# 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 ofEnergy Efficiency and

Renewable Energy Forrestal Building Mail Station EE-43 1000 Independence Avenue, SW Washington, D.C. 20585-0121
Dear Mr. Berringer:
Ireceived anotification from Michael McCabe ofthe June 24 workshop on Residential Water Heater Energy Efficiency Standards. Unfortunately, Iwill be unable to attend due to a conflict in schedule. Iwill be following the issue very closely, however, since thewater heater efficiency standard isofmajor 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 behalfofour members, Isubmit the following comments foruse at your meeting.
NRECA believes that the design and operation ofheat pump water heaters is so vastly different from the design and operation ofresistance water heaters that one standard cannot adequately coverboth. Wewould therefore recommend thatfor electric water heaters. at least two standards are needed; one forresistance 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 thatthere is acurrent need for a standard for either ofthe highly efficient heat pump water heaters. These units are still in an early commercialization stage, and mandatory standards atthis point ofdevelopment, could eliminate possible development ofpromising technologies.
On July 14, 1994. NRECA submitted comments onthe proposed standard forwater heaters during DOE's previous round ofproposed energy efficiency standards. At thattime, we recommended that DOE setthree separate standards for electric water heaters; one for heat pump withtank water heaters; one for electric resistance waterheaters; and one for add-on heat pump water heaters. Resistance heaters could implement efficiency improvements similar to those required fornatural gas heaters, i.e., increased insulation, installation ofheat traps and elimination ofleaks. This would increase the efficiency from electric water heaters fromthe base case of0.86 to0.89, a 3percent increase, the same increase as gas. TheBRYAN BERRINGER JUNE 19, 1997 PAGE 2 suggested efficiency improvement in gas water heaters would then increase to 0.57. also a .03 factor increase. Athree 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 aphased-in approach for the commercialization ofheat 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 5indicates that efficiency levels for gas and electric instantaneous will apply to type offuel. Thismay not betechnically 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 ifthese descriptions are still valid. Ibelieve that the descriptions are still valid.
* Page 7 ask for names ofsomeone to perform the peer review. Iwould suggest Carl Hiller ofEPRI. 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 ofthe 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