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APGA Furnace Rule Comments January 6, 2017

#DOE #DOEfurnace #GTI #doefurnacerule #APGACommentsandMotions #DOEFurnaceComments #doefurnacerulecomments

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Focus Search - APGA Furnace Rule Comments January 6, 2017

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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

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Focus Search - In addition, the DOE fuel switching analysis includes as a rule benefit cases in which rational fuel switching would accrue incremental benefits to the consumer compared to the TSL furnace

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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

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March 27 2015 - APGA Testified in opposition of DOE's proposed furnace rule

March 27, 2015 - Opening statement of APGA Vice President Dave Schryver on 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

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Focus Search - March 27, 2015 - Opening statement of APGA Vice President Dave Schryver on the Department of Energy (DOE)'s proposed rule (NOPR) increasing natural gas furnace standards

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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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APGA Files Comments in Response to DOE Proposed Natural Gas Furnace Efficiency Standard

(July 10, 2015) –Today, APGA filed comments in response to the Department of Energy’s (DOE) Notice of Proposed Rulemaking (NOPR) that proposes a new nationwide 92% efficiency standard for natural gas furnaces. Since the 92% standard can only be met by condensing furnaces, the NOPR would ban the sale of non-condensing furnaces in the United States

Press Release on APGA_s Furnace Comments July 2015-Revised (1).docx

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April 30 2015 - APGA and AGA Submit a Request for 90-day Extension on Furnace Rule Comments from DOE

April 30, 2015 - APGA and the American Gas Association submitted a request to the Department of Energy for a 90-day extension in the comments period for DOE’s furnace NOPR. The current deadline for comments is June 10th

AGA&APGA Request for Extension of Comment Period.pdf

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APGA Sends Letter in Support of Spire's Request for an Extension in the Furnace SNOPR Comment Period

Cymbalsky: On September 26, 2016, the American Gas Association (“AGA”) and the American Public Gas Association (“APGA”) (collectively, the “Associations”) filed a joint supplemental request with the Department of Energy (“Department”) for an extension of time for filing comments on the Supplemental Notice of Proposed Rulemaking (“SNOPR”) on Energy Conservation Standards for Residential Furnaces for a total of a ninety (90)-day comment period from the date of publication of the SNOPR in the Federal Register

161028 Supp Joint Request for Extension of Comment Period on Furnace SNO....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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November 6, 2015 - APGA Comments on DOE NODA

DOE asked for “comments, data, and information regarding this analysis” (id. at 55045), such comments to be filed by October 14, 2015

APGA Supplemental NODA Comments & Letter to Secretary Moniz Regarding NODA Extension.pdf