Regulatory Submissions

Final 071015 APGA Comments-c.pdf   403 KB   1 version
Uploaded - 07-12-2015
On July 10, 2015, APGA filed comments in response to the Department of Energy’s (DOE) Notice of Proposed Rulemaking (NOPR) that proposes a new nationwide standard of 92% annual fuel utilization efficiency (AFUE) for natural gas furnaces. The end result of this NOPR is a ban on the sale of non-condensing furnaces in the United States since condensing furnaces are the only ones capable of meeting the higher efficiency standard. In its comments APGA makes several legal arguments: the technical support documents (TSD) and accompanying spreadsheets DOE utilized to justify the NOPR have not undergone peer review; DOE should, at a minimum, suspend the subject proceeding until the required new test procedures are established to measure the energy efficiency, energy use, or estimated annual operating co