Minutes ofmeeting with Gas ApplianceManufacturers 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 ofGAMA and AGA, opposes theban 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 drivenproduct. Concernwas stated that aban on pilot lightsmay causepeople to switchfrom gasto electric ranges. Mr. Eckert speculated that older homes may not have a three-pronged, grounded outlet available, and because low income orretired persons often live in older homesthat thesepeople will be adversely affected. Mark Friedrichs (DOEPolicy Office) asked what kind of data the industry had. Carl Adams (DOE OCS) noted that the states ofWI, 

### MN, CA, OR, and NY had bans on pilot lightsin the 1980s. Dennis St. Gerrnain (Harper-Wyman) said he would provide us with datafromthe 1980s. Joe Geary (Peerless-Premier) stated that most gas ranges did not have power cords. Carl Adams (OCS)presented the Final Rule regarding StatePetitions for Exemption from Federal Standards for Clothes Dryers and Kitchen Ranges and Ovens, 49FR 11766 (March 27, 1984),in whichWhite Consolidated Industries commented that from approximately 1980-83the percentage ofranges shippedwith pilot lights had dropped from 58-43% and that Frigidaireno longer sold models with pilot lights. Mark Friedrichs (DOE:PO) stated that the key issue is how many houseshave proper outlets available and how many do not, and what percent ofreplacement market has grounded electricity available. Everyone at the meeting agreed. Frank Stanonik, GAMA, asked ifDOE had tried to work backwardsfrom when the electric code came into efEect ('93) to get an indicationofhow many homes had grounded outlets available. Joe Eckert (Harper-Wyman) stated that it is expensiveto install outletsin olderbuildings with cinder block walls and that the cost is passed on to the renter. Carl Adams (OCS) stated that theNew York Housing Authority stated that their conversionto pilotless ignition (between 1980-95)cost $30-40per outlet installed. Joe Eckert (HarperWyman) stated that this cost was not representative, and DOE agreed.

Minutes ofmeeting with Gas Appliance Manufacturers Association, American Gas Association and DOE Office ofCodes (OCS) and Standards on May 15, 1998
See attached agenda and industry presentation handout. Joe Eckert (Harper-Wyman), a member ofGAMA 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 orretired persons often live in older homes that these people will be adversely affected. Mark Friedrichs (DOE Policy Office) asked what kind ofdata the industry had. Carl Adams (DOE OCS) noted that the states ofWI, 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 thatfrom 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. MarkFriedrichs (DOE PO) stated that the key issue is how many houses have proper outlets available and how many do not, and what percent ofreplacement market has grounded electricity available. Everyone at the meeting agreed. Frank Stanonik, GAMA, asked ifDOE had tried to work backwards from when the electric code came into effect ('93) to get an indication ofhow many homes had grounded outlets available. Joe Eckert (Harper-Wyman) stated that it is expensive to install outlets in olderbuildings 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 ofmeeting with Gas Appliance Manufacturers Association, American Gas Association and DOE Office ofCodes (OCS) and Standards on May 15, 1998
See attached agenda and industry presentation handout. Joe Eckert (Harper-Wyman), a member ofGAMA 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 orretired persons often live in older homes that these people will be adversely affected. Mark Friedrichs (DOE Policy Office) asked what kind ofdata the industry had. Carl Adams (DOE OCS) noted that the states ofWI, 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 thatfrom 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. MarkFriedrichs (DOE PO) stated that the key issue is how many houses have proper outlets available and how many do not, and what percent ofreplacement market has grounded electricity available. Everyone at the meeting agreed. Frank Stanonik, GAMA, asked ifDOE had tried to work backwards from when the electric code came into effect ('93) to get an indication ofhow many homes had grounded outlets available. Joe Eckert (Harper-Wyman) stated that it is expensive to install outlets in olderbuildings 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) statedthat the Department hasbeen tryingto get data on how many people would need toinstall pilot lights, and DOE hasn't been abletoidentify any other data. DOE, in its analysis,tried to calculatethe economicbounds on people who would and would not have toinstall outlets. Joe Eckert (Harper-Wyman) suggestedDOE surveythe population to determine approximately how many homes would need to install grounded outlets. Mark Friedrichs (DOEPO) statedthat the survey would need to includehome visits to a few thousand homesbecause consumer surveys would not be accurate (ie, many consumers do not know ifthey have grounded outlets available.) Michael McCabe (OCS) asked ifthere are indirectwayswe could determine how many homes would need to install outlets. Dennis St Germain (Harper-Wyman) suggested talkingto service companies. Joe Geary (Peerless-Premier) suggestedthat DOE should spend the money to conduct the surveys to get the correct number. KirstieKumer (AGA)requested that DOE use AEO 98 energy forecasts and the Advisory Committee recommendationsfor energy rates. Michael McCabe (OCS) stated that any reanalysis would used AE098 Carl Adams (OCS) asked ifeveryone 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 tobalance the effects on subgroups againstthe big picture. Ted Williams (AGA) questioned why DOE is not promulgating standards for electricnon-selfcleaning ovens,which would save significantenergy. DOE stated that the savingsfor pilotless ignitionis over four timesgreater. Mark Friedrichs (DOE PO) stated that ifwe could obtain shipment data fromthe early eighties, we could determine what happened in the market as a result ofNAECA. He also stated that he was interested in timetrend data on the 673,000 (seepage 1

### ofindustry presentation handout) units with constantburning pilot lightsin order to determineifthe number is still declining quickly or ifit is beginningtoplateau in oderto giveus an indicationofwhat 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 approximatelythe sameprice ofa low end electricmodel. He stated that the electronicignition model sells for $350 (see attached advertisement). Jim Ruberti (Brown Stove) statedthat ifyou needed to install an outlet,you could install one for an electricrange (in orderto buy the low end $200 

### electric range) as easily as one for a gas electronic-ignition range. They both expressed concern over the possibility ofkel switching. KathiEpping (OCS) suggestedthat Michael McCabe (DOE OCS) stated that the Department has been trying to get data onhow 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 ifthey have grounded outlets available.) Michael McCabe (OCS) asked ifthere 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 ifeveryone 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 ifwe 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 ofindustry presentation handout) units with constant burning pilot lights in order to determine ifthe number is still declining quickly or ifit is beginning to plateau in oder to give us an indication ofwhat 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 ofa low end electric model. He stated that the electronic ignition model sells for $350 (see attached advertisement). Jim Ruberti (Brown Stove) stated that ifyou needed to install an outlet, you could install one for an electric range (in orderto buy the low end $200 electric range) as easily as one for a gas electronic-ignition range. They both expressed concern over the possibility offuel switching. Kathi Epping (OCS) suggested that Michael McCabe (DOE OCS) stated that the Department has been trying to get data onhow 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 ifthey have grounded outlets available.) Michael McCabe (OCS) asked ifthere 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 ifeveryone 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 ifwe 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 ofindustry presentation handout) units with constant burning pilot lights in order to determine ifthe number is still declining quickly or ifit is beginning to plateau in oder to give us an indication ofwhat 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 ofa low end electric model. He stated that the electronic ignition model sells for $350 (see attached advertisement). Jim Ruberti (Brown Stove) stated that ifyou needed to install an outlet, you could install one for an electric range (in orderto buy the low end $200 electric range) as easily as one for a gas electronic-ignition range. They both expressed concern over the possibility offuel switching. Kathi Epping (OCS) suggested that

### he1switching is unlikely to occurbecausethe manufacturer could produce a low end electronic ignition for $235, 

### and the consumerwould continueto buy it overthe electric range due to low gasprices comparedto electric. Joe Eckert (Harper-Wyman) stated that he would sendDOE a copy ofa ConsumersUnion report that the highest service item for gasranges isthe electronicignition. DarrellPaul (Battelle) stated that the maintenance costswould increase (DOE calculatedcosts based on one service call for the electronicignition, but the frequency ofa failure increases becausethere are two electronic ignitions.) Joe Eckert (Harper-Wyman) stated that this standardwould no longer allow consumersto cook during power outages. Kathi Epping stated that the cooktop couldbe lit with a match during an outage. Frank Stanonik(GAMA) and Joe Geary (Peerless-Premier)raised safetyconcerns. They stated that low income consumersmay use extensioncordsor otherunsafe measuresto avoid the cost to install aproperly grounded outlet. Mark Friedrichs (DOEPO) statedthat we shouldinvestigatehow the safety issues were dealt with under the statebans of standingpilot 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 occurbecause 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 ofa 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 ofstanding 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 occurbecause 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 ofa 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 ofstanding 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.

### IndustryMeetingWith

### U.S.

### Departmentof

### Energy (DOE) 

### on 

### Proposed

### Ban

### w

### Use of 

### StandingPilots

### WithGas

### Ranges, DOE

### DocketNos.EE-R1M-90-201and

### EE-RM-5-97-700 May 15,1998 

### DOEHead-= SVashhgton, 

### D.C. 

### ExpectedAttendance:


### MichaelMcCabe 

### Carl Adams 

### KathiEpping Mark Friedrichs 

### EugcneUafgolis

A. 

### Introductions 

### Deds

### St.Gennain Joe

### Eckert Linda Oreiner 

### Joe Geary 

### Jim 

### Ruberti Joe

### Mattingly 

### FrankA. 

### Stanonik JimRanform 

### TedWilliams 

### Darrell Paul 

### %; 

### is+;e&iL~t~ec

### Harper-Wyman 

### Harper-wyman Frigidaire Peerless-Premier Brown Stove GAMA 

### GAMA A.G.A. kG.A. 

### Battclle

PiGh


### B. Purposeof

### Meeting (JoeMattingly) C. 

### Discussionof

### SubjectsWhere

### DOED~lta/Conclusions 

### DoNot

### Match Industry DatalProjections 1. 

### Number of

### Consumers

### ImpactcdbyProposed Pilot

### LightBan 2. 

### Cost Impacts to 

### Consumers
a. 

### Higher

### rangepurchase

### price 

### b. Need

### to

### install 

### electricaloutlet c. 

### Costto

### install electrical

### outlet 

### d Highermaintenancecosts e. 

### Life 

### Cycle Cost Projections 

### f. Impacton low-income

### famiIiesand

### publichousing 3. 

### ExtentofNational Energy 

### Savings

### hm ProposedPilotLight

### Ban 4. 

### LossofProduct

### Utility(N4ECA Constraints) 5, 

### Health and 

### Safety 

### IssuesRaisedby

### NaDC 

### D. IndustryRecommendations to 

### DOE AGENDA IndustryMeetingWithU. S. DepartmentofEnergy (DOE) on

ProposedBan on UseofStandingPilots WithGasRanges, DOEDocketNos. EE·RM-90-201 and EE-RM-5-97-700

Expected Attendance:

Michael McCabe Carl Adams Kathi Epping MarkFriedrichs EugeneMargolis

A. Introductions B. Purpose ofMeeting (Joe Mattingly) Industry Dennis 81. Germain Joe Eckert 

### Linda Greiner Joe Geary Jim Ruberti JoeMattingly Frank.A. 8tanonik: JimRanfone TedWilliams Darrell Paul**~st~~** Harper-Wyman Harper-Wyman Frigidaire Peerless-Premier Brown Stove GAMA GAMA A.O.A. A.O.A. Battelle

C. Discussion ofSubjectsWhereDOE Data/Conclusions 

### Do Not Match Industty DataJProjections 1. NumberofConsumers ImpactcxibyProposedPilotLightBan 2. Cost Impacts to Consumers
a. Higherrangepurchaseprice b. Needtoinstall electrical outlet c. Costto install electrical outlet d Highermaintenance c;osts e. Life Cycle CostProjections f. Impactonlow-income families andpublic housing 3. Extent ofNational Energy Savings from Proposed PilotLightBan 4. Loss ofProductUtility(NAECA Constraints) 5. Health and SafetyIssues RaisedbyNRDC D. IndustryRecommendations to DOE AGENDA IndustryMeetingWithU. S. DepartmentofEnergy (DOE) on

ProposedBan on UseofStandingPilots WithGasRanges, DOEDocketNos. EE·RM-90-201 and EE-RM-5-97-700

Expected Attendance:

Michael McCabe Carl Adams Kathi Epping MarkFriedrichs EugeneMargolis

A. Introductions May 15,1998 DOE Headquarters Washington, D.C.
Industry Dennis 81. Germain Joe Eckert 

### Linda Greiner Joe Geary Jim Ruberti JoeMattingly Frank.A. 8tanonik: JimRanfone TedWilliams Darrell Paul**~st~~** B. Purpose ofMeeting (Joe Mattingly) Harper-Wyman Harper-Wyman Frigidaire Peerless-Premier Brown Stove GAMA GAMA A.O.A. A.O.A. Battelle

C. Discussion ofSubjectsWhereDOE Data/Conclusions 

### Do Not Match Industty DataJProjections 1. NumberofConsumers ImpactcxibyProposedPilotLightBan 2. Cost Impacts to Consumers
a. Higherrangepurchaseprice b. Needto install electrical outlet c. Costto install electrical outlet d Highermaintenance c;osts e. Life Cycle CostProjections f. Impactonlow-income families andpublic housing 3. Extent ofNational Energy Savings from Proposed PilotLightBan 4. Loss ofProductUtility(NAECA Constraints) 5. Health and SafetyIssues RaisedbyNRDC D. IndustryRecommendations 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 1997are Constant Burning Pilot Ranges - 

# per Harper-Wyman Data 1,538,500 Gas Ranges in 1997were 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 anelectrical 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 cannotuse 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 cannotuse 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 outletbehind the gas range back to tl~e fuse box

- 

# Older apartmentbuildings 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 outletbehind 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. 

# Gas Range Market
• 673,000 consumers will be impacted by a ban to constant burlling pilot gas ranges. The greatest impactwill 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 outletbehilld 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 outletbellind 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 impactwill 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 outletbehilld 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 outletbellind 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 competewith the lowest cost electric range. The Mass Merchandiers' Retail a Constant Burning Pilot Range at $200. Per newspaper advertisements. The major range manufacturers donot have a electric ignition gas model that would retail for 

# $37more than the Constant Burning Pilot M-odel. Typical retail price for an electric ignition model is 

# $350 

# to $400. Per newspaper advertisements. 

# Higher Range Purchase Price

• The ConstantBurning 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 ConstantBurning 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 atcertain 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 anunfair advantage in tl~e retail marketplace. 

# Higher Range Purchase Price

• The Retailers advertise like models of gas and electric ranges atcertain 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 atcertain 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 

# Impactto Low Income Families and Public Housing By Banning Constant BurningPilot 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



# Impactto Low Income Families and Public Housing By Banning Constant BurningPilot 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. 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 outletbehind 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 costto install an outletbehind 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 outletbehind 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 costto install an outletbehind 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 stillbe 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 anelectric 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. £ -/(m 

### -3 

### .:;:/f 

## '1/ 

# ImpactTo 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 ofpower 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 costto service alL electric ignition range is higher than a constantburning pilotrange. • TILe D.0 .E.'SPOSitiOIL is to allow standing pilots on cooktops and wall ovens. The typical older home/apartment/public ILousing does nothave 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/ 

# ImpactTo 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 ofpower 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 costto service alL electric ignition range is higher than a constantburning pilotrange. • TILe D.0 .E.'SPOSitiOIL is to allow standing pilots on cooktops and wall ovens. The typical older home/apartment/public ILousing does nothave 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.efor details. 

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# es Jp!
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5water levels

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lintfilter 

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# I

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lintfilter -Automatic

drying sensor 

## Expert Dishwasher 

# Installation Available! -Scycles including delicates - 2 wash/spin speeds ·3water levels

- Bleach & fabric softenerdispenser**GAFFERS~SATTLER** .30" Gas Range

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