On April 5, APGA met with Environmental Protection Agency (EPA) ENERGY STAR® staff and program contractors to discuss its proposed specifications for gas-fired residential water heaters. During this discussion, APGA reiterated the importance of ENERGY STAR® continuing to include commercially-available, highly efficient gas-fired appliances in its labeling program.
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 that no gas-fired storage water heaters would be able to don the ENERGY STAR® label.
In November 2021,
APGA submitted comments to EPA in response to the proposed specification. Through the 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 likely to not be as efficient – a downside for both the consumers’ long term energy costs and the environment.
ENERGY STAR®’s proposal to remove its label from gas-fired storage water heaters is one of several examples of EPA using the program to further what are seen as pro-electrification policies. In 2021, EPA also released its final recognition criteria for its 2022 Most Efficient appliances, which completely precluded gas-fired appliances from qualifying for the designation. APGA sent a letter to the agency outlining the negative impacts to efficiency and innovation that this misguided decision may lead to. APGA staff reiterated these concerns in its meeting with EPA this week.
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.