On September 26, APGA submitted comments in response to the U.S. Department of Energy’s (DOE) notice of proposed rulemaking (NOPR) pertaining to energy conservation standards for consumer water heaters. The American Gas Association (AGA), National Propane Gas Association (NPGA), and Spire also jointly submitted these comments with APGA.
Through the comments, the joint trades predominantly argued against DOE’s proposal to set a condensing-only standard for certain instantaneous gas-fired water heaters, commonly referred to as tankless water heaters. As with similarly situated gas-fired appliances, APGA argued for separate product classes to ensure that non-condensing technology is still available so consumers can select the appliance that best fits their needs, budget, and home or business.
Additionally, the joint trades noted how we were encouraged by DOE’s proposal to maintain non-condensing standards for most gas-fired storage water heaters; however, DOE’s underlying analysis still raises a number of questions, as well as potential product availability and safety.
Due to the complexity of this rulemaking and the significant implications if finalized, APGA and the joint trades requested a comment period extension because the comment period overlapped with two other critical DOE rulemakings impacting gas-fired boilers and cooking products. DOE unfortunately denied the extension request, thus denying all stakeholders a sufficient opportunity to develop meaningful comments.
APGA will continue to weigh in on DOE’s appliance efficiency rulemakings that impact gas-fired appliances. APGA members provide the energy needed to fuel these appliances, thus making public gas systems critical stakeholders in these rulemakings.
A copy of the final comments is available here.
APGA also issued a press release in coordination with the submission of these comments, which is available here.
If you have questions regarding this article, please contact Stuart Saulters of APGA staff by phone at 202-802-0493 or by email at ssaulters@apga.org.