Recommendations for New
Massachusetts Appliance
Standards
To: Jerrylyn Huckabee
Regulatory and Innovation Manager, Energy Efficiency Division
Massachusetts Department of Energy Resources (DOER)
From: Claire Miziolek
Senior Manager
Energy Solutions
cmiziolek@energy-solution.com
Date: October 18, 2024
Table of Contents
Background and Summary .............................................................................................................................4
New Standard Recommendations and Legislative Changes ..................................................................5
Automatic Landscape Irrigation Controllers ..........................................................................................5
Gas Fireplaces ...............................................................................................................................................6
Flexible Demand Appliance Standards (FDAS) Authority ..................................................................7
Revisions for Electric Vehicle Supply Equipment (EVSE) Standard .................................................8
Waivers and Regulatory Flexibility ....................................................................................................... 10
Conclusion ...................................................................................................................................................... 11
Appendix 1: Proposed Legislative Language .......................................................................................... 12
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About Energy Solutions
Energy Solutions is a mission-driven clean energy implementation firm that specializes in
programs that align with the market to deliver significant resource impacts. For 25 years we’ve
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This report was prepared for the Massachusetts Department of Energy Resources.
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Background and Summary
Appliance standards establish minimum energy and water efficiency or load flexibility
requirements for products. Appliance standards help to reduce customer utility bills,
greenhouse gas emissions, peak load, grid impacts, and water consumption. When properly
administered, they increase equitable access to higher quality products by removing the least-
efficient, worst-performing products from the market. The U.S. Department of Energy (DOE)
adopts national standards for dozens of residential, commercial, and industrial products. 1 With
the exception of plumbing fixtures, states can only establish efficiency standards for products
not covered by DOE. 2
For states, consumers, utilities, and other stakeholders, appliance standards provide significant
savings opportunities. As of 2023, 13 states and Washington D.C. have adopted state
appliance standards. Massachusetts adopted a suite of appliance standards in 2021 as part of
Chapter 8 of the Acts of 2021: An Act Creating a Next-Generation Roadmap for
Massachusetts Climate Policy, regulating 18 product categories. These standards have taken
effect in the Commonwealth, and this report provides recommendations for legislative updates
to the Massachusetts appliance standards to adopt new standards, make adjustments to the
current appliance standards, and amend the enforcement authority of DOER to make the
standards set forth in M.G.L. c. 25B(3) more practicable, for unforeseeable or unique
circumstances, as required by M.G.L. c. 25B(10).
Table 1. Recommendations for New Appliance Efficiency Standards
Product Reasoning Savings
Automatic This new standard was recently added to the ASAP This product has water savings for
landscape irrigation Model Bill and largely aligns with recent standards in non-agricultural irrigation
controllers CO and proposed in CA. systems.
This new standard would align with the gas saving
This standard would result in gas
Gas fireplaces requirements of New York, Nevada, Rhode Island,
consumption savings.
and Canadian standards.
This new language would provide DOER the FDAS would result in shifting of
Flexible demand authority to establish regulations that enable grid electricity usage to avoid peak
appliance standards interactivity of appliances. This authority is similar to electricity constraints and reduce
(FDAS) that of the California Energy Commission, and states electric system greenhouse gas
including CO, WA, and OR have established FDAS. emissions.
Electric Vehicle This update to the EVSE standard language allows for This is expected to have negligible
Supply Equipment necessary flexibility to ensure EVSEs can be installed impact on energy efficiency
(EVSE) to support broader decarbonization policy objectives. compared to the current standard.
This update is expected have
This new language would provide DOER the
Waivers negligible impact on the impact of
authority to grant limited waivers.
any existing standards.
1 https://www.energy.gov/eere/buildings/standards-and-test-procedures
2
DOE has nationally waived state preemption for plumbing products thus allowing states to set more stringent
plumbing standards; however, all other products cannot have more stringent efficiency standards set at the
state level without a waiver granted by DOE. https://www.energy.gov/eere/buildings/articles/appliance-and-
equipment-standards-fact-sheet
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New Standard Recommendations and
Legislative Changes
The following product categories and legislative adjustments are being recommended.
Automatic Landscape Irrigation Controllers
Automatic landscape irrigation controllers, which are connected to permanently plumbed
irrigation (or sprinkler) systems, control the frequency, start time, and duration of irrigation
based on external information. These controls support saving water that would otherwise be
unnecessarily used. The proposed standards save water (and, ultimately energy due to the
energy use required to operate water systems) through requirements regulating the control of
these systems to ensure they are operating when necessary (i.e., ensuring sprinkler systems do
not run during rainy weather). These standards are already established in Colorado and similar
standards have been proposed in California. 3 We recommend adopting the following definition
and granting DOER authority to ultimately establish performance requirements, as follows:
Said section 5 of said chapter 25B is hereby further amended by inserting:
“Automatic landscape irrigation controller” means a device used to remotely control
valves that operate a landscape irrigation system. Such devices include, but are not
limited to, weather-based irrigation controllers, soil moisture-based irrigation
controllers, and timer-based irrigation controllers, whether configured as a standalone
controller, a base controller, an add-on device, or a plug-in device. “Automatic
landscape irrigation controller” does not include irrigation control devices designed for
attachment to a hose bib or a hose end or those designed and marketed for agricultural
purposes.
Said section 5 of said chapter 25B is hereby further amended by inserting:
The commissioner may adopt and update regulations for Automatic Landscape
Irrigation Controls in order to facilitate the achievement of the people and the
commonwealth’s goals and objectives for climate mitigation.
Anticipated impact:
According to analysis conducted by the Appliance Standards Awareness Project (ASAP), 4 a
compliant product may cost up to $99 more than a non-compliant product, however given
significant water bill savings, that cost would be paid back in savings in just over 9 months. The
potential annual savings from an irrigation controller standard in Massachusetts in 2030 would
3
CO established through HB23-1161 passed in 2023, and CA docket:
https://efiling.energy.ca.gov/Lists/DocketLog.aspx?docketnumber=17-AAER-10
4 https://appliance-
standards.org/sites/default/files/2024_Massachusetts_Appliance_Standards_Savings_Report.pdf
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be 384 million gallons of water, which grows to 1,212 million gallons in 2040 and the
associated aggregate annual utility bill savings are expected to be up to $22.7 million in 2040.
Statewide metric 2030 Annual Savings 2040 Annual Savings
Water 384 million gallons 1,212 million gallons
Utility bill $6.2 million $22.7 million
Incremental cost Up to $99
Payback Period .7 years
Gas Fireplaces
Gas fireplaces are products that burn natural gas to provide either supplemental space heating
or a decorative aesthetic in a fireplace or stove. There are multiple configurations for these
products, but ultimately, they all provide the same function. State standards can provide
energy savings by reducing the usage of pilot lights and other ignition designs which result in
constant natural gas and energy use even when the product is not otherwise in use. These
standards are already established in Nevada, New York, Rhode Island, as well as in Canada. We
recommend the following requirements:
Said section 2 of said chapter 25B is hereby further amended by inserting the following
definitions:
• “Gas fireplace” means a decorative gas fireplace or a heating gas fireplace.
• "Decorative gas fireplace" means a vented fireplace, including appliances that are
freestanding, recessed, zero clearance, log set, or a gas fireplace insert, that is
fueled by natural gas or propane, is marked for decorative use only, and is not
equipped with a thermostat or intended for use as a heater.
• "Heating gas fireplace" means a vented fireplace, including appliances that are
freestanding, recessed, zero clearance, or a gas fireplace insert, that is fueled by
natural gas or propane and is not a decorative fireplace.
Said section 5 of said chapter 25B is hereby further amended by inserting the following
requirements:
• Gas fireplaces shall be capable of automatically extinguishing any pilot flame when
the main gas burner flame is extinguished.
• Gas fireplaces must prevent any ignition source for the main gas burner flame from
operating continuously for more than seven days from last use of the main burner.
Anticipated impact:
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According to analysis conducted by ASAP, 5 a compliant product may cost up to $38 more than
a non-compliant product, however given gas utility bill savings, that cost would be paid back in
savings in just over 9 months. The potential annual savings from a gas fireplace standard in
Massachusetts in 2030 would be 46 billion Btus of gas, which grows to 149 billion Btus in
2040. 6 As a gas saving technology, ASAP anticipated 7,900 metric tons of CO2 and 6.7 tons of
NOx to be reduced by 2040. The annual utility bill savings are expected to be up to $2.7
million in 2040.
Statewide metric 2030 Annual Savings 2040 Annual Savings
Gas 46 billion Btus 149 billion Btus
CO2 2,500 metric tons 7,900 metric tons
NOx 2.1 tons 6.7 tons
Utility bill $700,000 $2.4 million
Incremental cost Heating Fireplace: $38 Decorative Fireplace: $37
Payback Period .7 years
Flexible Demand Appliance Standards (FDAS) Authority
Grid enabled products have the capability to shift timing of when they consume electricity
to better match energy demand and supply, as well as enable excess renewable electricity
production to be used rather than curtailed. Appliance standards that establish requirements
for grid interactivity functionality are known as Flexible Demand Appliance Standards (FDAS).
FDAS have significant benefits when deployed, including improving grid reliability, minimizing
electrical grid greenhouse gas emissions, and cost benefits to consumers as the share of
intermittent renewable wind and solar power grows. When grid-enabled products are enrolled
in utility demand response programs, consumers have the opportunity to get paid for
participation in programs. The California Energy Commission has a program to establish new
FDAS,7 and several other states including Colorado, Washington, and Oregon have established
individual flexible demand appliance standards. 8
FDAS will eventually provide savings to household and business energy bills, which are
increasingly important to low-income households and small businesses. FDAS do not require
5 https://appliance-
standards.org/sites/default/files/2024_Massachusetts_Appliance_Standards_Savings_Report.pdf
6 Ibid.
7
https://www.energy.ca.gov/proceedings/active-proceedings/flexible-demand-appliances
8
Colorado established smart thermostat and flexible demand water heater standards through HB23-1161
passed in 2023. Washington and Oregon established flexible demand water heater standards through the
passage of HB 1444 in 2019 and HB 2062 in 2021, respectively.
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enrollment in demand flexibility programs, and therefore the standard itself does not impact
the performance of equipment. Instead, authorizing DOER to establish FDAS through
regulations would ensure that products installed in Massachusetts have the built-in capabilities
to become a flexible load resource such that residents have the opportunity to participate in
programs that provide an incentive for moving load to different times of day. This standard
would not result in direct energy or emissions savings, but would instead be an enabling
requirement to help ensure that there would be a sufficient installed base for effective load
shifting as a grid resource. Load flexibility is anticipated to be one of the least-cost strategies to
support decarbonization in Massachusetts. 9 Authorizing flexible demand standards would
ensure communication pathways that enable effective load shifting and align with industry
developed definitions for these capabilities, as follows:
Said section 2 of said chapter 25B is hereby further amended by inserting:
“Flexible demand” means the capability to schedule, shift, or curtail the electrical
demand of a load-serving entity’s customer through direct action by the customer or
through action by a third party, the load-serving entity, or a grid balancing authority,
with the customers consent.
“Flexible demand appliance standard” means a requirement for flexible demand
capabilities for a covered product.
Said section 5 of said chapter 25B, as so appearing, is hereby further amended by inserting:
The commissioner may adopt and update regulations for the standards for any
appliances to facilitate the deployment of flexible demand technologies. The
regulations may include labeling provisions to promote the use of appliances with
flexible demand capabilities. The flexible demand appliance standards shall be based on
feasible and attainable efficiencies or feasible improvements that will enable appliance
operations to be scheduled, shifted, or curtailed to reduce emissions of greenhouse
gases associated with electricity generation. The standards shall become effective not
earlier than 1 year after the date of their adoption or updating.
Revisions for Electric Vehicle Supply Equipment (EVSE)
Standard
When the initial EVSE standards were adopted in 2021, Massachusetts aligned standards for
Level 1 and Level 2 chargers with what was the current version of ENERGY STAR, V1.0. Level
1 and Level 2 chargers are installed in homes, workplaces, and for public access charging.
Massachusetts did not establish standards for direct current fast chargers (DCFC), which are
9Per the Energy Pathways report from the Massachusetts Decarbonization Roadmap
https://www.mass.gov/2050Roadmap, the DER Breakthrough scenario, which included flexible loads such as
water heaters, was the least cost pathway.
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typically installed in formal stations in heavy traffic corridors and were not included in the
scope of the original V1.0 ENERGY STAR specification.