Regulatory Submissions

Docket Number EERE-2014-BT-STD-0031/ RIN NO. 1904-AD20

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 The comments raise numerous concerns with the proposed rule and ultimately ask that the proposal be withdrawn.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.