Original Message -----

From: Kelly, Henry

To: Hagerman, Joseph; Miller, Bryan

Sent: Wed Dec 02 18:08:23 2009

Subject: Fw: story on heaters rule

----- Original Message -----

From: Harris, Jeffrey <JHarris@ase.org>

To: Kelly, Henry; Harris, Jeffrey <JHarris@ase.org>

Sent: Wed Dec 02 1S:3S:47 2009

Subject: RE: story on heaters rule

Henry - that's exactly right. I can send you the original ASAP press release (joined by ASE)

that triggered this story - but we made ~xactly that point, that the NOPR identified TSL S

and asked for comments on stepping up the proposed standard from TSL 4 to S.

We'll be sure to submit those comments &try to give DOE the strongest possible basis for

making that decision in the Final Rule.

My own view is that carving out the large-WH part of the market to introduce advanced tech's

is a good idea in this case, but an even better one (if DOE had the legis authority, which

we're also working on as you may know) would be to set a 2-level std: 1 for all products and

a higher level that can be spec'd for new construction via bUilding codes - which are now

largely pre-empted by NAECA.

This is exactly the solution we helped negotiate in the consensus stds agreement on HVAC

equip with AHRI a few weeks ago, but at that point we were not able to get them to include

WHo We'll keep trying, but one of the best ways to give the industry laggards a nudge towards

a negot agreement (& only 1 of the 3 mfrs is really reluctant) would be for DOE to show a

strong(er) leaning toward TSL 5 (or above!).

Cheers - jh

Jeffrey Harris

Vice President - Programs

Alliance to Save Energy

1850 MStreet NW, Suite 600

Washington, DC 20036

+1 202 S30 2243 office

+1 202 834 3297 mobile

www.ase.org

-----Original Message-----

From: Kelly, Henry <Henry.Kelly@ee.doe.gov>

Sent: Wednesday, December 02, 2009 2:S9 PM

To: Harris, Jeffrey <JHarris@ase.org>

Subject: story on heaters rule

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EE-2006-STD-0129 COMMENT 56.4
EE-2006-STD-0129 COMMENT 56.4

Jeff: You're quoted here recommending that we should consider higher standards for >55gal

water heaters. Our NOPR analyzed precisely this option, makes the point that it was

"strongly considered", and asks for

comments. H

Next, DOE considered T5L 5, in which DOE paired efficiency levels that would effectively

require different technologies for large-volume and small-volume gas-fired and electric

storage water heaters in an effort to promote advance technology penetration into the market

and potentially save additional energy. Specifically, T5L 5 would effectively require heat

pump technology for electric storage water heaters greater than 55 gallons and condensing

technology for gas-fired storage water heaters greater than 55 gallons .

DOE strongly considered T5L 5 and believes it would provide additional energy and carbon

savings, while mitigating some of the issues associated with a national heat pump water

heater standard. However, DOE has identified a number of potential issues with T5L 5 related

to proposing standards that effectively require different technologies for different subsets

of products. For today's proposed rule, the Secretary tentatively concludes that at T5L 5,

the benefits of energy savings, generating capacity reductions, economic savings for most

consumers, and the emission reductions would be outweighed by the large capital conversion

costs that could result in a large reduction in INPV for the manufacturers, the uncertainties

associated with the rapid introduction of new product technologies, the large increases in

first costs, especially for those consumers that would have to make structural changes, and

the uncertainties associated with a promulgation of an amended energy conservation standards

that only affects a subset of the market. DOE seeks comments and data from interested parties

that will assist DOE in bringing further clarity to some of the issues surrounding the

product division used in the two slope energy-efficiency equations, promulgation of different

standards for a subset of products, the heat pump water heater market, the condensing water

heater market, as well as help DOE determine how these issues can be adequately addressed

prior to the compliance date of an amended energy conservation standard for residential water

heaters. (See Issue 17 under "Issues on Which DOE Seeks Comment" in section VII. E of this

NOPR.) DOE will revisit this decision and strongly consider adoption of TSL 5 in the final

rule in light of any comments and data submitted by interested parties.

================================================

2. ENERGY EFFICIENCY: DOE proposal for water heaters disappoints consumer coalition

(12/02/2009)

Jenny Mandel, E&E reporter

A coalition of energy-efficiency groups is criticizing a draft federal rule for home water

heaters that it says will require incrementally better energy performance but fails to push

new technologies into the marketplace.

The Appliance Standards Awareness Project -- which includes the American Council for an

Energy-Efficient Economy and the Alliance to Save Energy, among other groups -- criticized

new residential water heater standards proposed last week by the Department of Energy in a

notice of proposed rulemaking.

The new standards would require that residential water heaters meet higher efficiency

metrics, which a DOE analysis says can be achieved by steps such as increasing the insulation

on tank-style water heaters.

DOE said the standards would save about 2.85 quads of energy over 30 years, equivalent to

about 61 days of U.S. gasoline use, and save consumers $15.6 billion.

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EE-2006-STD-0129 COMMENT 56.4

But the coalition said the proposal leaves out modest changes that could help push the market

toward much better technologies without causing disruptions for most homeowners.

The group said standards that would require more energy-efficient condensing gas and electric

heat pump water heaters for the biggest homes would benefit consumers in the long term.

"Big energy savings sometimes requires big changes in technology," said Andrew deLaski,

executive director of the coalition. "We're disappointed that the Obama administration has

shied away from making even a modest first step to transition America to the most efficient

types of water heaters."

The group agreed with DOE that requlrlng the new technologies to be installed in all homes

could be disruptive for some homeowners. But it said DOE should adopt a requirement that new

water heaters larger than

55 gallons, used in 4 percent of gas and 11 percent of electric water heater markets, should

be of the more efficient type.

Such a standard would save 3.7 quads of energy, the group said, and save consumers $22

billion.

Jeff Harris, vice president for programs with the Alliance to Save Energy, said requlrlng the

new technology in that limited case would have a market acceleration effect. "Our view is

that we hope that DOE will see fit to strengthen the standards that they've announced on a

preliminary basis here. We think that's justified by the economics and the technologies."

Harris said it would also be beneficial if DOE were given legislative authority to draft two

different standards, one for appliances in new homes and one for replacements made in

existing homes. It is often cost-effective to install new technologies in new buildings, but

impractical to put them into older homes that might have space constraints or lack piping or

electrical wiring for them.

The draft rule is expected to be published soon in the Federal Register, and a public hearing

on it will be held Jan. 7, 2010.

Click here to read the notice of proposed rulemaking.

Bryan Miller

Senior Counsel

US Department of Energy

202-586-8627

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