2/9/15 – DOE Proposes Standing Pilot Ban

On February 9, 2015, the US Department of Energy (DOE) published in the Federal Register a Notice of Proposed Rulemaking (NOPR) that would abolish standing pilots on all indoor and outdoor Hearth Products five years from the date of final adoption of the Rule. Comments must be submitted to DOE by April 10, 2015. A public meeting to discuss the Rule will be held on Monday, March 23, 2015, from 9am to 4pm at U.S. Department of Energy, Forrestal Building, Room 8E-089, 1000 Independence Avenue, SW., Washington, DC 20585. Information on participating in this meeting, either in person or via the webinar, is provided in the notice.  (Note: the Federal Register incorrectly identifies March 23 as a Wednesday).

Proposed Rule

Technical Support Document (TSD)

Sign the Petition to Save Gas Logs

Manual Standing Pilot Control Systems provide the lowest cost safety shutdown of gas flow to the main burner in the event of an interruption in the gas supply or a flameout. Standing Pilots are also used in Millivolt Controls that allow for remote operation by switches, wireless remote controls and home automation systems. Both systems would be forbidden by the Rule. In a time of high production and supplies of Natural Gas, the DOE has proposed to regulate Hearth Products under the Energy Policy and Conservation Act of 1975 (EPCA). After this initial regulation, DOE would be required by EPCA to revisit every five years means for improving energy conservation for Hearth Products. This could result further design restrictions and/or efficiency requirements that would likely negatively affect the aesthetics and market appeal of Hearth Products.

Barring any new technologies or changes in the requirements by DOE, the following control options would be available for gas log sets:

Natural Gas Vented = Match lighted (no safety shutdown) and Electronic Ignition (Safety Shutdown)
Propane Vented, Natural Gas Vent-free, Propane Vent-Free = Electronic Ignition (Safety Shutdown)

Please note that control systems for gas log sets must usually reside inside of the fireplace; they normally cannot be located outside of the fireplace except during new construction or an extensive remodel. Accordingly, Electronic Ignition Systems (EIS) must be battery powered (outlets are not located inside a fireplace). Unfortunately, the control manufacturers currently make no battery-powered EIS with sufficient gas capacity for set sizes larger than 30-inch. This Rule will severely restrict consumer choice for larger fireplaces.

The term “Hearth Products” is broadly defined as “a gas-fired appliance that simulates a solid-fueled fireplace or presents a flame pattern (for aesthetics or other purpose) and that may provide space heating directly to the space in which it is installed.” Breaking down this language, this Rule would apply to anything with a flame; DOE has previously stated that any flame provides heat, therefore any appliance with a flame is a heater. Accordingly, this Rule could apply to every indoor and outdoor product in the hearth products industry, including patio heaters, gas lights and, perhaps, gas grills. While some of these products may not be affected now by a standing pilot ban, being included in the Final Rule will subject them to future regulation. This is not good for the industry or consumer choice.

We fear that this Rule and subsequent regulations would have unintended consequences, such as:
1) Increased pollution from increased wood burning;
2) Health and safety issues by consumers who try to bypass the restrictions by creating their own control systems, or using Propane products with no safety shutdown systems.
3) Increases in product costs while decreasing consumer choices.
4) Reductions in sales that would result in companies going out of business and large job losses in the hearth industry.

We urge you to:
1) Attend the Public Meeting on March 23, 2015 in Washington, DC, to let your opinions be known;
2) Submit comments to DOE by April 10, 2015. Include how this would affect your business with respect to revenue loss and reduction of employees (job killer), as well as reducing consumer choice and safety options. Provide these same comments to your congressman and Senators;
3) Sign the Petition;
4) Encourage all of your hearth products manufacturers to join HPBA.
5) Purchase products from manufacturer members of the HPBA, as they are footing the legal and lobbying bills for opposing this overreach by government. We need increased revenue to cover these costs, which are projected to be $500,000 from Jan. 1 through July 31, 2015. Those who are not members of HPBA are “free riding” on the efforts and financial commitments of those who are, and should not be rewarded for their lack of action.
6) Make your customers aware of the impact of this Rule on their choices in order to enlist their support through signing the Petition and submitting comments to DOE.

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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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