Proposed waiver for large electric storage water heaters is unworkable, industry tells DOE
Originally published May 2, 2013
The Department of Energy should abandon a proposed waiver from energy efficiency standards for water heaters and instead adopt a separate appliance category for grid-enabled large-volume electric storage water heaters, said electric trade associations and a manufacturer. In joint April 29 comments, APPA, the National Rural Electric Cooperative Association, Edison Electric Institute, PJM Interconnection and Steffes Corp. said a proposed waiver process for large (55-gallon), grid-enabled electric storage water heaters would be "simply unworkable."
If DOE believes it lacks authority to create a separate category for the heaters, the department should adopt a simple waiver that would be valid for at least five years and thereafter subject to modification or elimination with three years notice, they said. "Only a simple, long-term waiver can give the electric utility industry the certainty it needs to continue to invest in [demand response] and [electric thermal storage] and the manufacturing community the certainty it needs to continue to produce the water heaters needed for those successful programs."
Unless the proposed rule is changed, the utility industry "may lose the ability to use large [electric storage water heaters] for load management programs critical for reducing utility and consumer costs, integrating an increasing amount of renewable energy, and providing essential grid-balancing services efficiently and with fewer emissions," APPA and the others said.
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