CFA joined other advocates in supporting the proposed test methods outlined in the NOPR and urge DOE to expeditiously finalize the proposed test procedures. There are currently no performance-based efficiency standards in place for cooktops, and DOE has missed its legal deadline for publishing a final rule for standards. Performance-based standards have the potential to achieve significantly greater savings than prescriptive requirements; however, performance-based test procedures are required for DOE to establish these standards. DOE has conducted significant round robin testing and has found the proposed test procedures to be adequately repeatable and reproducible without being overly burdensome to conduct. Therefore, we urge DOE to finalize the test procedures for cooktops as soon as possible to allow the Department to develop standards that can deliver large energy savings.