On September 26, 2023, NRECA filed comments in response to DOE's proposal to amend efficiency standards for consumer water heaters.​NRECA opposes the NOPR as drafted because it will impose a one-size-fits-all option for electric storage water heaters in the most commonly used sizes that will force heat pump water heater (HPWH) installation even in space-constrained homes, which will be prohibitively expensive. Couple this with the higher upfront cost of the HPWH and we expect the NOPR to result in disproportionate harm low- to moderate income (LMI) consumers. NRECA urges DOE to retain electric resistance water heater options for installations where HPWH installation imposes a time-consuming, costly burden to consumers and will ultimately outweigh any energy cost savings.​