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APGA Responds to DOE’s Request for Comment on Weatherized Gas Furnaces

By Stuart Saulters posted 02-02-2023 12:32 PM

  
On January 30, APGA submitted comments in response to the Department of Energy’s (DOE) notice of data availability (NODA) and request for comment pertaining to energy conservation standards (ECS) for weatherized gas furnaces (WGF). APGA was joined by the American Gas Association (AGA), National Propane Gas Association (NPGA), and Spire in submitting these comments.

APGA submitted similar comments last year in response to a request for information (RFI) regarding WGFs. Similar to APGA’s response to the RFI, the comments in response to the NODA reiterated earlier concerns regarding DOE’s underlying analyses that must be addressed before proceeding with any appliance rulemaking, including for WGF.

In previous submissions to DOE, co-commenters have raised concerns with how the agency models future natural gas prices and marginal natural gas prices, both of which are important in the agency’s analyses of whether a more stringent ECS is economically justified. Additionally, the comments reiterated earlier concerns with additional economic modeling used by the agency, such as how consumers decide what type of appliance to purchase. It is important that DOE address these concerns, as they underlie many of the agency’s appliance rulemakings, and can impact whether a more stringent efficiency standard for any given appliance is justified.

A copy of the comment letter is available here.

As a reminder, the same concerns regarding venting compatibility that APGA has for non-weatherized residential furnaces do not exist in the WGF rulemaking, as WGFs are installed outside. APGA is still closely tracking all gas-fired appliance rulemakings, including the Furnace Rule.

For questions on this article, please contact Stuart Saulters of APGA staff by phone at 202-802-0493 or by email at ssaulters@apga.org.

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