CFA strongly supports DOE’s proposed standard for non-weatherized gas furnaces at the technical standard level (TSL) 8, that is, at 95% AFUE for all such furnaces. For those households where the heat is provided by a non-weatherized gas furnace, the cost of the gas often represents the household’s largest energy bill.

The reductions in expenditures for fuel use are larger than the costs of the fuel-saving technologies – about twice as large.

• The payback period is less than half the life of the appliance.
• Many more consumers enjoy net benefits than bear net costs.
• The individuals who benefit have much larger gains than the losses of the individuals who do not.
• All of the conclusions about consumer benefits in the aggregate apply to low-income consumers as well.
• As large as the consumer pocketbook benefits are, we believe that the DOE has underestimated the net pocketbook benefits by overestimating the costs and underestimating the benefits.
• The consumer pocketbook savings are augmented by other indirect and external benefits. (e.g. environmental, public health, and macroeconomic)