Public Comments of AGL Resources

U. S. Department of Energy

Office of Energy Efficiency and Renewable Energy:

DOE Proposed Determination of Coverage: Proposed Determination of Natural 

Draft Commercial Packaged Boilers as Covered Equipment

Docket Number EE-2013-BT-STD-0030 

Regulatory Information Number (RIN) 1904-AD01

September 12, 2013

INTRODUCTION:

Headquartered in Atlanta, Georgia, AGL Resources is the parent company of seven 

natural gas distribution companies: Atlanta Gas Light (the oldest company in Georgia), 

Nicor Gas (Illinois), Florida City Gas, Chattanooga Gas (Tennessee), Virginia Natural

Gas, Elkton Gas (Maryland), and Elizabethtown Gas (New Jersey). In addition to 

distribution, our other business segments include retail operations, wholesale services, 

midstream operations, and cargo shipping. We are traded publicly on the New York 

Stock Exchange (NYSE) under the ticker symbol GAS. We are a Fortune 1000 

company; we currently serve 4.5 million utility customers and 1.1 million retail 

customers.

AGL Resources is committed to advocating the best interests of all its customers. We 

have retail and commercial customers in seven different states representing most 

regions of the United States. These customers are located in densely populated urban 

areas as well as rural areas, and range in size from sole proprietorship to companies 

with several thousand employees.

COMMENTS OF AGL RESOURCES ON PROPOSED DETERMINATION OF 

COVERAGE:

1. DOE should promulgate the definition for “natural draft commercial packaged 

boiler” as proposed in the Proposed Determination of Coverage. 

According to the DOE Proposed Determination of Coverage, DOE intends to initiate 

rulemaking for commercial packaged boilers in the near future. We support the 

proposed definition for “natural draft commercial packaged boiler” as it will enhance this 

future rulemaking and will ensure that this equipment is appropriately regulated.
2. The lack of a definition for natural draft commercial packaged boilers may lead to 

the elimination of this product during the upcoming development of efficiency 

standards for commercial packaged boilers.

DOE has stated its intention to initiate rulemaking for commercial packaged boilers. 

A separate definition for natural draft commercial packaged boilers would allow for 

consideration of amended energy conservation standards and test procedures for 

this equipment. This is desirable, since development of efficiency standards and 

test procedures for “commercial packaged boilers” in general, without distinguishing 

between natural draft and mechanical draft venting systems, could possibly lead to 

elimination of natural draft commercial packaged boilers as DOE reaches for the 

highest minimum efficiency levels possible for this equipment. This in turn would 

lead to the exclusion of a product that has a large market presence (41% of 

commercial packaged boilers according to the DOE Proposed Determination of 

Coverage) and would create less choice for consumers.

CONCLUSION:

Because of the comments stated above, AGL Resources supports the proposed 

definintion of natural draft commercial packaged boilers as stated in the DOE Proposed 

Determination of Coverage.

Respectfully submitted, this 12th day of September, 2013.

William Peeples

Managing Director, Marketing

AGL Resources