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 

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## tJBilt: 20515-3010 COMMITTEE ON SMALL BUSINESS

SUBCOMMITTEE ON ECONOMIC GROWTH, TAX AND CAPITAL ACCESS

The Honorable Dr. Ernest Moniz Secretary ofEnergy U.S. Department ofEnergy 1000 Independence Avenue, SW Washington, DC 20585 Dear Secretary Moniz: June 2, 2015 

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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 ofProposed Rulemaking (NOPR). I am concerned that the rule would adversely impact low-income renters and'hofueoWriers. As 

### amember 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**..

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### ~\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.

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. ' '' ' , ' , , ' 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 ofa 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() inst

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.. butrmore ewepsiye to.operate, resulting in heating bills that are double the cost of ,(heir 11on-condensing natural gas furnape;

.. · . · . · . . .

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..._ . . · .' , · · , , : · • , . . , . . . - 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

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,-,·. p,'\ PRINTED ON RECYCLED PAPERThe Honorable Dr. Ernest Moniz Secretary ofEnergy U.S. Department ofEnergy 1000 Independence Avenue, SW Washington, DC 20585

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



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