Submit Comments

The deadline for submitting public comment on the current NOPR is 5:00 pm EDT Friday April 10, 2015.  If you sell vented gas log sets now, or look to purchase gas log sets in the future (as either a dealer, distributor, builder, contractor, plumber, designer, architect or consumer), you will be affected by this Rule, and have a right to make your comments known.

Comments may be submitted using any of the following methods:

1. Federal eRulemaking Portal: www.regulations.gov. Follow the instructions for submitting comments.

2. Email: HearthHeatingProd2014 STD0036@ee.doe.gov

(Other methods are listed on page 7082 of the NOPR.)

If you desire, you may submit your comments to Rett@Rasmussen.biz for his opinion before submitting to DOE.

Email to:  HearthHeatingProd2014 STD0036@ee.doe.gov
cc to:  Brenda.Edwards@ee.doe.gov
rett@rasmussen.biz
carroll@hpba.org
[see below about contacting your Congressman]

Subject line must be: Docket Number EERE–2014–BT–STD–0036  RIN1904–AD35

Attach your comments as a PDF (preferred), .doc, .xls, or .txt file format

Format:  There is no specific format.  I recommend that you start with this template.

Substance of your comments:

Please identify yourself with some basic statements before you go into your comments on the twenty-three (23) issues and speak respectfully but honestly. DOE needs to have your personal opinion, based on your knowledge and experience.

–  My name is __________.

– My address is ________.

– I work for/represent/own ____________.

– [Company name] is located in _______________.

– We make  (or sell)______________.

– I work with or employ _____ people directly and approximately _____ people indirectly.

The following are important points for you to discuss:

1) If you employ less than 500 employees, be sure to identify yourself as a “small business”.  Tell about the history of your business, and your experience with vented gas log sets.  What percentage does vented gas logs represent to your annual overall sales?

2) Please comment on the impact to your business (loss of sales) and employees (ability to hire or need to fire) if the vented gas log sets available for you to market were limited to only those that were 30″ and smaller, and only equipped with Electronic Ignition Systems.  What impact would you feel if you could no longer sell match-lighted or standing-pilot equipped vented gas log sets?

3) Discuss what your market for gas log sets is like.  For example, do you primarily sell match-lighted sets?  Does your market require a safety control?

4) Discuss the economic makeup of your market and the impact adding $600+ list for an electronic ignition system to each gas log set would have on your sales and business.

5) Discuss your experience with how your consumers use their standing pilot lights.  Do they leave them on year round, turn them off after each use, or something in between?  DOE asserts that 75% of users leave their pilots on 24/7/365 – do your agree?  If not, why not?

6) Comment on your current experience with EIS.  Have you sold many?  Why or why not?  What issues have you have with EIS controls?

THERE ARE 23 NOPR ISSUES  FOR WHICH DOE REQUESTS COMMENTS:

Although DOE welcomes comments on any aspect of this proposal, DOE is particularly interested in receiving comments and views of interested parties concerning the following issues:

1. DOE seeks comment on the proposed definition for hearth products found in the December 2013 NOPD (78 FR 79638) and the range of products covered by the proposed rule if this definition were applied in the final rulemaking. DOE requests comment on which products would fall into each of the product groups as currently defined (1. vented fireplaces/stoves/inserts, 2. unvented fireplaces/stoves, inserts, 3. vented gas log sets, 4. unvented gas log sets, and 5. outdoor) and whether additional clarifying criteria should be added to the definition to cover intended products. DOE requests comment on which hearth products that are ‘‘gas appliances that simulate a solid-fueled fireplace or presents a flame pattern’’ may by the proposed definition be grouped into the hearth product category, but may warrant a different design standard due to such factors as utility of the feature to users. (See section III.A.)

2. DOE seeks input on the assumption that should standing pilot ignitions be disallowed, electronic intermittent ignitions would provide the same level of safety as a standing pilot and whether a standing pilot provides a means for ensuring that gas is lit prior to opening the gas valve and ensuring that oxygen levels in a the room remain at

a safe levels prior to the main burner ignition. DOE request comment on whether there are any ANSI safety standard certification, building code, or other industry safety standard that may preclude a manufacturer from selling a particular hearth product with an electronic intermittent ignition. (See section III.B.)

3. DOE seeks comment on its tentative conclusions regarding hearth product definitions and categorizations as they pertain to active mode energy use. (See section III.C and chapter 3 of the TSD.)

4. DOE seeks comment on its screening analysis including any potential impacts on product utility or availability. (See section III.G.1.d and chapter 4 of the TSD.)

5. DOE seeks comment on its assumptions regarding the electrical energy consumption of the ignition module for hearth products. (See section III.I and chapter 7 of the TSD).

6. DOE seeks comment on its list of identified technologies for reducing the fuel consumption of hearth products. (See section IV.A.3 and chapter 3 of the TSD.)

7. DOE seeks comment on its general engineering analysis approach for hearth products. (See section IV.C and chapter 5 of the TSD.)

8. DOE seeks comment on the availability and applicability of intermittent pilot ignition components for hearth products. (See section IV.C.1 and chapter 5 of the TSD.)

9. DOE requests comment on its assumption that ignition component costs for vented fireplaces, inserts, and stoves are equivalent. (See section IV.C.1 and chapter 5 of the TSD.)

10. DOE requests comment on the derived manufacturer production costs and markups. (See sections IV.C.3.e and IV.C.4 and chapter 5 of the TSD.)

11. DOE seeks input on the representative input capacities (kBtu/h) used to calculate the fuel used by the standing pilot for each of the five hearth product groups identified in the proposal and discussed in Chapter 7 of the TSD. In particular, the agency seeks input on whether the RECS 2009 annual space heating energy consumption numbers for vented and unvented fireplaces is representative of all hearth products and any data that would be helpful in estimating the energy consumption for the hearth product groups identified. DOE also seeks comment

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on the average on-time per cycle assumption of 30 seconds for intermittent pilot ignition and any data indicating specific on-time per cycle for different product groups to help inform the energy use analysis. (See section IV.E and chapter 7 of the TSD.)

12. DOE requests comment on the assumed pilot light usage, specifically the percentages of consumers who operate their hearth product standing pilots year round, for only the heating season, only when operating the unit, the treatment of LPG units, and the treatment of heat input into the space by the standing pilot. (See section IV.E and chapter 7 of the TSD.)

13. DOE requests comment on the assumption to not apply a trend to its manufacturer selling price, as well as any information that would support the use of alternate assumptions. (See section IV.F.1 and chapter 8 of the TSD.)

14. DOE requests comment on installation and retrofit assumptions regarding electrical connections and grounding. (See section IV.F.1 and chapter 8 of the TSD.)

15. DOE requests comment on intermittent pilot ignition module repair frequency and cost components applied in the life-cycle cost and payback period analysis. The agency requests input on the use of $142.89 as the bare material cost of repair of the intermittent pilot compared the bare material cost of a standing pilot of $43.72. In addition, the agency requests comment on the labor hours associated with the repair of both the standing pilot and intermittent pilot, which were both determined to be 1.50 labor hours as referenced in Section 8.2.3.2 of the TSD. DOE also requests comment on whether consumers may choose to replace the entire product as opposed to repair the failed ignition device and at what price point consumers would make that decision and for which hearth products. (See section IV.F.2.c and chapter 8 of the TSD.)

16. DOE requests comment on lifetime assumptions applied in the life-cycle cost and payback period analysis where DOE assumes the minimum lifetime of both the hearth product and ignition system to be 5 years and 1 year, respectively and that for purposes of the life-cycle cost analysis that any repair costs would be free to the consumer during this warranty period. In addition, DOE requests comment on the product lifetime distribution for hearth products that are average are assumed to be 15 years and for hearth product ignition systems are assumed to be 7.3 years as laid out in Section 8.2.3.3 of the TSD. DOE requests input on lifetime for products identified in the five different hearth product groups (vented fireplaces, unvented fireplaces, vented log sets, unvented log sets, and outdoor) that may inform the lifetime distribution analysis. (See section IV.F.2.d and chapter 8 of the TSD.)

17. DOE requests comment on the estimated base-case efficiency distribution. (See section IV.F.2.f and chapter 8 of the TSD.)

18. DOE requests comment on its assumption that switching from gas to electric hearth products due to the

imposition of the design standard would be negligible. (See section IV.G and chapter 9 of the TSD.)

19. DOE requests comment on DOE’s methodology to correlate housing starts with hearth products shipments. In addition, DOE requests comment on the assumed three-to- one ratio between non-HPBA and HPBA shipments used to develop the total patio heater shipments assumptions. DOE also requests comment on the assumed fraction of match-lit shipments for each hearth product group and the use of the midpoint of the HPBA range as representative of the market shares of match lit units for each product group as represented in Table 9.3.2 of the TSD. DOE also requests comment on the assumed 0.754 ratio of housing starts to hearth products shipments as discussed in section 9.5 of the TSD and what percentage of these hearth products are connected to natural gas pipelines versus homeowners’ propane storage tanks. (See section IV.G and chapter 9 of the TSD.)

20. DOE requests comment on expected industry capital and product conversion costs. For the capital conversion costs, DOE requests comment on the determination that the design standard would primarily entail a component swap, in which manufacturers would assemble hearth products using a different set of purchased parts for the ignition system and that re-tooling or reconfiguring production facilities likely would be limited. In particular, DOE requests comment on the assigned nominal capital conversion cost per manufacturer, equivalent to $10,000, to account for any one-time capital investments and calculated industry conversion costs of $0.9 million as discussed in Chapter 12.4.6 of the TSD. For the product conversion costs, DOE requests comment on the conversion cost estimates on the assumption that manufacturers would incur limited costs related to R&D, testing and certification, and development of marketing materials in order to bring into compliance models not currently offered with the option of an electronic ignition system. In particular, DOE requests comment on the assumed product conversion cost of $10,000 in fixed costs per model to arrive at the total industry product conversion costs of $7.8 million. DOE also requests comment on the number

of hearth product manufacturers who may need to invest in capital equipment, assumed to be 90 manufacturers, and the number of hearth product models, assumed to be 781 models, that may need model redesigns in order to comply with the proposed standards. (See section V.B.2 and chapter 12 of the TSD.)

21. DOE requests comment on potential impacts of an energy conservation standard on domestic production employment. (See section V.B.2 and chapter 12 of the TSD.)

22. DOE requests comment on product- specific regulations that take effect between 2018 and 2024 that would contribute to manufacturers’ cumulative regulatory burden. DOE requests information identifying the specific regulations, as well as data quantifying the associated cost burden on manufacturers. (See section V.B.2 and chapter 12 of the TSD.)

23. DOE requests comment on the approach for estimating monetary benefits associated with emissions reductions. (See section V.B.6 and chapter 14 of the TSD.)

Comments

Roberto DiLisio 07-09-2011, 01:57

Attn: DOE
Let’s not worry about stupidity like gas Decorative logs. Concern yourselves with your Jobs. They are unnecessary to the American Consumer, who will get what they want, with or without your socialist approval.
You may want to start by eliminating HUMMERS , which do not save energy or our economic growth. In fact, GMC went Bankrupt on MY money after accepting the “Obama Bailout” Worry about that, not gas logs, (Moron’s)

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Background

How did we get here? What is the basis for the US Department of Energy's assault on gas logs? Here is the background information ...

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The Threat

The US Department of Energy Proposed Rule would harm the market for gas logs, and severely limit consumer choice ...

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Action

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Fallacy of ‘”Decorative” 9000 BTU

900 btu

With the stroke of a pen, the US Department of Energy declared that (as of July 1, 2011), a gas log set must not consume more that 9000 BTU/hour to be termed "decorative". If it consumes more gas than that, it must meet efficiency ratings for which no testing methodogy exists. Watch this video where Rett Rasmussen illustrates the fallacy of 9000 BTU/Hour being "decorative."

Watch Video