Water Heater Standards ChallengedBy Derrill Holly | ECT Staff Writer Published: March 19th, 2013
Electric cooperatives are calling on the U.S. Department of Energy to rethink the application of energy efficiency standards to large capacity electric water heaters, which could otherwise derail load management programs and increase the cost of power for consumers.
“The standards might take a valuable tool away from us that enables us to shed load and pass on that savings to our members,” said Dave Graves, a senior member services associate with Fall Creek, Wis.-based Eau Claire Energy Cooperative.
Graves was among 20 representatives of distribution cooperatives, G&Ts, statewide associations and NRECA commenting on a proposed one-year limited waiver from DOE water heater efficiency standards taking effect in 2015. They spoke at a March 15 hearing at DOE.
Without changes to the proposed waiver, the standards effectively phase out large-capacity electric resistance water heaters commonly used in residential demand response programs, in favor of smaller units and more expensive heat pump technology.
“Large capacity resistance water heaters are an extremely important part of our load management programs,” said Markus Bryant, general manager of Wellington, Ohio-based Lorain-Medina Rural Electric Cooperative and North Central Electric Cooperative, based in Attica. “Consumers will not continue in load management programs, if they run out of hot water.”
Co-op officials called for much longer waiver periods and more flexibility than DOE proposed.
“The one-year waiver is simply too short, and from a practical sense is no waiver at all,” said David Logeman, director of power supply for Central Electric Power Cooperative. “As soon as it’s begun, the clock will be ticking on applying for extending it.”
The Columbia, S.C.-based G&T has had more than 30 years of experience including water heater programs in the load control programs operated by its member distribution cooperatives.
Central initially found that 40-gallon tanks limited control to two-hour periods. A switch to 80-to-100 gallon reservoirs allowed the G&T to double the control period to four hours without compromising the hot water supply of participating members, said Logeman.
More than 250 electric cooperatives in 33 states currently use electric resistance water heaters in demand response programs. As automated metering infrastructure deployments continue, more co-op systems are expected to offer such options. Co-op representatives also expressed strong reservations about proposed requirements that water heaters must include specific load-control devices to qualify for the waiver from the efficiency standards.
“There presently is no single standard used by electric cooperatives to control these devices,” said Jim Coleman, CEO of Shelby Electric Cooperative, headquartered in Shelbyville, Ill. “If we do not know from year to year whether the water heater that meets requirements will be available, we cannot justify their inclusion in our load control program.”
Besides the 20 co-op representatives who spoke at the DOE hearing, others monitored portions of the proceedings remotely, and additional public comments will be accepted through April 29, providing time for additional input on the issues from NRECA members and other interested parties.
“Development and implementation of load control programs is a complex, multi-year process,” Jay Morrison, vice president of regulatory issues for NRECA, told DOE officials. “We would suggest that you replace the one-year waiver process in the proposed rule with a simple evergreen waiver that will last at least five years.”