On October 6, APGA submitted extensive comments in response to the Department of Energy’s (DOE) proposed minimum appliance efficiency standards for residential furnaces – also known as the Furnace Rule. The comments raise numerous concerns with the proposed rule and ultimately ask that the proposal be withdrawn.
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, we remain 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 stringently opposed the proposed rule in its comments.
The 70-page comment letter, along with 300 additional pages of supporting documentation, went into significant detail about how the proposed rule is unnecessary and unlawful. As it has done in previous iterations of this rulemaking, APGA argued that the proposed rule is not economically justified, that DOE has overstated energy efficiency gains, and that DOE has exceeded its statutory authority, among other points. Because of the many deficiencies of the proposal, APGA requested that DOE withdraw the proposed Furnace Rule.
A copy of the comments is available
here. In addition to the individual comments, APGA also signed onto two coalition letters: the first was submitted by numerous trade associations and manufacturers in the natural gas value chain – including gas suppliers, homebuilders, appliance manufacturers, and contractors – raising high-level concerns similar to those raised in APGA’s own comments, and the second was submitted by a variety of trade associations outlining issues with DOE’s use of the social cost of greenhouse gases. Furthermore, at least one public gas system sent in comments echoing APGA’s position.
APGA will continue to weigh in on DOE’s appliance efficiency rulemakings that impact gas-fired appliances, as our members provide the energy needed to fuel these appliances, thus making public 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.