11 May 2018
DOE Reviewing Petitions on Cooking Tops, Residential Dishwashers
The U.S. Department of Energy has received a petition from the Association of Home Appliance Manufacturers that seeks to withdraw and immediately stay the effectiveness of the current energy test procedures for conventional cooking tops. Interested parties may submit comments, as well as any data or information that could be used in the DOE’s determination, no later than 25 June.
In its petition, AHAM requests that the DOE undertake rulemaking to withdraw the cooking top test procedure while maintaining the repeal of the oven test procedure that was part of the December 2016 final rule setting forth new energy test procedures for cooking products. In the interim, AHAM is seeking an immediate stay of the effectiveness of the final rule, including the requirement that manufacturers use the final test procedure to make energy related claims. Should the DOE continue to pursue a revised cooking top test procedure, AHAM asserts that the agency should demonstrate through round robin testing that the test is repeatable and reproducible and, for gas cooking tops, accurate. AHAM claims that its analyses show that the test procedure is not representative for gas cooking tops and, for gas and electric cooking tops, has such a high level of variation it will not produce accurate results for certification or enforcement purposes and will not assist consumers in making purchasing decisions based on energy efficiency.
Additionally, the DOE is seeking input by 25 June on a separate petition from the Competitive Enterprise Institute requesting the creation of a new product class under the Energy Policy and Conservation Act for residential dishwashers that would cover dishwashers with a cycle time of less than one hour from washing through drying. Parties may submit any data or information that could be used in the DOE’s determination on whether to proceed with this petition.
CEI is not suggesting specific energy and water requirements for this new product class, stating that these details could be determined during the course of the rulemaking. CEI did note that dishwasher cycle times have become dramatically longer under the existing mandatory energy conservation standards and that consumer satisfaction/utility has dropped as a result of these longer cycle times. The association also provided data regarding the increase in dishwasher cycle times, including data that correlates increased cycle time with the DOE’s adoption of amended efficiency standards for dishwashers.