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

Are we ready for the 100% renewable energy movement?

by John Ackerly, President of the Alliance for Green Heat
reprinted from Biomass Magazine

Many in the biomass heating movement bemoan warm winters, low fossil fuel prices and the slow pace of conversions to biomass heating systems.  But systems are being put in place to adopt renewable heating and that we can be part of, but we are not.

Scores of cities across the US and Canada have already pledged to go 100% renewable.  Even more will be announcing their plans in the next year or two.  Some cities are only focusing on 100% renewable electricity, but many are adopting a two stage approach.  The first stage addresses electricity needs while the second stage addresses heating.

Take Portland, Oregon, Hanover, New Hampshire and East Hampton, New York. Portland is shooting for 100% renewable electricity by 2035 and plans to tackle heating from 2035 to 2050.  Hanover is planning for 100% renewable electricity by 2030 and 100% renewable heating by 2050.  East Hampton, NY is moving even faster: 100% renewable electricity by 2020 and 100% renewable heating by 2030. Much of this heating will be fueled by electricity but chip and pellet systems could also be in demand.

A parallel trend is the Zero Net Energy (ZNE) movement.  To be considered a ZNE building, a house,  There is no one accepted definition of ZNE, so cities, campuses and communities have some leeway in how they define it.  A strict definition says biomass has to be grown and harvested on-site, but other definitions could include biomass harvested from within 30 miles, for example.  After all, the sun isn’t on-site either but the energy from it is produced on-site. 

building or campus, it cannot use more energy than the renewable energy it generates.

The point is that aggressive renewable energy strategies need to address heating and if the biomass community is not at the table, we may be left out of policies and definitions.  The Hearth, Patio & Barbecue Association has been at the table in some instances, but they are mostly fighting with the natural gas industry against gas restrictions in ZNE initiatives. 

The Biomass Thermal Energy Council (BTEC) is a natural leader for this type of advocacy, as they represent industry players that heat buildings and campuses.  This advocacy is not cheap and could easily require a full time person to engage with all the organizations and agencies involved in these movements.  But this would be an investment in the future that would pay dividends over the next 10 – 20 years. 

The renewable electricity movement is taking off because laws require utilities to sell or produce a certain percentage of their electricity from renewable sources.  The mandates typically increase until a target year, such as 20% renewables by 2020, or 25% renewables by 2025.  Legislatures can do this because state-level public service commissions (PSCs) have authority over public and private utilities.  But why don’t we regulate the heating grid the same way as we regulate the electric grid? 

Piped gas is just like electricity in many respects and is regulated in many of the same ways, but are there any gas companies required to ensure that 20% of their BTUs are renewable by 2020?  If gas companies had to install some percentage of their business as geothermal, solar thermal or biomass thermal, the renewable thermal sector would develop quickly, just as renewable electricity has.  Gas companies could install the systems themselves, just like utilities can install their own wind turbines or solar farms, or buy renewable energy credits from companies who build and operate them. 

During these Trump years, federal policy and funding of renewables will dwindle, but that is making some states, cities and campuses even more motivated to push forward.  Renewable heating is part of the equation, but are we at the table?

(This article is reprinted from Biomass Magazine.  The Biomass Magazine version had a slight error in the text.)