New Source Review - what it really means

Per Lynne Kiesling:

Much of the angst regarding the revisions to the NSR process flows from a lack of perspective. Perhaps an example of the EPA’s revised approach to NSR applied to a residential scenario will help "clear the air".

The owners of an older home notice that their water heater has begun to leak and must be replaced. While shopping for a new water heater, they discover that new water heaters of the same storage capacity and energy input are available with higher efficiencies than their old unit and that these higher efficiency water heaters would thus use less energy to produce the same amount of hot water and cost less money to operate. They decide to purchase one of the more efficient water heaters.

However, the salesman then hands them a copy of an EPA document entitled “Homeowners’ Guide to NSR Compliance”. The homeowners read the guide and learn that, if they replace their old water heater with a more efficient water heater of the same storage capacity and energy input, they will also be required to bring all other aspects of their home and its energy using equipment into compliance with current codes and standards. This would involve replacing their existing heating and cooling system with a new system which meets the minimum efficiency standards established by the National Appliance Energy Conservation Act (NAECA) and perhaps also their current clothes washer and dryer, range, refrigerator, etc. It would also require that they replace their current windows or add storm windows, increase the insulation levels in their walls and ceilings, renew caulking and weather stripping and take other energy conservation measures required by the codes in their state and/or city.

On further reflection, the homeowners decide that the extra operating cost of the new, but lower efficiency, water heater is not so bad compared with the cost of bringing their entire home into compliance with current codes and standards all at once. This decision does not make their home less energy efficient than it was before, but it does leave it less efficient than it might otherwise have been, at least until the next time the water heater requires replacement.