Jay Morrison, NRECA vice president, regulatory affairs, said the Department of Energy will listen to co-op input on the issue.

 

Co-ops have “a pretty good chance” of making the case for the change, which would eliminate a threat to many demand response efforts, he said.

 

To succeed, they must weigh in by DOE’s July 13 deadline on how the regulations would put benefits to their members at risk.

 

More than 240 co-ops in 21 states use large capacity electric resistance water heaters to heat and store hot water at night, when electric demand and power supply costs are low. This lowers peak demand during the day, when costs are highest.

 

However, DOE’s revised standards require electric water heaters with storage capacities of more than 55 gallons to have a 200 percent efficiency factor by April 16, 2015. This standard can be met only with heat pump water heaters, the association noted.

 

“We support the use of heat pump water heaters,” Morrison emphasized. “But the revised standards have the effect of taking electric resistance models out of the available mix. This would have a huge impact on utility demand response programs.”

 

A coalition of stakeholders, including NRECA, Maple Grive, Minn,-based Great River Energy, and others, has turned the department’s attention to the threat. DOE has issued a request for information about its standards’ impact on utility demand response programs that use electric storage water heaters.

 

DOE’s information request solicits feedback on the effects of the amended standards on such programs. Comments are due by July 13.

 

“This request is a very positive step,” Morrison told participants in a June 27 conference call.

 

Anti-backsliding provisions bar the department from lowering the standards, he pointed out. But it can say that electric resistance water heaters used for thermal storage are a different kind of appliance—a battery—subject to a different efficiency standard.

 

“To get over the next hump,” the NRECA executive told co-ops, “we need good information on how many water heaters you’re using and the amount of value this brings to members.”

 

Morrison characterized the likelihood of obtaining relief as favorable, “if we can get comments on the request.”

 

He said a decision from DOE is not likely until at least September.