Gas stoves and fireplaces appliances need better regulation and transparent efficiencies

Public comment from the Alliance for Green Heat 

April 8, 2022

RE: Docket Number EERE-2021-BT-DET-0034: Notice of Proposed Determination of Miscellaneous Gas Products as a Covered Consumer Product

Thank you for the opportunity to comment on miscellaneous gas products as a covered consumer product. 87 Fed. Reg. 6786 (February 7, 2022).

In the United States, efficiencies of gas stoves are often unavailable, and it can be very confusing. The only reliable database is maintained by the Canadian government and consumers often do not know to check it, even if they want a more efficient appliance. Consumers who are trying to save on heating bills often use their gas stove or fireplace to heat the core of the house instead of using the gas furnace to heat entire house. Gas furnaces can waste up to 30% of their heat from leaking ducts. According to the DOE, “Ducts that leak heated air into unheated spaces can add hundreds of dollars a year to your heating ... bills."

We found that very few websites provide accurate information about gas appliances for consumers, in part because there are many gray areas due to lack of regulation. The CEO of one US manufacturer of gas stoves that we spoke to did not know if was required to test for efficiency or even if his products had been tested even though they were designed and marketed as heaters. We also called many retailers and received a wide mix of contradictory information. One told us we had to ask the manufacturer about efficiency. One had no idea how to determine efficiency. And one provided an efficiency from the “nameplate” but when we checked that number with the Canadian database, it was different. We concluded that consumers should beware of efficiency claims on manufacturer websites or from retailers and to always check the Canadian database if they wanted to know the efficiency of a product.

As a result of this, we strongly support the DOE finding that decorative hearths and outdoor heaters qualify as covered products under EPCA. Gas fireplaces and stoves are often used daily to provide heat for homes, as both a primary and secondary heat source. Consumers stand to save significant amounts of money and gas if these heaters are regulated and have to meet minimum efficiency standards. Many retailers advertise that gas inserts can easily serve as the primary source of heat for your home and claim that they use “50% to 90% less gas than gas logs and up to 75% less gas than a gas furnace.”3

Advertisements often
tout the heating benefits
of gas over wood in a
variety of ways.

We also support DOE’s determination to include propane products in the scope of this proposed coverage determination for miscellaneous gas products. Stoves and fireplaces that use propane are nearly identical to those that use natural gas and are very popular in areas that are not served by gas pipelines. The same companies that make gas appliances also make propane ones and it makes little sense to regulate one and not another and would create a confusing and artificial distinction for manufacturers, retailers and consumers. Propane is typically even more expensive than natural gas, so consumers stand to save far more if they have transparent and minimum efficiency ratings.

We are concerned that DOE may have underestimating the annual shipments of miscellaneous gas products. To the extent the DOE relied on figures from HPBA, they must consider that HPBA shipment data typically only includes appliance shipments by their member companies, not by all companies that make and ship gas appliances. In recent years, some of the largest gas appliance manufacturers have dropped their membership in HPBA, and as a result, shipments from those companies would probably not be included. HPBA does not disclose which companies provided data and which didn’t. Even for member companies, they cannot require disclosure of shipment data, but it appears member companies usually participate.

Thank you. Sincerely,

John Ackerly
President
Alliance for Green Heat