The Consumer Federation of America (CFA) and the National Consumer Law Center (NCLC) (on behalf of our low-income clients) oppose S, 1029 which would, in essence, prohibit the Department of Energy (DOE) from issuing much needed and long overdue improvements in efficiency standards for gas furnaces. Consumers continue to be harmed through energy bills that are higher than they should be because industry has been operating under a minimum standard that essentially was set over 25 years ago. Further delays to improving furnace efficiency standards will extend the economic harm to consumers.