Large Grid-Enabled Water Heaters in Peril But We re Working Towards a Negotiated Solution Keith Dennis, PE Senior Principal End-Use Solutions and Standards 11/4/13
NRECA Overview Not-for-profit, national service organization representing over 900 not-for-profit, member-owned, rural electric cooperative systems Serve 42 million customers in 47 states. NRECA estimates that cooperatives own and maintain 2.5 million miles or 42 percent of the nation s electric distribution lines covering three-quarters of the nation s landmass. Cooperatives serve approximately 18 million businesses, homes, farms, schools and other establishments in 2,500 of the nation s 3,141 counties.
Efficiency Standards and Water Heaters Overview: 2010-2012 The Energy Policy and Conservation Act of 1975 gives DOE the authority to set energy conservation standards for appliances ranging from motors to dishwashers and microwaves. In 2010, DOE finalized a final rule that effectively bans manufacture of electric resistance water heaters (ERWHs) sized over 55 gallons in 2015 in favor of heat pumps a standard almost twice as high as in the proposed rule. As it stands, this will adversely affect many cooperatives and other utilities demand response / load shifting and energy storage programs. Large water heaters can be considered thermal batteries that can be charged at night or when there is excess capacity (or wind) available. In June, 2012 DOE issued an RFI on the issue, and PJM, NRECA, APPA, EEI, Steffes submitted joint comments in July.
Communicating Benefits Grid-Enabled Water Heaters Co-ops provide leadership in load control programs that save at least 500 MW of demand and hundreds of millions of dollars per year for consumers. Approximately 250 co-ops in 34 states have voluntary demand response programs using large capacity electric resistance water heaters that allow co-ops to reduce demand for electricity during peak hours. Benefits include: Load shifting Energy Storage Grid regulation and balancing There are MANY Federal policies that support the DR benefits and cheap energy storage. 4
Overview of NRECA s Position Co-ops support strong energy efficiency standards as long as they are cost effective and many of our members have programs that promote purchase of heat pump water heaters for EE programs. However, we must be sure that efficiency standards do not undermine demand response programs: saving kwhs, but using them at the wrong times of day. We strongly believe that the 75+ gallon electric water heaters used in load management make our Nation s energy grid more efficient. We would like to work with all stakeholders to demonstrate that this cheap energy storage technology benefits us all and that a simple solution to the unintended consequences of the 2010 rule is needed. We would like a new classification for 75+ gallon ERWH units, which we can work to distinguish from smaller units through marketing and product differentiation.
We Need To Solve This Problem In 2013, DOE issued a new preliminary rule to allow waivers from the 2010 rule for ERWHs used in DR programs, but the waivers were annual in nature and very complex, making them unworkable. In its February 2013 Notice of Proposed Rulemaking DOE stated: DOE believes that electric thermal storage (ETS) programs involving water heaters provide numerous benefits to consumers, utilities, and the Nation DOE believes that the evidence presented indicates that these programs provide a number of valuable benefits to consumers, utilities, and the Nation. As a result, DOE agrees that action should be taken to mitigate the impacts of the April 2010 final rule standard levels on utility ETS programs in order to help preserve these benefits
Working Together on a Solution!
EE Water Heaters The Legislative Front NRECA is pursuing a legislative solution to the issue created by the 2010 rule. Stakeholders reached a consensus on legislative language to address the water heater and it has been distributed by Senate staff as a consensus document. The future of the legislation is uncertain, but it could potentially be included as an amendment to the Shaheen- Portman Bill, which is currently stalled in Congress. In addition to the legislation, 94 members of Congress recently signed a letter and sent it to DOE to pressure them to fix their waiver process.
EE Water Heaters The Regulatory Front While the legislative solution has the backing of the entire stakeholder group, DOE is simultaneously involved in a rulemaking process. Key considerations in a rule include: Limiting the solution to >75 gallon, highly efficient units (222,000 units in 2012, 2.9% of total market) Marketing strategy to ensure units are only installed in load control programs An activation key / mechanism Would eliminate leakage concern and ensure these units are not used to meet high demand consumers, but rather DR program participants
Questions Welcome!