DOE recognizes non-condensing furnace tech in proposed rulemaking

The U.S. Department of Energy (DOE) published a notice of proposed rulemaking that considers non-condensing technology to be a “feature” for the purposes of setting product/equipment classes for covered products/equipment.

The U.S. Department of Energy (DOE) notice of proposed rulemaking comes after the agency considered public comments on a petition by the gas industry, including the National Propane Gas Association. Photo: iStock.com/Olivier Le Moal

DOE says it granted the request for an interpretive rule after considering public comments on a petition by the gas industry, including the National Propane Gas Association (NPGA). The petition was submitted in October 2018 and published a month later in the Federal Register for public review and input.

“It is certainly a positive outcome in that we are able to convince DOE that condensing/non-condensing technology is a feature in the sense identified in [the Energy Policy and Conservation Act (EPCA) of 1975],” says Sarah Reboli, deputy counsel, regulatory affairs, at NPGA.

In previous rulemaking actions, the DOE did not consider non-condensing technology to be a feature for the purposes of setting product/equipment efficiency standards for covered products/equipment. The latest action ensures that no DOE rulemaking may prescribe a standard that would make the feature unavailable.

“NPGA supports recognition of condensing versus non-condensing as a feature under EPCA because certain extremely high levels of efficiency cannot be met by non-condensing furnaces. Many – though not all – propane furnaces are non-condensing,” Reboli explains. “If a new efficiency standard from DOE could not be met by non-condensing furnaces and a homeowner’s furnace is to be replaced, the homeowner would have to choose between redesigning the ventilation system to accommodate a propane furnace or switch to a non-propane energy source.”

Difficulties posed by space constraints, installation costs and physical changes to room layouts associated with condensing-type products would have significant enough impacts on consumers to merit a different approach, DOE found. In addition, DOE says the proposed interpretation would allow it to maintain neutrality toward competing fuel types and ensure that it will not impede energy affordability by mandating high-cost condensing products and installations.

Also in the notice of proposed rulemaking, DOE denied another request by the gas industry to withdraw the agency’s proposals for residential furnaces and commercial water heaters. DOE is accepting comments, data and information in response to the notice until Sept. 9.

“Now the real work begins,” Reboli says. “Now we must engage DOE on furnace efficiency standards that take into account the energy consumption and emissions from source to site, utilizing the full-fuel-cycle analysis to account for national energy expenditures and savings in any proposed efficiency standard.”