CFA joined by National Consumers Law Center,  Massachusetts Union Of Public Housing Tenants and Texas Ratepayers’ Organization to Save Energy, submitted  comments in response to the Department of Energy’s request for further input on its rulemaking relating to  efficiency standards for furnaces. The case for a 2 tiered standard that would exempt smaller furnaces from increased standards but set a higher standard for furnaces above 55,000 Btus/hr.  was further amplified. This approach would offset the negative impact in a  relatively small number of cases that has caused concern about the proposed rule while providing long overdue energy savings to a substantial percentage of consumers. (Furnace efficiency standards have basically not changed for over 20 years.)