CFA and other advocates responded to the Department of Energy’s request for information (RFI) on updating water heater efficiency standards.

The following points were made in the comments submitted by the groups:

•  DOE should consider the full range of heat pump designs including gas, gas-hybrid, CO2, and 120-volt products.
• We support the storage water heater product classes used in the 2010 final rule.
• We urge DOE to again consider standard levels that include capacity break points.
• We strongly oppose a separate product class for non-condensing water heaters, which would be both unnecessary and illegal.
• We urge DOE to eliminate the tabletop water heater product class and avoid adding new product classes that are unnecessary and could undermine future standards if niche classes are subjected to weak standards.
• We urge DOE to fully evaluate higher standards for grid-enabled water heaters and consider consolidating the product class with other storage water heaters.
• DOE should include consumer choices to select smaller storage volume water heaters and adjust set points if needed to meet their water heating needs as part of its consumer choice modeling.
• DOE must enforce its water heater standards.
• We urge DOE to inventory and pay attention to developments in the market for demand flexible water heaters.”