On April 17, the Competitive Enterprise Institute and 30 free-market organizations filed a comment with the Department of Energy (DOE) critical of its proposed new energy efficiency standards for residential stoves. As we detail in our comment, this proposal is especially burdensome for natural gas stoves relative to electric versions. The Biden Administration is targeting gas stoves as part of its climate change agenda, but in doing so the proposed rule violates the consumer protections in the law and therefore should be withdrawn.
DOE’s authority to set efficiency standards for appliances is not absolute, and in fact the agency is expressly forbidden from imposing any measure that compromises product features or performance. Unfortunately, the proposal does precisely that to gas stoves, which comprise 40 percent of the market and are the preferred choice of serious cooks. For example, the standard would likely eliminate the very high heat burners on gas stoves needed for such tasks as stir frying and searing. It may also preclude the heavy-duty cast iron grates ideal for safely handling large pots. It would also add to cooking times on gas stoves. And all for a claimed energy savings of about $1.50 per year for a gas cooktop.
In addition to the features associated with cooking performance, having a stove that can operate during a blackout is also a protected feature, and it is one that is of increasing relevance to consumers. There is a documented and growing risk to electric reliability across much of the nation, especially as baseload generation sources like coal and natural gas are being retired and replaced by wind and other intermittent renewable sources. Quite arguably, the same Biden Administration climate agenda that favors electric stoves over gas is also making dependence on electric stoves increasingly problematic. In any event, the ability to cook during an electricity outage is a feature that gives gas stoves an advantage over electric ones, and is one more reason why fully-featured gas stoves must be preserved.
DOE claims significant climate benefits from the rule, but the agency’s calculations are based on the highly problematic 2021 Interagency Working Group on the Social Cost of Greenhouse Gases (IWG 2021). There are numerous flaws with IWG 2021, nearly all of which serve to overstate the calculated benefits of avoided emissions. Among them are the use of improperly-low discount rates, reliance on climate models that have consistently overstated actual warming, reliance on baseline emission scenarios that implausibly assume an increasingly coal-centric global energy system through 2100 and beyond, and downplaying the capacity for adaptation to mitigate climate impacts. More realistically, an analysis from Dr. Kevin Dayaratna of the Heritage Foundation estimates that the proposed rule would reduce the earth’s temperature by 0.0004°C by 2050 – far too small to make any discernable difference.
Granted, DOE’s proposed rule is not an outright ban on gas stoves. Gas stoves could still be manufactured and sold under it, but they would be ones with compromised quality and features. Add to that a long list of other Biden Administration measures burdening gas stoves – separate regulatory proceedings by the Consumer Product Safety Commission, $840 in federal incentives for new electric stoves but none for gas versions, federal funding encouraging state and local governments to ban natural gas hookups in new construction, opposition to new natural gas pipelines needed to supply many communities, and others – and the cumulative effect over time could become a de facto ban on gas stoves and other gas appliances.
Assuming the agency finalizes the rule as proposed later this year, the next steps are potential litigation as well as Congressional consideration of overturning the rule under the Congressional Review Act.