Letter in Support of Energy Efficiency Standard Exemption
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Letter in Support of Energy Efficiency Standard Exemption

Dear Secretary Moniz:

WASHINGTON, D.C. – April 20, 2015 – (RealEstateRama) — We are alarmed by the Department of Energy’s abrupt decision to reverse course and withdraw a proposed waiver from new energy efficiency standards for water heaters used as part of utility demand response programs which will adversely impact our constituents. We ask the Department of Energy to immediately grant an energy efficiency standard exemption in regards to large-volume water heaters that are used in demand response and electric thermal storage programs.

In March 2010, the Department issued an energy efficiency standard requiring 200 percent efficiency for large capacity electric resistance water heaters. This regulation effectively prohibits the manufacture of electric resistance waters heaters with more than 55 gallon capacity, which is a common appliance in homes across the United States.

Stakeholders from electric utility, environmental, manufacturing, and energy efficiency organizations have been working with the Department of Energy for years to find a solution to the unintended consequences of this regulation. As a product of this collaboration, the Department proposed a waiver to the rule over two years ago. However, three weeks before the rule was slated to take effect, the Department suddenly pulled the waiver without notice to stakeholders who have worked together since the efficiency standard was proposed in 2010.

Furthermore, the Department cited a study and a small scale pilot project regarding the capabilities of heat pump water heaters to justify their action. The study was not peer reviewed or available for comment from stakeholders such as energy providers who are technological experts in the industry. The conclusions drawn by the Department from the study and pilot research are one-sided and fail to incorporate concerns about the technical and economic viability of heat pump water heaters as part of demand response systems at this time. This is unacceptable.

Increased energy efficiency is a shared goal, but energy providers, manufacturers and consumers will be negatively impacted if the rule does not accommodate large capacity hot water heaters which provide a variety of other benefits like integrating higher levels of renewable energy resources and increasing grid reliability. Pulling the waiver instantly blocked all of the progress previously made by stakeholders, and most alarmingly, ignores an agreement that was reached in good faith. Finally, the Department recently created an exemption for two classes of solar water heaters and should expeditiously move to do the same for large-volume water heaters.

Given the significant Congressional interest in the issue and the rule’s April 16, 2015 implementation date, we urge you to immediately grant a waiver regarding the Applicability of Energy Conservation Standards for large-volume water heaters.


Collin C. Peterson

Tom Emmer

Jeff Duncan

Jim Costa

Walter B. Jones

Kevin Cramer

Tom Rice

Tim Walz

Bill Huizenga

Ron Kind

Erik Paulsen

Vicky Hartzler

John Kline

Rodney Davis

Reid Ribble

Kristi Noem

Rod Blum

Rick Nolan

Sean Duffy

Members of Congress