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On June 6, APGA, the American Gas Association, the National Association of Homebuilders and several other groups submitted a document to the Department of Energy (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 form 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 further communicates 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 from the market. The filing further states that as technology advances, it may 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 asks 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 furnaces).

A copy of the document that was filed with DOE is available on the APGA website. For questions on this article, please contact Dave Schryver of APGA staff by phone at 202-464-2742 or by email at dschryver@apga.org.