AGA: Proposed Standards for Consumer Furnaces Flawed and Harmful

Washington, D.C. – The American Gas Association (AGA) filed comments today on the U.S. Department of Energy’s (DOE) notice of proposed rulemaking for Energy Conservation Standards for Consumer Furnaces, saying:

“AGA has long supported improved building and appliance energy codes and standards that are technologically feasible, economically justified, and follow the law.”


“The Proposed Rule suffers from an array of economic, technical, and procedural flaws that will render it harmful to consumers, counterproductive to energy efficiency goals, and unlawful.”  

DOE’s proposal will eliminate natural gas furnaces that millions of American homes are currently designed for and use. The proposed rule requires 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, DOE 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.

If finalized, the proposed rulemaking would result in higher overall costs for nearly one in five gas furnace consumers, including 15 percent of senior-only households, 14 percent of low-income households, and 20 percent of small business consumers. However, a careful examination of DOE’s economic analysis reveals that 29 percent of households with non-weatherized gas furnaces affected by this rule will face negative impacts due to the proposed rule. Moreover, 40 percent of all low-income consumers across the country with non-weatherized gas furnaces impacted by this rule will have higher costs forced on them.

AGA has identified material errors and methodological defects in the model and assumptions that DOE has used to justify its proposal. AGA has brought these issues to the Department’s attention on several occasions and has not received any substantive response.

“Even DOE’s flawed analysis shows that millions of consumers will pay more and have fewer energy choices,” said Karen Harbert, AGA President and CEO. “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 a diverse set of stakeholders in submitting comments that outline the group’s strong support for energy efficiency and conservation, while also highlighting the negative impacts this rulemaking would have on homeowners. Signatories on the letter included American Gas Association, American Pipeline Contractors Association, American Public Gas Association, American Society of Gas Engineers, American Supply Association, Arkansas Gas Association, Consumer Energy Alliance, Distribution Contractors Association, Hearth, Patio & Barbecue Association, Hispanics in Energy, Louisiana Gas Association, Manufactured Housing Institute, National Apartment Association, National Association of Home Builders, National Leased Housing Association, National Multifamily Housing Council, National Propane Gas Association, National Utility Contractors Association, Natural Gas Supply Association, Northeast Gas Association, Plastics Pipe Institute, Plumbing-Heating-Cooling Contractors Association, Rinnai America Corporation, Thermo Products LLC U.S. Chamber of Commerce, Utility Workers Union of America, AFL-CIO, Williams Furnace Co. dba Williams Comfort Products or Williams.

AGA encourages 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.

Households that use natural gas for heating, cooking and clothes drying save an average of $1,041 per year compared to homes using electricity for those applications and result in lower overall energy use and greenhouse gas emissions.

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AGA Media Contact:
Emily Carlin
(202) 824-7278