NPGA plans to testify at a Department of Energy (DOE) hearing today expressing our concerns over the agency's proposal to include vented gas log sets under the definition of Direct Heating Equipment. Direct Heating Equipment is equipment typically designed to provide heat to a given space such as room heaters, wall furnaces, floor furnaces, etc. and such equipment must meet minimum efficiency requirements. Vented gas log sets, and indeed, vented gas fireplaces are designed to provide decorative or aesthetic appeal. Their main function is not to provide heat even though some may provide incidental heat.
Part of NPGA's argument is that DOE overstepped its authority to regulate these types of products as the enabling statute does not define decorative products as Direct Heating Equipment. Moreover, DOE believes that by providing certain exclusion criteria, certain vented gas logs or gas fireplaces would be exempt from meeting DOE's minimum efficiency requirements. While we have some concerns over the exclusion criteria, our overriding concern is the regulation of these products as Direct Heating Equipment.
Written comments are due by September 20, and NPGA will be filing more detailed comments then. We are also exploring other possible options to prevail in this effort against DOE. We will keep you posted.
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