Regulatory Submissions

On November 22nd, APGA submitted comments to the Department of Energy (DOE) in response to a Supplemental Notice of Proposed Rulemaking (SNOPR), released by DOE in September, which would establish a residential furnace nationwide mandate of 92 annual fuel utilization efficiency (AFUE) with a small furnace exemption for furnaces of 55,000 Btu or less. Furnaces under the small furnace exemption would be allowed to be non-condensing; while all furnaces above that threshold would have to be condensing. Because of the difference in combustion technology, condensing furnaces have additional venting requirements associated that add significant dollars to the cost of installation. APGA has maintained that the additional venting requirements associated with replacing a non-condensing natural gas furnace with a condensing furnace will push many residential customers—particularly those in warmer climates—to purchase and install less efficient home heating alternatives with potentially higher greenhouse gas emissions and higher monthly utility bills. In its comments, APGA communicated that the solution to addressing this issue is for DOE to acknowledge that condensing and non-condensing furnaces are separate product classes and therefore each should have its own efficiency standard. APGA’s comments also emphasized that DOE continues to rely on flawed methodologies to justify the proposed increase in furnace efficiency standards as demonstrated by a report released by the Gas Technology Institute (GTI) which accompanied APGA’s comments. For example, DOE does not rely on economic decision making to separate affected from non-affected consumers, which is a critical threshold step in the Life Cycle Cost analysis; rather, it relies on a random selection number. This random-sampling approach produces irrational outcomes, as demonstrated when the trial samples relied upon by DOE are closely looked at. APGA’s comments also communicate that the furnace market is functioning well without a new furnace efficiency standards rule, as market data demonstrates that consumers are purchasing condensing furnaces in large numbers where the operating cost savings justify the extra expense, and are purchasing non-condensing furnaces where the operating cost savings are more problematic. “We hope that DOE will carefully review the concerns raised by APGA and other stakeholders. Our research clearly demonstrates the serious disconnect between DOE’s projections and the realities that American families are facing each day. It is important that DOE take the time to get this critically important rule right rather than rush to push out a rule that will have significant adverse impacts on consumers. I am hopeful DOE will utilize our work and the work of so many other organizations to review and fix the deficiencies associated with the current energy efficiency development process. We look forward to working the various stakeholders to develop a program that benefits American homeowners by promoting a wide range of energy efficient products that are cost effective. To APGA and our members this is the cornerstone of a sound energy policy.” Attached in pdf format are the American Public Gas Association’s (APGA) comments in response to the Department of Energy’s Supplemental Notice of Proposed Rulemaking proposing amendments to the energy conservation standards for residential non-weatherized gas furnaces and mobile home gas furnaces (Docket No. EERE-2014-STD-0031). In addition to APGA’s comments, also attached are several documents that we would like to be submitted as part of our comments. These documents include: Technical Analysis of DOE Supplemental Notice of Proposed Rulemaking on Residential Furnace Minimum Efficiencies, GTI-16/0002, and accompanying spreadsheets; Empirical Analysis of Natural Gas Furnace Sizing and Operation, GTI-16/0003; APGA Comments to the Department of Justice (Nov. 8, 2016); APGA/NAHB Letter to Office of Management and Budget (June 14, 2016); APGA Letter to DOE Inspector General (Nov. 17, 2015); APGA Letter to DOE Secretary (Oct. 22, 2015); and DOE FOIA Response to APGA and attachments (Sept. 7, 2016). Please call or email me if you have any questions or need additional information.

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