THE SOURCE - Winter 2016 - 10


industry update

Furnace Rule Report

O

n September 23, the
Department of Energy's
(DOE) Supplement Notice of a
Proposed Rule (SNOPR) for residential
furnaces appeared in the Federal
Register. DOE is proposing a nationwide
mandate of 92 Annual Fuel Utilization
Efficiency (AFUE) with a small furnace
exemption for furnaces of 55,000
Btu or less. Furnaces under the small
furnace exemption would be allowed
to be non-condensing; all furnaces
above that threshold would have to
be condensing. The rule would go
into effect five years after the rule is
finalized. Needless to say, this SNOPR
will have a significant impact upon
public natural gas systems, particularly
those in warmer climates.
Because of the difference in
combustion technology, condensing
furnaces have additional venting
requirements that add significant
dollars to the cost of installation.
Condensing furnaces are a great piece
of equipment, but there are many
situations where the homeowner may
not be able to install a condensing
furnace in their home or may not
be able to afford the additional cost
associated with the installation of
this furnace. It is APGA's position that
the additional venting requirements
associated with replacing a noncondensing natural gas furnace with
a condensing furnace will push many
residential customers to purchase
and install less efficient home heating
alternatives with potentially higher
greenhouse gas emissions and higher
monthly utility bills.
In response to the release of the
SNOPR, APGA released a statement
communicating that DOE, "has
once again proposed a new energy

conservation standard for natural gas
furnaces that will harm consumers
and ultimately undermine energy
efficiency." APGA also stated that "the
proposed rule will cause uneconomic
fuel switching as many consumers-
especially in southern states-will
be compelled to change their natural
gas furnaces to electric heat pumps."
Lastly, APGA communicated that the
SNOPR "will impose significant harm
upon APGA members' consumers, and
as a result, APGA will leave no stone
unturned, including possible litigation,
to protect these consumers."
APGA has also stated in comments
to DOE and elsewhere that DOE is
attempting to address a problem that
doesn't exist. Data shows that the
furnace market is working properly
without a rule. Consumers that
should be purchasing condensing
furnaces because it makes economic
sense for where they live are making
this decision already under current
standards. If implemented, the
SNOPR will compel consumers to
make uneconomic choices that will
hurt low and fixed-income families,
homeowners in the south, and
many others who live in condos or
rowhomes.
DOE initially provided only 30
days to comment, which is wholly
inadequate and unreasonable. In
addition to the 488-page rule, DOE
has released seven additional files
and models, including a 1,198-page
Technical Support Document. All of
this data must be interpreted and
understood to comment meaningfully
on the proposal. APGA and the
American Gas Association formally
requested a 60-day extension,
bringing the total comment period

10	 THE SOURCE | THE VOICE AND CHOICE OF PUBLIC GAS

to 90 days. DOE did not grant the
60-day extension request but did
extend the comment period for
another 30 days, which would set the
comment deadline for November.
DOE has scheduled a public meeting
for October 17 to discuss the data
that presently should occur after the
comment deadline. APGA's DirectUse Task Group and Regulatory
Subcommittee will play a lead role
in developing APGA's comments in
response to the SNOPR. For questions
on the DOE furnace rule and APGA's
advocacy efforts, please contact Dave
Schryver of APGA staff by phone at
202-464-2742 or by email at
dschryver@apga.org.

It is APGA's position that
the additional venting
requirements associated
with replacing a
non-condensing
natural gas furnace
with a condensing
furnace will push many
residential customers
to purchase and install
less efficient home
heating alternatives
with potentially
higher greenhouse gas
emissions and higher
monthly utility bills.



Table of Contents for the Digital Edition of THE SOURCE - Winter 2016

First Person
APGA Events
Industry Update: Furnace Rule Report
The Future of Natural Gas in Zero Energy Building Design
Bringing Success to Succession in the Utility World
Taking a Fresh Look at Distributed Generation and CHP
Why Energy Codes Matter and How They Impact Your Utility
Environmental Group and Utility Work Together
Legislative Outlook
The Pipeline
Marketing Matters
At Last
Advertisers’ Index/ Advertiser.com
THE SOURCE - Winter 2016 - bellyband1
THE SOURCE - Winter 2016 - bellyband2
THE SOURCE - Winter 2016 - cover1
THE SOURCE - Winter 2016 - cover2
THE SOURCE - Winter 2016 - 3
THE SOURCE - Winter 2016 - 4
THE SOURCE - Winter 2016 - 5
THE SOURCE - Winter 2016 - 6
THE SOURCE - Winter 2016 - First Person
THE SOURCE - Winter 2016 - APGA Events
THE SOURCE - Winter 2016 - 9
THE SOURCE - Winter 2016 - Industry Update: Furnace Rule Report
THE SOURCE - Winter 2016 - The Future of Natural Gas in Zero Energy Building Design
THE SOURCE - Winter 2016 - 12
THE SOURCE - Winter 2016 - 13
THE SOURCE - Winter 2016 - Bringing Success to Succession in the Utility World
THE SOURCE - Winter 2016 - 15
THE SOURCE - Winter 2016 - Taking a Fresh Look at Distributed Generation and CHP
THE SOURCE - Winter 2016 - 17
THE SOURCE - Winter 2016 - 18
THE SOURCE - Winter 2016 - 19
THE SOURCE - Winter 2016 - Why Energy Codes Matter and How They Impact Your Utility
THE SOURCE - Winter 2016 - 21
THE SOURCE - Winter 2016 - Environmental Group and Utility Work Together
THE SOURCE - Winter 2016 - 23
THE SOURCE - Winter 2016 - Legislative Outlook
THE SOURCE - Winter 2016 - 25
THE SOURCE - Winter 2016 - The Pipeline
THE SOURCE - Winter 2016 - Marketing Matters
THE SOURCE - Winter 2016 - 28
THE SOURCE - Winter 2016 - 29
THE SOURCE - Winter 2016 - 30
THE SOURCE - Winter 2016 - Advertisers’ Index/ Advertiser.com
THE SOURCE - Winter 2016 - cover4
THE SOURCE - Winter 2016 - outsert1
THE SOURCE - Winter 2016 - outsert2
THE SOURCE - Winter 2016 - outsert3
THE SOURCE - Winter 2016 - outsert4
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