On September 2, the Department of Energy (DOE) released a pre-publication notice for a Supplement Notice of a Proposed Rule (SNOPR) for residential furnaces. DOE is proposing a nationwide mandate of 92 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; all furnaces above that threshold would have to be condensing. The rule would go into effect five years after the rule is finalized. This SNOPR will have a significant impact upon public gas systems, particularly those in warmer climates.
DOE has provided only 30 days to comment, which is wholly inadequate and unreasonable. In addition to the 488-page rule, DOE has released seven additional files and models, including a 1,198-page technical support document. All of this data must be interpreted and understood to comment meaningfully on the proposal.
In response to the release of the SNOPR, APGA released a statement communicating that DOE “has once again proposed a new energy conservation standard for natural gas furnaces that will harm consumers and ultimately undermine energy efficiency.” APGA also stated that “the proposed rule will cause uneconomic fuel switching as many consumers—especially in southern states—will be compelled to change their natural gas furnaces to electric heat pumps.” Lastly, APGA communicated that the SNOPR “will impose significant harm upon APGA members’ consumers, and as a result, APGA will leave no stone unturned, including possible litigation, to protect these consumers.” APGA has asked DOE for a 90-day extension so we can properly address "the immensity and complexity of the documents to be reviewed and analyzed."
Research by the Gas Institute of Technology, American Public Gas Association and the American Gas Association shows that high initial costs associated with the installation and additional venting requirements will push many residential customers—particularly those in warmer climates—to purchase and install potentially less efficient home heating alternatives. Read the DOE Fuel Switching Study.