Regulatory Submissions

APGA Weighs in on ENERGY STAR® Water Heaters Specification (June 28 2022) 

06-30-2022 12:18 PM

On June 28, APGA submitted comments in response to the Environmental Protection Agency’s (EPA) final draft specifications for water heaters. Through the comments, APGA raised concerns of how the new specifications may negatively impact consumers.

Last year, EPA released a draft specification that would raise the qualifying efficiency level for gas-fired storage water heaters to one that can only be met by heat pump technology, despite no such appliances being commercially available. APGA provided feedback on how such specifications could hurt consumers. In response, EPA proposed to set a condensing-only level specification for these water heaters.

Through the comments, APGA noted its appreciation for lowering the specification to a level that is currently commercially available, but also raised concerns about how those with non-condensing appliances would no longer be able to identify top performing appliances that meet their needs and budget. Additionally, APGA warned against EPA’s proposal to sunset the gas-fired water heaters specification, as it would be contrary to the ENERGY STAR® program’s Congressionally-stated goals.

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