Gas Industries Response to the DOE September 6 Webinar on the Model Used to Justify the Proposed 95% AFUE Minimum Efficiency Requirement for Consumer Furnaces.
Last week, we reported on the DOE September 6 webinar on the model used to justify the proposed 95% AFUE minimum efficiency requirement for consumer furnaces. We were disappointed that the DOE limited the discussion at the webinar primarily to the actual operation of the model with very limited discussion from DOE staff and consultants, to address topics regarding the LCC model on the specific questions and issues requested in the attached August 29th correspondence. To help ensure that the DOE will address and respond to the questions and topics of concern, AGA, APGA, NPGA, Spire Inc., Spire Missouri Inc., Spire Alabama Inc., and Atmos Energy sent the attached September 13, 2022 correspondence to DOE requesting that they do so in a meaningful manner prior to issuance of a final rule, hopefully by a public forum, such that the responses are consistent with DOE’s Process Rule, which pledges DOE will “use qualitative and quantitative analytical methods that are fully documented for the public and that produce results that can be explained and reproduced, so that the analytical underpinnings for policy decisions on standards are as sound and well-accepted as possible.
Please don’t hesitate to contact with us if you have any questions on the DOE proposed consumer furnace rulemaking.
State Codes Activity Update.