Nationl Rural Elecric

7^ Cooperative Association I

4301 Wilson Boulevard

Arlington. VA 22203-1860

Telephone: (703) 907-5500

TT- (703) 907-5942

June 19, 1997

Mr. Bryan Berringer

U.S. Department of Energy Efficiency and

Renewable Energy

Forrestal Building

Mail Station EE-43

1000 Independence Avenue, SW

Washington, D.C. 20585-0121

Dear Mr. Berringer:

I received a notification from Michael McCabe of the June 24 workshop on

Residential Water Heater Energy Efficiency Standards. Unfortunately, I will be unable to

attend due to a conflict in schedule. I will be following the issue very closely, however, since

the water heater efficiency standard is of major concern to our members. The National Rural

Electric Cooperative Association represents the nearly 1,000 not-for-profit consumer-owned

electric utilities serving 30 million people in 46 states. On behalf of our members, I submit

the following comments for use at your meeting.

NRECA believes that the design and operation of heat pump water heaters is so vastly

different from the design and operation of resistance water heaters that one standard cannot

adequately cover both. We would therefore recommend that for electric water heaters. at least

two standards are needed; one for resistance heaters and one for heat pump water heaters.

Heat pump water heaters could be subdivided into two classes, those with storage tanks, and

those without storage tanks. Furthermore, we do not feel that there is a current need for a

standard for either of the highly efficient heat pump water heaters. These units are still in an

early commercialization stage, and mandatory standards at this point of development, could

eliminate possible development of promising technologies.

On July 14, 1994. NRECA submitted comments on the proposed standard for water

heaters during DOE's previous round of proposed energy efficiency standards. At that time,

we recommended that DOE set three separate standards for electric water heaters; one for heat

pump with tank water heaters; one for electric resistance water heaters; and one for add-on

heat pump water heaters. Resistance heaters could implement efficiency improvements

similar to those required for natural gas heaters, i.e., increased insulation, installation of heat

traps and elimination of leaks. This would increase the efficiency from electric water heaters

from the base case of 0.86 to 0.89, a 3 percent increase, the same increase as gas. The

EE-RM-97-900 COMMENT 01F
BRYAN BERRINGER

JUNE 19, 1997

PAGE 2

suggested efficiency improvement in gas water heaters would then increase to 0.57. also a .03

factor increase. A three standard approach for electric water heaters would allow for

increased efficiency for water heaters: should not artificially affect the competition between

gas and electric utilities; and would allow for a phased-in approach for the commercialization

of heat pump water heaters without disrupting markets. We believe this recommendation is

still valid.

Other comments on the June 11 Draft Water Heating Rulemaking Framework:

* Page 5 indicates that efficiency levels for gas and electric instantaneous will apply to

type of fuel. This may not be technically possible, since the testing efficiency

standards for these heaters are not applicable.

* Page 6 defines the base case for.three different water heaters and asks if these

descriptions are still valid. I believe that the descriptions are still valid.

* Page 7 ask for names of someone to perform the peer review. I would suggest Carl

Hiller of EPRI. I further suggest that NRECA be added to the peer review list. so that

we might have our knowledgeable members review the draft.

* Page 11 looks at Life-Cycle costs and payback. A regional variable should probably

be added, since cost and operating cycles are very different regionally.

,.,

Thank you for the opportunity to review the draft of the Water Heater Rulemaking

Framework. NRECA will have a representative at the June 24 meeting.

Sincerely yours,

,- /,A

'John Holt

Manager,

Fuels and Transportation

JH/ap

EE-RM-97-900 COMMENT 01F