On December 26, the Department of Energy (DOE) issued the Final Rule establishing Standards for Gas-Fired Instantaneous Water Heaters.
Final Rule is establishing efficiency standards for certain consumer water heaters at levels that will eliminate more affordable appliance options for American households. The Final Rule adopts amended standards for gas-fired instantaneous water heaters less than 2 gallons and greater than 50,000 Btu/hour, at an efficiency level that requires condensing technology and thus bans non-condensing technologies for most gas-fired instantaneous water heaters.
According to the published notice, DOE asserts that the amended standards for these products would result in “significant conservation of energy and are technologically feasible and economically justified.”
The effective date of this rule is March 11, 2025. Compliance with the amended standards established in this final rule is required on and after December 26, 2029.
On December 17, following DOE’s prepublication of the Final Rule, APGA issued a press release expressing concern with the Final Rule.
Recall, on August 22, APGA jointly submitted comments to the DOE concerning the notice of data availability (NODA) for the energy conservation standards for consumer water heaters. APGA filed comments jointly with the American Gas Association (AGA) and the National Propane Gas Association (NPGA).
Joint commenters felt it was important to engage, given their members, including public gas utilities and water heater manufacturers, will be impacted if policy limits consumers’ ability to choose to install certain gas-fired instantaneous water heaters.
The input submitted identified numerous, significant issues, particularly that DOE currently relies on data used in rules designed for other natural gas appliances and not gas-fired instantaneous water heaters. Based on the flaws in the NODA, joint commenters urged DOE to restart the rulemaking process for gas-fired instantaneous water heaters. If not willing to restart, joint commenters urged at the time that DOE should at least issue a supplemental notice of proposed rulemaking (SNOPR) that contains analysis with the appropriate technical and economic data and address the significant issues in the analysis.
APGA will continue to work on this issue and will inform members of any future actions by DOE concerning consumer water heaters.
For questions on this article, please contact Sydney Novoa of APGA by phone at 202-464-0834 or email at snovoa@apga.org.