NPGA letter to DOE supports full fuel cycle analysis in water heater tests

摘要

NPGA is urging the U.S. Department of Energy (DOE) to include a full fuel cycle analysis in its new water heater efficiency test procedure and the new universal energy descriptor, as well as on any label recommendation to the Federal Trade Commission, the association announced. In its filing with DOE, NPGA argues that the full fuel cycle analysis is the most accurate way to calculate energy use and environmental emissions because it accounts for energy consumed in the extraction, processing and transport of primary fuels; energy losses in electric power generation or gas processing plants; energy losses associated with transmission and distribution of fuel to the end user; and greenhouse gas emissions associated with each step within the process.