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APGA Supports DOE’s Delay of Effective Date for Gas-Fired Instantaneous Water Heater Standards

By Sydney Novoa posted 03-20-2025 11:39 AM

  
On March 13, APGA submitted comments in support of the Department of Energy’s (DOE) decision to delay the effective date of its Final Rule on energy conservation standards for gas-fired instantaneous water heaters (GIWHs). The rule, if implemented, would establish minimum efficiency requirements that effectively ban a class of efficient and affordable consumer water heaters. 
 
APGA, along with the American Gas Association (AGA) and the National Propane Gas Association (NPGA) urged DOE to further extend the delay to allow for a more thorough review of the rule’s impact. Commenters also reiterated concerns about its feasibility and impact on consumers. 
 
In response, DOE, which initially postponed the effective date to March 21, 2025, has now further delayed it to May 20, 2025.  
 
This delay follows the Regulatory Freeze Pending Review memorandum issued by President Trump on January 20, which instructed federal agencies to reevaluate certain regulations before they take effect. The DOE also sought public comments on the rule’s potential impacts, receiving feedback from various stakeholders, including APGA. 
 
These actions align with broader efforts to reconsider recent appliance efficiency mandates. On February 14, DOE announced the postponement of seven energy conservation rules issued under the Biden administration, citing concerns about increased costs, reduced consumer choice, and diminished appliance quality. 
 
The Final Rule, published on December 26, 2024, establishes stricter efficiency standards for gas-fired instantaneous water heaters under 2 gallons and over 50,000 Btu/hour, effectively mandating condensing technology, eliminating non-condensing options for most units. This shift would significantly impact customers, limiting consumer choice and increasing costs for those who rely on these appliances to meet their specific energy needs.  
 
APGA has actively engaged in this issue, previously submitting joint comments with the American Gas Association (AGA) and the National Propane Gas Association (NPGA) during DOE’s rulemaking process.  
 
APGA strongly supports DOE’s decision to delay the effective date and continues to advocate for policies that maintain affordability, preserve consumer choice, and ensure the long-term viability of natural gas appliances.  
 
Read the filed comments here.  
 
APGA will continue to monitor DOE’s actions on consumer water heaters and provide updates on any future developments regarding consumer water heater standards. 
 
For questions on this article, please contact Sydney Novoa of APGA by phone at 202-464-0834 or email at snovoa@apga.org.  

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