APGA and the American Gas Association (AGA) submitted comments to the Department of Justice (DOJ) regarding the anti-competitive effects of DOE’s furnace Supplemental Notice of Proposed Rulemaking (SNOPR). A copy of the filing is attached. In the filing, APGA and AGA communicate, among other things, that the SNOPR will lessen competition by driving natural-gas using consumers to less expensive but less efficient electric alternatives. The filing also states that “serious technical flaws in the SNOPR analysis that render its rationale for the proposed 92% standard and small furnace exception unacceptable.” APGA and AGA also state that the record shows that the furnace market is working without a rule and therefore the practical effect of the SNOPR’s new minimum standards will be that consumers either are forced by the government to make an uneconomic choice (i.e., they will incur a net cost to purchase a condensing furnace), or they will switch from natural gas to a less efficient electric alternative.#furnacerule #DOEfurnace
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