To the Secretary of Energy, Mr. Steven Chu:
quote
Subject: Misuse of Energy Star Label in "legititmate" applications
Date: Sun, 28 Mar 2010 09:09:24 -0300
Dear Mr. Chu:
Besides some of the outright hoaxes under the Energy Star label, there are occasionally problems of disastrous misuse of the label, which may seem perfectly legitimate on the surface.
Perhaps the biggest "legitimate" hoax under the Energy Star label is the oxymoron of a Tankless Hot Water Heater with Energy Star Rating, which qualifies for tax incentives to boot, but which positively undermines the
architecting of a renewable energy future.
The problem here is one of sub-optimization, and is in this case quite disastrous in nearly all applications of Hot Water Heaters. Namely, DHW storage is the cheapest most effective form of Energy Storage imaginable,
and switching to a tankless system is a ruinous decision from an energy management standpoint, since it means throwing out nearly "free" batteries, that would allow a property to harvest cheap energy, be it off-peak grid power, via time-of-use metering, or peak-load power such as wind or solar.
Conversely tankless water heaters may be quite valuable as backup power, in situations where renewable peak power is used, however in that case the Energy Star models should not be used, as they introduce needless maintenance issues if they only fire up a few times a year. So for that application, actually the non-energy star models are preferred, because they will last longer and are therefore dollar for dollar more effective and likely to be more reliable.
This issue is big enough that it deserves top level attention. There are geothermal heatpumps which can generate DHW with 400% efficiency, and as long as you design water storage large enough for intra-day use during peak power, you can run these off-peak on the grid, or alternatively with peak loads such as wind or solar, and have "free storage," and I'm using "free" advisedly, for the analytical point is that the water storage is cost justifiable from the DHW application alone.
Even large organizations, like NYC Housing Authority, have used stimulus funding to install tankless hot water heaters, and thus undermine their own long-term renewable energy future. It is time for this fallacy to stop.
Of course more generally there is always a risk of sub-optimization, if the attention becomes focused on the component level. Thus there is need for wide use of system-level Energy Star ratings, which could offset the
type of abuse of the rating here. It is too silly that stimulus money should be used to prolong the carbon intensive energy economy, instead of enabling the renewable energy future.
unquote
To which the unfortunate reply was:
quote
EXEC-2010-005700
Dear Rogier Fentener van Vlissingen,
Thank you for contacting the U.S. Department of Energy. I understand you have concerns about ENERGY STAR qualified tankless hot water heaters.
ENERGY STAR is a joint program of the U.S. Department of Energy (DOE) and the U.S Environmental Protection Agency (EPA) designed to help all consumers save money and protect the environment through energy efficient products and practices. In an effort to ensure that only products meeting the program requirements can receive an ENERGY STAR label, the EPA and DOE are further strengthening the certification process. For an outline of these steps, please view:
ENERGY STAR
News and Announcements
EPA, DOE Announce Changes to Bolster ENERGY STAR Program (April 2010)
http://www.energystar.gov/index.cfm?c=news.nr_news&news_id=http://www.energystar.gov/cms/default/index.cfm?LinkServID=E77FB9F2-96D9-EAAD-6B3C6ECF0D9E4808#c_B4A3256E-188B-36F7-215E56FDB1D2450C
If you have further questions about ENERGY STAR product ratings, please contact ENERGY STAR directly through the contacts listed on the following web page:
ENERGY STAR
Contact Us
http://www.energystar.gov/index.cfm?c=contact.ct_index
You may be interested in reviewing rulemaking activities and regulations regarding energy efficiency for residential water heaters available through the DOE Office of Energy Efficiency and Renewable Energy’s (EERE) Building Technologies Program:
U.S. Department of Energy
Office of Energy Efficiency & Renewable Energy (EERE)
Building Technologies Program
Appliances & Commercial Equipment Standards
Residential Water Heaters
http://www.eere.energy.gov/buildings/appliance_standards/residential/waterheaters.html
The federal tax credits for energy efficiency are congressionally mandated. Products that qualify as a federal energy efficiency tax incentive were set forth in the Energy Policy Act of 2005. On October 3, 2008, former U.S. President George W. Bush signed into law the Emergency Economic Stabilization Act of 2008 to extend many of the energy efficiency tax incentives first enacted in 2005 that expired at the end of 2007, or that were scheduled to expire at the end of 2008. On February 17, 2009, Congress passed the American Recovery and Reinvestment Act of 2009 which includes several provisions modifying and expanding the scope of the energy efficiency and renewable energy incentives:
The Tax Incentives Assistance Project (TIAP) Legislative Language & Pending Updates
http://energytaxincentives.org/general/legislative.php
To inquire about possible changes to the list of eligible products, please contact your local congressperson.
For information on how energy related stimulus funds are being implemented in the state of New York, you may wish to contact your state energy office or view New York’s recovery website. Below you will find your state’s energy office contact information as well as a link to your state’s Recovery Act website:
New York State Energy Research and Development Authority
Energy Efficiency Services
17 Columbia Circle
Albany, NY 12203-6399
Phone: (518) 862-1090
http://www.nyserda.org/
Recovery New York
http://www.recovery.ny.gov/
As you mentioned geothermal heat pumps, you may be interested in viewing the following websites:
U.S. Department of Energy
Office of Energy Efficiency and Renewable Energy Energy Savers
Geothermal Heat Pumps
http://www.energysavers.gov/your_home/space_heating_cooling/index.cfm/mytopic=12640
Geothermal Heat Pump Consortium
The Consortium is a national non-profit trade association of the geothermal heat pump industry.
http://www.geoexchange.org/
U.S. Energy Information Administration (EIA)
Geothermal Heat Pumps
http://www.eia.doe.gov/cneaf/solar.renewables/page/heatpumps/heatpumps.html
Western Area Power Administration
Geothermal Heat Pumps
www.wapa.gov/es/pubs/fctsheet/GHP.pdf
Sincerely,
Amy Foster Parish
EERE Information Center
Office of Energy Efficiency & Renewable Energy (EERE)
U.S. Department of Energy
http://www.eere.energy.gov
unquote
Oh well, so off I go, now to write to the Energy Star program directly... to be continued.
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