THE SOURCE - Summer 2017 - 22

feature

Furnace Rule Update

G

iven that a great deal of APGA's resources have been utilized in responding to the Department
of Energy's (DOE) proposed furnace rule standard, APGA now supplies an update in THE
SOURCE on where things currently stand in regard to the proposed rule. As background, in
September 2016, DOE released a Supplemental Notice of Proposed Rulemaking (SNOPR) that
would establish a nationwide residential furnace mandate of 92 percent annual fuel utilization
efficiency (AFUE), with a small furnace exception for furnaces of 55,000 Btu/hour or less. Thus,

under the SNOPR, all new and replacement furnaces would be required to be condensing furnaces except those with an
input capacity at or below 55,000 Btu. 
Because of the difference in
combustion technology, condensing
furnaces have additional venting
requirements that add significant
dollars to the cost of installation. APGA
has maintained that the substantial
additional costs associated with
replacing a non-condensing natural
gas furnace with a condensing furnace
will push many residential customers-
particularly those in warmer climates-
to purchase and install less efficient
(non-gas burning) home heating
alternatives with potentially higher
greenhouse
gas emissions and higher monthly
utility bills.
The comment deadline for the
SNOPR was November 22, 2016 and
APGA filed its comments that day.
However, late that day, DOE extended
the comment deadline to January 6,
2017. This is the second time that DOE
has extended a furnace comment
deadline without giving parties timely
notice, which, of course, means that the
extension has no value to stakeholders
like APGA that have spent much time

and money to meet the scheduled
deadline.
In addition to the comments APGA
submitted on November 22, which
focused on the numerous flaws in the
technical data that DOE has used to
support the proposed rule and the
significant adverse impacts the rule will
have upon natural gas consumers, APGA
also filed supplemental comments on
January 6. The January 6 comments
focused on APGA's frustration with the
last-minute extension. The comments
also communicated that the extension
DOE provided "is only meaningful if it
is issued well before the comment due
date so that the affected parties can use
the additional allotted time efficiently
to maximize their available resources."
The January 6 extension in the
comment period, effectively pushed
decisions on how to proceed on the
furnace SNOPR to President Trump's
Administration. APGA has met with
members of President Trump's DOE
Landing Team to communicate our
ongoing concerns related to the flawed
science that has been utilized to justify

22 THE SOURCE | THE VOICE AND CHOICE OF PUBLIC GAS

the furnace SNOPR. For example,
DOE's models randomly "assigned"
installation or use scenarios without
regard to the economic consequences
of the installation. This implies that
purchasers of a piece of equipment
literally never consider the economics
of their purchases including initial
cost, maintenance cost or cost of
operation. The result is rules and
standards that do not represent the
actual market or consumer choice.
APGA has argued that an economic
decision-making process should be
utilized wherein DOE's model would
put the furnace that made economic
sense in each home. This would allow
for a more accurate calculation of the
benefits and costs the proposed rule
would have. At this point, it is unclear
how the Trump Administration will
address the
furnace SNOPR.
Information on the furnace SNOPR,
including a copy of APGA's comments,
can be found on the APGA website at
www.apga.org/furnacerule.


http://www.apga.org/furnacerule

Table of Contents for the Digital Edition of THE SOURCE - Summer 2017

First Person
APGA Events
Q&A: Representative Walden
A Conversation with an APGA Member
Look Out Your Window
Winning Insight into Gas Losses
Electrify, Electrify
Furnace Rule Update
Legislative Outlook
The Pipeline
Marketing Matters
At Last
THE SOURCE - Summer 2017 - bellyband1
THE SOURCE - Summer 2017 - bellyband2
THE SOURCE - Summer 2017 - cover1
THE SOURCE - Summer 2017 - cover2
THE SOURCE - Summer 2017 - 3
THE SOURCE - Summer 2017 - 4
THE SOURCE - Summer 2017 - 5
THE SOURCE - Summer 2017 - 6
THE SOURCE - Summer 2017 - 7
THE SOURCE - Summer 2017 - 8
THE SOURCE - Summer 2017 - First Person
THE SOURCE - Summer 2017 - APGA Events
THE SOURCE - Summer 2017 - 11
THE SOURCE - Summer 2017 - Q&A: Representative Walden
THE SOURCE - Summer 2017 - A Conversation with an APGA Member
THE SOURCE - Summer 2017 - 14
THE SOURCE - Summer 2017 - 15
THE SOURCE - Summer 2017 - Look Out Your Window
THE SOURCE - Summer 2017 - 17
THE SOURCE - Summer 2017 - Winning Insight into Gas Losses
THE SOURCE - Summer 2017 - 19
THE SOURCE - Summer 2017 - Electrify, Electrify
THE SOURCE - Summer 2017 - 21
THE SOURCE - Summer 2017 - Furnace Rule Update
THE SOURCE - Summer 2017 - Legislative Outlook
THE SOURCE - Summer 2017 - 24
THE SOURCE - Summer 2017 - 25
THE SOURCE - Summer 2017 - The Pipeline
THE SOURCE - Summer 2017 - Marketing Matters
THE SOURCE - Summer 2017 - 28
THE SOURCE - Summer 2017 - At Last
THE SOURCE - Summer 2017 - 30
THE SOURCE - Summer 2017 - cover3
THE SOURCE - Summer 2017 - cover4
THE SOURCE - Summer 2017 - outsert1
THE SOURCE - Summer 2017 - outsert2
THE SOURCE - Summer 2017 - outsert3
THE SOURCE - Summer 2017 - outsert4
THE SOURCE - Summer 2017 - outsert5
THE SOURCE - Summer 2017 - outsert6
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