THE SOURCE - Fall 2017 - 17

feature

Update on DOE's
Furnace Rule
The Trump Administration has moved slowly in terms of getting its political appointees within the various
branches of the federal government. As of mid-May, the Administration has made 85 nominations
to the Senate. By comparison, in that same period in their first terms, President Barack Obama made
212 nominations, President George W. Bush made 161 nominations, President Bill Clinton made 182 nominations,
and President George H. W. Bush made 135 nominees. Within the Department of Energy (DOE), there are
22 politically-appointed positions of which only one has been filled - Secretary Rick Perry.
Two others, Dan Brouillette for Deputy
Secretary and David Jonas for General
Counsel, have been nominated but as of
mid-May have yet to be confirmed. This
is important because until that senior
management team is in place, it is difficult
for the Administration to develop and
implement its goals and objectives in
terms of DOE priorities.
This has had an impact on DOE
action in many areas including efficiency
regulations such as DOE's furnace
Supplemental Notice of Proposed
Rulemaking (SNOPR). In September 2016
DOE released a SNOPR, which 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 noncondensing 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.
APGA continues to communicate
to DOE the flaws in the technical data
that was utilized to justify the 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.
More recently, APGA was part of a joint
request to DOE for a legal interpretation
confirming that the Energy Policy and
Conservation Act of 1975 does not

authorize the adoption of efficiency
standards that would limit the market
for natural gas appliances or equipment
to condensing products. In the filing,
APGA communicates that standards "that
can only be safely achieved through the
use of condensing technology would
eliminate gas products with important
features - including compatibility with the
atmospheric venting systems present in
the vast majority of existing buildings in
which such products are installed - that
are often necessary to make the use of
gas products a practical option." The
document further states that DOE "is
not authorized to adopt standards that
would limit the range of available product
features in this way." APGA's hope is that
the legal interpretation confirms that
DOE cannot lawfully impose efficiency
standards that can only be achieved
through the use of condensing technology
unless it: (1) determines that such
standards are justified for power-vented
products requiring condensate disposal;
and, (2) specifies separate product classes
so that it can impose such standards while
preserving the availability of products that
do not require condensate disposal and
are compatible with atmospheric venting
systems. APGA is awaiting a response from
DOE on this filing.
THE SOURCE | FALL 2017, VOL. 10, ISSUE 1 17



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

First Person
APGA Events
A Conversation with an APGA Member: Southeast Gas
Update on DOE’s Furnace Rule
The Second Annual NGV Road Rally
Levelized Cost of Energy (LCOE) and How it Affects the Direct-Use of Natural Gas
APGA Strategic Planning: What’s Next?
Growing Revenue Without Capital - Combined Heat and Power
APGA Endorses Leading Home Repair Provider
Legislative Outlook
The Pipeline
Marketing Matters
At Last
THE SOURCE - Fall 2017 - intro
THE SOURCE - Fall 2017 - ebelly1
THE SOURCE - Fall 2017 - ebelly2
THE SOURCE - Fall 2017 - cover1
THE SOURCE - Fall 2017 - cover2
THE SOURCE - Fall 2017 - 3
THE SOURCE - Fall 2017 - 4
THE SOURCE - Fall 2017 - 5
THE SOURCE - Fall 2017 - 6
THE SOURCE - Fall 2017 - 7
THE SOURCE - Fall 2017 - First Person
THE SOURCE - Fall 2017 - 9
THE SOURCE - Fall 2017 - APGA Events
THE SOURCE - Fall 2017 - 11
THE SOURCE - Fall 2017 - A Conversation with an APGA Member: Southeast Gas
THE SOURCE - Fall 2017 - 13
THE SOURCE - Fall 2017 - 14
THE SOURCE - Fall 2017 - 15
THE SOURCE - Fall 2017 - 16
THE SOURCE - Fall 2017 - Update on DOE’s Furnace Rule
THE SOURCE - Fall 2017 - The Second Annual NGV Road Rally
THE SOURCE - Fall 2017 - 19
THE SOURCE - Fall 2017 - Levelized Cost of Energy (LCOE) and How it Affects the Direct-Use of Natural Gas
THE SOURCE - Fall 2017 - 21
THE SOURCE - Fall 2017 - APGA Strategic Planning: What’s Next?
THE SOURCE - Fall 2017 - 23
THE SOURCE - Fall 2017 - 24
THE SOURCE - Fall 2017 - 25
THE SOURCE - Fall 2017 - Growing Revenue Without Capital - Combined Heat and Power
THE SOURCE - Fall 2017 - 27
THE SOURCE - Fall 2017 - APGA Endorses Leading Home Repair Provider
THE SOURCE - Fall 2017 - 29
THE SOURCE - Fall 2017 - Legislative Outlook
THE SOURCE - Fall 2017 - 31
THE SOURCE - Fall 2017 - 32
THE SOURCE - Fall 2017 - 33
THE SOURCE - Fall 2017 - The Pipeline
THE SOURCE - Fall 2017 - 35
THE SOURCE - Fall 2017 - Marketing Matters
THE SOURCE - Fall 2017 - 37
THE SOURCE - Fall 2017 - 38
THE SOURCE - Fall 2017 - 39
THE SOURCE - Fall 2017 - At Last
THE SOURCE - Fall 2017 - 41
THE SOURCE - Fall 2017 - 42
THE SOURCE - Fall 2017 - cover3
THE SOURCE - Fall 2017 - cover4
THE SOURCE - Fall 2017 - outsert1
THE SOURCE - Fall 2017 - outsert2
THE SOURCE - Fall 2017 - outsert3
THE SOURCE - Fall 2017 - outsert4
https://www.nxtbook.com/naylor/PGAQ/PGAQ0218
https://www.nxtbook.com/naylor/PGAQ/PGAQ0118
https://www.nxtbook.com/naylor/PGAQ/PGAQ0417
https://www.nxtbook.com/naylor/PGAQ/PGAQ0317
https://www.nxtbook.com/naylor/PGAQ/PGAQ0217
https://www.nxtbook.com/naylor/PGAQ/PGAQ0117
https://www.nxtbook.com/naylor/PGAQ/PGAQ0416
https://www.nxtbook.com/naylor/PGAQ/PGAQ0316
https://www.nxtbook.com/naylor/PGAQ/PGAQ0216
https://www.nxtbook.com/naylor/PGAQ/PGAQ0116
https://www.nxtbook.com/naylor/PGAQ/PGAQ0415
https://www.nxtbook.com/naylor/PGAQ/PGAQ0315
https://www.nxtbook.com/naylor/PGAQ/PGAQ0215
https://www.nxtbook.com/naylor/PGAQ/PGAQ0115
https://www.nxtbookmedia.com