Comments call for real-world cost and performance data, fuel-neutral analysis, consumer choice, grid reliability, and stronger recognition of federal preemption.

The National Energy & Fuels Institute (NEFI) has filed comments with the U.S. Department of Energy (DOE) calling for major improvements in how the federal government analyzes efficiency standards for furnaces, boilers, water heaters, and other consumer appliances.

Under the Energy Policy and Conservation Act (EPCA), DOE may establish minimum efficiency standards only when they are technologically feasible and economically justified. Those decisions depend heavily on assumptions about equipment and installation costs, energy savings, product life, and consumer behavior. DOE opened the current review after the National Academies of Sciences, Engineering, and Medicine identified weaknesses in portions of its analytical methods.

For fuel dealers, HVAC contractors, equipment manufacturers and distributors, and their customers, those assumptions have real consequences. NEFI argued that federal analyses must better reflect how heating equipment actually performs, how it is purchased and installed, and what consumers actually pay.

Specifically, NEFI urged DOE to:

• Account for the full cost of fuel switching. If a federal standard causes a homeowner to switch fuels or technologies, DOE should count electrical upgrades, venting, piping, distribution-system changes, backup heat, operating costs, and other conversion expenses—not simply treat the change as a shift in product sales.
   
• Use regional and real-world data. Heating loads, energy prices, installation costs, and product lifetimes vary dramatically by region. Consider that roughly one-in-four Northeast homes use heating oil or propane, with a much higher share in some states. In Maine, where roughly 70% of homes heat with oil or propane, a household should not be analyzed using assumptions that average it together with households in much warmer states with fundamentally different heating needs and energy markets. DOE’s 30-year analyses should also account for the replacement cost of equipment that does not last the full study period.
   
• Recognize emergency replacement decisions and hybrid systems. A homeowner whose boiler fails in January often must choose equipment that is immediately available, compatible with the existing system and infrastructure, and affordable. NEFI also urged DOE to treat hybrid systems combining heat pumps with boilers or furnaces as a distinct option rather than an either-or choice between electric and combustion heating.
   
• Measure field performance and recognize what AFUE misses. NEFI specifically highlighted boilers and hydronic systems, where AFUE measures space heating only and can miss the effects of oversizing, idle losses, thermal-purge controls, and combined space-heating and domestic-hot-water operation. NEFI cited NORA field research showing about 25% average energy savings when older equipment was replaced with low-mass thermal-purge boilers, savings that are substantially greater than the change in AFUE alone would predict. DOE should evaluate in-service performance, not ratings alone, across all technologies.
   
• Compare fuels on equal terms and account for grid impacts. When DOE compares technologies using different fuels—or expects a standard to cause fuel switching—NEFI urged it to consider the full economics of that change. Cross-fuel comparisons should account for the full fuel cycle, including electricity generation, transmission, and distribution losses. If a standard shifts heating load onto the grid, DOE should also account for added generation and capacity needs, particularly during peak winter demand.
   
• Protect national market uniformity and consumer choice. NEFI asked DOE to recognize the economic costs of fragmented state and local requirements that can restrict the practical availability of heating equipment and narrow consumers’ fuel and technology options. These policies can impose added manufacturing, distribution, inventory, training, and service costs.
   

NEFI also urged DOE to obtain verified installation, service, and repair cost data directly from contractors and their industry trade associations and research organizations, which have firsthand knowledge of what appliances and equipment actually cost consumers to install, maintain, and repair.

NEFI will continue engaging with DOE as it considers revisions to its analytical framework and will work to ensure that the experience of heating fuel dealers, contractors, and equipment manufacturers is reflected in future federal standards.

Get up to speed on the broader fight for energy choice next week at SNEEC! NEFI and its association partners will provide a comprehensive update at the Southern New England Energy Conference in Newport, Rhode Island, September 14–15. Hear where key federal and state policy battles stand, what comes next, and how the industry is responding. Registration and sponsorship opportunities are still available. Register and learn more by clicking here.