were improperly
constructed by randomly "assigning"
high-efficiency boilers to installation
scenarios without regard to the economic
consequences of the installation involved,
as though - in the absence of regulation -
purchasers of commercial boilers literally
never consider the economics of such
purchases at all. The result is that the trial
cases do not represent the market that
actually exists; instead they represent
an imaginary market in which purchases
of high-efficiency gas boilers made in
the absence of regulation are no more

likely to be economically beneficial for
the purchaser - and no less likely to be
economically disastrous for the purchaser -
than purchases that would only occur as a
result of regulatory compulsion.
The judge ordered DOE to publish the
standards within 28 days of the ruling. DOE
has an opportunity to appeal the ruling.
One final note is that APGA and a
coalition of other stakeholders, including
energy trade associations, continue to
work on a legislative solution to address
Section 433 of the Energy Independence
and Security Act of 2007. This law
mandates elimination of all fossil fuelgenerated energy use in federal buildings
by the year 2030. The mandate covers
new buildings and major renovations of at
least $2,500,000 (in 2007 dollars). The law
does not allow for the direct use of natural
gas, combined heat and power (CHP), or
distributed generation, and eliminates all
fossil fuel-generated electricity regardless
of emissions. APGA has raised concerns
that the ban ultimately works against
energy efficiency in federal buildings.
For example, the threshold amount for
renovations is very low and would mean
almost all renovations to federal buildings
would trigger mandatory compliance,
resulting in many agencies not undertaking
retrofits at all. While legislation addressing
this issue will likely only move as part of a
larger comprehensive energy bill, APGA
continues to work towards a legislative
solution to this issue.

www.cgs-inc.com
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THE SOURCE | SUMMER 2018, VOL. 10, ISSUE 4 13
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Table of Contents for the Digital Edition of THE SOURCE - Summer 2018

APGA Events
First Person
2018 Starts off with Gas Records
Energy Regulatory Update
The Result of Not Addressing Increasing Cybersecurity Risk
Conversation with an APGA Member
APGA Leads Charge to Lower Pipeline Rates to Match Lower Tax Rates
Legislative Outlook
Enhancing Resilience of Critical Infrastructure with Combined Heat and Power
The Pipeline
The Importance of Getting Involved with State and Local Building Code Developments
At Last
Advertisers’ Index/Advertiser.com
THE SOURCE - Summer 2018 - Intro
THE SOURCE - Summer 2018 - bellyband1
THE SOURCE - Summer 2018 - bellyband2
THE SOURCE - Summer 2018 - cover1
THE SOURCE - Summer 2018 - cover2
THE SOURCE - Summer 2018 - 3
THE SOURCE - Summer 2018 - 4
THE SOURCE - Summer 2018 - 5
THE SOURCE - Summer 2018 - 6
THE SOURCE - Summer 2018 - APGA Events
THE SOURCE - Summer 2018 - First Person
THE SOURCE - Summer 2018 - 9
THE SOURCE - Summer 2018 - 2018 Starts off with Gas Records
THE SOURCE - Summer 2018 - 11
THE SOURCE - Summer 2018 - Energy Regulatory Update
THE SOURCE - Summer 2018 - 13
THE SOURCE - Summer 2018 - The Result of Not Addressing Increasing Cybersecurity Risk
THE SOURCE - Summer 2018 - 15
THE SOURCE - Summer 2018 - 16
THE SOURCE - Summer 2018 - 17
THE SOURCE - Summer 2018 - Conversation with an APGA Member
THE SOURCE - Summer 2018 - 19
THE SOURCE - Summer 2018 - APGA Leads Charge to Lower Pipeline Rates to Match Lower Tax Rates
THE SOURCE - Summer 2018 - 21
THE SOURCE - Summer 2018 - Legislative Outlook
THE SOURCE - Summer 2018 - Enhancing Resilience of Critical Infrastructure with Combined Heat and Power
THE SOURCE - Summer 2018 - 24
THE SOURCE - Summer 2018 - 25
THE SOURCE - Summer 2018 - The Pipeline
THE SOURCE - Summer 2018 - The Importance of Getting Involved with State and Local Building Code Developments
THE SOURCE - Summer 2018 - 28
THE SOURCE - Summer 2018 - At Last
THE SOURCE - Summer 2018 - Advertisers’ Index/Advertiser.com
THE SOURCE - Summer 2018 - cover3
THE SOURCE - Summer 2018 - cover4
THE SOURCE - Summer 2018 - divider1
THE SOURCE - Summer 2018 - divider2
THE SOURCE - Summer 2018 - 35
THE SOURCE - Summer 2018 - 36
THE SOURCE - Summer 2018 - 40
THE SOURCE - Summer 2018 - 41
THE SOURCE - Summer 2018 - 42
THE SOURCE - Summer 2018 - 43
THE SOURCE - Summer 2018 - 44
THE SOURCE - Summer 2018 - 45
THE SOURCE - Summer 2018 - 46
THE SOURCE - Summer 2018 - 47
https://www.nxtbook.com/naylor/PGAQ/PGAQ0218
https://www.nxtbook.com/naylor/PGAQ/PGAQ0118
https://www.nxtbook.com/naylor/PGAQ/PGAQ0417
https://www.nxtbook.com/naylor/PGAQ/PGAQ0317
https://www.nxtbook.com/naylor/PGAQ/PGAQ0217
https://www.nxtbook.com/naylor/PGAQ/PGAQ0117
https://www.nxtbook.com/naylor/PGAQ/PGAQ0416
https://www.nxtbook.com/naylor/PGAQ/PGAQ0316
https://www.nxtbook.com/naylor/PGAQ/PGAQ0216
https://www.nxtbook.com/naylor/PGAQ/PGAQ0116
https://www.nxtbook.com/naylor/PGAQ/PGAQ0415
https://www.nxtbook.com/naylor/PGAQ/PGAQ0315
https://www.nxtbook.com/naylor/PGAQ/PGAQ0215
https://www.nxtbook.com/naylor/PGAQ/PGAQ0115
https://www.nxtbook.com/naylor/PGAQ/PGAQ0414
https://www.nxtbook.com/naylor/PGAQ/PGAQ0314
https://www.nxtbook.com/naylor/PGAQ/PGAQ0214
https://www.nxtbook.com/naylor/PGAQ/PGAQ0114
https://www.nxtbook.com/naylor/PGAQ/PGAQ0413
https://www.nxtbook.com/naylor/PGAQ/PGAQ0313
https://www.nxtbook.com/naylor/PGAQ/PGAQ0213
https://www.nxtbook.com/nxtbooks/naylor/PGAQ0113
https://www.nxtbook.com/nxtbooks/naylor/PGAQ0412
https://www.nxtbook.com/nxtbooks/naylor/PGAQ0312
https://www.nxtbook.com/nxtbooks/naylor/PGAQ0212
https://www.nxtbook.com/nxtbooks/naylor/PGAQ0112
https://www.nxtbook.com/nxtbooks/naylor/PGAQ0411
https://www.nxtbook.com/nxtbooks/naylor/PGAQ0311
https://www.nxtbook.com/nxtbooks/naylor/PGAQ0211
https://www.nxtbook.com/nxtbooks/naylor/PGAQ0111
https://www.nxtbook.com/nxtbooks/naylor/PGAQ0410
https://www.nxtbook.com/nxtbooks/naylor/PGAQ0310
https://www.nxtbook.com/nxtbooks/naylor/PGAQ0210
https://www.nxtbook.com/nxtbooks/naylor/PGAQ0110
https://www.nxtbook.com/nxtbooks/naylor/PGAQ0409
https://www.nxtbook.com/nxtbooks/naylor/PGAQ0309
https://www.nxtbook.com/nxtbooks/naylor/PGAQ0209
https://www.nxtbook.com/nxtbooks/naylor/PGAQ0109
https://www.nxtbook.com/nxtbooks/naylor/PGAQ0408
https://www.nxtbook.com/nxtbooks/naylor/PGAQ0308
https://www.nxtbookmedia.com