rmoenrmne ACA . Gas Association DN, ran GAEBICAN SUPPOY ABBOCIATION . NPGA. NATIONAL PROPANE GAS ASSOGATION Puan nein COOLING OwTRAGTORS ASSOCIATION February 21, 2025 ‘The Honorable Chris Wright The Honorable Lee Zeldin Secretary ‘Administrator ULS. Department of Energy USS. Environmental Protection Agency 1000 Independence Ave., SW 1200 Pennsylvania Avenue, NW Washington, DC 20585 Washington, DC 20460 Re: Review of Building Electrification Programs and Related Guidance Dear Secretary Wright and Administrator Zeldin: On behalf of America's home heating oil and propane distributors, public utilities, plumbing and HVAC service professionals, and manufacturers of liquid- and gas-fired consumer appliances, our organizations write to express our strong support for your agencies’ renewed focus on energy security, reliability, and consumer choice. In keeping with these priorities, we would like to highlight our concerns regarding building electrification programs that warrant your immediate attention. ‘We commend Secretary Wright's commitment to promoting affordability and consumer choice in home appliances, as outlined in his February Sth Secretarial Order, particularly the emphasis on conducting thorough cost-benefit analyses that consider both upfront costs and actual savings for ‘American families." We also support similar statements and principles outlined by Administrator Zeldin in his own memorandum, "Powering the Great American Comeback.” When conducting reviews to ensure your agencies" programs are in keeping with the administration's priorities in these areas, we ask that you give special attention to building electrification initiatives. Our members have voluntarily improved environmental performance through cost-effective solutions such as adoption of renewable heating fuels, high efficiency appliances and equipment, contractor training, and consumer education, Building electrification programs established by the Inflation Reduction Act (IRA) and Infrastructure Investment and Jobs Act (IIJA) ignore and even undermine these achievements, restrict consumer choice, and jeopardize American energy security and grid reliability. Many are also designed to suppor state and local efforts to ban conventional heating fuels and appliances and force residential electrification, policies that would exponentially increase the cost of housing while limiting access to affordable home comfort solutions. The previous administration's building electrification policies were deeply flawed. They fail to account for source emissions and the extraordinary costs associated with removal of existing appliances and heating systems and the installation of all-electric appliances and air source heat pumps, nor did they consider whether electrification was either feasible or appropriate for certain households. For many residences, particularly those in states with older buildings and colder climates, these costs can exceed $30,000. Furthermore, these policies do not recognize the benefits of renewable heating fuels or the installation of more efficient liquid- and gas-fired systems.Coalition Lever to US. DOE and EPA February 21,2025 Page 20f3 We therefore respectfully request that your agencies conduct a comprehensive review of all building electrification programs under the IRA and IIJA, including but not limited to: © The State-based Home Electrification Rebate Program; # State-Based Contractor Training Grants in support of residential electrification;* ‘+ Electric heat pump subsidies provided under the Greenhouse Gas Reduction Fund;* ‘© Electric heat pump manufacturing subsidies authorized through the previous administration’ invocation of the Defense Production Act;® © The Clean Energy for Federal Buildings rule, which mandates full electrification of all federal buildings by 2030;" and © Utilization of funds under the Building Energy Codes Program to support adoption and implementation of building codes that support mandated electrification. Additionally, we request that you withdraw and thoroughly review all electrification-related guidance documents, including those provided to states regarding program requirements, so-called “model programs” and “best practices,” and permissible use of funds, to ensure alignment with your agencies’ newly announced priorities. This includes, but is not limited to: * Guidance to states for the IRA home energy rebate programs, including recommendations for “Envelope First, Heat Pump Ready” programs, which encourages states to ban natural gas, heating oil, and propane homes from accessing whole home efficiency rebates for the installation of more efficient furnaces and boilers.” © Guidance allowing the “social cost of carbon” to be considered when performing energy audits under the low-income Weatherization Assistance Program (WAP), making it easier to justify costly electrification retrofits, despite the program’s long history of being fuel- and technology neutral and discouraging fuel switching.'” © “Decarbonizing the U.S. Economy by 2050: A National Blueprint for the Buildings Sector,” published on April 2, 2024, “Achieving a Net-Zero Federal Emissions Building Portfolio” published in April 2024, and the “National Definition of a Zero Emissions Building,” published on June 6, 2024. Our organizations stand ready to support your efforts to develop balanced policies that protect consumer choice and allow Americans to choose the best home energy solutions that meet their personal needs, preferences, local climates, and family budgets. Please note that the above lists of electrification policies and programs deserving of the administration’s review are not exhaustive. We would welome the opportunity to meet with your teams to discuss these matters in greater detail and share our perspectives on achieving our shared goals, ‘Thank you in advance for your consideration. Sincerely, American Public Gas Association ‘American Supply Association ‘National Association of Oil & Energy Service Professionals National Energy & Fuels Institute National Propane Gas Association Plumbing-Heating-Cooling Contractors (PHCC) National AssociationCoalition Letro US BOE and EPA February 21,2025 Page 30f3 ce: The Honorable Russell Vought, Director, Office of Management and Budget The Honorable Kevin Hassett, Director, National Economie Council The Honorable Doug Burgum, Interior Secretary and Director, National Energy Council 1 US. Department of Energy Secretarial Order, "Unleashing the Golden Era of American Energy Dominance,” February 5, 2025. 2 US. Environmental Protection Agency, "Powering the Great American Comeback," February 4, 2025, *Pub.L.117-169, Section 50122 (42 U.S.C. 8 187958). “Ibid. Section $0123 (42 U.S.C. § 187850). + Ibid, Section 60103 (42 U.S.C. 8 7437). Notably, Greenhouse Gas Reduction Fund grants fo state and local building electrification programs, including $450 million forthe New England Heat Pump Accelerator program and $38 million to subsidize the installation of electric heat pumps in homes in coastal Alaska, Section 30001 of the inflation Reduction Act (Pub.L.117-168) provided $500 million to fund President Joe Biden's June 6, 2022 invocation of the Defense Production Act (DPA) which aimed to “accelerate domestic production of ve key energy technologie: (1) solar; (2) transformers and electric grid components; (3) neat ‘pumps; (4) insulation; and (5) electrolyzers, fuel cells, and platinum group metals.” On Aprit 18, 2023, the Biden Administration announced that $250 milion of these funds would be used to subsidize electric heat pump manufacturing. See nitps://nww energy gov/mesclenhanced-use-defense-production-act-1950. 7US, Department of Energy, “Clean Energy for New Federal Bulldings and Major Renovations of Federal Buildings,’ 89 Fed. Reg. 3564-35439 (May 1, 2024) (codified at 10 C.F.R. 88 433, 435). * Section 40511 ofthe Infrastructure Investment and Jobs Act (Pub.L.117-68) provided $226 million for the Building Energy Codes Program, which was utilized by the previous edministration forthe promotion, adoption, and implementation of “modern building energy codes, combined with innovative approaches, such as stretch codes, bullding performance standards, and adjacent policies” in support ofits building Gecerbonization goals. See U.S. Department of Energy, “DOE Establishes Bipartisan Infrastructure Law's $226 Million for Improved Building Codes,” April 12, 2022. U.S, Department of Energy, “Administrative and Legal Requirements Document (ALRD): Home Efficiency Rebetes and Home Electrification and Appliance Rebates,” July 27, 2023; and “Recommendations for Envelope First, Heat Pump Ready Home Etficiency Rebate Programs," August 2, 2023 °°U.S, Department of Energy, Weatherization Program Notice 22-10 (Revised), October 21, 2022, Section 40551 of the Infrastructure Investment and Jobs Act (Pub.L.117-58) provided $3.5 billion for the Weatherization Assistance Program (WAP).