Earlier this week, the APGA Codes & Standards Committee hosted a member roundtable to discuss the likely impacts that consumers would experience if the Department of Energy’s (DOE) proposed minimum appliance efficiency standards for residential furnaces—also known as the Furnace Rule—were finalized. Members engaged with a representative of the appliance installation contracting community and each other to discuss required retrofits and equipment, as well as challenges many homeowners, especially those with low or fixed incomes, would likely experience if this rule were implemented as proposed.
The roundtable followed a webinar that APGA hosted in late July, which focused on the technical underpinnings of DOE’s appliance efficiency rulemakings. During that webinar, members were introduced to several concerning assumptions that have been built into DOE’s economic modeling, which is the underlying basis for the proposed Furnace Rule.
The Furnace Rule proposes to set minimum efficiency standards at a condensing-only level for the appliance. While APGA is generally supportive of improved efficiency, APGA remains concerned that this proposed rule will have negative effects on consumers, primarily because condensing furnaces are not an easy one-for-one swap out with an existing non-condensing furnace. Due to venting incompatibilities, replacing older furnaces under this new rule will require costly retrofits – if even possible – else require fuel switching. Accordingly, APGA continues to oppose this proposed rule.
In addition to engaging members, APGA has been engaging directly with DOE throughout the rulemaking process. On July 25, APGA and other trade associations
requested an extension of the Furnace Rule’s comment period. During the DOE’s public webinar discussing the rule on August 3, APGA verbally raised concerns with the inability of stakeholders’ technical experts to duplicate DOE’s analysis values and reiterated our request for an extension of the comment period, as well as requesting a workshop during which DOE could work with stakeholders to discuss concerns with the modeling. Joined by other trades, APGA also
submitted a written letter to reiterate this request. Others have also submitted similar requests, but no extension or workshop has been granted by DOE. APGA continues to develop comments in anticipation of the current submission deadline of September 6.
APGA will continue to weigh 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.
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.