On May 27, the  Federal Trade Commission’s  Federal Register Notice   proposed changes to the appliance labeling rule that applies to  natural gas  furnaces, water heaters, boilers, pool heaters and clothes dryers. As a reminder, the Rule “requires manufacturers to attach yellow Energy Guide labels to many covered products and prohibits retailers from removing these labels or rendering them illegible. In addition, it directs sellers, including retailers, to post label information on websites and in paper catalogs from which consumers can order products.  The NOPR provided ranges of comparability for the specific covered product that is calculated on its estimated annual operating cost (based on national average energy cost), annual energy consumption or its energy efficiency rating. The NOPR included revised ranges of comparability for each of the covered products as well as samples of Energy Guide labels for each appliance. In the past, the gas industry proposed to modify the metric for the energy efficiency rating for furnaces, water heaters, pool heaters, and boilers to be based on “source” or “full fuel cycle” calculations rather than on “site” usage as the technically correct metric for measuring total energy use and thus provides consumers with a more accurate basis for consumers to make appliance purchasing decisions. On July 11, AGA, the American Public Gas Association, and the National Propane Gas Association submitted a joint letter (attached) 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, this past Wednesday, 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 is 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. We will be reviewing any, potential options to determine what steps can be taken to have the FTC take an approach to address appliance labeling that provides consumers with useful efficiency information.

 

For those interested in shipment trends for residential and commercial gas and electric storage type water heaters, residential gas and oil furnaces, electric heat pumps and air-conditioners, click here for the October 14, 2022 Air-Conditioning Heating, & Refrigeration (AHRI) Press Release that provides the August, 2022 U.S. Heating and Cooling Equipment Shipment Data. For previous monthly shipment releases and historical data, please click here . You may also wish to share this information with other groups or individuals within your organization that would be interested in this shipment data.