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Comments to DOE on Conservation Standards for Furnaces and Water Heaters

The Department of Energy ("DOE") sets energy-efficiency standards for certain appliances and equipment, including residential furnaces, under the Energy Policy and Conservation Act ("EPCA"). In January 2021, DOE issued a final interpretative rule determining that a certain, less-efficient type of gas furnace would be subject to less-stringent standards than other gas furnaces, departing from DOE's traditional approach to determining when a product feature warrants a different standard. In August 2021, DOE proposed to return to its prior, long-standing interpretation, which would require these less-efficient gas furnaces to meet the same standard as other gas furnaces. We filed comments supporting the proposal, while cautioning DOE against making unnecessary statements that might hinder its ability in the future to set standards that would encourage consumers to switch from gas-fired appliances to electric appliances.

Policy Integrity gratefully acknowledges Jemie Fofaneh and William Rose for their research assistance for this comment letter.