On April 26, APGA and the American Gas Association (AGA) sent a letter to the Department of Energy (DOE), raising concerns with its proposal to promulgate new test procedures for gas-fired commercial warm air furnaces (CWAFs).
In a notice issued earlier this year, DOE proposed a new test procedure and metric to measure the energy efficiency of CWAFs. The efficiency test procedures developed by DOE are a key element in establishing minimum efficiency standards for appliances covered by federal law. Unfortunately, one of the proposed updates has not been sufficiently vetted by impacted stakeholders, and DOE has not provided any data to show that the new metric or the test procedure is justified. Furthermore, there is a concern that the proposed new metric would impose a condensing standard for CWAFs, which is not only inappropriate to do in a test procedure rulemaking but also contrary to DOE’s recent notice of proposed determination, in which DOE did not find new energy conservation standards for CWAFs justified.
The comment letter also more broadly supported the technical comments of the Air-Conditioning, Heating, & Refrigeration Institute (AHRI), the trade association that represents the manufacturers of CWAFs.
Test procedures must be developed in an open and transparent manner, based on technically-supported data that results in methods that provide reliable and repeatable results. Without such a test procedure underlying the appliance efficiency requirements, manufacturers may have difficulty bringing these gas-fired products to market and maintaining compliance with the applicable statute. APGA weighs in on DOE’s appliance efficiency rulemakings that impact gas-fired appliances, as APGA members provide the energy needed to fuel these appliances, thus making public natural gas systems critical stakeholders in these rulemakings.
A copy of the comments is available
here.
For questions on this article, please contact Renée Lani of APGA staff by phone at 202-464-0836 or by email at
rlani@apga.org.