Association of Home Appliance Manufacturers (AHAM) Announces Agreement on Home Appliance Standards with Energy Efficiency Advocates.

On Thursday, AHAM announced an agreement on home appliance minimum efficiency home appliance standards including residential gas cooking products and clothes dryers, with the following groups: American Council for an Energy-Efficient Economy, Alliance for Water Efficiency, Appliance Standards Awareness Project, Consumer Federation of America, Consumer Reports, Earthjustice, National Consumer Law Center, Natural Resources Defense Council, and Northwest Energy Efficiency Alliance.

According to the announcement, the agreement represents a “consensus plan to improve energy and water efficiency for refrigerators and freezers, beverage and wine chillers, clothes washers, clothes dryers, dishwashers, and cooking products. The jointly recommended standards, if adopted by the Department of Energy (DOE), are projected to save more than 9 quadrillion Btu of energy—reducing costs for families and cutting greenhouse gas emissions while allowing home appliance manufacturers to continue to deliver highly efficient products with the features that consumers want and expect.“  If DOE adopts the recommendations in the agreement, six categories of appliances will see updated minimum energy efficiency standards, along with updated water efficiency standards for certain products. A summary of the proposed changes in efficiency compared to current standards is below: 

• The recommended standards would reduce new refrigerator and freezer energy use by approximately 10-15%, effective in January 2029 or January 2030, depending on product type.

•  For beverage and wine chillers, the recommended standards, taking effect in 2029, would reduce energy use by 30% for the major product categories.

•  For clothes washers, approximately 11% energy savings and 28% water savings for top-load models and 9% energy savings and 17% water savings for front-load models would kick in beginning in 2028.

• Clothes dryers meeting the recommended standards would use up to 40% less energy starting in 2028.

• The recommended standards for dishwashers would reduce energy use by 15% and water use by 34% relative to the current standards, likely beginning in late 2027.

• New efficiency standards for electric and gas cooking products, which would preserve the features and functionality that consumers expect from their cooking products and have access to today, would take effect in 2028.

A more detailed description of the efficiency levels that the parties have agreed to recommend to DOE is included in a term sheet.

AGA is encouraged that an effort has been made between some stakeholders to agree on new requirements for these appliances. The announcement is a positive signal, and the agreement, paired with significant bipartisan legislative support for gas stoves, sends a clear message to DOE that gas stoves are popular and the initial proposal on gas cook tops went too far.

Keep in mind that this agreement should not be considered an official negotiated DOE rulemaking since the requirements for that process are clearly defined. AGA will strongly recommend that these proposals follow the required DOE-negotiated rulemaking process for transparency and public comment.

Preliminary AGA observations related to gas cooking products and gas clothes dryers are as follows:

• On breakout regarding how much energy savings is attributed to gas dryers and what improvements are required:  the 40% claim combines both gas and electric, so it’s not possible at this point to determine how much energy savings is determined for gas dryers and what improvements are being made to attain the savings.

• On gas cooking products: More information is also needed since it is not proposing a minimum requirement for electric coil-type cooktops but there is a requirement for gas cooktops (1770) that is close to the baseline (1900).  This may permit that gas cooktops are not restricted on the number and type of burners available,  but AGA remains consistent with our comments on the DOE NODA that the requirement for gas cooktops would provide de minimis savings, if any.

AGA staff and BECS Committee members will thoroughly analyze the proposed standards for gas cooking appliances and gas clothes dryers in the announcement to assess their full implications. We will provide AGA members with additional information and analysis as it becomes available.

AGA, APGA, and NPGA File comments to the Department of Justice (DOJ) on the Consumer Boilers Notice of Proposed Rulemaking (NOPR) by the Department of Energy (DOE).

As a reminder, DOE issued the 8.14.2023 Federal Register Notice  NOPR for minimum efficiency standards for consumer (residential) boilers with comments due no later than October 13, 2023. (The pre-publication NOPR was provided in the July 28, 2023 BECS Update.) In this NOPR, DOE is proposing a 95% AFUE minimum efficiency requirement gas-fired hot water boilers and for gas-fired steam boilers, an 82% AFUE minimum efficiency requirement. DOE is proposing a slight increase for consumer oil boilers and no increase for consumer electric boilers. DOE will accept comments, data, and information regarding this NOPR until October 13, 2023. The Energy Policy and Conservation Act (EPCA) requires the Attorney General to provide to DOE a written determination of whether the proposed standard is likely to lessen competition and the “U.S. Department of Justice Antitrust Division invites input from market participants and other interested persons with views on the likely competitive impact of the proposed standard on or before September 13,  2023.” Attached are timely comments on the likely competitive impact of the proposal filed on September 13 by AGA, the National Propane Gas Association (NPGA), and the American Public Gas Association (APGA) on the potential competitive impact of the of this proposal for consumer boilers, including the market and competition, fuel switching (fuel gas to electric) and small business impacts.

AGA Files a Freedom of Information Act (FOIA) Request of EPA Concerning the ENERGY STAR Program.

In the June 9th Update on End Use Codes and Standards, we reported on the EPA  release of the ENERGY STAR Residential Boilers Discussion Guide and their invitation for feedback as they “evolve the “ENERGY STAR program from its focus on traditional fossil fueled technologies to embrace emerging advances in efficiency”.   The EPA announcement proposes two actions: sunsetting the ENERGY STAR Boilers specification and launching a new specification to cover heat pump hydronic heating appliances, for which EPA and DOE will develop test methods. The discussion guide seeks “additional information that will inform development of a proposed test method and first draft specification.  EPA explains that “These actions reflect the unprecedented opportunity for the ENERGY STAR program to support the national transition to the most energy efficient equipment available. The opportunity arises through passage of the Inflation Reduction Act and availability of new efficient electric technologies on the US market. Our proposal also reflects the longstanding high market share of the boiler’s specification and the lack of additional cost-effective differentiation above current ENERGY STAR levels. The discussion guide covers each of these topics in more detail.“

In May, EPA had issued a similar proposal for the elimination of the ENERGY STAR program for residential fuel fired furnaces.   AGA joined six other organizations, including the National Propane Gas Association, the American Public Gas Association, the National Energy & Fuels Institute, the Energy Marketers of America, the Oilheat Manufacturers Association, and the Plumbing-Heating-Cooling Contractors – National Association on joint comments strongly objecting to the EPA’s proposal to sunset the ENERGY STAR certification for residential fuel fired furnaces and central air conditioners.  

Because of the seriousness of the EPA’s proposal to eliminate ENERGY STAR programs for fossil fuel appliances that also would impact the recognition of these products in federal and state incentive programs, tax credits and energy efficient homes and businesses, AGA has filed a FOIA request (attached) with the EPA. The very detailed FOIA request seeks specific information, data, supporting documentation and resources, etc., that resulted in the drastic action of EPA eliminating natural gas and all other fossil fueled appliances from this very, influential energy efficiency program. We will provide the EPA response when available.