610.666.8980 | www.pjm.com 

2750 Monroe Boulevard 

Audubon, PA 19403-2497 

Terry Boston 

President and CEO 

610.666.8262 

610.666.4281 | FAX 

April 7, 2014 

Dr. Kathleen Hogan 

Deputy Assistant Secretary 

Office of Energy Efficiency and Renewable Energy 

U.S. Department of Energy 

1000 Independence Ave., S.W. 

Washington, DC 20585 

RE: Urgent Action on Energy Conservation Standards for Residential Water Heaters (Docket Number: EERE2012-BT-STD-0022) 

Dear Dr. Hogan, 

I am submitting this letter on behalf of PJM Interconnection, the electric grid operator for 13 states and the District 

of Columbia serving over 60 million people. As part of a coalition which includes the National Rural Electric 

Cooperative Association, water heater manufacturers and the Electric Power Research Institute, among others, 

we petitioned your office back in the winter of 2011 to reform the April 2010 efficiency standard governing 

residential electric resistance water heaters. The reforms are necessary to advance the benefits to energy 

efficiency and the environment from those water heaters which could interact with the grid and operate as energy 

storage devices. 

I am concerned that, to date, there has been no action or clear indication of intent from DOE on our petition. The 

situation is becoming urgent because, without prompt action, these water heaters will be illegal to manufacture 

by April 15, 2015. This pending deadline and the uncertainty of DOE's position are placing an undue risk and burden 

on manufacturers and utilities as to whether these cost-effective water heater control programs will have a path 

forward to expand, both in size and in sophistication of control. 

PJM is working closely with manufactures and entrepreneurs to unleash the vast energy storage potential of 

residential electric water heating control – a resource with a combined energy storage capacity on par with today’s 

pumped storage hydro fleet. Electric water heater storage is the most cost-effective form of energy storage 

available and has enormous potential to help PJM integrate the projected 33,000 MW of wind and 9,200 MW of 

solar energy that the state RPS requirements call for by 2029 in our footprint. 

I urge your office’s expedited action on this matter. Extensive information has been submitted in the docket along 

with proposals for resolution of this matter, all of which have been thoroughly briefed and discussed 

Without action from DOE, it will be harder for the region and policymakers to meet the state goals for integrating 

renewables. A recent study by GE showed that PJM will need 1,500 MW of added regulation resources for load 

frequency control as wind is added to our system. Not only can storage water heaters help with load frequency 

control, they will help us manage other grid problems which occur primarily at night when loads on the system are 

low, causing us to reduce generation. Additional storage would help us avoid the need to reduce nuclear 
Dr. Kathleen Hogan 

Page 2 

610.666.8980 | www.pjm.com 

generator output (which can risk fuel damage) and being forced to feather the blades on wind turbines in the 

western part of PJM. 

I appreciate your attention to this urgent matter and look forward to working together in the future to advance 

electric storage water heating technology. I would be grateful for an indication of the status of this matter and 

expedited action to prevent this promising energy storage option from being eliminated in light of the April 2015 

deadline. 

Sincerely, 

Terry Boston 

cc: Secretary Earnest Moniz 

 John Cymbalsky, DOE 

ExParteCommunications@hq.doe.gov ; Docket EERE-2012-BT-STD-002