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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. Furnaces under the small furnace exemption would be allowed to be non-condensing; while all furnaces above that threshold would have to be condensing

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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 Supports Blackburn Amendment

(April 30, 2015) – This morning, the American Public Gas Association (APGA) along with the American Gas Association (AGA) and several other associations sent a letter to all House members in support of Representative Blackburn’s (R-Tenn.) amendment to the fiscal year 2016 Energy and Water Appropriations Bill, which defunds the furnace rule released in March by the Department of Energy (DOE). Representative Blackburn’s amendment would prohibit DOE, starting October 1, from using any resources on the furnace rule for a period of one year, which is the 2016 fiscal year

APGA Supports Blackburn Amendment.pdf


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New DOE Furnace Efficiency Standard Ultimately Reduces Efficiency

Court of Appeals vacated a direct final rule (DFR) concerning furnace efficiency standards issued by DOE in 2011. The 2011 proposal would have established a 90 percent fuel efficiency standard for furnaces in the northern region of the United States. This would have eliminated non-condensing natural gas furnaces from the northern region and likely driven many consumers in that region to switch to less efficient heating alternatives that have higher greenhouse gas emissions. Unfortunately, DOE’s new proposed standard will again adversely affect homeowners because the new standards will require all homes, nationwide, to utilize the higher costing condensing furnace

2 11 15 Furnace Rule Press Release.pdf


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

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. This language provides DOE and stakeholders with the time and opportunity to get this important rule correct

Senate Energy Bill Furnace Provision Support letter January 21 2016.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. Because of the difference in combustion technology, condensing furnaces have additional venting requirements associated with their installation that add significant dollars to their overall costs. This raises serious fuel switching issues for APGA and its members, as many consumers, especially those in fixed and low income brackets, will switch to a lower first cost, albeit less efficient, electric furnace to avoid the installation costs of a condensing furnace

6 11 15 GTI Study.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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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. Because of the difference in combustion technology, condensing furnaces have additional venting requirements associated with their installation that add significant dollars to their overall costs

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