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.
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Table of Contents
- Appliance Standards Awareness Project 1
- American Council for an Energy-Efficient Economy 1
- Consumer Federation of America 1
- National Consumer Law Center on behalf of its low-income clients 1
- Natural Resources Defense Council 1
- New Buildings Institute 1
- Northwest Energy Efficiency Alliance 1
- For replacement applications we believe that a consumer with an existing GIWH would be unlikely to replace it with a gas storage water heater since the consumer would be unlikely to 2
- DOE estimates that 70 of current sales of GIWHs are already at condensing levels and more than 60 of current sales meet EL 2. 3
- Joanna Mauer Matt Malinowski 3
- Deputy Director Director Buildings Program 3
- Appliance Standards Awareness Project American Council for an Energy-Efficient Economy 3
- Courtney Griffin Berneta Haynes 3
- Director of Consumer Product Safety National Consumer Law Center 3
- Consumer Federation of America On behalf of its low-income clients 3
- Jackie Wong Ralph DiNola 3
- Senior Vice President for Climate and Energy CEO 3
- Natural Resources Defense Council New Buildings Institute 3
- Blake Ringeisen Sr. Engineer Codes and Standards Northwest Energy Efficiency Alliance 3
