RE: Docket Number EERE–2021–BT–STD–0031/RIN 1904–AF19: Notice of Proposed Determination for Energy Conservation Standards for Oil, Electric, and Weatherized Gas Consumer Furnaces

Department of Energy Office of Energy Efficiency and Renewable Energy Building Technologies Office, EE-5B 1000 Independence Avenue SW Washington, DC 20585 RE: Docket Number EERE–2021–BT–STD–0031/RIN 1904–AF19: Notice of Proposed Determination for Energy Conservation Standards for Oil, Electric, and Weatherized Gas Consumer Furnaces Dear Ms. [...] Hegarty: This letter constitutes the comments of the Appliance Standards Awareness Project (ASAP), American Council for an Energy-Efficient Economy (ACEEE), Natural Resources Defense Council (NRDC), New York State Energy Research and Development Authority (NYSERDA), and Northwest Energy Efficiency Alliance (NEEA) on the notice of proposed determination (NOPD) for energy conservation standards for. [...] DOE stated that it was unable to conclude that amended standards would be economically justified due to the potential manufacturer challenges that may impact the market for these products; however, DOE did not complete a manufacturer impact analysis (MIA) for this NOPD.1 Nonetheless, DOE’s analysis shows that strengthening standards for these products would result in considerable cost savings for. [...] After accounting for the additional costs associated with switching to condensing technology, DOE found that the max-tech level for this product class would provide average life-cycle cost (LCC) savings of more than $1,000. [...] Senior Technical Advocacy Associate Director of Codes and Building Standards Appliance Standards Awareness Project American Council for an Energy-Efficient Economy Joe Vukovich Chris Corcoran Energy Efficiency Advocate Team Lead – Codes, Products, & Standards Natural Resources Defense Council New York State Energy Research and Development Authority (NYSERDA) Nicole Dunbar, P.