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Workshop on Energy Efficiency StandardsforWater Heaters November 9, 1998, Issues Issue: Will DOErevisit the screening ofdesign options, specifically heat pump water heaters (HPWH)? Response: In theprocess rule the department has committed to eliminate "problematic design options early inthe process." Based on thecomments 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 toreceive new information. We will reconsider the position based on new information. Issue: Onwhat basis did DOE limitthe recovery efficiency to 78.5%? Response: DOE limited the recovery efficiency to 78.5% based on consideration ofthe 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 ofissues (geographic, horizontal flue length, chimney height and otherconfigurations). DOEtranslated the flue loss efficiency to a recovery efficiency value of78.5% or less using the default values given inthe TANK computer simulation model. Issue: Why arethe highest efficiency models in the current DOE analysis not at levels represented inthe 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 testdata from GAMA and manufacturers for the full range ofEFs. Issue: Why is there a difference in the retail mark-ups ofgas and electric water heaters? Response: The Department understands there is an apparent difference inthe retail markups and retail price ofgas 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 toprovide abetter representation of manufacturer prices from wholesale plumbing outlets. B. Apply an equal mark-up to all incremental manufacturing costs ofgasand electric water heaters e.g. 1.32

-1-Issue: Should DOE use aconstant hot water outlet temperature for the life-cycle cost (LCC) analysis? The goal ofthe LCC isto capture the variability associated withwater heateruse byreal consumers. DOE will use acombination ofdata including a weighting factor for current shipments ofwater heaters that are set to 120°F to capture this variability. DOE requests additional information associated with hotwater outlet temperature. Issue: Why are the paybacks so different for2" insulation for gas and electric water heaters? Response: As demonstrated by Jim McMahon onNovember 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 maybe 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 ofcurrently available, more efficient water heaters? Response: DOE has some retail price data thathas been collected formore efficient water heaters and this data will be made available upon request. Additionally, DOEwill evaluate the retail prices ofmore efficient water heaters relative to the prices represented in the engineering analysis.

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