On Monday, AGA and APGA filed timely, joint comments  (attached)  on the August 23rd DOE proposed rulemaking on energy conservation standards for consumer clothes dryers. As reported in the August 26th End Use Codes and Standards Update, the DOE proposal has split the gas clothes dryers into two product classes based on the volume of the drum size of the clothes dryer.  They are:  Vented Gas, Standard (4.4 ft3 or greater capacity) 3.48 Combined energy factor (lbs/kWh)  and small Vented Gas, Compact (less than 4.4 ft3 capacity)  2.02 Combined energy factor (lbs/kWh). The joint comments stress the importance of the DOE to implement the recommendations from the recent National Academies of Sciences, Engineering, and Medicine (“NASEM report”) into this rulemaking for clothes dryer as well as all its appliance rulemakings, whether for test procedures or energy conservation standards.  The NASEM report comprehensively evaluated the agency’s appliance rulemaking process and identified several key areas in which DOE can improve its rulemaking process.  Several of these recommendations even align with suggestions Commenters have made over the years regarding economic modeling and data availability that would greatly help all stakeholders better understand the agency’s process and ensure that DOE is making its decisions on the most appropriate data and models. In addition, the joint comments support the comments of the Association of Home Appliance Manufacturers (AHAM) to finalize the efficiency test methodology for clothes dryers and to assess the disproportionate effect more stringent standards could have on low-income consumer, as well as DOE’s responsibility to not develop a standard that would negatively impact the appliance’s performance or have unintentional consequences that would undercut anticipated energy savings. We will provide the DOE response when available.

 

AGA Review of “Composition, Emissions, and Air Quality Impacts of Hazardous Air Pollutants in Unburned Natural Gas from Residential Stoves in California”  

The October 2022 Environmental Science & Technology journal published “Composition, Emissions, and Air Quality Impacts of Hazardous Air Pollutants in Unburned Natural Gas from Residential Stoves in California.” The AGA Review and Comments present several points, observations, and issues that are in need for further scrutiny on the report. The authors appear to have used an extreme, beyond “worst case” scenario to model potential exceedances of benzene in atypical circumstances. It appears that if these scenarios did occur, the odorants in the natural gas would alert the building occupants before the elevated benzene levels were encountered (based on the authors’ own numbers in a prior study). AGA believes that further investigation of the underlying methods, assumptions, and results is required to develop a full and fair exposition of the pertinent facts.

 

On Tuesday, the Federal Trade Commission (FTC) issued a Federal Register Notice ANPR seeking public comment on potential amendments to the Energy Labeling Rule (Rule), on energy labels for several new consumer product categories including natural gas appliances, and other possible amendments to “improve the Rule’s effectiveness and reduce unnecessary burdens”. The FTC is seeking comments on or before December 27, 2022.  Back on October 14, we reported that the FTC had ignored comments (attached July 11, 2022, comments) from AGA, the American Public Gas Association, and the National Propane Gas Association reiterating a request that the FTC initiate the process of revising the appliance labeling program to recognize “source” energy metrics to reflect the more technically accurate energy descriptors for providing appliance efficiency information be incorporated in the FTC appliance labeling program.  Unfortunately, the FTC issued a final rule that did not consider the request stating in Footnote 4 “These issues fall outside the scope of the current proceeding, but the Commission may address them in a future review of the Rule.” This was disappointing since the intent of the appliance labeling program is to provide consumers with useful information to assist in making purchasing decisions and in many instances, this is not the case.  A clear demonstration of this issue is illustrated on the efficiency rating for furnaces that shows that on the Energy Guide for all electric furnaces, the efficiency ratings (AFUE’s) is shown as 100% (page 61475). However,  the estimated annual operating cost,  when compared with similar natural gas furnaces will show they cost consumers 2 ½ to 3 times more annually than a natural gas furnace. This is counter to the purpose of the FTC appliance labeling appliance program since it is not only not assisting consumers in making purchasing decisions, but it can also be viewed as misleading consumers. This FTC ANPR provides an opportunity to propose a change to the Commissions appliance rule to recognize “source” energy as the technically correct metric that would be most useful for consumers to use in making purchasing decisions. We will be providing a draft of a proposed response to FTC ANPR on the most appropriate labeling information as well as comments on possible labeling of gas products currently not required to have labels, i.e., consumer cooking appliances, etc., in the coming weeks.

 

The Department of Housing and Urban Development (HUD or the Department) is seeking nominations of individuals for appointment to the Manufactured Housing Consensus Committee (MHCC), a federal advisory committee established by the National Manufactured Housing Construction and Safety Standards Act of 1974.  HUD will make appointments from nominations submitted in response to this notice. Individuals that applied previously must re-apply; prior applications on file will not be considered for appointments. Current MHCC members whose first term ends on December 31, 2022, are eligible for reappointment but will need to submit their nomination application to be considered. DATES: The Department will accept nominations until December 27, 2022.

 

 

A petition has been filed by a coalition of groups to the Department of Housing and Urban Development. Among other things, the petition calls for a phase out of fossil fuel-based appliances, including those that run on natural gas, in all public housing units. The petitioners are arguing that this step would reduce the risk of fire, improve indoor air quality, and reduce energy costs and is requesting HUD to initiate a rulemaking on this request. We will report on HUD’s response to the petition when available.