Friday, July 24, 2015
The Air-Conditioning, Heating, and Refrigeration Institute (AHRI) has filed comments in response to the U.S. Department of Energy’s (DOE) notice of proposed rulemaking on energy conservation standards for residential furnaces (80 Fed. Reg. 13,120). AHRI is objecting to a proposed revised minimum 92% AFUE standard for non-weatherized and mobile home gas furnaces. The institute’s review of the proposal and associated technical support document has identified significant errors and invalid assumptions that illustrate the standard is not economically justified.
AHRI asserts that DOE’s decision to use randomly assigned variables rather than actual market conditions to determine potential energy savings will result in 40% less energy saved; DOE underestimated projected shipments of condensing furnaces in the absence of a new standard by 10%, while overestimating the percentage of the population that would be positively affected by the proposed new standard; DOE’s estimate of the lifecycle costs to consumers for purchase and installation of the products is two to three times lower than what those costs would actually be, based on real-world cost data.
Further, DOE’s estimate of the increase in manufacturer costs to comply with the proposed rule is too low by about 35%; and in 15% to 20% of situations nationally, 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 Stephen Yurek, AHRI president and CEO.
“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,” he added. “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 asserts that DOE’s decision to use randomly assigned variables rather than actual market conditions to determine potential energy savings will result in 40% less energy saved; DOE underestimated projected shipments of condensing furnaces in the absence of a new standard by 10%, while overestimating the percentage of the population that would be positively affected by the proposed new standard; DOE’s estimate of the lifecycle costs to consumers for purchase and installation of the products is two to three times lower than what those costs would actually be, based on real-world cost data.
Further, DOE’s estimate of the increase in manufacturer costs to comply with the proposed rule is too low by about 35%; and in 15% to 20% of situations nationally, 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 Stephen Yurek, AHRI president and CEO.
“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,” he added. “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.”
