On May 16, 2022, NRECA filed comments with the U.S. Department of Energy (DOE) in response to the agency's preliminary technical support document that it has developed to inform the next rulemaking on energy conservation standards for consumer water heaters.
NRECA's comments urge DOE to update the analysis in the preliminary technical support document ahead of releasing a new proposed standard on consumer water heaters:
- Water heaters are important demand response tools for electric cooperatives, who have a vital stake in the outcome of DOE's review of energy conservation standards.
- DOE should amend the analysis in its preliminary technical support document to account for the need for a broad range of options for consumers. DOE should avoid an outcome with a one-size-fits-all approach.
- DOE should update its analysis to more accurately represent the costs of retrofits required as part of replacing electric resistance water heaters with heat pump water heaters.