NMHC/NAA and the National Leased Housing Association sent a comment letter to the DoE. We are urging them to keep the current 80 AFUE minimum for non-weatherized gas furnaces, with a heating input capacity of 80,000 BTUh or less, for existing properties that will have venting issues.
We are also recommending that they adopt a regional approach to furnace efficiency like the current regional air conditioning standard. This approach properly apportions efficiency requirements and initial product cost with operating expenses. It also provides relief for some, or all, of the more expensive retrofits.