APGA Opposes ENERGY STAR’s Proposal to Remove Designation from Certain Water Heaters

By Renée Lani posted 10 days ago


On November 9, APGA submitted comments to the U.S. Environmental Protection Agency (EPA) in response to its proposed ENERGY STAR® specifications for gas-fired residential water heaters. In its draft, EPA proposes to remove the label, which easily identifies highly efficient appliances for consumers, from all gas-fired storage water heaters on the market.

EPA’s draft specification, if finalized, would raise the qualifying efficiency level for gas-fired storage water heaters to one that can only be met by heat pump technology. However, no such appliances are currently commercially available, which means no that no gas-fired storage water heaters would be able to don the ENERGY STAR® label.

Through our comments, APGA argued that such a decision was not only contrary to the program’s mission but would also likely result in consumers buying less efficient products. Some APGA members’ appliance rebate programs are dependent on the ENERGY STAR® designation, as are many other rebate programs offered by state governments or other organizations. Without the ENERGY STAR® label easily identifying high-efficiency appliances and because those appliances would no longer qualify for certain rebates, many consumers will buy more affordable alternatives that are unlikely to be as efficient – a downside for both consumers' long term energy costs and the environment.

EPA released the proposed specification days before it released its final recognition criteria for its 2022 Most Efficient appliances, which completely precluded gas-fired appliances from qualifying for the designation. APGA sent an earlier letter to the agency outlining the negative impacts to efficiency and innovation that this misguided decision may lead to.

A copy of the comments on the draft specification is available here. For questions on this article, please contact Renée Lani of APGA staff by phone at 202-464-0836 or by email at rlani@apga.org.