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DOE Proposed Natural Gas Furnace Efficiency Standard Harms Natural Gas Consumers and Undermines Efficiency

(March 12, 2015) –The Department of Energy’s (DOE) Notice of Proposed Rulemaking (NOPR) released in today’s Federal Register proposes a new natural gas furnace efficiency standard that will have an adverse impact on millions of Americans who currently use natural gas to heat their homes

DOENatGas.pdf



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New DOE Furnace Efficiency Standard Ultimately Reduces Efficiency

(February 11, 2015) –The Department of Energy (DOE) has released a new natural gas efficiency standard that will have an adverse impact on millions of Americans who currently use natural gas to heat their homes

2 11 15 Furnace Rule Press Release.pdf


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July 10, 2015- APGA files comments in response to Department of Energy's Notice of Proposed Rulemaking on natural gas furnaces

APGA filed comments in response to the Department of Energy’s (DOE) Notice of Proposed Rulemaking (NOPR) that proposes a new nationwide standard of 92% annual fuel utilization efficiency (AFUE) for natural gas furnaces. The end result of this NOPR is a ban on the sale of non-condensing furnaces in the United States since condensing furnaces are the only ones capable of meeting the higher efficiency standard. In its comments APGA makes several legal arguments: the technical support documents (TSD) and accompanying spreadsheets DOE utilized to justify the NOPR have not undergone peer review; DOE should, at a minimum, suspend the subject proceeding until the required new test procedures are established to measure the energy efficiency, energy use, or estimated annual operating co #DOEFurnaceComments #Regulatory #Codes #doefurnacerulecomments #2015Comments #APGACommentsandMotions

Final 071015 APGA Comments-c.pdf


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Analysis Shows Flaws in DOE Justification for Furnace NOPR

(June 11, 2015) –The American Public Gas Association (APGA) has been working with the Gas Technology Institute—an independent technology organization—to conduct a thorough review of the Technical Support Document and the modeling that the Department of Energy (DOE) has used as a justification for the Notice of Proposed Rulemaking (NOPR) released in March, which proposes to establish a 92 percent Annual Fuel Utilization Efficiency standard for natural gas furnaces. This NOPR proposes to ban the sale of non-condensing furnaces in the United States and instead require only condensing furnaces, as they are the only type of furnace capable of meeting the higher efficiency standard

6 11 15 GTI Study.pdf


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APGA Submits Comments to DOE in Response to Proposed Furnace Rule

On November 22nd, APGA submitted comments to the Department of Energy (DOE) in response to a Supplemental Notice of Proposed Rulemaking (SNOPR), released by DOE in September, which would establish a residential furnace nationwide mandate of 92 annual fuel utilization efficiency (AFUE) with a small furnace exemption for furnaces of 55,000 Btu or less

12 attachments

Focus Search - Instead, the Base Case AFUE, which is the efficiency of the furnace that is chosen by an individual consumer without the influence of DOE’s rule, is assigned randomly in the DOE NOPR LCC model


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APGA joined industry letter to Senators in support of language in S. 2012, the Energy Policy Modernization Act

January 21, 2016 Dear Senator, We write today with an urgent request for your continued support of language in S. 2012, the Energy Policy Modernization Act, to review the Department of Energy’s (DOE) rulemaking on efficiency standards for residential non-weatherized gas furnaces currently underway. The provision in this bill, which is identical to Senators Hoeven and Alexander’s legislation (S.1029), is vitally needed to ensure that DOE commits to working with all stakeholders to achieve an efficiency standard that meets environmental and economic goals without penalizing families and businesses, rather than running out the clock to finalize the residential gas furnace rule at the expense of consumers

Senate Energy Bill Furnace Provision Support letter January 21 2016.pdf


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APGA and AGA File Comments with Department of Justice on the Furnace

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)

APGA and AGA Competition Comments to DOJ (2).pdf


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June 8 2015 - Letter to DOE Secretary Moniz about Proposed Furnace Rule on High Costs and Efficiency Concerns

Department of Energy Secretary Ernest Moniz on APGA's concern about the recent rulemaking for residential furnaces that would raise the nationwide standard to 92%, imposing significant costs to consumers and force them to switch to less efficient alternatives

2015-6-8 Congressional Letter to Sec_ Moniz.pdf


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March 27 2015 - APGA Submitted Comments on the DOE proposed furnace rule

March 27, 2015 - APGA submitted comments (here) on the Department of Energy (DOE)'s proposed rule (NOPR) increasing natural gas furnace standards under Docket EERE-2014-BT-STD-0031. APGA Vice President Dave Schryver also testified on the issue in front of the Department of Energy (DOE)'s proposed rule (NOPR) increasing natural gas furnace standards. APGA, whose members are predominantly located in southern tier states, is concerned that the NOPR, by eliminating non-condensing furnaces from the marketplace, is, among other things, taking away customer choice, discriminating against low-income persons, and precipitating fuel switching to less efficient energy alternatives – all to the detriment of the American public

03_20_2015 APGA Comments-c.pdf