Voglio sapere a riguardo di…

khammond on DSKJM1Z7X2PROD with RULES

Federal Register / Vol. 86, No. 247 / Wednesday, December 29, 2021 / Rules and Regulations ASAP et al. stated that non-condensing and condensing furnaces have different venting configurations, but that these different configurations are a matter of cost and not utility, and there are a variety of solutions to challenging venting requirements. ASAP et al., No.
143 at p. 2 A.O. Smith stated that it is technologically feasible to replace noncondensing equipment in every commercial setting. A.O. Smith, No.
133 at p. 9
In contrast, AGA et al. asserted that the record for the January 2021 Final Interpretive Rule shows that for millions of applications, appliances with condensing technology would not work or would present hazardous conditions if the appliances were installed within existing home and business venting and plumbing systems, absent modification.
AGA et al., No. 135 at p. 28 In support of its assertion, AGA et al. pointed to DOEs estimates that upwards of 10
percent of households with gas-fired furnaces would face difficult installation situations if non-condensing furnaces were eliminated, as well as a survey from installation contractors that AGA et al. stated showed that atmospheric venting systems often prevent use of condensing furnaces. Id.
at pp. 29, 31 AGA et al. argued that, although DOE claims the existence of technological solutions to difficult installation situations, no evidence is cited for that proposition. Id. at p. 31
AGA et al. further commented that the National Fuel Gas Code ANSI Z223.1/
NFPA 54 and the International Fuel Gas Code, which are installation codes for gas appliances that are adopted and enforced in the majority of States and jurisdictions within the United States, do not permit venting a condensing type of vented gas appliances positive venting pressure with a noncondensing type of vented appliance negative venting pressure because of safety concerns. Id. at p. 32 AGA et al.
stated that, therefore, even if technological issues were overcome, replacement of non-condensing appliances with condensing appliances would still violate the aforementioned installation codes to the extent that the condensing appliance is vented in the same vent line with a negative venting pressure non-condensing appliance.
Id.
AHRI commented that consumers, especially in older homes, will struggle to replace their appliances if condensing-only appliance standards are set in efficiency rulemakings. AHRI, No. 139 at p. 1 Kramer commented that non-condensing furnaces are sometimes installed in unheated spaces such as an attic or garage, and that such locations
VerDate Sep<11>2014

16:59 Dec 28, 2021

Jkt 256001

cannot accommodate a condensing furnace because the condensation will freeze and cause damage to the heating unit. Kramer, No. 124 at p.1 Kramer further commented that relocation of such units to the heated part of the home is cost-prohibitive due to reworking of the ductwork and would result in loss of living space inside the home. Id.
Crown Boiler, New Yorker Boiler, and U.S. Boiler stated that the research conducted by Oak Ridge National Laboratory ORNL referenced by DOE
in the August 2021 NOPIR demonstrates that condensing furnace standards would result in a significant problem.
Crown Boiler, No. 127 at p. 3; New Yorker Boiler, No. 130 at pp. 34; U.S.
Boiler, No. 129 at pp. 34 These commenters asserted that the EntrainVent technology discussed in the ORNL research cited by DOE is problematic because: 1 If the common portion of the vent becomes blocked, the condensing appliance will force flue products backwards down the category I vent and into the living space through the draft diverter and that detecting this spillage will be a significant technical challenge; and 2 this system will only work when the furnace inducer is running, meaning that water heater cannot safely operate when the furnace inducer is off. Crown Boiler No. 127 at p. 4; New Yorker Boiler, No. 130 at pp.
45; and U.S. Boiler, No. 129 at pp. 4
5 Crown Boiler, New Yorker Boiler, and U.S. Boiler further commented that the use of other venting systems described in the ONRL report i.e., the DuraVent FasNSeal 80/90 and draft inducer paired with a chimney liner is not practical in situations where there are offsets in the chimney, or where the cross-sectional area of the chimney is too small to provide adequate drafting for the water heater after the new liners are added.
Crown Boiler No. 127 at p. 5; New Yorker Boiler, No. 130 at p. 5; U.S.
Boiler, No. 129 at p. 5 These commenters stated that any concentric vent system consisting of a pressurized vent system inside a Category I vent system raises safety concerns because the inner pipe will be difficult or impossible to inspect and a breach in the pipe will lead to flue gas inside the building and that this problem would be particularly acute for a pipe modified with a draft inducer that was not designed to be pressurized. Id.
Bradford White commented that a non-condensing commercial gas-fired water heater installed in a high-rise building in a large, older city e.g., New York City, Boston, Chicago would not be able to be replaced with a condensing equivalent, as it would not be able to
PO 00000

Frm 00015

Fmt 4700

Sfmt 4700

73961

vent horizontally due to jurisdictions prohibiting side wall venting in these applications. Bradford White, No. 146
at p. 3 Bradford White further commented that if the mechanical room is in the basement or ground level floor of a 15-story building and shorter in some cases, the water heater may not be certified with a long enough vent length to be able to vent vertically through the buildings roof, and that if the venting had to run up through current living spaces, there would be impacts to the building space. Id.
AGA et al. and APGA et al. stated that, in the current market, the known solutions often require making major reconfigurations to building venting and plumbing systems. AGA et al., No. 135
at p. 18; APGA et al., No. 140 at p. 9
APGA et al. stated that most of the existing buildings in which gas furnaces and water heaters are installed were architecturally designed to accommodate standard atmosphericallyvented products and have built-in atmospheric venting systems to serve such products, often with vents sized to serve two or more commonly-vented products. APGA et al., No. 140 at p. 8
APGA et al. commented that there are instances when it is possible to use existing venting when switching from non-condensing to condensing technologies or to scrap the existing venting and run new venting through the same chase, but there are many common scenarios in which this would not be possible Id. at p. 7 APGA et al.
further commented that if atmospherically-vented products were unavailable, replacement of an existing atmospherically-vented product would require building modifications to facilitate the installation of condensing products in buildings that were not designed to accommodate them and potentially a relocation of the heating system, which would result in orphaned venting infrastructure. Id. at pp. 7, 8
Bradford White commented that DOE
should not base its analysis on a technology that is not currently commercially available i.e., venting technologies that could make it easier to switch from noncondensing to condensing appliances. Bradford White, No. 146 at p. 2
AHRI stated that there is no justification or evidence provided by DOE for its statements regarding the existence of technological solutions for gas-fired installation issues, orphaned water heaters, or other issues raised by the gas industry petition that would support the Departments proposed policy change. AHRI, No. 139 at p. 2
The commenter argued that requiring new venting for condensing
E:FRFM29DER1.SGM

29DER1