RE: Docket Number EERE–2017–BT–STD–0019/RIN 1904–AD91: Notification of Availability of Preliminary Technical Support Document for Energy Conservation Standards for Consumer Water Heaters

In the preliminary analysis, DOE considered absorption and adsorption HPWHs as technology options but tentatively decided to screen them out due to the lack of manufacturer development and challenges with wide-scale manufacturing, installation, and service of the units.5 As DOE notes in the PTSD, gas heat pump technology is commercially available in space cooling, space heating, and commercial wat. [...] We encourage DOE to evaluate the energy performance of 120V/15A HPWHs for the notice of proposed rulemaking (NOPR). [...] In the preliminary analysis, in analyzing historical prices of water heaters, DOE examined prices of water heaters as a whole.10 However, we would expect that the price trends associated with heat pump and condensing technologies, which currently represent a very small portion of the water heater market, will be significantly different than the overall price trends of water heaters. [...] In the 2017 Direct Final Rule for standards for residential central air conditioners and heat pumps, DOE assumed that heat pumps would experience the same price trend as central air conditioners and applied a learning rate (defined as the fractional reduction in price expected from each doubling of cumulative production) of 10.7±1.1%.11 Similarly, in the recent proposed rule for room air condition. [...] Multiple studies indicate that a consistent decline in gas customers and/or consumption will result in an increase in gas prices for the remaining customers.14,15 For example, as the NRDC outlines in their comments on the PTSD, their analysis found that gas prices will exceed 600% of the AEO projections in the Pacific and Mid-Atlantic regions in multiple electrification scenarios.