THE SOURCE - Winter 2017 - 12


Furnace Rule Update
Update on DOE Regulations and
Codes and Standards


here continues to be little action on the Department of
Energy (DOE) appliance efficiency rulemaking front. APGA still
awaits action on a proposed DOE commercial boiler rule as
well as on new Supplemental Notice of Proposed Rulemaking
efficiency standards for natural gas furnaces.

As APGA awaits DOE action on these
and other rulemakings, we have continued
to communicate to DOE and others the
benefits that natural gas appliances
provide, such as high efficiency on a fullfuel-cycle basis and reduced emissions.
More recently, on June 6, APGA, the
American Gas Association, the National
Association of Homebuilders and several
other groups submitted a document to
DOE requesting a legal interpretation that
the Energy Policy and Conservation Act
(EPCA) does not authorize the adoption of
efficiency standards that would limit the
market for fuel gas vented appliances or
equipment to condensing products.
DOE has pushed for efficiency
standards, such as those proposed for
natural gas furnaces that would eliminate
non-condensing natural gas furnaces
from the marketplace. 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 filing communicated that EPCA
expressly prohibits the adoption of an
energy conservation standard if it has
been shown that the standard would
have the effect of eliminating a currently
available product feature, such as noncondensing furnaces, from the market.
The filing further stated that as technology
advances, it might become possible for
gas products to achieve higher efficiencies
without sacrificing their compatibility
with atmospheric venting systems and
their ability to function without plumbing
connections. Until then, DOE can impose
higher efficiency standards as appropriate,
but only by creating separate standards
for separate product classes as necessary
to preserve the availability of those
product features. The filing asked DOE
to confirm that it may not promulgate
efficiency standards that would result in



the unavailability in the United States of any
covered product such as non-condensing
In addition, in July, APGA submitted
comments in response to a Request for
Information (RFI) on reducing regulation
and controlling regulatory costs of DOE. The
RFI is a result of an Executive Order signed
by President Trump that required DOE to
"review all existing regulations, orders,
guidance documents, policies, and any
other similar agency actions (collectively,
agency actions) that potentially burden the
development or use of domestically produced
energy resources, with particular attention
to oil, natural gas, coal, and nuclear energy
APGA's comments addressed a number
of issues that have come out of the challenges
we have faced in recent DOE appliance
efficiency rulemakings, such as the furnace
rule. Among other things, APGA's comments
communicated that the Office of Energy
Efficiency and Renewable Energy's orientation
has created a bias against natural gas
appliances and therefore appliance standard
outcomes would be improved if there were
a separation of the appliance standards
obligations of DOE into its own office.
APGA's comments also addressed a number
of process reforms we have communicated
in the past, such as the need for greater
transparency and that test procedures must
be completed prior to DOE moving forward
with a new efficiency standard. The comments
also raised the issue of DOE modeling,
communicating that the models created
by DOE to justify efficiency standards have
grown excessively complex, impenetrable,
as well as costly. APGA urged DOE to utilize
a more simplified approach to evaluating
existing minimum efficiency standards and
for setting new ones. A more simplified and
straightforward approach would lower
the cost of DOE's regulations as well as the
burden on industry and consumers.


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

A Vision from Our Industry: Listen, Define, Allocate, Execute
First Person
APGA Events
Q&A: Chairman Chatterjee
Furnace Rule Update
Delivering the Needs of Customers Through Legislative Action
Reaching Your Future Customers
Whistling In The Dark: Shortcomings of Natural Gas Indices Persist
Growth in Renewable Natural Gas
Legislative Outlook
The Pipeline
Marketing Matters
At Last
THE SOURCE - Winter 2017 - intro
THE SOURCE - Winter 2017 - ebelly1
THE SOURCE - Winter 2017 - ebelly2
THE SOURCE - Winter 2017 - A Vision from Our Industry: Listen, Define, Allocate, Execute
THE SOURCE - Winter 2017 - cover2
THE SOURCE - Winter 2017 - 3
THE SOURCE - Winter 2017 - 4
THE SOURCE - Winter 2017 - 5
THE SOURCE - Winter 2017 - 6
THE SOURCE - Winter 2017 - 7
THE SOURCE - Winter 2017 - First Person
THE SOURCE - Winter 2017 - 9
THE SOURCE - Winter 2017 - APGA Events
THE SOURCE - Winter 2017 - Q&A: Chairman Chatterjee
THE SOURCE - Winter 2017 - Furnace Rule Update
THE SOURCE - Winter 2017 - 13
THE SOURCE - Winter 2017 - Delivering the Needs of Customers Through Legislative Action
THE SOURCE - Winter 2017 - 15
THE SOURCE - Winter 2017 - Reaching Your Future Customers
THE SOURCE - Winter 2017 - 17
THE SOURCE - Winter 2017 - Whistling In The Dark: Shortcomings of Natural Gas Indices Persist
THE SOURCE - Winter 2017 - 19
THE SOURCE - Winter 2017 - 20
THE SOURCE - Winter 2017 - Growth in Renewable Natural Gas
THE SOURCE - Winter 2017 - 22
THE SOURCE - Winter 2017 - Legislative Outlook
THE SOURCE - Winter 2017 - 24
THE SOURCE - Winter 2017 - The Pipeline
THE SOURCE - Winter 2017 - Marketing Matters
THE SOURCE - Winter 2017 - 27
THE SOURCE - Winter 2017 - At Last
THE SOURCE - Winter 2017 - 29
THE SOURCE - Winter 2017 - 30
THE SOURCE - Winter 2017 - cover3
THE SOURCE - Winter 2017 - cover4
THE SOURCE - Winter 2017 - outsert1
THE SOURCE - Winter 2017 - outsert2
THE SOURCE - Winter 2017 - outsert3
THE SOURCE - Winter 2017 - outsert4
THE SOURCE - Winter 2017 - outsert5
THE SOURCE - Winter 2017 - outsert6