The U.S. Department of Energy (DOE) issues Federal Register Supplemental Notice of Proposed Rulemaking (SNOPR) Pertaining to Energy Conservation Standards for Consumer Cooking Products.

On Wednesday, DOE issued a Federal Register supplemental notice of proposed rulemaking (SNOPR) pertaining to energy conservation standards for consumer conventional cooking products including gas and electric  cooktops and ovens. The Energy Policy and Conservation Act (EPCA), prescribes standards for various consumer products and certain commercial and industrial equipment, including consumer conventional cooking products. EPCA also requires DOE to periodically determine whether more-stringent standards would be technologically feasible and economically justified and would result in significant energy savings. In this SNOPR, DOE proposes new and amended standards for consumer conventional cooking products to receive comment on these proposed standards and associated analyses and results. DOE will accept comments, data, and information regarding this SNOPR until April 3, 2023,  In reviewing the SNOPR for cooking products and focusing only on gas cook tops and ovens, we note that the DOE is making no proposed changes to gas ovens, retaining the current prescriptive requirement that gas ovens cannot have standing pilot lights, Since there is no change to the existing requirement for gas ovens, there is no  comments needed  on this requirement.  However, on gas cooking tops, this is a new approach from the DOE with the establishment of a Maximum Integrated Annual Energy Consumption (IAEC) factor that we are assessing since to our knowledge, has not been an approach implemented by the DOE for gas products. The DOE efficiency test procedure for cooking products establishes an efficiency metric and this is usually used in establishing a minimum efficiency level on an annual energy usage basis. At the DOE webinar held on these products on January 31st, it was reported that some industry testing of gas cooktops indicated that a limited number of 6 cooktops tested were able to meet the IAEC level proposed by DOE.  We are seeking more technical information on the impact that the proposed level has on existing gas cooktops as well as reviewing the DOE Technical Support Document (TSD) to assess what the DOE has determined is justified from a cost and design change to burner and grate designs or other suggested modifications that would be needed to meet the IAEC. DOE is also proposing to eliminate the current standing pilot ban on gas cook tops in lieu of the propose IAEC. BECS Committee members are requested to review the proposal and provide us with comments on the proposal be March 3rd. Comments to DOE can be submitted on the docket number EERE–2014–BT–STD-0005, by email ([email protected]), Federal eRulemaking portal (http://www.regulations.gov

AGA, APGA and NPGA File Comments on the Appliance Labeling Program Advance Notice of Proposed Rulemaking (ANPR) published by the Federal Trade Commission (FTC).

AGA, the American Public Gas Association (APGA), and the National Propane Gas Association (NPGA), filed the attached comments on the Advance Notice of Proposed Rulemaking (ANPR)  appliance labeling program published by the Federal Trade Commission (FTC) on October 25, 2022. The extensive comments proposed specific requests for modifications to the FTC appliance labeling program to improve the labeling information for consumers on the appliance’s efficiency, estimated annual operating cost and energy usage. The comments proposed using the full fuel cycle (FFC)  metrics to provide consumers with accurate information on total energy consumption for the specific appliances. In summary, the comments noted that “ The FTC has authority to adopt a label that accurately presents to the consumer the true cost of household appliance purchasing decisions.  Doing so promotes fuel neutrality and advances the policy priorities of the Biden Administration by helping to tackle climate change.  The FFC test procedures necessary to adopt this new label are straightforward and already available to the FTC. Industry and consumer considerations reflect a desire to be more energy efficient and emissions conscious.”  Finally, we urged “ the FTC to move forward with this approach to inform the consumer of the full spectrum of energy costs, efficiencies, and emissions for appliances in the consumer’s region through implementation of an FFC label.  Accordingly, the FTC should propose and finalize such an amendment to its EnergyGuide regulation following this ANPR.” We will report on the FTC response when available.

AGA, APGA, NPGA Spire, Inc., Responses to the DOE Availability of Preliminary Technical Support Document, Request for Comments for Weatherized Gas Furnaces.

On Monday, AGA, APGA, NPGA and Spire Inc., filed timely, joint  comments on the  DOE November 29, 2022  Federal Register Notice  that announced the availability of the preliminary analysis it has conducted for purposes of evaluating the need for amended energy conservation standards for oil-fired furnaces (NWOFs), mobile home oil-fired furnaces (MHOFs), weatherized gas furnaces (WGFs), weatherized oil-fired furnaces (WOFs), and electric furnaces (EFs). Of particular interest to the gas industry are weatherized gas furnaces (WGFs). We reported on the DOE announcement in the December 2, 2022, BECS Update on End Use Codes and Standards that the DOE analysis is provided in a preliminary technical support document (TSD) for this rulemaking but that the DOE not proposing any efficiency level with this announcement.   The joint comments reiterated our position that it is important the DOE implement the recommendations from the recent National Academies of Sciences, Engineering, and Medicine (“NASEM report”) into all its appliance rulemakings, whether for test procedures or energy conservation standards, including for WGFs.  The NASEM report comprehensively evaluated the agency’s appliance rulemaking process and identified several key areas in which DOE can improve its rulemaking process. We will report on the DOE response when available.