Minutes of meeting with Gas Appliance Manufacturers Association, American Gas Association 

and DOE Office of Codes (OCS) and Standards on May 15, 1998 

See attached agenda and industry presentation handout. 

Joe Eckert (Harper-Wyman), a member of GAMA and AGA, opposes the ban on pilot lights. He 

stated the data is suspect, and it's not clear who is impacted to what extent. He also stated the 

gas range is a retail driven product. 

Concern was stated that a ban on pilot lights may cause people to switch from gas to electric 

ranges. 

Mr. Eckert speculated that older homes may not have a three-pronged, grounded outlet available, 

and because low income or retired persons often live in older homes that these people will be 

adversely affected. 

Mark Friedrichs (DOE Policy Office) asked what kind of data the industry had. 

Carl Adams (DOE OCS) noted that the states of WI, MN, CA, OR, and NY had bans on pilot 

lights in the 1980s. 

Dennis St. Gerrnain (Harper-Wyman) said he would provide us with data from the 1980s. 

Joe Geary (Peerless-Premier) stated that most gas ranges did not have power cords. 

Carl Adams (OCS) presented the Final Rule regarding State Petitions for Exemption from Federal 

Standards for Clothes Dryers and Kitchen Ranges and Ovens, 49 FR 1 1766 (March 27, 1984), in 

which White Consolidated Industries commented that from approximately 1980-83 the percentage 

of ranges shipped with pilot lights had dropped from 58-43% and that Frigidaire no longer sold 

models with pilot lights. 

Mark Friedrichs (DOE: PO) stated that the key issue is how many houses have proper outlets 

available and how many do not, and what percent of replacement market has grounded electricity 

available. Everyone at the meeting agreed. 

Frank Stanonik, GAMA, asked if DOE had tried to work backwards from when the electric code 

came into efEect ('93) to get an indication of how many homes had grounded outlets available. 

Joe Eckert (Harper-Wyman) stated that it is expensive to install outlets in older buildings with 

cinder block walls and that the cost is passed on to the renter. 

Carl Adams (OCS) stated that the New York Housing Authority stated that their conversion to 

pilotless ignition (between 1980-95) cost $30-40 per outlet installed. Joe Eckert (HarperWyman) stated that this cost was not representative, and DOE agreed. 

EE-RM-S-97-700_EERE-1997-STD-0070 COMMENT 41

Minutes of meeting with Gas Appliance Manufacturers Association, American Gas Association 

and DOE Office of Codes (OCS) and Standards on May 15, 1998 

See attached agenda and industry presentation handout. 

Joe Eckert (Harper-Wyman), a member of GAM A and AGA, opposes the ban on pilot lights. He 

stated the data is suspect, and it's not clear who is impacted to what extent. He also stated the 

gas range is a retail driven product. 

Concern was stated that a ban on pilot lights may cause people to switch from gas to electric 

ranges. 

Mr. Eckert speculated that older homes may not have a three-pronged, grounded outlet available, 

and because low income or retired persons often live in older homes that these people will be 

adversely affected. 

Mark Friedrichs (DOE Policy Office) asked what kind of data the industry had. 

Carl Adams (DOE OCS) noted that the states of WI, MN, CA, OR, and NY had bans on pilot 

lights in the 1980s. 

Dennis St. Germain (Harper-Wyman) said he would provide us with data from the 1980s. 

Joe Geary (Peerless-Premier) stated that most gas ranges did not have power cords. 

Carl Adams (OCS) presented the Final Rule regarding State Petitions for Exemption from Federal 

Standards for Clothes Dryers and Kitchen Ranges and Ovens, 49 FR 11766 (March 27, 1984), in 

which White Consolidated Industries commented that from approximately 1980-83 the percentage 

ofranges shipped with pilot lights had dropped from 58-43% and that Frigidaire no longer sold 

models with pilot lights. 

Mark Friedrichs (DOE PO) stated that the key issue is how many houses have proper outlets 

available and how many do not, and what percent of replacement market has grounded electricity 

available. Everyone at the meeting agreed. 

Frank Stanonik, GAMA, asked if DOE had tried to work backwards from when the electric code 

came into effect ('93) to get an indication of how many homes had grounded outlets available. 

Joe Eckert (Harper-Wyman) stated that it is expensive to install outlets in older buildings with 

cinder block walls and that the cost is passed on to the renter. 

Carl Adams (OCS) stated that the New York Housing Authority stated that their conversion to 

pilotless ignition (between 1980-95) cost $30-40 per outlet installed. Joe Eckert (HarperWyman) stated that this cost was not representative, and DOE agreed. 

Minutes of meeting with Gas Appliance Manufacturers Association, American Gas Association 

and DOE Office of Codes (OCS) and Standards on May 15, 1998 

See attached agenda and industry presentation handout. 

Joe Eckert (Harper-Wyman), a member of GAM A and AGA, opposes the ban on pilot lights. He 

stated the data is suspect, and it's not clear who is impacted to what extent. He also stated the 

gas range is a retail driven product. 

Concern was stated that a ban on pilot lights may cause people to switch from gas to electric 

ranges. 

Mr. Eckert speculated that older homes may not have a three-pronged, grounded outlet available, 

and because low income or retired persons often live in older homes that these people will be 

adversely affected. 

Mark Friedrichs (DOE Policy Office) asked what kind of data the industry had. 

Carl Adams (DOE OCS) noted that the states of WI, MN, CA, OR, and NY had bans on pilot 

lights in the 1980s. 

Dennis St. Germain (Harper-Wyman) said he would provide us with data from the 1980s. 

Joe Geary (Peerless-Premier) stated that most gas ranges did not have power cords. 

Carl Adams (OCS) presented the Final Rule regarding State Petitions for Exemption from Federal 

Standards for Clothes Dryers and Kitchen Ranges and Ovens, 49 FR 11766 (March 27, 1984), in 

which White Consolidated Industries commented that from approximately 1980-83 the percentage 

ofranges shipped with pilot lights had dropped from 58-43% and that Frigidaire no longer sold 

models with pilot lights. 

Mark Friedrichs (DOE PO) stated that the key issue is how many houses have proper outlets 

available and how many do not, and what percent of replacement market has grounded electricity 

available. Everyone at the meeting agreed. 

Frank Stanonik, GAMA, asked if DOE had tried to work backwards from when the electric code 

came into effect ('93) to get an indication of how many homes had grounded outlets available. 

Joe Eckert (Harper-Wyman) stated that it is expensive to install outlets in older buildings with 

cinder block walls and that the cost is passed on to the renter. 

Carl Adams (OCS) stated that the New York Housing Authority stated that their conversion to 

pilotless ignition (between 1980-95) cost $30-40 per outlet installed. Joe Eckert (HarperWyman) stated that this cost was not representative, and DOE agreed. 
Michael McCabe (DOE OCS) stated that the Department has been trying to get data on how 

many people would need to install pilot lights, and DOE hasn't been able to identify any other 

data. DOE, in its analysis, tried to calculate the economic bounds on people who would and 

would not have to install outlets. 

Joe Eckert (Harper-Wyman) suggested DOE survey the population to determine approximately 

how many homes would need to install grounded outlets. 

Mark Friedrichs (DOE PO) stated that the survey would need to include home visits to a few 

thousand homes because consumer surveys would not be accurate (ie, many consumers do not 

know if they have grounded outlets available.) 

Michael McCabe (OCS) asked if there are indirect ways we could determine how many homes 

would need to install outlets. 

Dennis St Germain (Harper-Wyman) suggested talking to service companies. 

Joe Geary (Peerless-Premier) suggested that DOE should spend the money to conduct the surveys 

to get the correct number. 

Kirstie Kumer (AGA) requested that DOE use AEO 98 energy forecasts and the Advisory 

Committee recommendations for energy rates. 

Michael McCabe (OCS) stated that any reanalysis would used AE0 98 

Carl Adams (OCS) asked if everyone agreed that the ban on pilot lights is cost effective for those 

people who do not need to install outlets. He also stated that DOE has to balance the effects on 

subgroups against the big picture. 

Ted Williams (AGA) questioned why DOE is not promulgating standards for electric non-selfcleaning ovens, which would save significant energy. DOE stated that the savings for pilotless 

ignition is over four times greater. 

Mark Friedrichs (DOE PO) stated that if we could obtain shipment data from the early eighties, 

we could determine what happened in the market as a result of NAECA. He also stated that he 

was interested in time trend data on the 673,000 (see page 1 of industry presentation handout) 

units with constant burning pilot lights in order to determine if the number is still declining quickly 

or if it is beginning to plateau in oder to give us an indication of what resistance there may be. 

Joe Eckert (Harper-Wyman) stated that a low end free standing range with a pilot light sells for 

$199, which is approximately the same price of a low end electric model. He stated that the 

electronic ignition model sells for $350 (see attached advertisement). Jim Ruberti (Brown Stove) 

stated that if you needed to install an outlet, you could install one for an electric range (in order to 

buy the low end $200 electric range) as easily as one for a gas electronic-ignition range. They 

both expressed concern over the possibility of kel switching. Kathi Epping (OCS) suggested that 

EE-RM-S-97-700_EERE-1997-STD-0070 COMMENT 41

Michael McCabe (DOE OCS) stated that the Department has been trying to get data on how 

many people would need to install pilot lights, and DOE hasn't been able to identifY any other 

data. DOE, in its analysis, tried to calculate the economic bounds on people who would and 

would not have to install outlets. 

Joe Eckert (Harper-Wyman) suggested DOE survey the population to determine approximately 

how many homes would need to install grounded outlets. 

Mark Friedrichs (DOE PO) stated that the survey would need to include home visits to a few 

thousand homes because consumer surveys would not be accurate (ie, many consumers do not 

know if they have grounded outlets available.) 

Michael McCabe (OCS) asked if there are indirect ways we could determine how many homes 

would need to install outlets. 

Dennis St Germain (Harper-Wyman) suggested talking to service companies. 

Joe Geary (Peerless-Premier) suggested that DOE should spend the money to conduct the surveys 

to get the correct number. 

Kirstie Kumer (AGA) requested that DOE use AEO 98 energy forecasts and the Advisory 

Committee recommendations for energy rates. 

Michael McCabe (OCS) stated that any reanalysis would used AEO 98. 

Carl Adams (OCS) asked if everyone agreed that the ban on pilot lights is cost effective for those 

people who do not need to install outlets. He also stated that DOE has to balance the effects on 

subgroups against the big picture. 

Ted Williams (AGA) questioned why DOE is not promulgating standards for electric non-selfcleaning ovens, which would save significant energy. DOE stated that the savings for pilotless 

ignition is over four times greater. 

Mark Friedrichs (DOE PO) stated that if we could obtain shipment data from the early eighties, 

we could determine what happened in the market as a result ofNAECA. He also stated that he 

was interested in time trend data on the 673,000 (see page 1 of industry presentation handout) 

units with constant burning pilot lights in order to determine if the number is still declining quickly 

or if it is beginning to plateau in oder to give us an indication of what resistance there may be. 

Joe Eckert (Harper-Wyman) stated that a low end free standing range with a pilot light sells for 

$199, which is approximately the same price of a low end electric model. He stated that the 

electronic ignition model sells for $350 (see attached advertisement). Jim Ruberti (Brown Stove) 

stated that if you needed to install an outlet, you could install one for an electric range (in order to 

buy the low end $200 electric range) as easily as one for a gas electronic-ignition range. They 

both expressed concern over the possibility of fuel switching. Kathi Epping (OCS) suggested that 

Michael McCabe (DOE OCS) stated that the Department has been trying to get data on how 

many people would need to install pilot lights, and DOE hasn't been able to identifY any other 

data. DOE, in its analysis, tried to calculate the economic bounds on people who would and 

would not have to install outlets. 

Joe Eckert (Harper-Wyman) suggested DOE survey the population to determine approximately 

how many homes would need to install grounded outlets. 

Mark Friedrichs (DOE PO) stated that the survey would need to include home visits to a few 

thousand homes because consumer surveys would not be accurate (ie, many consumers do not 

know if they have grounded outlets available.) 

Michael McCabe (OCS) asked if there are indirect ways we could determine how many homes 

would need to install outlets. 

Dennis St Germain (Harper-Wyman) suggested talking to service companies. 

Joe Geary (Peerless-Premier) suggested that DOE should spend the money to conduct the surveys 

to get the correct number. 

Kirstie Kumer (AGA) requested that DOE use AEO 98 energy forecasts and the Advisory 

Committee recommendations for energy rates. 

Michael McCabe (OCS) stated that any reanalysis would used AEO 98. 

Carl Adams (OCS) asked if everyone agreed that the ban on pilot lights is cost effective for those 

people who do not need to install outlets. He also stated that DOE has to balance the effects on 

subgroups against the big picture. 

Ted Williams (AGA) questioned why DOE is not promulgating standards for electric non-selfcleaning ovens, which would save significant energy. DOE stated that the savings for pilotless 

ignition is over four times greater. 

Mark Friedrichs (DOE PO) stated that if we could obtain shipment data from the early eighties, 

we could determine what happened in the market as a result ofNAECA. He also stated that he 

was interested in time trend data on the 673,000 (see page 1 of industry presentation handout) 

units with constant burning pilot lights in order to determine if the number is still declining quickly 

or if it is beginning to plateau in oder to give us an indication of what resistance there may be. 

Joe Eckert (Harper-Wyman) stated that a low end free standing range with a pilot light sells for 

$199, which is approximately the same price of a low end electric model. He stated that the 

electronic ignition model sells for $350 (see attached advertisement). Jim Ruberti (Brown Stove) 

stated that if you needed to install an outlet, you could install one for an electric range (in order to 

buy the low end $200 electric range) as easily as one for a gas electronic-ignition range. They 

both expressed concern over the possibility of fuel switching. Kathi Epping (OCS) suggested that 
he1 switching is unlikely to occur because the manufacturer could produce a low end electronic 

ignition for $235, and the consumer would continue to buy it over the electric range due to low 

gas prices compared to electric. 

Joe Eckert (Harper-Wyman) stated that he would send DOE a copy of a Consumers Union report 

that the highest service item for gas ranges is the electronic ignition. 

Darrell Paul (Battelle) stated that the maintenance costs would increase (DOE calculated costs 

based on one service call for the electronic ignition, but the frequency of a failure increases 

because there are two electronic ignitions.) 

Joe Eckert (Harper-Wyman) stated that this standard would no longer allow consumers to cook 

during power outages. Kathi Epping stated that the cooktop could be lit with a match during an 

outage. 

Frank Stanonik (GAMA) and Joe Geary (Peerless-Premier) raised safety concerns. They stated 

that low income consumers may use extension cords or other unsafe measures to avoid the cost to 

install a properly grounded outlet. 

Mark Friedrichs (DOE PO) stated that we should investigate how the safety issues were dealt 

with under the state bans of standing pilot lights. 

The industry representatives stated that they would call DOE within a week to inform the 

Department how much time it will take to gather the requested information. 

EE-RM-S-97-700_EERE-1997-STD-0070 COMMENT 41

fuel switching is unlikely to occur because the manufacturer could produce a low end electronic 

ignition for $235, and the consumer would continue to buy it over the electric range due to low 

gas prices compared to electric. 

Joe Eckert (Harper-Wyman) stated that he would send DOE a copy ofa Consumers Union report 

that the highest service item for gas ranges is the electronic ignition. 

Darrell Paul (Battelle) stated that the maintenance costs would increase (DOE calculated costs 

based on one service call for the electronic ignition, but the frequency of a failure increases 

because there are two electronic ignitions.) 

Joe Eckert (Harper-Wyman) stated that this standard would no longer allow consumers to cook 

during power outages. Kathi Epping stated that the cooktop could be lit with a match during an 

outage. 

Frank Stanonik (GAMA) and Joe Geary (Peerless-Premier) raised safety concerns. They stated 

that low income consumers may use extension cords or other unsafe measures to avoid the cost to 

install a properly grounded outlet. 

Mark Friedrichs (DOE PO) stated that we should investigate how the safety issues were dealt 

with under the state bans of standing pilot lights. 

The industry representatives stated that they would call DOE within a week to inform the 

Department how much time it will take to gather the requested information. 

fuel switching is unlikely to occur because the manufacturer could produce a low end electronic 

ignition for $235, and the consumer would continue to buy it over the electric range due to low 

gas prices compared to electric. 

Joe Eckert (Harper-Wyman) stated that he would send DOE a copy ofa Consumers Union report 

that the highest service item for gas ranges is the electronic ignition. 

Darrell Paul (Battelle) stated that the maintenance costs would increase (DOE calculated costs 

based on one service call for the electronic ignition, but the frequency of a failure increases 

because there are two electronic ignitions.) 

Joe Eckert (Harper-Wyman) stated that this standard would no longer allow consumers to cook 

during power outages. Kathi Epping stated that the cooktop could be lit with a match during an 

outage. 

Frank Stanonik (GAMA) and Joe Geary (Peerless-Premier) raised safety concerns. They stated 

that low income consumers may use extension cords or other unsafe measures to avoid the cost to 

install a properly grounded outlet. 

Mark Friedrichs (DOE PO) stated that we should investigate how the safety issues were dealt 

with under the state bans of standing pilot lights. 

The industry representatives stated that they would call DOE within a week to inform the 

Department how much time it will take to gather the requested information. 
Industry Meeting With U. S. Department of Energy (DOE) on 

Proposed Ban w Use of Standing Pilots With Gas Ranges, 

DOE Docket Nos. EE-R1M-90-201 and EE-RM-5-97-700 

May 15,1998 

DOE Head-= 

SVashhgton, D.C. 

Expected Attendance: 

Michael McCabe 

Carl Adams 

Kathi Epping 

Mark Friedrichs 

Eugcne Uafgolis 

A. Introductions 

Deds St. Gennain 

Joe Eckert 

Linda Oreiner 

Joe Geary 

Jim Ruberti 

Joe Mattingly 

Frank A. Stanonik 

Jim Ranform 

Ted Williams 

Darrell Paul 

%; is+;e &iL~t~ecHarper-Wyman 

Harper-wyman 

Frigidaire 

Peerless-Premier 

Brown Stove 

GAMA 

GAMA 

A.G.A. 

kG.A. 

Battclle 

PiGh 

B. Purpose of Meeting (Joe Mattingly) 

C. Discussion of Subjects Where DOE D~lta/Conclusions Do Not Match Industry 

DatalProjections 

1. Number of Consumers Impactcd by Proposed Pilot Light Ban 

2. Cost Impacts to Consumers 

a. Higher range purchase price 

b. Need to install electrical outlet 

c. Cost to install electrical outlet 

d Higher maintenance costs 

e. Life Cycle Cost Projections 

f. Impact on low-income famiIies and public housing 

3. Extent of National Energy Savings hm Proposed Pilot Light Ban 

4. Loss of Product Utility (N4ECA Constraints) 

5, Health and Safety Issues Raised by NaDC 

D. Industry Recommendations to DOE 

EE-RM-S-97-700_EERE-1997-STD-0070 COMMENT 41

AGENDA 

Industry Meeting With U. S. Department of Energy (DOE) on 

Proposed Ban on Use of Standing Pilots With Gas Ranges, 

DOE Docket Nos. EE·RM-90-201 and EE-RM-5-97-700 

Expected Attendance: 

Michael McCabe 

Carl Adams 

Kathi Epping 

Mark Friedrichs 

Eugene Margolis 

A. Introductions 

B. Purpose of Meeting (Joe Mattingly) 

Industry 

Dennis 81. Germain 

Joe Eckert 

Linda Greiner 

Joe Geary 

Jim Ruberti 

Joe Mattingly 

Frank. A. 8tanonik: 

JimRanfone 

Ted Williams 

Darrell Paul 

~st~~ 

Harper-Wyman 

Harper-Wyman 

Frigidaire 

Peerless-Premier 

Brown Stove 

GAMA 

GAMA 

A.O.A. 

A.O.A. 

Battelle 

C. Discussion of Subjects Where DOE Data/Conclusions Do Not Match Industty 

DataJProjections 

1. Number of Consumers Impactcxi by Proposed Pilot Light Ban 

2. Cost Impacts to Consumers 

a. Higher range purchase price 

b. Need to install electrical outlet 

c. Cost to install electrical outlet 

d Higher maintenance c;osts 

e. Life Cycle Cost Projections 

f. Impact on low-income families and public housing 

3. Extent of National Energy Savings from Proposed Pilot Light Ban 

4. Loss of Product Utility (NAECA Constraints) 

5. Health and Safety Issues Raised by NRDC 

D. Industry Recommendations to DOE 

AGENDA 

Industry Meeting With U. S. Department of Energy (DOE) on 

Proposed Ban on Use of Standing Pilots With Gas Ranges, 

DOE Docket Nos. EE·RM-90-201 and EE-RM-5-97-700 

Expected Attendance: 

Michael McCabe 

Carl Adams 

Kathi Epping 

Mark Friedrichs 

Eugene Margolis 

A. Introductions 

May 15,1998 

DOE Headquarters 

Washington, D.C. 

Industry 

Dennis 81. Germain 

Joe Eckert 

Linda Greiner 

Joe Geary 

Jim Ruberti 

Joe Mattingly 

Frank. A. 8tanonik: 

JimRanfone 

Ted Williams 

Darrell Paul 

~st~~ 

B. Purpose of Meeting (Joe Mattingly) 

Harper-Wyman 

Harper-Wyman 

Frigidaire 

Peerless-Premier 

Brown Stove 

GAMA 

GAMA 

A.O.A. 

A.O.A. 

Battelle 

C. Discussion of Subjects Where DOE Data/Conclusions Do Not Match Industty 

DataJProjections 

1. Number of Consumers Impactcxi by Proposed Pilot Light Ban 

2. Cost Impacts to Consumers 

a. Higher range purchase price 

b. Need to install electrical outlet 

c. Cost to install electrical outlet 

d Higher maintenance c;osts 

e. Life Cycle Cost Projections 

f. Impact on low-income families and public housing 

3. Extent of National Energy Savings from Proposed Pilot Light Ban 

4. Loss of Product Utility (NAECA Constraints) 

5. Health and Safety Issues Raised by NRDC 

D. Industry Recommendations to DOE 
Gas Range Market 

2,485,000 Freestanding Gas Ranges were produced in 1997 - 

per AHAM Data. 

673,000 units or 27% of the total produced in 1997 are Constant 

Burning Pilot Ranges - per Harper-Wyman Data 

1,538,500 Gas Ranges in 1997 were purcl~ased to replace ail 

older gas range - per Appliance Magazine Data. 

The consumer chose to replace their range with a Constant 

Burning Pilot Range due to: 

- The Consumer cannot use a range with an electrical cord 

- The Consumer chose this range because of the low cost of 

this model 

EE-RM-S-97-700_EERE-1997-STD-0070 COMMENT 41

Gas Range Market 

• 2,485,000 Freestanding Gas Ranges were produced in 1997 -

per AHAM Data. 

• 673,000 units or 27% of the total produced in 1997 are Constant 

Burning Pilot Ranges - per Harper-Wyman Data 

• 1,538,500 Gas Ranges in 1997 were purcllased to replace all 

older gas range - per Appliance Magazine Data. 

• The consumer chose to replace their range witll a Constant 

Burning Pilot Range due to: 

- The Consumer cannot use a range with an electrical cord 

- The Consumer chose this range because of the low cost of 

this model 

Gas Range Market 

• 2,485,000 Freestanding Gas Ranges were produced in 1997 -

per AHAM Data. 

• 673,000 units or 27% of the total produced in 1997 are Constant 

Burning Pilot Ranges - per Harper-Wyman Data 

• 1,538,500 Gas Ranges in 1997 were purcllased to replace all 

older gas range - per Appliance Magazine Data. 

• The consumer chose to replace their range witll a Constant 

Burning Pilot Range due to: 

- The Consumer cannot use a range with an electrical cord 

- The Consumer chose this range because of the low cost of 

this model 
Gas Range Market 

a 673,000 consumers will be impacted by a ban to constant 

burning pilot gas ranges. The greatest impact will be to low 

income families who have purchased older homes in urban 

areas, and retired families in urban axeas. 

- Homeowners with older homes must install a grounded 

outlet behind the gas range back to tl~e fuse box 

- Older apartment buildings must install a grounded outlet 

behind the gas range back to the fuse box 

- Older Government Supported High Rise Public Housing 

must install a grounded outlet behind the gas range back 

to the fuse box at a tremendous cost. 

Banning the lowest cost gas range in the market place will 

drive some consumers to purchase the lowest cost electric 

range. This will increase energy usage and negate any 

savings in gas consumption. 

EE-RM-S-97-700_EERE-1997-STD-0070 COMMENT 41

Gas Range Market 

• 673,000 consumers will be impacted by a ban to constant 

burlling pilot gas ranges. The greatest impact will be to low 

income families who Ilave purchased older homes in urban 

areas, alld retired families in urban areas. 

- Homeowners with older homes must install a grounded 

outlet behilld the gas range back to tIle fuse box 

- Older apartmellt buildings must install a grounded outlet 

bellind the gas range back to the fuse box 

- Older Governmellt Supported Higil Rise Public Housillg 

must install a grounded outlet bellind tIle gas range back 

to the fuse box at a tremelldous cost. 

• Banning the lowest cost gas range in the market place will 

drive some consumers to purchase the lowest cost electric 

rallge. This will increase energy usage alld negate allY 

savings ill gas consumption. 

Gas Range Market 

• 673,000 consumers will be impacted by a ban to constant 

burlling pilot gas ranges. The greatest impact will be to low 

income families who Ilave purchased older homes in urban 

areas, alld retired families in urban areas. 

- Homeowners with older homes must install a grounded 

outlet behilld the gas range back to tIle fuse box 

- Older apartmellt buildings must install a grounded outlet 

bellind the gas range back to the fuse box 

- Older Governmellt Supported Higil Rise Public Housillg 

must install a grounded outlet bellind tIle gas range back 

to the fuse box at a tremelldous cost. 

• Banning the lowest cost gas range in the market place will 

drive some consumers to purchase the lowest cost electric 

rallge. This will increase energy usage alld negate allY 

savings ill gas consumption. 
Higher Range Purchase Price 

The Constant Burning Pilot Gas Range is the lowest cost gas 

range the consumer can purchase. The retailer uses this 

range as a loss leader to compete with the lowest cost electric 

range. 

The Mass Merchandiers' Retail a Constant Burning Pilot 

Range at $200. Per newspaper advertisements. 

The major range manufacturers do not have a electric 

ignition gas model that would retail for $37 more than the 

Constant Burning Pilot M-odel. Typical retail price for an 

electric ignition model is $350 to $400. Per newspaper 

advertisements. 

EE-RM-S-97-700_EERE-1997-STD-0070 COMMENT 41

Higher Range Purchase Price 

• The Constant Burning Pilot Gas Range is tl1.e lowest cost gas 

range tl1.e consumer can purchase. TI1.e retailer uses this 

range as a loss leader to compete with the lowest cost electric 

range. 

• The Mass Merchandiers' Retail a Constal1.t BUrl1.il1.g Pilot 

Range at $200. Per newspaper advertisements. 

• The major range manufacturers do not 11.ave a electric 

ignition gas model tl1.at would retail for $37 more than tI1.e 

Constant Burnil1.g Pilot Model. Typical retail price for an 

electric ignition model is $350 to $400. Per newspaper 

advertisements. 

Higher Range Purchase Price 

• The Constant Burning Pilot Gas Range is tl1.e lowest cost gas 

range tl1.e consumer can purchase. TI1.e retailer uses this 

range as a loss leader to compete with the lowest cost electric 

range. 

• The Mass Merchandiers' Retail a Constal1.t BUrl1.il1.g Pilot 

Range at $200. Per newspaper advertisements. 

• The major range manufacturers do not 11.ave a electric 

ignition gas model tl1.at would retail for $37 more than tI1.e 

Constant Burnil1.g Pilot Model. Typical retail price for an 

electric ignition model is $350 to $400. Per newspaper 

advertisements. 
Higher Range Purchase Price 

The Retailers advertise like models of gas and electric 

ranges at certain price points. If the low cost gas 

model is taken out of the marketplace, we are driving 

consumers to purchase the low cost electric range 

which will defeat the energy savings. A ban on the 

low cost gas range gives the electric range an unfair 

advantage in tl~e retail marketplace. 

EE-RM-S-97-700_EERE-1997-STD-0070 COMMENT 41

Higher Range Purchase Price 

• The Retailers advertise like models of gas and electric 

ranges at certain price POiIltS. If tl1e low cost gas 

model is taken out of the marketplace, we are driving 

consumers to purchase tl1e low cost electric range 

wl1ich will defeat t11e energy savings. A ban on the 

low cost gas range gives the electric range an unfair 

advantage in t11e retail marketplace. 

Higher Range Purchase Price 

• The Retailers advertise like models of gas and electric 

ranges at certain price POiIltS. If tl1e low cost gas 

model is taken out of the marketplace, we are driving 

consumers to purchase tl1e low cost electric range 

wl1ich will defeat t11e energy savings. A ban on the 

low cost gas range gives the electric range an unfair 

advantage in t11e retail marketplace. 
Impact to Low Income Families and 

Public Housing By Banning Constant 

Burning Pilot Ranges 

673,000 consumers will be forced into spending more money 

to buy a replacement gas range 

- Forced to pay a higher price for a replacement range 

- Longer payment terms if purchased on a credit card 

- Higher interest cost over payment terms 

- Impact to increase Consumer Debt 

If all consumers must install an outlet and buy a gas range 

with an electrical cord 

- Using the D.O.E. Data 

$127 Cost Adder x 673,000 Consumers = $85,471,000 increase 

to Consumer National Debt 

EE-RM-S-97-700_EERE-1997-STD-0070 COMMENT 41

Impact to Low Income Families and 

Public Housing By Banning Constant 

Burning Pilot Ranges 

• 673/000 consumers will be forced irlto spending more money 

to buy a replacement gas range 

- Forced to pay a higlier price for a replacement range 

- Longer payment terms if purchased on a credit card 

- Higher interest cost over paymelit terms 

- Impact to increase Consumer Debt 

• If all COlisumers must install an outlet and buy a gas range 

with ali electrical cord 

- Using the D.O.E. Data 

$127 Cost Adder x 673/000 Consumers = $85/471/000 ilicrease 

to Consumer National Debt 

Impact to Low Income Families and 

Public Housing By Banning Constant 

Burning Pilot Ranges 

• 673/000 consumers will be forced irlto spending more money 

to buy a replacement gas range 

- Forced to pay a higlier price for a replacement range 

- Longer payment terms if purchased on a credit card 

- Higher interest cost over paymelit terms 

- Impact to increase Consumer Debt 

• If all COlisumers must install an outlet and buy a gas range 

with ali electrical cord 

- Using the D.O.E. Data 

$127 Cost Adder x 673/000 Consumers = $85/471/000 ilicrease 

to Consumer National Debt 
Impact To Low Income Families And Public 

Housing By Banning Constant Burning Pilot 

Ranges 

* Cost impact to Apartment Building Owners and Renters 

- Installing a grounded outlet behind a range to the fuse 

box in older buildings will cost more than the D.O.E.'s 

estimate of $90. T11e actual cost will be passed onto the 

renter. 

* Cost impact to Government Supported Public Housing 

- The cost to install an outlet behind a range to the fuse box 

through plaster walls will be cost prohibitive and not 

achieve a life cycle cost savings. 

- A cost estimate should come from a City Manager of 

Public Housing to determine the true financial impact to 

Public Housing Buildings. 

- If there is no life cycle cost savings, then the general 

taxpayers are forced to fund this entire cost. 

EE-RM-S-97-700_EERE-1997-STD-0070 COMMENT 41

15.(.( fY/-S ~. 7' 7 - 700 4J 

Impact To Low Income Families And Public 

Housing By Banning Constant Burning Pilot 

Ranges 

• Cost impact to ApartmelLt Building Owners and Renters 

- Installing a grounded outlet behind a range to the fuse 

box in older buildings will cost more tllan the D.O.E.' s 

estimate of $90. TILe actual cost will be passed onto tIle 

renter. 

• Cost impact to Government Supported Public Housillg 

- The cost to install an outlet behind a ralLge to the fuse box 

througll plaster walls will be cost prollibitive and not 

achieve a life cycle cost savilLgs. 

- A cost estimate sllould come from a City Manager of 

Public Housing to determine the true fillancial impact to 

Public Housing Buildings. 

- If there is no life cycle cost savillgs, thell tIle general 

taxpayers are forced to fund this entire cost. 

15.(.( fY/-S ~. 7' 7 - 700 4J 

Impact To Low Income Families And Public 

Housing By Banning Constant Burning Pilot 

Ranges 

• Cost impact to ApartmelLt Building Owners and Renters 

- Installing a grounded outlet behind a range to the fuse 

box in older buildings will cost more tllan the D.O.E.' s 

estimate of $90. TILe actual cost will be passed onto tIle 

renter. 

• Cost impact to Government Supported Public Housillg 

- The cost to install an outlet behind a ralLge to the fuse box 

througll plaster walls will be cost prollibitive and not 

achieve a life cycle cost savilLgs. 

- A cost estimate sllould come from a City Manager of 

Public Housing to determine the true fillancial impact to 

Public Housing Buildings. 

- If there is no life cycle cost savillgs, thell tIle general 

taxpayers are forced to fund this entire cost. 
Impact To Low Income Families And 

Public Housing 

During a power outage, Constant Burning Pilot Ranges can 

still be used for cooking. The ice storm and loss of power in 

the Northeast this past winter, is a good example of how 

important this feature can be to the consumer. 

Life cycle cost will increase with electric ignition gas ranges 

- The cost to service an electric ignition range is higher than 

a constant burning pilot range. 

The D.O.E.'s position is to allow standing pilots on cooktops 

and wall ovens. The typical older home/ apartment/ public 

housing does not have room in the kitchen to install a cooktop 

into the countertop, and build the oven into the wall cabinets. 

This is not a simple cost option for the consumer. The cost of 

this option greatly exceeds the cost of a freestanding range. 

EE-RM-S-97-700_EERE-1997-STD-0070 COMMENT 41

£ -/(m -3 .:;:/f '1/ 

Impact To Low Income Families And 

Public Housing 

• During a power outage, Constant Burning Pilot Ranges can 

still be used for cooking. The ice storm and loss of power in 

the Northeast this past winter, is a good example of how 

important this feature can be to tIle consumer. 

• Life cycle cost will increase witlL electric ignition gas ranges 

- TILe cost to service alL electric ignition range is higher than 

a constant burning pilot range. 

• TILe D. 0 .E.' S POSitiOIL is to allow standing pilots on cooktops 

and wall ovens. The typical older home/apartment/public 

ILousing does not have room in tILe kitchen to install a cool<top 

ilLtO tILe countertop, and build tILe oven into tILe wall cabinets. 

This is not a simple cost option for tILe consumer. The cost of 

tl1.is option greatly exceeds tILe cost of a freestandirlg range. 

£ -/(m -3 .:;:/f '1/ 

Impact To Low Income Families And 

Public Housing 

• During a power outage, Constant Burning Pilot Ranges can 

still be used for cooking. The ice storm and loss of power in 

the Northeast this past winter, is a good example of how 

important this feature can be to tIle consumer. 

• Life cycle cost will increase witlL electric ignition gas ranges 

- TILe cost to service alL electric ignition range is higher than 

a constant burning pilot range. 

• TILe D. 0 .E.' S POSitiOIL is to allow standing pilots on cooktops 

and wall ovens. The typical older home/apartment/public 

ILousing does not have room in tILe kitchen to install a cool<top 

ilLtO tILe countertop, and build tILe oven into tILe wall cabinets. 

This is not a simple cost option for tILe consumer. The cost of 

tl1.is option greatly exceeds tILe cost of a freestandirlg range. 
EE-RM-S-97-700_EERE-1997-STD-0070 COMMENT 41

or details. 

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es 

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• Delicate & permanent 

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- Self-cleaning 

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I I 

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cycles including 

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·3 drying temperatures 

• Front-mounted 

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Expert Dishwasher 

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Jf details. 

r 

:enfood 

es 

Jp! 

!from 

121/98. 

I 

Super Capacity 

Washer 

·2 wash/spin speeds 

• Delicate & permanent 

press cycles 

- 4 temperatures & 

5 water levels 

- Self-cleaning 

lint filter 

I I 

-4 drying 

cycles including 

permanent press 

·3 drying temperatures 

• Front-mounted 

lint filter 

-Automatic 

drying sensor 

Expert Dishwasher 

Installation Available! 

-Scycles 

including delicates 

- 2 wash/spin speeds 

·3 water levels 

- Bleach & fabric 

softener dispenser 

GAFFERS~SATTLER 

.30" Gas Range 

- Upswept cooktop 

- 4" backguard 

-Soliddoor 

I I 

02 cycles 

• 2 temperatures 

° Up-front lint filter 

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'or A Special Appliance? 

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• Auto-Sense 

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your sales counselor 

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