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Published: February 2010

DOE should strengthen energy efficiency requirements to reduce costs, emissions

Coalition: Energy Projects

Consumer Action asked the Department of Energy to further strengthen energy-efficiency requirements for the largest water heaters, reducing both heating costs for consumers and global warming emissions.

We are writing about the above-referenced rule-making as water heating represents the third largest energy use in the home, and therefore, consumers stand to benefit greatly from more stringent efficiency standards for residential water heaters.

We applaud the Department of Energy for its initial proposal to increase efficiency standards.  But we urge you to take the additional step of strengthening the requirements for the largest water heaters. Stronger standards for the biggest units would both boost economic benefits for consumers and reduce global warming emissions by more than 40% compared to the proposed rule.  Just as importantly, DOE would help spur the use of advanced technologies – condensing gas and heat pump water heaters – to become mainstream products and speeding the transition to next-generation water heaters.

By strengthening the standard, which becomes effective five years after the rule is published, for the larger volume storage, the following additional savings could be achieved over 30 years:

• 1.1 quads of energy or enough to power over 5 million typical U.S. homes for a year;
• $6.4 billion dollars in net savings to consumers and businesses; and
• 63 million metric tons of CO2, an amount equivalent to the annual emissions of 25 coal-fired power plants.

In adopting Trial Standard Level (TSL) 5 level as opposed to what has been proposed, the median payback period would increase slightly from 2.7 to 3.0 years for gas and from 5.8 to 5.9 years for electric. However, we feel that these are reasonable payback periods and that consumers will benefit in the long run from the reduced operating costs. The life cycle savings increase in both instances as well from $68 to $78 for gas; $39 to $96 for electric. 

We appreciate your consideration of our comments and urge DOE to adopt stronger standards for the larger volume water heaters.  Capturing these significant savings will further benefit consumers and help our environment.

Lead Organization

Consumer Federation of America

Other Organizations

Mel Hall-Crawford, Consumer Federation of America | Phyllis Rowe, Arizona Consumers Council | Diane Brown, Arizona Public Interest Research Group | Paul Schrader, Consumers Assistance Council of Cape Cod | Walter Dartland, Consumer Federation of the Southeast | Bill Newton, Florida Consumer Action Network | Jeanne Foy, Massachusetts Consumers Coalition | Paul Schlaver, Massachusetts Consumers Council | Charles Harak, National Consumer Law Center on behalf of its Low Income Clients | Jack Cooper, Massachusetts Union of Public Housing Tenants | Beverly Isbell Brown, Oregon Consumer League | Randall Chapman, Texas Legal Services Center | Irene Leech, Virginia Citizens Consumer Council

More Information

EERE-2006-BT-STD-0129 and RIN 1904–AA90

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