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 regardi ng furnace replacements intended to begin on 5/1/13 or 5/1/15.

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

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

However converting these furnaces to 90Afue or greater, will require a pvc venting syst em that may be difficult or impossible to achieve in all locatio ns. 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 th e outside of the buildi ngs. 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 a nd hot water heater also share the chimney with the surrounding units, making running the exhaust lines impo ssible. 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 pr oblem, 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 installe d high efficiency furnaces in attics in the past, with a slew of freeze up problems, since these condensating furnaces make wa ter. In a mild winter, such as this one, the problems are minimal, however when we get cold st retches that stay around 0 degrees for over a week,problems occur with freeze ups. Heavy snow also re stricts 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 ceili ng causing damage to the ceiling and interior of the home. We can wrap the condensate line and inta ke 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 lik e the concept, but I am not sure this can be done in a lot of instances.

When I challenged the Montreal Pr otocol, regarding utilizing dry condens ers, 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 la ws 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 th at 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 consider ation in this matter.

Truly yours,

Robert Gnatowski

President

Cc: Justin Yetmar, AHS

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