AGA, APGA, NPGA Gas Association  and Spire, Inc.,  file Comments on the DOE  Notification of Availability of Preliminary Technical Support Document (TSD) for Energy Conservation Standards for Consumer Water Heaters.
On Monday, in response to the DOE March 1, 2022 Notification of Preliminary Technical Support Document for Energy Conservation Standards for Consumer Water Heaters, AGA, the American Public Gas Association (APGA), the National Propane Gas Association (NPGA) and Spire, Inc., filed timely and extensive comments (attached) on the preliminary TSD. The joint comments requested that the DOE  reconsider its position with respect to standards that would make atmospherically-vented consumer gas water heaters unavailable and should consider the need for separate product classes for natural gas models that operate without an external electric supply.  In addition, the joint comments stated that “DOE must address its failure to consider the nature and extent of any relevant market failures and its related failure to correct the errors created by its “random assignment” methodology.“  Note that there are 5 attachments,  A,B,C,D &E,  to the joint comments that provide additional information on the gas industries response to the DOE notification. Of particular importance are the extensive technical and economic comments and analysis of the DOE Technical Support Document (TSD) authored by Ted Williams of Natural Gas Direct that provide constructive comments and observations that DOE will need to address. We will report on the DOE responses to the notification when available.

AGA and the American Public Gas Association File Comments on the DOE Notice of Proposed Rulemaking (NOPR) Pertaining to Test Procedures for Consumer Boilers.
Also on Monday May 16,  AGA and APGA filed timely comments (attached) on the DOE NOPR pertaining to the test procedures that measure the efficiency of consumer gas, electric and oil boilers.  In our comments, we urged the DOE to “ promulgate test procedures that are accurate, repeatable, and reproducible and not unduly burdensome to conduct.”  To help guide the agency in this task, AGA and APGA supported  comments and recommendations  made by the Air-Conditioning, Heating, & Refrigeration Association (“AHRI”) who represent residential boiler manufacturers.  In addition, AGA and APGA recommended that the DOE implement the recommendations from the recent National Academies of Sciences, Engineering, and Medicine (“NASEM report”) into all its appliance rulemakings, whether for test procedures or energy conservation standards. The NASEM report comprehensively evaluated the agency’s appliance rulemaking process and identified several key areas in which DOE can improve its rulemaking process. We will report on the DOE response when available.

DOE Publishes a Notice of Proposed Rulemaking and Announces a Public Meeting Pertaining to Standards for Commercial Water Heating Equipment.

Yesterday, the U.S. Department of Energy (DOE)  published a Federal Register notice of proposed rulemaking (NOPR) pertaining to energy conservation standards for commercial water heating equipment (CWH).The Energy Policy and Conservation Act, as amended (EPCA), prescribes standards for certain commercial and industrial equipment, including commercial water heaters, hot water supply boilers, and unfired hot water storage tanks (hereinafter referred to as “commercial water heating (CWH) equipment”). EPCA requires DOE to periodically determine whether more-stringent standards for CWH equipment would be technologically feasible and economically justified, and would result in significant energy savings. In this NOPR, DOE proposes to amend the standards for certain classes of CWH equipment for which DOE has tentatively determined there is clear and convincing evidence to support more-stringent standards. Recall back on May 6, we reported that the prepublication of the rule has the following requirements for natural gas CWS’s,  Specifically, DOE is proposing a minimum efficiency  requirement of 95% Thermal Efficiency for storage type gas fired CWH’s and 96% Thermal Efficiency for gas-fired instantaneous water heaters and hot water supply boilers. These efficiency levels would require condensing technologies and would eliminate non-condensing gas commercial water heaters.   In another indication of DOE’s support for “electrification”, DOE is not recommending any changes for electric CWH’s Additionally, DOE is proposing to codify standards for electric instantaneous CWH equipment from EPCA into the Code of Federal Regulations (CFR). DOE also announces a public meeting to receive comment on these proposed standards and the associated analyses and results. DOE will accept comments, data, and information regarding this NOPR until July 18, 2022. Interested persons may submit comments identified by docket number EERE-2021-BT-STD-0027, by email (, Federal eRulemaking portal ( DOE will hold a webinar on Thursday, June 23, 2022, from 1:00 p.m. to 5:00 p.m. Click here to register for the webinar. The TSD is available on the rulemaking docket.

DOE Issues a Final Rule Pertaining to Standards for Manufactured Housing .
Yesterday, the U.S. Department of Energy (DOE) issued a pre-publication Federal Register final rule to establish energy conservation standards for manufactured housing pursuant to the Energy Independence and Security Act of 2007. This document presents standards based on the 2021 version of the International Energy Conservation Code (IECC) and comments received during interagency consultation with the U.S. Department of Housing and Urban Development, as well as from stakeholders. The adopted standards would provide a set of “tiered” standards based on size that would apply the 2021 IECC-based standards to manufactured homes, except that single-section manufactured homes would be subject to less stringent building thermal envelope requirements compared to multi-section manufactured homes. AGA has been following this rulemaking for years in the event that there would be provisions added that would adversely impact the direct use of natural gas in manufactured housing such as requiring electrification or imposing unwarranted gas appliance efficiency provisions or installation requirements,  but none are in this final rule.  The effective date of this rule is 60 days after the Final Rule has been published in the Federal Register. Compliance with the adopted standards established for manufactured housing in this final rule is required on and after 1 year after date of publication in the Federal Register. The incorporation by reference of certain publications listed in this rule is approved by the Director of the Federal Register 60 days after date of publication in the Federal Register. DOE will send a follow up email to announce the effective dates once the notice has published in the Federal Register. Product information can be found at  Manufactured Housing including current standards and test procedures, statutory authority, waivers, exceptions and contact information.