The Threat

Gas log sets, as we know them, are under threat.  The US Department of Energy Proposed Rule would harm the market for gas logs, and severely limit consumer choice.

If the DOE’s Proposed Rule is published as a Final Rule (which could happen in later 2015), vented gas logs sold after 2020 would be prohibited from having standing pilots. This removes a large choice for consumers and manufacturers, significantly increasing the cost of a gas log set. It wold also allow DOE to review gas logs every five years for further regulation to “conserve energy”, which could result in requirements that would remove the aesthetics that so many people have enjoyed in their fireplace for over 50 years.

The DOE’s previous Proposed Rule attempted to  impose the following requirements:

1) Must comply with the AFUE appliance efficiency rating.  (Unfortunately, no testing methodology exists for vented gas log sets, so this is not a current option.  Is is doubtful that such a methodology could exist, as gas log sets are used in an enclosure and venting system (fireplace) that is not a part of the gas log set, and usually not made by the gas log manufacturer).

2) Must consume less than 9000 BTU/hour of gas so that the gas log set falls under the Proposed Rule’s definition of a “decorative” product.  (No gas log set on the market burns such a small amount of gas.  Most gas log sets are in the 50,000 to 90,000 BTU/hour range.  9000 BTU/hour is equivalent to about thirteen 1 1/2-inch long pilot flames.  This requirement would apply to a 96-inch wide gas as it would a 12-inch wide gas log set.  This is not a viable option for vented gas log sets).

3) Vented gas log sets can gain exclusion from either #1 or #2 by meeting all of the following criteria:

a) Must be certified to ANSI Z21.60 National Standard for Vented Decorative Gas Logs.  (This ignores the “RADCO” standard sets and unlisted/uncertified sets, the combination of which currently account for over 75% of all gas log sales).

b) Must be sold without a thermostat and have a warranty provision expressly voiding all warranties if the gas log set is ever used with a thermostat.  (Thermostats are not a huge part of vented gas log sales, and are currently not allowed under ANSI Z21.60, but it does restrict consumer choice for those who wish them).

c) Must include on the rating plate and all advertising and literature that vented gas log sets are “Decorative Product: Not For Use As A Heating Appliance.” (What is confusing is that in order for the DOE to regulate vented gas logs, they had to term them as Direct Heating Equipment (DHE), because they “warm the air”.  Yet under this regulation, we have to contradict the DHE ruling and specifically deny in product markings and promotion that they are not heaters at all.)

d) Must not be equipped with a standing pilot light.  (This is what DOE, NRDC and ACEEE want most.  Unfortunately, in their horribly deficient research, they failed to identify Match-Lighted Sets, which account for more than 50% of the current gas log set market.  ANSI Z21.60 (see #a above) requires that a gas log set be equipped with a safety control – if standing pilots are prohibited by the Final Rule, and since match-lighted is not allowed under Z21.60, then the only remaining option is an Electronic or Intermittent Ignition System (EIS).  Unfortunately, less than 5% of current gas log sales are with EIS, none of which are ANSI Z21.60 certified.  Because EIS components are larger and more heat-sensitive than those of standing pilot systems, co-locating them in a fireplace with a gas log set is challenging, especially in small fireplaces.  EIS are the least mature aspect of gas log controls offered by the control manufacturers – they are still an emerging technology with much improvement needed to make them more mainstream and to meet all sizes of fireplaces (very deficient in EIS for large BTU that can be installed inside the fireplace).  Additionally, EIS are much more expensive than standing pilot and match lighted options, which will greatly increase the price of a gas log set.  The lowest priced sets may triple or quadruple in retail price, which will severely limit consumer choice and product affordability, which will depress gas log sales).

4) If unable to achieve any of the above, then gas log manufacturers must remove their non-compliant vented gas log sets from the market.  (It would be difficult to remain a gas log manufacturer without being able to make and sell vented gas log sets.  Instead, gas log manufacturers will narrow their choices of sets, which would be required to be ANSI Z21.60-certified and EIS-equipped.  Innovation would be stifled due to the restrictions of the ANSI Z21.60 standard and the EIS requirement).

Comments

Tom Parks 06-09-2011, 13:12

Thanks for clarifying a complicated issue. Although I believe the future of hearth products will lean more “green” as we go, which means we will see more electronic ignition systems and Z21.88 vented fireplace heaters taking over the market anyway, there are a large number of architects and designers (and contractors) that aren’t on board yet, and there are a large number of American made products that would become obsolete if the new DOE hearth products rule sticks.

I think the impact would be similar if the DOE decided that incandescent is illegal. We know how valuable LED and fluorescent lighting products are for energy saving, but we still have a huge number of incandescent lighting products – perhaps the majority of products out there. How would such a sweeping change affect American lighting manufacturers, wholesalers and retailers in a suffering economy? It would be devastating.

In an industry where we are constantly improving already, is it really necessary to mandate change? Isn’t there any one else that needs some motivation, say, for instance, automobile manufacturers? When the energy crisis of the ’70s should have made American auto manufacturers think seriously about a plan “B” when plan “A” is foreign oil dependence, hearth products manufacturers were already looking or more efficient ways to burn wood, our most renewable source of fuel. Give us some credit for focusing on the future!

As it stands, the hearth industry offers plenty of energy efficient technologies, and the Federal Government has even rewarded energy-efficient (on bio-mass fuels – wood, pellet, etc.) choices with tax incentives. Instead of punishing the American manufacturers that will suffer if an unenlightened, sweeping change is made, how about considering a reward for consumers that choose energy-efficient GAS products that meet a similar efficiency requirement of 75% or more?

Reply
admin 06-09-2011, 17:54

Tom: Thank you for your thoughts. While Z21.88-type products proliferate because they are easier and less costly for builders to install than for a vented woodburning fireplace, I receive a lot of pushback and dissatisfaction to them from consumers, mostly in the form of “can I replace my ugly logs with wimpy flames with your beautiful gas logs (or contemporary fires)?” Unfortunately, I must inform them that they are stuck, that no changes can be made to their fireplace appliance without compromising safety and voiding certifications and warranties. There are still plenty of consumers who want the open fireplace of the kind that Abraham Lincoln studied in front of, and the type that Santa Claus can deliver his packages from, without having to contend with a pane of glass. When one type of product is favored over another through government regulation, the consumer loses choice, and otherwise legitimate, successful businesses become at risk. I don’t know where you would find in our Constitution the government’s authority to declare winners and losers in our economy from proven products. Yes, I know they do it all the time, but it doesn’t make it right. This Proposed Rule is another erosion of our liberty by regulatory overreach and must be stopped.

Reply
Tom Parks 06-09-2011, 21:23

Agreed.
I would have to say that the majority of our clients would PREFER a gas fireplace without glass on the front, and without oversimplifying the technical aspects here, that basic choice is threatened.
Without endorsing either choice, I was trying to make the point that designers and homeowners are not “limited” by what is available now. If the government wants to “encourage” a certain approach (the EnergyStar approach), that is vastly different from prohibiting choice.

Reply
admin 06-09-2011, 21:34

Tom – Roger that. Maintaining or improving consumer choice, while not stifling innovation, should be the goal and responsibility of any regulatory body, whether DOE, a building code, or a standards committee.

Reply

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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

We're fighting for the survival of vented gas logs against the US Government, and we need all the help we can get. Here is what you can do to help save gas logs ...

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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."

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