Noritz supports the Department of Energy’s ongoing efforts to reduce our nation’s carbon footprint. Water heater manufacturers have actively participated in that effort for years. But we know much work remains, particularly in the necessary shift from conventional, non-condensing equipment to higher-efficiency condensing technologies.
But we are nonetheless puzzled at the DOE’s recently proposed changes to residential water heater standards. In particular, we do not understand why energy-wasting, non-condensing, storage tank water heaters, which command a significantly larger share of the American home market, remain a choice, even while condensing storage tank options are available.
At the same time, the instantaneous (tankless) category, currently a distinct minority in the U.S., loses the non-condensing option even though it is far more efficient than non-condensing storage units. Non-condensing tankless water heaters offer energy efficiency ratings of 80% and more, while ratings for non-condensing tankless water heaters are still around 60%.
It makes zero sense.
What’s the impact on homeowners? …on contractors?
No doubt, these rules, if enacted, will boost the efficiency of water-heating equipment. Water heating is the second-largest consumer of energy in the home, so reductions in energy usage will lead to lower carbon emissions and potentially lower utility bills for consumers.
But this rule-making will also cause pain — not only for manufacturers like Noritz but also for consumers. And there will also be some learning curve adjustments for professional contractors.
Consumers: The primary downside for the home or small building owner will be the obsolescence of their existing equipment. Newer, advanced technology products come with changes to installation practices. These changes will often necessitate significant infrastructure alterations to the interior in the case of replacement.
For example, switching from a non-condensing tank-type water heater to a condensing-type water heater will require changes to the vent. Such an installation must also create the means to neutralize and drain the acidic condensate that forms during water heater operation.
Most water heater replacements happen on an emergency basis, with slam-dunk, like-for-like replacements being the rule. But the new regs will short-circuit the usual like-for-like strategy, as the significant installation changes they necessitate bring higher costs in equipment and labor.
The new equipment will bring greater complexity, and complexity generally incurs higher costs. As the latest equipment’s market share grows, these costs may somewhat decline through economies of scale. But this will prove only a partial remedy. Higher-efficiency equipment, by nature, needs more material and controls to operate safely compared to older, less efficient products.
There are also concerns about retrofitting newer equipment into older homes successfully replacing existing equipment. In some cases, this will simply be a cost consideration; i.e., changing from a gas tank water heater to an electric heat pump may require an upgraded electrical panel.
But there are also homes with physical constraints, such as the size or location of an existing storage tank water heater. That reality may make replacement with a similarly performing but different type of water heater difficult.
Finally, the physical size of similarly performing tank equipment will change slightly, likely getting larger, as tanks add components or insulation to meet the required efficiency levels.
Of course, tankless water heaters suffer none of these size or location limitations. With their carry-on suitcase-size dimensions and ability to be wall-hung — tucked away in a closet, an attic, or outside the home in warmer climates — zero-footprint tankless water heaters can go where tank models can only dream of following.
Contractors: Professional installers and service techs will need more training, as many new pieces of equipment involve more sophisticated controls and mechanisms to meet the efficiency requirements. But this would not be the first time new water heating technology demanded climbing a learning curve. Years ago, when instantaneous wall-hung units first arrived in North America, contractors had to learn how to install, service, and maintain the new equipment, which was significantly more complex than the standard gas storage water heaters it was replacing.
But today’s heat pump water heaters bring a new wrinkle: refrigerants. Although HVAC contractors are well-versed, many plumbing contractors lack familiarity. Refrigerants are used in sealed, pressurized systems where leaks can be a concern, as many existing heat pump water heaters have very high GWP (Global Warming Potential).
Additionally, because these systems operate differently than traditional water heaters, consumer unfamiliarity may lead to more concerns and complaints.
Please reconsider, DOE
As a tankless water heater manufacturer, Noritz still sees substantial value in non-condensing tankless product remaining on the market. This is especially the case for lower-income customers unable to switch to a condensing-type water heater without incurring significant conversion costs during installation. Eighty-percent-efficient tankless water heaters still have many worthwhile uses, offering sustainable, green-building solutions to specific trending applications, such as accessory dwelling units, tiny homes, and many more.
If American home and building owners can retain the option for non-condensing instantaneous product, this concession could be offset by a corresponding minimum UEF increase or a slight adjustment on the minimum UEF requirement for compliant condensing water heaters.
On the other hand, if the DOE eliminates non-condensing units, might this push consumers into buying less expensive — and less-efficient — tank-type water heaters? And wouldn’t the net result be an increase, rather than a decrease, in energy consumption?
Finally, the DOE has indicated that condensing and non-condensing gas-fired water heaters have identical lifespans. Based on our limited internal testing (our company has marketed condensing water heaters only since 2009), Noritz doubts this is the case. Because they are less complex, non-condensing tankless water heaters will typically last between 10 and 20 percent longer than a similar condensing product.
Bottom line: Noritz hopes the DOE and other governmental bodies will reconsider their proposal to retain non-condensing tankless technology as a still-effective means of reducing the carbon footprint of many more American homes.