Invitation to Comment: Criteria for Environmental Innovation for Lennox Ultra-Low Emissions, High Efficiency Gas Furnaces
Green Seal’s Environmental Innovation Beta Advisory Program allows product manufacturers to explore environmental and health impacts, engage in transformative product innovation, and achieve global recognition to the newest sustainability standard.
Lennox is a member of the initial cohort of beta program participants who are pursuing certification of their products under the Environmental Innovation Standard (GS-20, Edition 2.0). The company submitted two products for the GS-20 Review: the Variable Speed, Ultra Low Emissions Gas Furnace (SL297NV) and Constant Torque, Ultra Low Emissions Gas Furnace (EL195NE) with the same primary innovation claim: A significantly reduced environmental impact resulting from both leadership levels of energy efficiency and ultra-low NOx emissions.
According to Lennox, the furnaces emit 65% less nitrogen oxides than other products on the market, having a nitrogen oxide emission level of no more than 14 nanograms per joule, while maintaining market leadership levels of energy efficiency.
Green Seal is seeking your feedback on the innovation claims for these products. We invite all members of our stakeholder community and the general public to submit comments by email to email@example.com. Feedback will be accepted through 11:59PM ET on December 6, 2019.
About Lennox Ultra Low Emissions Gas Furnaces
When used as intended, the Lennox Ultra Low Emissions gas furnaces provide forced air heat in single family homes and small commercial buildings.
Innovation Claim Details
Lennox claims that these products differ from others on the market as the line of Ultra Low Emissions Furnaces emits 65% less nitrogen oxides, having a nitrogen oxide emission level of no more than 14 nanograms per joule, while maintaining market leadership levels of energy efficiency. Leadership energy efficiency is defined as meeting the Qualification Requirements for ENERGY STAR v4.0, including:
- AFUE: ≥ 90.0% for U.S. South, ≥ 95.0% for U.S. North/Canada,
- Furnace Fan Efficiency: ≤ 2.0%, and
- Air Leakage: ≤ 2.0%.
Green Seal has not yet validated any of these claims. Once Green Seal finalizes the requirements after this public comment period, Lennox will submit documentation for third-party certification by Green Seal. The Variable Speed, Ultra Low Emissions Gas Furnace (SL297NV) and Constant Torque, Ultra Low Emissions Gas Furnace (EL195NE) will achieve Green Seal Certification for Environmental Innovation if all requirements within the Lennox Ultra Low Emissions Gas Furnace Criteria Document are met.
Environmental and Human Health Impacts
Gas furnaces function by burning natural gas that is provided from a municipal source. Given a 15-30 year life span, the use phase of a furnace is by far the most significant lifecycle phase. Natural gas is a fossil fuel, and its combustion causes greenhouse gas emissions – the main cause of climate change. The catastrophic risks of climate change are well documented in the scientific community.
In addition, according to the Union of Concerned Scientists, “cleaner burning than other fossil fuels, the combustion of natural gas produces negligible amounts of sulfur, mercury, and particulates. Burning natural gas does produce nitrogen oxides (NOx), which are precursors to smog...”
Nitrogen oxide emissions are one of six criteria air pollutants regulated by the EPA and are known to pose both human health risks and cause secondary forms of harmful air pollution. According to the American Lung Association, nitrogen oxides pose direct harm to the lungs, including “increased inflammation of the airways, worsened cough and wheezing, reduced lung function, and increased asthma attacks.” The ALA also warns that nitrogen oxide emissions are a probable cause of asthma in children.
About Green Seal’s Environmental Innovation Standard
Green Seal’s Environmental Innovation Standard (GS-20) provides a framework for the certification of environmental innovations in a variety of product categories. Applicants follow the steps below to complete the process:
Earning certification under the GS-20 Standard demonstrates that Green Seal, an independent third party, has verified the environmentally innovative aspect(s) of a product. The certification includes verification that the product innovation results in a significant reduction of human health and environmental impacts compared to products of the same functional class.
By Brie Welzer, Standards Program Manager