AGA Files Comments Opposing the EPA Energy Star Program Proposed Increased Criteria for Gas Storage Water Heaters.

Yesterday, AGA submitted timely comments (attached) opposing the EPA Energy Star program proposal to increase the criteria for gas storage type water heaters that would virtually limit any current models to be able to qualify for an Energy Star designation.  As background on the issue, we  reported in the October 8th update that the October 5, 2021 EPA Energy Star program announcement  (attached) proposed new Energy Star criteria for residential gas storage water heaters and stated the following:
“Consistent with the Biden Administration’s commitment to decarbonization, EPA is proposing significant increases in the criteria for gas-fired water heaters, while allowing them to remain in scope as familiarity with electric alternatives grows. The ENERGY STAR Version 5.0 Residential Water Heaters Draft 1 specification reflects changes to ensure ENERGY STAR gas-fired criteria represent the most energy efficient technology. The proposed gas-fired storage water heater level could be met with developments in technologies like gas heat pump water heaters. The gas-fired instantaneous water heater proposed criteria reflect differentiation within the market and improve consumer payback for these models. The requirements  that EPA is proposing for the Criteria for Certified Gas-Fired Storage Water Heaters at a UEF of 1 or greater thus mandating heat pump technology and .95 UEF for the Criteria for Certified Gas-Fired Instantaneous Water Heaters. “
AGA’s comments point out that there are no current models of gas storage water heaters available that can meet the proposed level of a UEF greater than 1 and that EPA’s procedures for establishing revised Energy Star levels do not allow establishment of levels for appliances that are not currently available on the market. In addition EPA cannot conduct a cost effective analysis on the proposed level since no product is available that would provide the needed information to conduct such an analysis exist. If the UEF level of greater than 1 were finalized by EPA, none of the current models of gas storage water heaters listed as Energy Star would  be able to continue being marketed and sold as Energy Star compliant. This would have a serious impact on many incentive programs, including natural gas utility efficiency programs, that offer rebates and other incentives to support energy efficiency improvements  to end  use customers.  We will provide additional information on EPA’s response to our comments as well as other commentors when available.
Manufactured Housing Consensus Committee (MHCC): Notice Inviting Nominations of Individuals To Serve on the Committee – Deadline December 8th.
On Monday November 8th, The Department of Housing and Urban Development (HUD) issued a Federal Register Notice  inviting the public to nominate individuals for appointment to the Manufactured Housing Consensus Committee (MHCC), a federal advisory committee established by the National Manufactured Housing Construction and Safety Standards Act (NMHC&SSA) of 1974, as amended by the Manufactured Housing Improvement Act of 2000. The Department will make appointments from nominations submitted in response to this Notice.  The Department will accept nominations until December 8, 2021. BECS Committee members are encouraged to apply for membership on the MHCC that is a federal advisory committee established by the NMHC&SSA  The NMHCSS  provides input and recommendations on provisions in the  National Manufactured Housing Construction and Safety Standards (NMHCSS)  The NMHCSS  contains the construction requirements for manufactured homes including provisions for fuel gas appliances including furnaces, water heaters, ranges, clothes dryers, fireplaces as well as interior gas piping, venting, etc. Please don’t hesitate to call if you have any questions on this HUD solicitation.
AHRI Releases September  2021 Heating and Cooling Equipment Shipment Data.
For those interested in shipment trends for residential and commercial gas and electric storage type water heaters, residential gas and oil furnaces, electric heat pumps and air-conditioners, click here for the November 12, 2021 Air-Conditioning Heating, & Refrigeration (AHRI) Press Release that provides the September, 2021 U.S. Heating and Cooling Equipment Shipment Data. You may also wish to share this information with other groups or individuals within your organization that would be interested in water heater and HVAC equipment shipment trends.