NEFI along with its industry partners submitted formal responses on June 22 to the U.S. EPA’s proposal to exclude furnaces and central air conditioners from the ENERGY STAR program. The collective response generated over 450 letters from members, associates, and concerned citizens, NEFI said. This action alert will be kept open through the July 7 deadline for public input established by the EPA for the proposal to remove boilers from ENERGY STAR.
A coalition of national home energy trade associations united to deliver a joint response to EPA’s proposal (read here), including the National Propane Gas Association (NPGA), American Gas Association (AGA), American Public Gas Association (APGA), National Energy & Fuels Institute (NEFI), Energy Marketers of America (EMA), Oilheat Manufacturers Association (OMA), and the Plumbing-Heating-Cooling Contractors (PHCC) National Association.
NEFI also submitted a separate response on behalf of the nation’s heating fuel dealers. It emphasizes the strides the liquid fuels industry has made to enhance efficiency and reduce carbon emissions through technological advancements and the adoption of low-carbon renewable liquid heating fuels (full letter available here).
The ENERGY STAR program, established in 1992, was designed to lower emissions and home energy costs by helping consumers identify the most energy-efficient appliances. Historically, the program has endeavored to be unbiased and technology-neutral, making it a critical and trusted tool for consumers when shopping for home appliances and electronics. Furthermore, many public and private entities utilize ENERGY STAR when establishing minimum requirements for energy efficiency tax credits, rebates, and financing programs. Given these factors, the EPA’s proposal to exclude liquid- and gas-fired systems is quite alarming, NEFI and the other groups said.
Key points from the letter:
- Excluding furnaces and boilers from ENERGY STAR restricts consumer choice and will increase costs, particularly for lower-income families.
- The proposal lacks sufficient justification and transparency, raising questions about the overall process and the reasoning behind the emphasis on electric heat pumps.
- NEFI insists that a Full Fuel Cycle (FFC) analysis, which includes both source and site emissions, is necessary to accurately assess the environmental impact of electric appliances.
- The exclusive promotion of heat pumps and other electric appliances is not the most effective path to achieving the program’s objectives. ENERGY STAR should remain focused on reducing energy consumption and greenhouse gas emissions while also lowering household costs.
- The Oilheat industry’s transition to low-carbon fuels provides an alternative pathway to decarbonization. This initiative is supported by several states with large Oilheat markets implementing renewable fuel blending requirements and incentives.
- Introduction of furnaces and boilers compatible with 100% biofuel blends represents a significant step towards residential decarbonization and aligns with both industry commitments and governmental policy goals for emissions reduction.
- Hybrid systems, which combine heat pumps with a furnace or boiler backup system, are essential for cold climates. The discontinuation of ENERGY STAR certification for such appliances could inadvertently encourage the adoption of less efficient hybrid systems.
- Maintaining ENERGY STAR labeling for high-efficiency furnaces and boilers designed for use with renewable fuels assists consumers in making energy-efficient and climate-conscious decisions.
The next step by NEFI and the other groups will be to prepare comments for the EPA’s proposal to eliminate the boiler specification and replace it with a new ENERGY STAR specification for air-to-water (hydronic) heat pumps. The deadline for public comments on this proposal is July 7, 2023. NEFI and its coalition partners are also developing a comprehensive legislative strategy in response to the proposals.For more information or if you have questions, reach out to NEFI Vice President Jim Collura at (202) 441-8857 or firstname.lastname@example.org.