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Workshop on Energy Efficiency Standards for Water Heaters

November 9, 1998, Issues

Issue: Will DOE revisit the screening of design options, specifically heat pump water

heaters (HPWH)?

Response: In the process rule the department has committed to eliminate "problematic

design options early in the process." Based on the comments received with respect to

manufacturability, serviceability, and consumer utility, the department has screened out

HPWH . As with any other issue, the record is always open to receive new information.

We will reconsider the position based on new information.

Issue: On what basis did DOE limit the recovery efficiency to 78.5%?

Response: DOE limited the recovery efficiency to 78.5% based on consideration of the

GRI/Battelle reports. The GRI/Battelle reports examined the flue loss efficiency

(combustion efficiency) and identified concerns associated with flue loss efficiencies

between 80% and 83% due to an array of issues (geographic, horizontal flue length,

chimney height and other configurations). DOE translated the flue loss efficiency to a

recovery efficiency value of 78.5% or less using the default values given in the TANK

computer simulation model.

Issue: Why are the highest efficiency models in the current DOE analysis not at levels

represented in the GAMA directory?

Response: To better calibrate the computer models, DOE will gather information on the

high EF models, including their characteristics, and the extent to which they incorporate

each design option. DOE requests GAMA certified ITS test data from GAMA and

manufacturers for the full range of EFs.

Issue: Why is there a difference in the retail mark-ups of gas and electric water heaters?

Response: The Department understands there is an apparent difference in the retail markups and retail price of gas and electric water heaters. The Department would like

comments on two alternatives that could address this issue.

Alternatives for analysis:

A. Develop a more robust price database to provide a better representation of

manufacturer prices from wholesale plumbing outlets.

B. Apply an equal mark-up to all incremental manufacturing costs of gas and

electric water heaters e.g. 1.32

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Issue: Should DOE use a constant hot water outlet temperature for the life-cycle cost

(LCC) analysis?

The goal of the LCC is to capture the variability associated with water heater use by real

consumers. DOE will use a combination of data including a weighting factor for current

shipments of water heaters that are set to 120°F to capture this variability. DOE requests

additional information associated with hot water outlet temperature.

Issue: Why are the paybacks so different for 2" insulation for gas and electric water

heaters?

Response: As demonstrated by Jim McMahon on November 9, this difference is largely

due to manufacturer costs, mark-ups and baseline insulation.

Issue: Should DOE consider installation costs for new homes versus replacement?

Response: For the LCC analysis, only incremental installation costs between the baseline

and more efficient products are relevant to calculate payback. The department recognizes

these incremental costs may be different for new construction versus the replacement

market. The Department will attempt to account for new construction in its analysis and

requests any relevant cost information.

Issue: What is the retail price of currently available, more efficient water heaters?

Response: DOE has some retail price data that has been collected for more efficient

water heaters and this data will be made available upon request. Additionally, DOE will

evaluate the retail prices of more efficient water heaters relative to the prices represented

in the engineering analysis.

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EE-RM-97-900 COMMENT 38OO