May 7, 1999

Mr. Timothy J. Shellenberger

Vice President, Product Engineering

American Water Heater Company

1100 E. Fairview Ave., P.O. Box 1378

Johnson City, TN 37602-1378

Dear Mr. Shellenberger:

The Department of Energy (DOE) has determined that it needs additional

information from manufacturers in order to determine the appropriate energy

conservation standard for electric water heaters. At the November 1998

workshop, several stakeholders asked why the DOE calculated energy factor for

electric water heaters with 2.5" of insulation and heat traps did not meet or exceed

the 0.93 energy factor of similar models listed in the GAMA directory. Using the

WATSIM model, DOE's highest energy factor is 0.91 for an electric water heater

with 2.5" insulation with heat traps and insulated tank bottom. It is important that

DOE staff resolve whether this difference is systemic so that we can determine the

correct energy factors for trial standards levels. This is critical information for

setting the standard.

Based upon our current analysis we believe the WATISM results are correct.

With further data from manufacturers, we will be able to either verify our results or

determine that another result is required.

In order to assist DOE, we request that you provide the test data you used to

certify the energy factors for high efficiency electric water heaters to DOE. For

each of the electric water heater models listed in Attachment A, please provide the

following: (1) date of the measurements, (2) the model number, (3) tank

identification, (4) the energy factor for each tank measured, (5) the average energy

factor for each model, and (6) the current GAMA directory listing for each model

tested.

DOE is committed to setting the new water heater standards based on achievable

results. We request your cooperation so we can meet this objective. Section 326(d)

of the Energy Policy and Conservation Act (EPCA), 42 U.S.C. 6296(d), as amended,

gives DOE the authority to request information or reports with respect to energy

efficiency and energy use from manufacturers of a covered product that it determines

EE-RM-97-900 COMMENT 65
is necessary for establishing energy conservation standards. Section 329(a) of EPCA,

as amended, 42 U.S.C. 6299(a), gives the Secretary subpoena authority for the

production of relevant books, records, papers and other documents. We prefer to

work cooperatively with you instead of using our subpoena authority.

Thank you for your prompt attention to this matter. Please send this data within

30 days of receipt of this letter. If you have any questions, please call Terry Logee

at (202) 586-1689.

Sincerely,

Mark Ginsberg

Deputy Assistant Secretary

Building Technology, State

and Community Programs

Energy Efficiency and Renewable Energy

Attachment

EE-RM-97-900 COMMENT 65
Duplicate Letters Sent to:

Mr. Eric M. Lannes

Vice president, Engineering

Bradford White Corporation

200 Lafayette Street

Middleville, MI 49333-0247

Mr. William T. Harrigill

Vice President, Product Development

and Research Engineering

Rheem Manufacturing Company

101 Bell Road

Montgomery, AL 36117

Mr. Otto Z. Vago

Chief, Product Engineer

State Industries, Inc.

500 By Pass Road

Ashland City, TN 37015-1299

Mr. Wilbur L. Haag, Jr.

Manager, Certification & Standards

A.O. Smith Corporation

U.S. Highway I North, P.O. Box 600

McBee, SC 29101