DONALD M. PAYNE, JR. 

10TH DISTRICT, NEW JERSEY 

COMMITTEE ON HOMELAND SECURITY 

SUBCOMMITTEE ON EMEflGENCY PREPAREDNESS, 

RrnPONSE AND COMMUNICATIONS 

RANKING MEMBER 

SUBCOMMITTEE ON OVERSIGHT 

AND MANAGEMENT EFFICIENCY 

l!CongreS'% of tbe 1lntteb ~tates 

~ouse of ~prel.lentatibeZi 

\!m'asbfngton, tJBilt: 20515-3010 

COMMITTEE ON SMALL BUSINESS 

SUBCOMMITTEE ON ECONOMIC GROWTH, 

TAX AND CAPITAL ACCESS 

The Honorable Dr. Ernest Moniz 

Secretary of Energy 

U.S. Department of Energy 

1000 Independence Avenue, SW 

Washington, DC 20585 

Dear Secretary Moniz: 

June 2, 2015 

£k£C- :<.DJS- 003693 WASHINGTON OFFICE 

103 CANNON HOUSE OFFICE BUILDING 

WASHINGTON, DC 20515-3010 

(202) 225-3436 

DISTRICT OFFICES 

LEROY SMITH PUBLIC SAFETY BUILDING 

60 NELSON PLACE 

14TK FLOOR 

NEWARK, NJ 07102 

(973) 645-3213 

253 MARTIN LUTHER KING DRIVE 

JERSEY CITY, NJ 07305 

(201) 369-0392 

I write this letter to urge you to consider postponing the rulemaking regulating non-weatherized natural gas 

furnaces, as set forth in the Federal Register notice of Proposed Rulemaking (NOPR). I am concerned that the 

rule would adversely impact low-income renters and'hofueoWriers. As a member of Congress, I fully support 

energy efficiency standards that reduce monthly utility costs and carbon emissions, particularly for those in 

vulnerable communities. However, I fear that the proposed rule could harm both factors and result in higher 

energy costs for low-income consumers in the long run. 

As I am sure you are aware, the proposed rulemaking mandates replacement of non-condensing natural gas 

furnaces with newer condensing models .. While. more energy efficient, condensing models requfre significant 

up-front: purchase and iμ~tallation .~osts .. Pi:i ~s~~agy,'. C,()ndensiμg furtj~c~s c?st. ~\i~ut '$357 more' 'than. n?ric 

condensmg models, and often require an add1t10nal $1,500 - $2,200 m installat10h costs· due to retrofitt1hg 

required to accommodate the condensing equipment. These costs can be much higher in older buildings and 

~partm~nts where a~~ess to ~utside ver#ilation is not available. ' . , . ,. ' ' , , ~ .' , . '' . ' . . I . ' ' ' ' , ' , , ' 

The high cost of installation and repii1~el!;leJ;lf will. deter. l~nd,\o,rd,s from ador,tihi condensing nati:iral gas 

furnaces. Landlords will be unable to secure financing' because lending ·111etrics do not.':convert such 

investments into revenue for loan repayment, and landlords are not likely to pay out-of-pocket. Instead, 

landlords will shift from energy efficient non-condensing natural gas furnaces to less efficient non-natural gas 

appliances, which are less expensive to install but more costly to operate. Low-income tenants who pay their 

own utilities will see their heating costs double, and other tenants whose heating costs are paid by the landlord 

will see their rent increased, to cover the landlord's additional heating expenses. 

Low-income homeowners will make similar choices for the same reasons. Many low-income homeowners 

cannot access consumer loans, and do not have the equity or cash savings to afford the significant upfront costs 

of a condensing natural gas furnace. While it is !rue that low-income consumers would save money in the long 

run by switching to a condensing furna9e, many ,low-incomefa111Bies do not nave the financial flexibility to 

~ake decisions based on life-cycle-costs: ;\; ~ re~ult, the'se h~llleowners may adbpfa fumace a~pliatl'ce that is 

less l'l\Pensive t() inst119 .. butrmore ewepsiye to. operate, resulting in heating bills that are double the cost of 

,(heir 11on-condensing natural gas furnape; .. · . · . · . . . . , (_ , . ' ' , . ' , ; ' I ·, ~ - ' ' , ' , , ' ; ! , - /. : ; < ' • • - - • • 

I , ~ .' . , _, : J · · , : , ! ·; ... _ . . · .' , · · , , : · • , . . , . . . -

Again, 1 re~pectfully request that the Departmen(of Em\rgy delay the propiised rulemaking until the results 

described above can be ~voided .. I look forward'fo working with you' to'flnd a solutidrl to this im]'.lortant matter. - ,_. .. ,,. -11· ·I· · ·• ,-. · . • 

Thank yoμ: .. · ,,. · "' · ' · .'·I 

,,·,_ 

' : J' 

,-,·. p,'\ 

PRINTED ON RECYCLED PAPER 
The Honorable Dr. Ernest Moniz 

Secretary of Energy 

U.S. Department of Energy 

1000 Independence Avenue, SW 

Washington, DC 20585 

Ef.'.:;p!.}SP i ~.2C;!:;;as; 

M.C. 

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