October 19, 2010
OFFICE OF ENERGY EFFICIENCY AND RENEWABLE ENERGY
UNITED STATES DEPARTMENT OF ENERGY
Statement of Policy for Adopting Full-Fuel-Cycle Analyses Into Energy Conservation Standards Program
COMMENTS OF THE AMERICAN GAS ASSOCATION
Pursuant to the Notice of Proposed Policy (“Notice”) issued August 20, 2010,1 the American Gas Association (“AGA”) is pleased to submit comments in response to the proposed policy of the U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy (“Department” or “DOE”) to adopt full-fuel-cycle analyses into its energy conservation standards program. AGA supports the proposal and encourages the Department to take additional steps to implement the recommendations of the National Academy of Sciences regarding the use of full-fuel cycle measures into the establishment of energy conservation standards.