From: The Honorable Mo Brooks
Sent By: email@example.com
This letter is supported by the American Public Gas Association, which represents the interests of approximately 1,000 public gas systems in 37 states. An Energy & Water appropriations amendment on this issue passed by voice vote last week. Please see this list of state/regional municipal gas associations in your state/district.
As you may be aware, on March 12, 2015, the Department of Energy (DOE) released a Notice of Proposed Rulemaking (NPRM) that proposes to establish a nationwide standard of 92% Annual Fuel Utilization Efficiency (AFUE) for natural gas furnaces.
If this NPRM goes into effect, non-condensing natural gas furnaces would be eliminated from the marketplace since the only furnace that can attain the 92% standard would be a condensing furnace. Condensing natural gas furnaces require additional venting reconfigurations that will impose significant additional costs to their installation. This will force many residential customers—particularly those in warmer climates—to forego the use of natural gas-fired furnaces and instead install less expensive and less efficient home heating alternatives.
By DOE’s own numbers, over 20% of the homes nationwide will experience a net cost (versus a net saving) by being required to install 92% AFUE furnaces. This percentage skyrockets to 31% experiencing a net cost in the South on average and to 39% for low-income households in the South.
I urge you to join me in expressing concern to Secretary Moniz by adding your name to the attached letter which communicates concerns regarding the impact of this NPRM. For more information or to cosign this letter, please contact Peter J. White at firstname.lastname@example.org.
Dear Secretary Moniz,
We are writing to express strong concern over the Department of Energy’s recent notice of proposed rulemaking for residential furnaces. While we support energy efficiency, we are extremely concerned that the nationwide 92% standard proposed in this rule will significantly increase costs to natural gas consumers, force them to switch to less efficient alternatives, and ultimately undermine the efficiency goals that underlie the Energy Policy and Conservation Act. The DOE’s own data shows that at the proposed 92% efficiency standard (replacing the current 80% standard), over 20% of consumers nationwide and 31% of consumers in the South seeking to replace an existing non-condensing furnace would experience a “net cost” (versus a net benefit) over the life of the furnace. As a result, DOE assumes that over 10% of such consumers in the North and 20% of such consumers in the South would switch from natural gas to electric heat. The fuel switching numbers are even more staggering in the new construction market.
By setting a nationwide energy efficiency standard that precludes a consumer from choosing to install a non-condensing furnace, DOE will be forcing many homeowners either to abandon the use of natural gas to heat their homes or to pay substantially more for the installation of a furnace that meets the new standard. Each of these options will cost residents, regardless of in what part of the country they reside, thousands of dollars. This will have a major impact on the ability of low and fixed income families to replace an aging furnace with the fuel of their choice. Many families will be faced with the difficult choice of having to replace their non-condensing furnace with either a condensing furnace with higher installation costs or electric heat and accompanying higher monthly energy bills.
We strongly encourage DOE to avoid such an “either-or” approach to furnace efficiency, by establishing separate product classes for condensing and non-condensing furnaces, each with its own efficiency standard. We are extremely concerned that requiring the elimination of the economical and efficient non-condensing furnace will place an unnecessary burden on already struggling homeowners in our states.
We thank you in advance for your consideration of our concerns.