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On July 7, APGA submitted comments in response to the Environmental Protection Agency’s (EPA) proposal to sunset its residential fuel-fired boiler ENERGY STAR specification, strongly opposing the proposed action.  APGA jointly submitted these comments with other fuel providers, such as the American Gas Association, National Propane Gas Association, National Energy & Fuels Institute, and more.

ENERGY STAR’s appliance labeling program is a voluntary program in which manufacturers can choose to have their appliances tested according to Department of Energy (DOE) appliance test procedures.  This allows certain appliances to qualify for the ENERGY STAR label, which helps consumers easily identify top performing appliances from a range of appliances.

Through the joint comments, and similar to previous comments, APGA argued that EPA’s proposal to sunset the labeling program for fuel-fired boilers 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 or tax incentives offered by state and federal 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 or other incentives, many consumers will likely 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 all fuel-fired residential boilers, which includes natural gas boilers, is one of several examples of EPA using the program to further what are seen as pro-electrification policies.  Late last month, APGA also submitted joint comments in opposition to EPA’s proposal to sunset its ENERGY STAR specification for fuel-fired furnaces.  More sunset proposals for fuel-fired appliances are anticipated in the future.  Also, in 2021, EPA released its final recognition criteria for its 2022 Most Efficient appliances, which completely precluded gas-fired appliances from qualifying for the designation, and limited qualifying gas water heaters to condensing only with plans to also sunset the specification in the near future.  APGA has remained actively engaged with the agency and Congress, emphasizing the negative impacts to efficiency and innovation that this misguided decision may lead to.

Even though the comment deadline has passed, we encourage APGA members to engage on this issue, especially since this proposal is one of several proposals to sunset ENERGY STAR fuel-fired appliance specifications.  To help support communication on this effort, APGA staff has developed a form letter that your system/community/company can utilize, which is available here.  Please do not hesitate to reach out if APGA can support you in this action.

A copy of the comment letter is available here.

For questions on this article, please contact Stuart Saulters of APGA staff by phone at 202-802-0493 or by email at ssaulters@apga.org.