Transcontinental Gas Pipe Line Company, LLC submits responses to Staff's May 19, 2015 Environmental Data Request regarding the Atlantic Sunrise Project under CP15-138.

APPLICATION FOR EXCEPTION UNITED STATES DEPARTMENT OF ENERGY OFFICE OF HEARINGS AND APPEALS ____________________________________ ) In the Matter of: ) ) The Steffes Corporation ) Case No: __________________ 3050 Highway 22 North ) Dickinson, North Dakota 58601 ) ) Filing Date: July 18, 2014 ) ____________________________________ Background The Steffes Corporation (Steffes or the Applicant) respectfully submits this Application for Exception (Application) to a Final Rule issued by the United States Department of Energy (DOE) on April 16, 20101 (Final Rule). In that Final Rule, DOE amended existing energy conservation standards for residential water heaters manufactured2 on or after April 16, 2015 (the Compliance Date), including standards for certain electric storage water heaters that would require an Energy Factor (EF) of 2.0. In practical terms, the Final Rule requires the use of an electric heat pump for electric storage water heaters larger than 55 gallons in volume and eliminates the use of like sized electric resistance water heaters. Heretofore, DOEs minimum standards for all residential electric storage water heaters, irrespective of size, would have allowed the use of electric resistance elements. As discussed in more detail herein, heat pump water heaters offer consumers the potential for substantial energy savings but, currently, they are not a good fit for use in certain common niche applications like load shifting, renewables integration and demand response. These applications typically require the use of electric storage water heaters larger than 55 gallons. Under the current rule, a heat pump water heater will be required for these larger tanks after April 16, 2015; however, a heat pump water heater today cannot meet the requirements of the niche applications aforementioned. This Application requests an exception from the Final Rule to allow Steffes to continue to fabricate large capacity storage electric resistance water heaters in certain limited circumstances. The Applicant, Steffes, is a sixty year old U.S. manufacturing company that employs about 200 persons in North Dakota where all of its products are made. For the past twenty-seven years, Steffes has made and supplied to the U.S. electric utility industry a variety of innovative off-peak space and water heating products. Operationally, these off-peak products are designed to cut-off electric resistance heating elements for periods of time when a utility sends a signal, thereby allowing the utility to manage its peak loads. By reducing peak loads, utilities are able to operate their generation, transmission and distribution systems more efficiently and avoid the construction of new, more expensive generation which, in turn, helps to keep rates affordable for consumers. While such peak-shaving activities are well ...