## 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

Doc ket Number EE

- 2013

- BT

- STD

- 0030
Regulatory In formation 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, o ur 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. W e 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 proprietor ship to companies

w ith 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

standar ds for commercial pack aged boil ers.

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 procedu res for this equipment. This is desirable, since d evelopment of efficiency standards and test procedures for “commercial packaged boilers” in general, without distinguishing

between nat ural draft and mechanical draft venting systems, could possibly lead t o 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 pack aged 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.

Re spectfully submitted, this 1 2 th day of Septembe r, 201 3

.

William Peeples Managing Director, Marketing

AGL Resources