Hegarty: This letter constitutes the comments of the Appliance Standards Awareness Project (ASAP), American Council for an Energy-Efficient Economy (ACEEE), Consumer Federation of America (CFA), and Natural Resources Defense Council (NRDC) on the preliminary technical support document (PTSD) for energy conservation standards for oil, electric, and weatherized gas furnaces. [...] In the past, some manufacturers have commented on the inability to produce condensing NWOFs due to the high quantity of sulfur content in heating oil.1 However, fuel regulations in many northeastern states have helped to substantially reduce the sulfur content in heating oil,2 resulting in condensing NWOFs becoming technologically feasible and commercially available. [...] In the preliminary analysis, DOE evaluated condensing NWOFs with an annual fuel utilization efficiency (AFUE) of 96% as the maximum technologically feasible (“max-tech”) level.3 After accounting for the additional installation costs associated with switching to condensing technology, the Department found that the max-tech level for this product class would provide average life-cycle cost (LCC) sav. [...] In the PTSD, DOE noted that manufacturers have had concerns with condensing WGFs due to the difficulties of burying the condensate line below the frost line, which is necessary to prevent condensate from freezing in colder climates.7 However, DOE identified at least one WGF that uses a condensing heat exchanger and analyzed its product literature, which provided evidence that condensing WGFs can r. [...] In addition, DOE accounted for the costs associated with burying condensate lines below the frost line.9 After considering all installation costs, DOE found that standards set at the max-tech level would result in average LCC savings of $190, and 50% of consumers would experience a net benefit.10,11 We encourage DOE to consider evaluating an intermediate condensing efficiency level (EL) for NWOFs.
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