Technical: Comments to DOE Residential
Gas Furnace Proposal
The Plumbing-Heating-Cooling Contractors–National Association supports responsible use of energy efficient products. Our members would prefer to sell the best product that fits a particular application. Unfortunately, in some instances, this proposed efficiency standard will deprive contractors and consumers of practical choices. There will be installations with venting issues that will preclude the use of a condensing furnace, there will be tough choices to be made in those instances .Low income and fixed income individuals will also have difficult choices. That may mean making repairs to older inefficient equipment, some consumers may elect to continue running faulty equipment, or space heaters will be utilized to get by. None of those choices are in the best interest of efficiency and may pose significant safety risks.
The proposed rule is based on assumptions made and applied to a complex statistical model. Models are an interesting way to predict outcomes but result in a distribution of outcomes. This distribution will inevitably have outliers, consumers who are set aside as not a significant factor. How many consumers are in this group? How do we decide who should have benefit and who should be ignored. If the assumptions are incorrect, these outliers become magnified, much more significant. A survey of contractors was undertaken jointly by PHCC, ACCA, and AHRI (attached as an Appendix) which indicates that the installed costs are greatly understated, this suggests significant error in the model.
Specific markets will also react to this proposed rule in different manners. Southern regions will most likely move to electric heating as their hours of operation reduce payback. Multi-family projects may also move to electric heating, initial installation costs will be reduced, fuel costs will be increased. This fuel cost will be born by the tenant either directly or through rental payments. Many of these tenants will be economically challenged yet bear the cost of this proposed rule.
PHCC strongly recommends postponing this rule and convening stakeholder negotiations to work on alternative solutions. It has been suggested to create two categories of appliances, condensing and non-condensing, work should commence to maximize the potential in both categories. The market has proven to be successful in promoting energy efficiency, perhaps with some refinement, that can be built upon without regional standards or blanket efficiency standards which penalize many individuals in the HVAC arena.