American Gas Association: Thumbs down on federal plan to eliminate natural gas furnaces
A proposed rule from the U.S. Department of Energy (DOE) that would eliminate natural gas furnaces used in millions of American homes suffers from an array of economic, technical, and procedural flaws that will render it harmful to consumers, counterproductive to energy efficiency goals, and unlawful, according to the American Gas Association (AGA).
The DOE should rescind its July 7 proposed rulemaking for Energy Conservation Standards for Consumer Furnaces, which would amend the energy conservation standards for non-weatherized gas furnaces and mobile home gas furnaces, according to AGA comments filed on Oct. 6.
Specifically, the DOE’s proposed rule would require condensing furnace equipment, which costs more to install and requires a different ventilation system and a drainage solution to dispose of water. As a result, the department would force many consumers to replace their natural gas furnaces with other equipment that is more expensive to operate in order to avoid the enormous cost of remodeling their homes, according to the association.
“AGA believes that federal policy should recognize that improving energy efficiency in residential, commercial, industrial, transportation, and other natural gas applications is a cornerstone strategy for reducing greenhouse gas emissions,” according to the organization’s comments, which were submitted by AGA Assistant General Counsel Matthew Agen.
Unfortunately, however, AGA says the proposed rule is procedurally flawed; cannot be economically justified using the analytical methods employed in the DOE rulemaking; and would make conventional, non-condensing furnaces unavailable to consumers when millions of American homes were designed with “atmospheric venting systems” that include chimneys, vents, and utility closets that cannot accommodate condensing furnaces.
Additionally, DOE’s analysis shows that its rule will lead to fuel switching to electricity, increasing overall energy use for many consumers, according to AGA’s comments.
“The department is unlawfully promoting fuel switching. Congress designed the energy conservation standards to be fuel neutral and not favor one energy source over another,” says AGA. “By considering fuel switching a benefit in some contexts and ignoring it in others, the department improperly favors a single energy source, contrary to its authority and against consumers’ interests.”
At the same time, AGA says it has identified material errors and methodological defects in the model and assumptions that DOE has used to justify its proposal, noting that it has brought these issues to the attention of the department on several occasions, but has not yet received any substantive response.
“Even DOE’s flawed analysis shows that millions of consumers will pay more and have fewer energy choices,” said AGA President and CEO Karen Harbert in an Oct. 7 statement. “One-in-three households affected by this rule will face higher costs to heat their homes, and low-income homes will be disproportionately affected. These impacts are unreasonable and unfair.”
AGA also led numerous organizations in submitting another set of comments on Oct. 6 to Julia Hegarty, general engineer in the DOE’s Office of Energy Efficiency and Renewable Energy, that voiced support for energy efficiency and conservation, and highlighted the negative impacts the DOE’s proposed rule would have on homeowners.
The DOE’s notice of proposed rulemaking “would eliminate an entire category of gas furnaces, i.e., non-condensing furnaces, currently used in millions of homes,” the groups said. “The proposal, if adopted, would negatively impact individual homeowners, including senior and low-income households, small businesses, and the overall furnace market. The undersigned organizations request that DOE not implement the proposal.”
Among the groups that joined AGA in signing the letter were the U.S. Chamber of Commerce, the American Pipeline Contractors Association, the American Supply Association, the Consumer Energy Alliance, the Distribution Contractors Association, the Hearth, Patio & Barbecue Association, Hispanics in Energy, the Manufactured Housing Institute, the National Apartment Association, the National Association of Home Builders, the Plumbing-Heating-Cooling Contractors Association, the Utility Workers Union of America, and the AFL-CIO, among many others.
They encouraged DOE to work with stakeholders to develop a solutions-oriented approach to energy conservation that ensures any proposed consumer furnace efficiency standards reduce energy use, protect consumers, and preserve the specific furnace features consumers need for their homes, according to their comments.
