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APGA Engages in DOE’s Conventional Cooking Products Rulemaking (June 3 2024) 

06-06-2024 12:03 PM

On June 3, APGA submitted comments in response to the Department of Energy’s (DOE) direct final rule and notice of proposed rulemaking pertaining to the Energy Conservation Standards (ECS) for Consumer Conventional Cooking Products. APGA’s utility members provide the energy needed for gas cooking products, so it was critical that APGA share concerns. Specifically, the underlying analysis for the ECS showed minimal energy savings and just $3 of consumer savings over the lifetime of the appliance. APGA urged DOE to pursue standards in future rulemakings that had significant energy savings and consumer savings.
 
On February 14, DOE published the direct final rule and notice of proposed rulemaking pertaining to the Energy Conservation Standards for Consumer Conventional Cooking Products.
 
The Energy Policy and Conservation Act of 1975 (EPCA) established efficiency standards for numerous appliances and requires DOE to review these standards to determine whether amended standards are warranted. APGA is concerned that DOE’s estimated savings are not sufficient to justify this rulemaking for cooking products under EPCA.
 
APGA is also concerned that this rulemaking does not appear to save any more energy than a previous iteration of the ECS. Notably, with the last iteration of this rule in 2009, DOE decided not to set a new standard due to a lack of significant conservation of energy for gas cooktops.
APGA is concerned that DOE is now planning to set a new standard based on the 
same minimal energy savings that were previously deemed insufficient to dictate a new ruling in 2009.
 
On September 1, 2023, APGA submitted comments in response to DOE’s notification of data availability (NODA) pertaining to cooking products, asking DOE to not adopt new minimum efficiency standards as they would not be economically justified or result in significant conservation of energy. Read more here.
 

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240603 Cooking Products ECS DFR NOPR Comments Final.pdf   199 KB   1 version
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