DOCKETED  
Docket Number:  20-AAER -02 
Project Title:  Air Filters  
TN #:  245718  
Document Title:  Public Notice 15 -day comment period  
Description:  Public notice initiating a 15 -day comment period for new 
regulation, this document supersedes docket TN# 245617  
Filer:  Alex Galdamez  
Organization:  California Energy Commission  
Submitter Role:  Commission Staff   
Submission Date:  8/29/2022 12:31:18 PM  
Docketed Date:  8/29/2022  
 STATE OF CALIFORNIA — NATURAL RESOURCES AGENCY  Gavin Newsom, Governor  
 
CALIFORNIA ENERGY COMMISSION   
715 P Street  
Sacramento, California 95814  
 
energy.ca.gov  
 
CEC -057 (Revised 1 /21)
NOTICE OF 15 -DAY PUBLIC COMMENT PERIOD 
PROPOSED REVISIONS TO THE  
AIR FILTERS  REGULATIONS  
 
California Energy Commission  
Docket No. 20 -AAER- 02 
 
On March 25,  2022, the California Energy Commission (CEC) published a Notice of 
Proposed Action with proposed amendments to the air filters regulations contained in 
the California Code of Regulations, Title 20. The CEC made all the documents available 
for a 45 -day comment period and held a public hearing on May 10, 2022.   
Based on comments received during the written comment period and the public hearing, the CEC is proposing changes to the proposed amendments offered on March 25, 
2022. Any interested persons are invited to review and provide written comments 
to the CEC for consideration during the 15 -day comment period from August 2 9, 
2022, through September 13 , 2022.  The CEC appreciates receiving written comments 
at the earliest possible date. Comments submitted after  September 13 , 2022,  are 
considered untimely and the CEC may, but is not required to, respond to such 
comments, including those raising significant issues.  
 The CEC encourages use of its electronic commenting system. Visit the e- commenting 
page at 
https://www.energy.ca.gov/rules -and-regulations/appliance -efficiency -
regulations -title-20/appliance- efficiency -proceedings -0, which links to the comment 
page for this docket.  Enter your contact information and a comment title describing the 
subject of your comment(s). Comments may be included in the “Comment Text” box or 
attached as a downloadable, searchable document consistent with 20 California Code 
of Regulations Section 1208.1. The maximum files size allowed is 10 MB.  
Written comments may also be submitted by email. Include docket number 20- AAER -02 
in the subject line and email to docket@energy.ca.gov .  
    
A paper copy may  be sent to:  
 
California Energy Commission  
Docket Unit  
Docket No. 20-AAER -02 
715 P Street, MS -4 
Sacramento, CA 95814  
 
Written and oral comments, attachments, and associated contact information (including 
address, phone number, and email address) will become part of the public record of this 
proceeding with access available via any internet search engine.  
 The 15 -day proposed language and related documents are available for review on the 
CEC website at 
https://www.energy.ca.gov/rules -and-regulations/appliance- efficiency -
regulations -title-20/appliance- efficiency -proceedings -0.  
 In accordance with Government Code sections 11346.8 and 11347.1, these documents 
are made available for public comment at least 15 days before the CEC’s conside ration 
and possible adoption of the proposed regulations. Copies of these documents are available for public inspection at the CEC located at the address above, subject to 
COVID -19 limitations. The CEC has considered all public comments received in 
developing the 15 -day proposed language.  
 
The text of the modified regulatory language is also included as Attachment A. Amendments to the existing code that were made public with the 45 -day notice on 
March 25, 2022, are shown in strike through to indicate deletions and underline to 
indicate additions. Additional amendments proposed with this 15- day notice are shown 
in double strikethrough for deletions and double underline for additions.  
 
In the Final Statement of Reasons, staff will respond to all comments received on the 
record during comment periods. The Administrative Procedure Act requires that staff 
respond to each objection or recommendation made regarding the specific adoption, 
amendment, or repeal proposed, together with an explanation of how the proposed 
action has been changed to accommodate each objection or recommendation, or the 
reasons for making no change. Therefore, staff will only address comments received 
during opportunities to comment that are responsive to this notice, documents added to 
the record, or the changes detailed in the proposed 15- day language at the above -
referenced website.  
 
To stay informed about this proceeding and receive documents and notices of 
upcoming workshops and hearings as they are filed, please subscribe to the proceeding 
email subscription at the foll owing link: https://www.energy.ca.gov/rules -and-
regulations/appliance- efficiency -regulations -title-20/appliance- efficiency -proceedings -0. 
The email subscription sends out email notifications and direct links when documents 
and notices are filed in the proceeding docket. If you are unable to access the website 
and would like a copy of the rulemaking documents mailed or emailed to you, or if you have any questions, please contact Corrine Fishman at 
corrine.fishman@energy.ca.gov .  
 The CEC’s Public Advisor provides the public assistance in participating in CEC 
proceedings. If you want information on how to participate in this forum, please contact 
the Public Advisor at publicadvisor@energy.ca.gov
, or by phone at (916) 957 -7910. 
Requests for language services and reasonable accommodations should be made as soon as possible or at least five days in advance. The CEC will work diligently to 
accommodate late requests.  
 Direct media inquiries to the Media and Public Communications Office at (916) 654- 
4989, or by email at mediaoffice@energy.ca.gov
.  
If you have question on the subject matter of this notice, please contact Alejandro Galdamez at alejandro.galdamez@energy.ca.gov
 or (916) 237 -2550.  
 SUMMARY OF PROPOSED MODIFICATIONS  
The following is a summary of the amendments proposed with 15 -day language. It does 
not include non- substantive amendments to correct typographical or grammatical errors, 
change/correct numbering or formatting, or improve clarity.  
 
Section 1602:  
 
- The following definitions were edited or deleted:  
o Air filters definition was updated to include suggested language received through public comments to clarify which products fall within the definition, 
including an enumerated list of products, such as electronic air cleaners, that do not constitute air filters. The changes to the definitions were 
necessary to add clarity and exclude a specific appliance that may be 
regulated or is in the process of becoming regulated by the U.S. 
Department of Energy.  
o The term “electronic air cleaner” was defined to make clear these appliances are excluded from this regulation.  
 
Section 1606:  
- Changed the effective date of the proposed regulation from December 1, 2022, to April 1, 2023. The change was necessary to provide ample time for 
manufacturers to make the necessary changes required for compliance under the proposed regulations. CEC staff has simplified the labeling requirements 
under the proposed regulation to accommodate implementation and prevent 
shortages due to the impacts COVID -19 pandemic has had on inventory and the 
supply chain. Further, the proposed effective date will not affect current inventory since the proposed regulation is applicable only to air filters manufactured after the proposed effective date. Reminder that Public Resources Code section 
25402(c)(1)(A) does not apply to labeling requirements.  
 Section 1607:  
- Made changes to 1607(d)(11) to require that products be marked on the pleated 
pack or retail package when sold individually, instead of on the filter itself  with an 
effective date of April 1, 2023 .  
- Included language to 1607(d)(11) to require specific informati on to be labeled on 
the filter frame as needed to assure the correct filter replacement. This requirement will become effective on January 1, 2026.  
- Made changes to 1607(d)(11)(A)(2) and 1607(d)(11)(B)(2) to add the word sizes to the phrase air filter to a dd clarity to the provision that allows for different sizes 
of the same basic model of an air filter to be labeled with information based on testing of the basic model only.  
- Edited Table Z -1 and Table Z -2 to clarify the “*Max Rated Airflow.” Previously, 
Tables Z -1 and Z -2 gave the impression that there was a maximum rated value 
in addition to values 4 and 5 (respectively) of said tables. Values 4 and 5 of the tables are the maximum rated airflows identified on tables Z -1 and Z -2 
(respectively), and the empty cell under the “*Max Rated Airflow” was removed to avoid creating this confusion.  
- Added Table Z -3 as an example table to the label requirement for the frame of 
the air filter becoming effective on January 1, 2026.  
SUMMARY OF COMMENTS NOT IMPLEMENTED 
Section 1602:  
- Changes to the basic model were suggested  to remove specific language from 
the definition. After review of the role that material  type, material grade, 
construction , and the different descriptors in the proposed definition have toward 
the effi ciency of the air filter, the suggested changes were not implemented.  
Section 1604:  
- The suggested requirement to calculate the initial value at 0.2 inches water 
column was not implemented. The intent to calculate the initial resistance at 0.1 
inches water column is aimed to support the requirements specified in the 
California Energy Code (Part 6 of the Title 24 Building Standards Code) for new 
residential construction and is based on a 150 fpm face velocity flowrate. Staff notes that this does not prohibit manufacturers from calculating the face velocity 
of the filter at 0.2 inches of wate r column for existing equipment as suggested.  Sectio n 1606:  
- The suggested effective date of 1- year after adoption was not implemented. CEC 
understands that manufacturers require time to implement the required labelling 
procedures and has responded to this  need by delaying the effective date by two 
calendar quarters while also simplifying the labeling requirement itself. Further, because the required labeling procedures only apply to filters manufactured from 
the effective date on, they will not affect exis ting inventory and accessibility of 
existing air filters at retail stores.  
Section 1607:  
- Suggested change from “ shall” to “ can” in 1607(d)(11)(A)(2)(b) and 
1607(d)(11)(B)(2)(b) was not implemented because,  although smaller or bigger 
filters may have slightly differen t values for filter resistance when tested, the 
purpose of the proposed language is to establish objectives and consistent 
product performance tests and communicate performance information derived from those tests. The propos ed regulatory language does not prohibit any 
manufacturer from conducting additional testing for different size filters and labeling filters of associated sizes with performance information resulting from 
said tests.  
- Suggestion to change the particle size on the label to reflect the particulate 
matter (PM) rather than the proposed particle limits was not implemented to 
avoid any confusion and/or ambiguity since the proposed values are those used 
in the proposed test procedures.   
- Suggested removal of the particle size efficiency from the labeling requirements was not implemented since it reflects the results from the proposed test 
procedure and provides the minimum efficiency information for consumers and 
designers of the systems where the filters are used. The label requirements 
proposed under this regulation do not prohibit manufacturers from supplying 
additional information to assist consumers on the efficiency of the filters.  
- The suggested removal of an airflow rate of 125 percent  from the label was not 
implemented because it is an efficiency performance datapoint reflected in the 
proposed ANSI/ASHRAE 52.2- 2017 test procedure. The removal of the value 
from the label would  only cause confusion when the test lab results are 
compared to the label.  
- The suggestion to allow for the labeling information to be available online only was not implemented since it assumes that all consumers  in California  have 
access to the internet or own a smart phone to access the performance data of 
the label. Since the suggestion could  negatively impact low- income individuals 
and those in disadvantage communities from having access to the information 
under the proposed regulation,  the suggestion was not implemented.