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APGA is currently working on comments in response to a Department of Energy (DOE) proposed interpretive rule released in early July in response to a petition submitted to DOE by APGA and other gas industry stakeholders.  The petition, submitted last June, requested 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.  In its proposed interpretive rule, DOE “partially grants the petition by issuing an interpretation that non-condensing operation is a product feature and that no DOE rulemaking may prescribe a standard that would make that feature unavailable.  DOE’s proposal also states that the “proposed change would ensure that DOE will not impede energy affordability, particularly for persons with low incomes, by mandating high-cost condensing products and installations.”

While APGA and its members are strong supporters of energy efficiency (in fact the direct use of natural gas is one of the most efficient uses of energy at 90 percent), we have continually expressed strong concerns that proposed rules requiring the replacement of non-condensing appliances with condensing appliances, such as the furnace rule, will ultimately undermine efficiency goals while significantly increasing consumer costs.  This is primarily because condensing furnaces have additional venting requirements associated with their installation which add significant dollars to their overall costs.  This raises serious fuel switching issues for APGA and its members. In the case of the furnace rule, many consumers, especially those in fixed and low-income brackets, will switch to less energy-efficient electric heat as it has lower first cost to avoid the installation costs of a condensing furnace.  APGA has maintained that having separate product classes for condensing and non-condensing appliances is the best approach towards improving energy efficiency, maintaining consumer choice and ensuring affordable energy costs.     

The deadline for filing comments in response to the proposed interpretive rule is September 9, 2019.  If you have any questions on this article, please contact Dave Schryver of APGA’s staff by phone at 202-464-2742 or by email at dschryver@apga.org.