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On February 17, APGA and the American Gas Association (AGA) sent a letter to the U.S. Department of Energy (DOE), raising concerns with its proposal to promulgate test procedures for certain gas-fired cooking products that lacked sufficiently repeatable efficiency testing results.

In a notice of proposed rulemaking (NOPR) issued in November 2021, DOE proposed a new test procedure to measure the energy efficiency of certain cooking products, both gas-fired and electric.  The efficiency test procedures developed by the agency are a key element in establishing minimum efficiency standards for appliances covered by federal law.  Accordingly, test procedures must be developed in an open and transparent manner, based on technically-supported data that results in methods that provide reliable and repeatable results.  Without such a test procedure underlying the appliance efficiency requirements, manufacturers may have difficulty bringing these gas-fired products to market and maintaining compliance with the applicable statute.

The comment letter also more broadly supported the technical comments of the Association of Home Appliance Manufacturers (AHAM), the trade association which represents the manufacturers of residential cooking products.  A copy of the comment letter is available here.

If you have questions regarding this article, please contact Renée Lani of APGA staff by phone at 202-464-0836 or by email at rlani@apga.org.