CFA joined fellow advocates – Appliance Standards Awareness Project, American Council for an Energy-Efficient Economy, National Consumer Law Center, Natural Resources Defense Council, and Northwest Energy Efficiency Alliance – in responding to DOE’s notice of proposed rulemaking for consumer boilers test procedure. We encouraged DOE to establish test procedures for air-to-water and water-to-water heat pumps. We also urged DOE to further investigate appropriate return water temperatures (RWTs) that may more accurately capture relative boiler efficiencies.