The Hon. Ernest Moniz 

Secretary of Energy 

U.S. Department of Energy 

([ongrciiii of tIrc lftllitcil §tatcii 

lIIu5J,illgtoll, D<E 20515 

June 8, 2015 

1000 Independence Avenue, S.W. 

Washington, D.C. 20585 

Dear Secretary Moniz, 

We are writing to express strong concern over the Department of Energy's (DOE) recent notice of proposed 

rulemaking for residential furnaces. While we support energy efficiency, we are extremely concerned that the 

nationwide 92% standard proposed in this rule will significantly increase costs to natural gas consumers, force them 

to switch to less efficient alternatives, and ultimately undermine the efficiency goals that underlie the Energy Policy 

and Conservation Act. The DOE's own data shows that at the proposed 92% efficiency standard (replacing the 

current 80% standard), over 20% of consumers nationwide and 31 % of consumers in the South seeking to replace an 

existing non-condensing furnace would experience a "net cost" (versus a net benefit) over the life of the furnace. As 

a result, DOE assumes that over 10% of such consumers in the North and 20% of such consumers in the South 

would switch from natural gas to electric heat. The fuel switching numbers are even more staggering in the new 

construction market. 

By setting a nationwide energy efficiency standard that precludes a consumer from choosing to install a noncondensing furnace, DOE will be forcing many homeowners either to abandon the use of natural gas to heat their 

homes or to pay substantially more for the installation of a furnace that meets the new standard. Each of these 

options will cost residents, regardless of in what part of the country they reside, thousands of dollars. This will have 

a major impact on the ability of low and fixed income families to replace an aging furnace with the fuel of their 

choice. Many families will be faced with the difficult choice of having to replace their non-condensing furnace with 

either a condensing furnace with higher installation costs or electric heat and accompanying higher monthly energy 

bills. 

We strongly encourage DOE to avoid such an "either-or" approach to furnace efficiency, by establishing 

separate product classes for condensing and non-condensing furnaces, each with its own efficiency standard. We 

are extremely concerned that requiring the elimination of the economical and efficient non-condensing furnace will 

place an unnecessary burden on already struggling homeowners in our states. 

We thank you in advance for your consideration of our concerns. 

Sincerely, 

Mo Brooks 

Member of Congress 

cc: Kathleen Hogan, Deputy Assistant Secretary for Energy Effic iency 

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