Press Releases and Statements

APGA Concerned with DOE’s Proposed Consumer Water Heater Standards 

09-26-2023 09:41 PM

FOR IMMEDIATE RELEASE CONTACT:
Stuart Saulters
American Public Gas Association 
Phone: 202-802-0493
Email: ssaulters@apga.org


APGA Concerned with DOE’s Proposed Consumer Water Heater Standards


Washington, D.C. (September 26, 2023) – The American Public Gas Association (APGA), representing more than 730 local, municipally owned natural gas systems in 38 states, issued the following statement in response to the Department of Energy’s (DOE’s) proposed regulation on consumer water heaters. 

“Today, APGA submitted comments in response to a DOE notice of proposed rulemaking that, if finalized, would unnecessarily raise efficiency standards for consumer water heaters and negatively impact consumers. APGA strongly supports energy efficiency and energy conservation standards for gas-fired water heaters. However, we are deeply troubled by the proposed requirements for certain consumer instantaneous water heaters, which are commonly  referred to as tankless water heaters. 

This proposal would effectively eliminate non-condensing instantaneous water heaters. For many consumers, a non-condensing instantaneous water heater is a more affordable option than its condensing counterpart and is more energy efficient than many other types of water heaters available on the market.

APGA is concerned that if this proposed regulation is finalized, its implications would be contrary to the environmental objectives of this administration. Furthermore, it would potentially create severe negative economic impacts on public gas utility customers, as well as the manufacturers of non-condensing instantaneous water heaters that provide well-paying American jobs. The consumers that our members serve should have access to the water heater that best fits their needs, budgets and homes. This should be the case for all gas-fired appliances, and APGA recently commented as such regarding consumer cooking products in early September. APGA will also continue to closely monitor the consensus agreement recently recommended to DOE and engage appropriately to ensure the availability of the features for gas stoves and cooktops that consumers prefer.

APGA will be commenting on proposed consumer boiler standards in October, again, urging the Administration to pursue efficiency regulations that are supported by accurate data. APGA strongly believes that DOE should assess and evaluate any negative impacts that appliance efficiency rulemakings could have on American consumers and manufacturers, and subsequently develop appropriate standards that are economically and technologically justified.”

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Notice of Proposed Rulemaking and Request for Comment: Energy Conservation Program: Energy Conservation Standards for Consumer Water Heaters, EERE-2017-BT-STD-0019, RIN 1904-AD91, 88 Fed. Reg. 49058 (July 28, 2023)

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