This efficiency standard would disproportionately target natural gas-using stoves relative to electric ones and compromise consumer choice and features.
Department of Energy, Energy Conservation Program: Energy Conservation Standards for Consumer Conventional Cooking Products
The undersigned free market and consumer organizations have a longstanding interest in bringing to light the deleterious consequences of federal regulations, which are often neglected by agencies in their attempts to adopt a regulatory agenda. For over 20 years, we have participated in rulemakings conducted by the Department of Energy (DOE) regarding energy and water conservation standards for home appliances. This includes agency rulemakings and subsequent litigation impacting dishwashers, air conditioners, clothes washers and dryers, showerheads, light bulbs, and furnaces.
Our focus has been on ensuring that the consumer protections built into the underlying statute, the Energy Policy and Conservation Act of 1975 (EPCA), are given full weight by DOE in the rulemaking process, and that the statutory option of declining to set a standard is chosen when appropriate. In our view, these consumer protections have frequently been downplayed or ignored by the agency when setting excessively stringent appliance efficiency standards that raise overall costs and/or compromise product quality and choice.
Over the last two years, the risk of DOE appliance standards harming consumers has been heightened by the Biden Administration’s “whole of government” prioritization of climate change considerations, which has been fully adopted by the agency. This agenda has included efforts by DOE, along with other agencies, to discourage the use of residential natural gas in favor of the electrification of all appliances.
However, doing so serves to subordinate the best interests of consumers to unrelated environmental objectives and thus is contrary to EPCA’s overriding emphasis on consumer utility.
It is for these reasons that we are very concerned about the proposed rule at issue here regarding consumer conventional cooking products. As will be discussed below, we believe this efficiency standard, the first of its kind for residential stoves, is not compliant with EPCA. In particular, it would disproportionately target natural gas-using stoves relative to electric ones while compromising consumer choice and features, and thus is arbitrary and capricious and in violation of the law. For these and other reasons, we believe the proposed rule should be withdrawn.
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im all for gas stoves but does amac know how dangerous natural gas explosions are? has to be some standards
Gas stoves are far more efficient than electric stoves. Their use of natural gas is negligible. This proposed rule would be deleterious to the common good.