This regulation will generate a significant increase in replacement costs for consumer water heaters. If this rule were finalized, seniors would be unable to afford to replace their existing natural gas systems and forced to switch to higher-cost electrical water heating.
September 20, 2023
The Honorable Andrew Ogles
5th Congressional District of Tennessee
151 Cannon House Office Building
Washington, DC 20515
Dear Representative Ogles,
On behalf of the over 2.2 million members of AMAC – Association of Mature American Citizens, including over 6,200 members residing in TN-05, I write to offer our support for your bill to require the Secretary of Energy to withdraw an ill-conceived proposed rule relating to energy conservation standards for consumer water heaters.
This bill seeks to ultimately, and most appropriately, remove an incomprehensible proposed regulation by the Department of Energy (DOE) from consideration and subsequent implementation. A detailed analysis of the regulation, “Energy Conservation Program: Energy Conservation Standards for Consumer Water Heaters,” notes that compliance with this regulation will generate a latent and significant increase in replacement costs for consumer water heaters. This is an issue for senior Americans on fixed incomes. If this rule were finalized, seniors would be unable to afford to replace their existing natural gas systems and forced to switch to higher-cost electrical water heating.
The Energy Policy & Conservation Act (EPCA) outlines strict requirements for DOE to determine if a new energy efficiency or water conservation standard is necessary. These requirements include determining if the increase in energy efficiency is more significant than the economic impact caused by the proposed regulation. Additionally, DOE has a policy to prevent “fuel switching” due to proposed energy efficiency regulations. This proposed regulation violates both of those requirements. Replacing a non-condensing water heater with a condensing water heater requires significant changes to the home to ensure safety in venting flue gases. These changes require significant spending by homeowners that drives up the economic impact of this proposed rule. These costs will be significant enough that many homeowners will switch from natural gas or propane to electric systems. In too many parts of the country, the cost of electricity far exceeds that of natural gas, further increasing the economic impact of this proposed rule. This is precisely the kind of regulatory overreach that the REINS Act (we thank you for cosponsoring) is intended to prevent.
AMAC thanks you, Representative Ogles, for introducing this critical legislation to protect Americans, particularly seniors, from this regulatory overreach.
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