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APPA, others urge DOE to withdraw draft proposal on water heaters

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APPA "is both alarmed and disappointed that the Department of Energy is proposing radical changes to code requirements that will essentially eliminate the ability of consumers to choose cost-effective and affordable electric resistance water heaters to meet their hot water needs," the association said Oct. 19.

A recent DOE proposal would change water heater efficiency standards to effectively eliminate the use of electric resistance water heaters in residential and commercial buildings, APPA and others told the Energy Department.

DOE is proposing to make this change part of the International Energy Conservation Code model building code. The agency plans to complete its review by December and to send the proposals to the International Code Council, which develops building codes that many states and municipalities adopt as ordinances.

APPA said it "strongly opposes the misguided proposals" on both residential water heaters (DOE's "concept RA-4"), and commercial hot water heaters ("concept CA-17").

The residential proposal would increase the cost of water heaters in new homes in climate zones 1-5 by at least $1,000 per home and would allow the use of instantaneous gas water heaters that would increase energy usage, compared to higher efficiency storage water heaters, APPA said.

The proposal would "be biased against high-efficiency electric resistance water heaters that produce no emissions at homes, and can be powered by zero-emission power plants (hydro, solar, wind, nuclear, tidal, etc.)," APPA said. RA-4 also would "be biased against electric water heaters," since the incremental cost to meet the provision with a highly efficient electric water heater is well over $1,000, while the incremental cost to meet the provision with a slightly more efficient gas water heater "is estimated to be negative" (-$141), APPA said.

The proposal would "undermine and eventually eliminate electricity demand-response programs" that Congress has directed DOE to support, APPA said. "Unlike electric resistance water heaters, the water heaters DOE seeks to require through the proposed code change are not effective for utility demand-response programs."

APPA also opposes CA-17, the draft proposal on commercial water heaters, in part because it would significantly increase the cost of water heaters in new businesses.

Other utility groups also sent DOE comments opposing the proposals.

"Any code that promotes and or mandates tankless water heaters removes an electric utility's ability to manage one of its largest loads and eliminates the opportunity to implement a demand-response program," said the Northwest Public Power Association.

"Load management programs, whether for existing or new facilities, are among our members' best options to control peak demand, and tankless electric water heaters would actually increase peak demand because they require high amounts of energy over very short periods of time," said NWPPA, which is headquartered in Vancouver, Wash. Instantaneous water heaters also "create problems with the electricity distribution system and cause power factor issues," the association said.

DOE should "continue codes and standards for incentives that go hand in hand with the continued use of electric resistance hot water heaters," said Public Utility No. 1 of Grays Harbor County in Washington. "For many of our customers, this is the best and sometimes the only means for providing their hot water," the PUD said.

Tankless hot water heaters "will negatively impact peak loads, as that is precisely the time that most people want hot water," said Grays Harbor PUD. "We should not be looking to Europe for ideas, as they have very different systems," the PUD added.

Nearly 65 percent of public power consumers in North Carolina use electric hot water heaters, ElectriCities of North Carolina told the Energy Department. "In fact, electric water heating is the only option available for a significant number of consumers in the state." As part of their energy efficiency programs, many public power utilities in North Carolina offer customers a rebate to encourage them to buy high-efficiency electric water heaters, ElectriCities said.

The draft proposals are posted on DOE's website. The residential proposal (concept RA-4) can be found at The commercial proposal (concept CA-17) is posted at

"This is a separate proceeding from our efforts to get the Department of Energy to revise its water heater efficiency standards to recognize that large-capacity electric resistance water heaters make a lot of sense when tied to our members’ demand-response programs," noted Alex Hofmann, senior energy and environmental services engineer for APPA. (See the July 19 Public Power Daily.) —JEANNINE ANDERSON


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