ARLINGTON, Va. — The Air-Conditioning, Heating, and Refrigeration Institute (AHRI) has filed comments in response to the U.S. Department of Energy’s (DOE’s) notice of proposed rulemaking (NOPR) on Energy Conservation Standards for Residential Furnaces.

“Since the passage of the National Appliance Energy Conservation Act of 1987, our furnace manufacturer members have worked continuously to include models at the highest levels of efficiency as part of expanded product lines that provide cost effective choices to meet the diverse heating needs of American consumers,” said Stephen Yurek, AHRI president and CEO. “Even though the federal minimum efficiency standard for residential furnaces has been essentially unchanged since 1992, today one out of every two residential furnaces shipped by our members is a condensing model utilizing the most efficient technology currently available. It is apparent that consumers are making energy efficient choices, based on their own economic situations, rather than responding to a federal mandate.”

AHRI noted that, for many reasons, it cannot support the proposed minimum 92 percent AFUE standard for non-weatherized and mobile home gas furnaces. AHRI stated its review of the NOPR and associated technical support document has identified significant errors and invalid assumptions that illustrate the proposed standard is not economically justified:

• DOE’s decision to use randomly assigned variables rather than actual market conditions to determine potential energy savings will result in 40 percent less energy saved, in AHRI’s estimation.

• DOE underestimated projected shipments of condensing furnaces in the absence of a new standard by 10 percent, while overestimating the percentage of the population that would be positively affected by the proposed new standard.

• DOE’s estimate of the life-cycle costs to consumers for purchase and installation of these products is two to three times lower than what those costs would actually be, based on real-world cost data, said AHRI.

• DOE’s estimate of the increase in manufacturer costs to comply with the proposed rule is too low by approximately 35 percent.

• In 15-20 percent of situations nationally, AHRI said there will be installation issues that make it impractical and even impossible to install units that comply with the proposed standard.

“We are perplexed and disappointed that DOE has chosen to ignore real-world market realities and impacts, particularly on small businesses and lower income consumers, rather than relying on sound economic analysis to develop this rule,” said Yurek.

AHRI stated it is continuing to work with a representative group of stakeholders, including industry and environmental organizations, to try to reach agreement on a consensus standard for these products that would save energy while benefiting consumers, manufacturers, and the environment.

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Publication date: 7/13/2015

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