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NWGA Comments on ENERGY STAR Program – Version 5.0 Furnace Specification



May 16, 2024


Ann Bailey, Director

ENERGY STAR Labeling Branch

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue NW

Washington, DC 20460


RE: NWGA Comments on ENERGY STAR Program – Version 5.0 Furnace Specification


Director Bailey:

 

The Northwest Gas Association (NWGA) represents the natural gas utilities and transmission pipelines serving warmth and comfort to10 million people across Idaho, Oregon, Washington and the Canadian province of British Columbia.

 

NWGA appreciates the opportunity to comment on the Environmental Protection Agency’s (EPA) first draft of Version 5.0 ENERGY STAR furnace specifications with a target effective date of 2026 (April 2024 Draft). We commend the EPA for considering prior comments regarding sunsetting the ENERGY STAR furnace efficiency specification and responding instead with a proposal to update the specification.

 

Regarding the April 2024 Draft, NWGA requests that EPA: 1) reevaluate the proposed elimination of separate geographic designations; 2) include gas heat pumps in the updated furnace specification, and 3) extend the timeline for implementing changes to the ENERGY STAR program.

 

Retain Regional Distinctions: NWGA encourages EPA not to eliminate but instead to retain furnace efficiency specifications and labels that reflect regional differences. As an organization whose members serve warmth in cold weather regions of the northern tier of North America, one size does not fit all.

 

Include Gas Heat Pumps (GHPs): NWGA urges EPA to include GHPs in the updated furnace specification. GHPs are highly efficient, low emissions, align with the intent of ENERGY STAR, and are already a recognized product by the federal government. Furthermore, GHPs can help to mitigate the energy burden carried by many low- and moderate- income households. Including GHPs in the ENERGY STAR specification will further reduce costs by qualifying them for Inflation Reduction Act incentives.

 

Extend the Implementation Timeline: An effective date of 2026 is simply too aggressive and misaligns with the Inflation Reduction Act. EPA should extend implementation of the updated ENERGY STAR furnace specification to 2028 in order to be consistent with the Inflation Reduction Act and to allow sufficient time for energy efficiency programs and supply chains to effectively adjust.

 

Thank you for the opportunity to comment on the April 2024 Draft of Version 5.0 ENERGY STAR Furnace Specifications. We hope our comments are helpful. Please don’t hesitate to contact us with any questions.

 

Warmly,





DAN S. KIRSCHNER

Executive Director




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