2/23/12 

US Dept of Energy 

Office of Energy Efficiency and renewable Energy 

Washington, D.C. 

Attn: Mr Mohamed Khan, Furnace Applications 

Re: 76FR 37408 

Dear Mohamed, 

Thank you for the time you spent discussing the above new pending regulations regarding furnace replacements 

intended to begin on 5/1/13 or 5/1/15. 

As per our discussion, this will enhance the heating business, by requiring 90% or 95% furnaces to replace the 

old 80% afue furnaces in the northern tier states, which New Jersey would be. 

However converting these furnaces to 90Afue or greater, will require a pvc venting system that may be difficult 

or impossible to achieve in all locations. The following are my concerns: 

1. Condominiums----In many cases, the condo associations, have refused to allow contractors to run the 

PVC exhaust and intake pipes on the outside of the buildings. Because of the local codes regarding 

placement of the exhaust ( minimum of 2 ft from a window, door or decking), the pipes are considered 

unsightly, when run along the outside wall to meet these code rulings. 

2. Apartment Units (Co-op Housing) In most co-op housing, the furnaces are located in a laundry room, 

which also houses a hot water heater. The furnace and hot water heater also share the chimney with the 

surrounding units, making running the exhaust lines impossible. We tried a couple of times without 

success and had to refund the customer the money back. 

3. Finished basements in homes also create a venting problem, especially when the furnace is located in the 

center of the basement. In some cases, you can run the PVC up the old chimney. Should there be a hot 

water heater located in the same area, sharing the chimney will cause a problem resulting in a “cold 

chimney effect” where the exhaust gases from the hot water heater will not rise and fall back into home 

causing the dangerous health risk. Currently we place a flue liner in the chimneys for hot water heaters, 

when we install a 95% furnace in an open basement with the furnace flue pipe exhausting out through 

the basement. Unfortunately, trying to fit an old chimney with a 3” PVC, and a 4” chimney liner is 

almost impossible, so we have not installed high efficiency 90 Afue furnaces in these applications. 

4. Attic Applications: We have installed high efficiency furnaces in attics in the past, with a slew of freeze 

up problems, since these condensating furnaces make water. In a mild winter, such as this one, the 

problems are minimal, however when we get cold stretches that stay around 0 degrees for over a week, 
problems occur with freeze ups. Heavy snow also restricts the flow of the condensate causing a back up 

into the furnaces, and into the emergency overflow pans. Since these pans are currently made of plastic, 

they tend to crack and sending water through the ceiling causing damage to the ceiling and interior of 

the home. We can wrap the condensate line and intake and exhaust lines, but we cannot protect the 

pans. In areas like Buffalo, New England and Maine these conditions will be even worse. 

As I stated earlier, I like the concept, but I am not sure this can be done in a lot of instances. 

 When I challenged the Montreal Protocol, regarding utilizing dry condensers, your offices stated that this 

law would only apply to new construction, since the cost on the public would have been extreme, especially 

in these tough times. Perhaps these laws should fall under the same category. 

The Government initialtive in 2010 giving a $1500 rebate, saw a jump in conversions, where most furnaces 

we installed were high efficiency. A continuation of that policy in the northern zones, will probably result 

in many more furnaces being upgraded to 95 Afue, where construction will allow. 

Thank you for your consideration in this matter. 

Truly yours, 

Robert Gnatowski 

President 

Cc: Justin Yetmar, AHS 

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