As discussed in recent CEI testimony before the House Energy and Commerce Committee, the Biden administration Department of Energy (DOE) has proposed an avalanche of bad energy efficiency regulations impacting home appliances. In this year alone, the agency has targeted stoves, washing machines, refrigerators, dishwashers, and ceiling fans.
The agency’s most recent proposal is for water heaters, and today CEI submitted a coalition comment explaining why regulators are once again putting the administration’s costly climate agenda ahead of the best interests of consumers.
Specifically, the proposed rule would set new efficiency standards for water heaters and do so in a manner that threatens product choice. It is important to emphasize no two homes and no two homeowners are exactly alike – there are differing home sizes and configurations and venting requirements as well as different patterns of water heater use. Thus, having a wide variety of water heater types to choose from is best from a consumer standpoint. However, the proposed rule would limit options. For some homes that currently have a non-condensing gas furnace, the new models may be significantly more difficult to install, not only raising costs but leading to potential performance and safety issues. This is particularly true of older and space constrained homes. Low income and senior households would be hardest hit, as they often own such homes.
Further reducing consumer choice, non-condensing gas-fired instantaneous (tankless) water heaters are subject to an extremely stringent standard under the proposed rule and quite likely would disappear as an option. Although such water heaters are a relatively small percentage of the current market, there are homeowners who prefer them. Among the advantages are relative ease of installation due to smaller size as well as the ability to provide an unlimited supply of hot water – factors that provide “utility to the consumer,” and thus should be preserved under the law.
Ironically, instantaneous water heaters are inherently more energy efficient than comparable storage water heaters since they heat the water when needed rather than maintain a tank full of hot water at all times. But by subjecting them to an impossibly high standard, the proposed rule would effectively take them off the market.
Overall, the proposed rule complicates the continued use of natural gas water heaters in favor of electric ones, and this is by design. Water heaters, as with stoves and furnaces (which are also the subject of pending efficiency regulations for which CEI submitted critical comments) come in both natural gas and electric versions, and the Biden administration has fully bought into the notion that weaning homeowners away from natural gas is a necessary part of its climate agenda. It is misusing the energy efficiency standards program to push homeowners towards electric appliances.
Perhaps worst of all is the fact that the proposed water heater standard favors electric water heaters while other Biden administration climate policies are making reliance on electric appliances increasingly risky. Both the North American Electric Reliability Corporation (NERC) and PJM have warned of growing risks to electric reliability as baseload coal and natural gas is being replaced by intermittent wind and other renewables. In other words, the electrification agenda – of which the proposed rule on water heaters is a part – means homeowners would be putting more of their eggs in one basket (the electrification basket), while other Biden administration climate policies are making that basket increasingly flimsy