Status of the DOE Postponement of Appliance Efficiency Standards for Gas-Fired Instantaneous Water Heaters – Overview of AGA, APGA and NPGA Draft Comments to DOE Due March 13.

Back on February 21, we reported that DOE had announced the postponement of the implementation of seven of the Biden-Harris administration’s efficiency standards for home appliances, six electric and one for gas-fired instantaneous water heaters (giwh’s) . Additionally, DOE reported that they intend to create a new energy efficiency category for giwh’s, instead of banning non-condensing,  models which was the position of the Biden-Harris administration.  Specifically, on December 26, 2024  DOE published the Federal Register Notice with the Final Rule adopted amended standards for giwh’s less than 2 gallon and greater than 50,000 Btu/hour, at an efficiency level that requires condensing technology. The Notice list “the effective date of this rule as March 11, 2025. Compliance with the amended standards established for gas-fired instantaneous water heaters in this final rule is required on and after December 26, 2029.”  The DOE postponement announcement also states that DOE “is creating a new energy efficiency category for natural gas tankless water heaters. Creating a new category for these popular and low-cost water heaters exempts these products from the Biden-Harris Administration’s onerous rules and gives the American people the power to choose the best option for their homes and budgets.” There are no details on what the new category DOE is considering to issue. Also, on February 21,  DOE announced that it has delayed the effective date of the gas-fired instantaneous water heaters rule amending issued on December 26, 2024, until March 21, 2025 and is accepting written comments and information on or before March 13, 2025.

AGA is working with the American Public Gas Association (APGA) and the National Propane Gas Association (NPGA) in developing additional comments in support of our position that DOE should recognize the benefits of maintaining the availability for consumers for non-condensing giwh’s and will be submitting comments that 1. Support the  DOE decision in delaying the effective date, 2. Reiterate our prior extensive comments submitted in this proceeding back on September 26, 2023, in response to the notice of proposed rulemaking that  provided substantial feedback outlining multiple errors and concerns with the proposal that remain pertinent to the final rule and the delay in the effective date since many of the concerns raised remain unaddressed by DOE and 3. Urge DOE to further delay the effective date of this rule and address the errors and concerns that the DOE flawed analysis erroneously supported the elimination of specific types of non-condensing giwh’s  and issuance of a  “new energy efficiency category for giwh’s that would maintain non-condensing giwh’s. We will keep the committee updated on any new developments on this important DOE rulemaking.

State Codes Activity Update.

Attached is a weekly feature of the “Friday Update” covering state code calendar activities as presented by the online utility “Fiscal Note,” which is sponsored by APGA and AGA Code and Standards. Please review the update and determine if there are state code activities that impact your service territory or organization.