NPGA Win on the Consumer Water Heater Rule

NPGA secured a regulatory win on Tuesday, April 30th, when the Department of Energy (DOE) released for prepublication its Final Rule: Energy Conservation Standards for Consumer Water Heaters. In the Proposed Rule, DOE sought to eliminate non-condensing tankless water heaters through efficiency standards which could only be met by condensing models. In 2023, NPGA led a coalition response to the Proposed Rule, including engaging with the DOE, the Department of Justice, and the Department of Commerce, where NPGA explained its concerns and the concerns of its members with the Proposed Rule. NPGA supplemented those efforts by meeting in 2024 with the Office of Management and Budget regarding the Proposed Rule’s impact. NPGA’s comments focused, in part, on the impact to gas-fired tankless water heaters and the Final Rule chose not to summarize or respond to any comments specific to gas-fired tankless water heaters in this notice, nor discuss any analytical methodologies or results for this product class as DOE continues to consider the comments submitted in response to the July 2023 Notice of Proposed Rulemaking and December 2023 Supplemental Notice of Proposed Rulemaking.

NPGA, along with its coalition partners (American Gas Association, American Public Gas Association) and member engagement (Rinnai America) will be reviewing the 543 page Final Rule in depth and continue to engage DOE on its potential plans to amend conservation standards for gas-fired tankless water heaters.

Questions? Please contact VP Regulatory & Industry Affairs Benjamin Nussdorf.