AGA Files Comments Opposing the DOE Proposed 95% AFUE Minimum Efficiency Requirement for Consumer Furnaces
As a reminder, on July 7, 2022, the DOE issued a Federal Register Notice that proposed a minimum efficiency requirement of 95% AFUE for mobile home and non-weatherized, residential gas furnaces that would go into effect in 2029. The 95% AFUE level would eliminate non-condensing type furnaces from being manufactured after the effective date. We have been reporting almost weekly on this proposal and appreciate BECS Committee members feedback and suggestions on outlines and drafts of our comments.  Yesterday, AGA filed timely and extensive comments (attached) opposing the DOE proposed 95% AFUE minimum efficiency requirement. The AGA comments provide extensive, specific concerns on the negative impact the proposal will have on many consumers,  especially low-income consumers and senior citizens on fixed incomes, technical and modeling issues on the DOE analysis justifying the proposal and potential legal violations and procedural errors in DOE’s development and issuance of the proposal. Finally, the comments outline the reasons the proposal would be counterproductive to the country’s energy efficiency goals.  The BECS members and the public in general, can access the docket that publishes all of the public comments submitted on the DOE proposal here .
In another filing on the furnace rulemaking,  AGA signed on to Business Community comments (attached) specifically on the proposed rule’s use of the social cost of greenhouse gas (“SC-GHG”) estimates.  The comments outlined the importance of the DOE in ensuring that any SC-GHG estimates that are used in agency rulemakings, including the rulemaking process for this proposed rule, are the product of a sound, transparent, and inclusive process and are not misleading or inaccurate.
Finally, attached are comments also filed yesterday on the DOE furnace rule by a broad coalition of interested and impacted businesses and associations including AGA that outline the concerns and negative impact the proposed final rule will have on low-income and senior households.
We will provide DOE’s response on the proposed furnace rule as well as their response on the Business Community’s comments on the use of and determination of the social cost of greenhouse gas (“SC-GHG”) estimates when available.
State Codes Activity Update.