Consumer Federation of America and associated organizations support a minimum efficiency standard for furnaces set at an Annual Fuel Utilization Efficiency (AFUE) of at least 92% and believe that it is clearly in the consumer and national interest. Joint Commenters further propose that DOE set the standard at 95% AFUE, since DOE’s own analysis shows that this yields greater net benefits for consumers, but we propose exempting units of 50,000 BTU capacity or less to address concerns about burdens to low income households, small or well-insulated units where installation of 95% AFUE units may not be cost-justified, as well as some single family attached units.