APGA Pushes Back Against DOE’s Proposed Commercial Water Heating Rule

By Renée Lani posted 08-04-2022 02:35 PM

On August 1, APGA submitted joint comments in response to the Department of Energy’s (DOE) notice of proposed rulemaking (NOPR) pertaining to commercial water heating equipment (CWH), specifically consumer hearth heaters. Through the comment letter, APGA and other gas industry stakeholders argued that the proposed condensing-only efficiency standard for these appliances was unjustified.

Similar to what DOE has proposed for the Furnace Rule, DOE would like to set a condensing-only standard for CWHs. This means that when any existing non-condensing appliances are required to be replaced, a building owner would be forced to do a retrofit to allow for the new venting requirements, which is not always possible—else install an electric appliance, which would also likely require an upgrade to the electrical panel. Through the comments, APGA and others raised many technical concerns with the rulemaking and why it is not economically justified. The comments were jointly submitted with the American Gas Association (AGA), the National Propane Gas Association (NPGA), and Spire Inc.

APGA weighs in on DOE’s appliance efficiency rulemakings that impact gas-fired appliances, as APGA members provide the energy needed to fuel these appliances, thus making public natural gas systems critical stakeholders in these rulemakings.

A copy of the comments and relevant attachments are available here

For questions on this article, please contact Renée Lani of APGA staff by phone at 202-464-0836 or by email at