cover image: RE: Docket Number EERE–2017–BT–STD–0019/RIN 1904–AF65: Notice of Data Availability for Energy Conservation Standards for Consumer Water Heaters We continue to support the proposed standards for gas-fired instantaneous water heaters (GIWHs).

20.500.12592/5s2vne2

RE: Docket Number EERE–2017–BT–STD–0019/RIN 1904–AF65: Notice of Data Availability for Energy Conservation Standards for Consumer Water Heaters We continue to support the proposed standards for gas-fired instantaneous water heaters (GIWHs).

23 Aug 2024

In the July 2023 notice of proposed rulemaking (NOPR) for consumer water heaters, DOE proposed to adopt Efficiency Level (EL) 2 for GIWHs;1 EL 2 represents an intermediate condensing level and reflects the Joint Stakeholder recommendations.2 DOE’s updated analysis for the NODA continues to show that EL 2 would provide cost-effective energy savings, with average life-cycle cost savings for consumer. [...] In the NODA, DOE made several updates to the analysis for GIWHs including incorporating the most recent version of the 1 88 Fed. [...] While we note that the energy savings and economic results presented in the NODA are similar to those in the July 2023 NOPR, we believe that the updates in the NODA improve the analysis. [...] In particular, as part of the analysis for the NODA, DOE revised its estimates of manufacturer conversion costs at efficiency levels reflecting condensing technology to specifically incorporate the costs that would be incurred to repurpose a domestic manufacturing facility that is currently optimized for producing non-condensing GIWHs.6 DOE’s analysis for the NODA shows that the potential impacts. [...] $146);11 in other words, the cost differential between gas storage and gas instantaneous water heaters would remain essentially unchanged with the proposed standards for GIWHs—at EL 2, the estimated total installed cost of GIWHs would continue to be 41% higher than that of a gas storage water heater meeting the updated standards.

Authors

Joanna Mauer

Pages
3
Published in
United States of America

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