Energy savings from water heaters should not come at a high cost to those who can least afford it, NRECA told the Department of Energy, which is proposing that most residential water heaters use heat pump technology, removing electric resistance options used by many electric cooperative members.

Electric co-ops serve 92% of the persistent poverty counties in the United States, and DOE’s proposed rule will result in “disproportionate harm” to low-to-moderate-income consumers, NRECA said in comments filed to the department Sept. 26.

“This proposal is going to be problematic for a lot of consumers living in smaller or space-constrained homes,” said NRECA Regulatory Affairs Director Stephanie Crawford.

Buying and installing a heat pump water heater could cost a homeowner up to $3,500 because these appliances often require significant modifications to a dwelling, especially smaller and older houses, she said.

According to DOE, air-source heat pump water heaters must be sited in areas that don’t get too hot or too cold and need up to 1,000 cubic feet of air space to operate properly. Crawford said that’s a tall order in many co-op-served homes.

“Heat pump water heaters are impractical in these settings, and retrofits required to make them work in these cases will be prohibitively expensive,” she said. “DOE should maintain electric resistance water heater options for these cases instead of imposing a one-size-fits-all solution.”

NRECA also urged DOE to retain the existing standard’s “grid-enabled” or electric resistance water heater category applicable to water heaters larger than 75 gallons.

“These larger, grid-enabled water heaters remain an important load control tool to our members and must be maintained by DOE to give cooperatives as much demand-side management flexibility as possible amidst a changing grid with increasing intermittent renewables, distributed generation and electrification,” NRECA said.

DOE has until April 30, 2024, to finalize its energy conservation standards for consumer water heaters. The standards will take effect in 2029.

The pace to potentially convert the electric storage water heater market to heat pump technology is “simply too fast to avoid unintended consequences,” NRECA said.

“DOE should incorporate changes to its proposed rule that may result in more heat pump water heater adoption but also address real-world constraints in a meaningful way,” Crawford said.

NRECA recommended DOE take at least one of the following actions in its new standard:

• Delay implementation for 40-gallon water heaters to grant more time for the manufacturers to design a heat pump water heater that can fit in many small or manufactured home settings.
• Maintain electric resistance options for storage tank sizes up to 50 gallons for space-constrained installations until further innovation by manufacturers.
• Apply the standard to new construction only, given that a new home can be designed to accommodate a heat pump water heater upfront.