Appliance Standards and Rulemaking Federal Advisory Committee

Commercial HVAC, WH, and Refrigeration Certification Working Group

Alternative Efficiency Determination Methods (unanimous – note abstentions)

Background (Unanimous)

On February 26, 2013, members of the Appliance Standards and Rulemaking Federal Advisory 

Committee (ASRAC) unanimously decided to form a working group to negotiate rulemaking on 

certification for commercial heating, ventilation, and air-conditioning (HVAC), water heating 

(WH), and refrigeration equipment (CRE). In communication with staff from the U.S. 

Department of Energy, ASRAC members established a deadline of September 1, 2013 for a final 

recommendation to be submitted to ASRAC for review and open deliberation. The Commercial 

HVAC, WH, and Refrigeration Certification Working Group (Commercial Certification WG) is also 

required to submit an interim report by June 26, 2013.

A notice of intent to form the Commercial Certification WG was published in the Federal 

Register on March 12, 2013, to which DOE received 35 nominations. Of the 35, 22 were 

selected to serve as members, in addition to two members from ASRAC, and one DOE 

representative (see Appendix A). During the working group’s first meeting, working group 

members voted to expand the scope of the negotiated rulemaking efforts to include developing 

methods of estimating equipment performance based on simulations commonly referred to as 

Alternative Efficiency Determination Methods (AEDMs). As a starting point, the Commercial 

Certification Working Group held a two-day meeting at the U.S. Department of Energy’s 

headquarters in Washington, DC on May 14-15 to begin negotiations. 

Although the WG’s Ground Rules only require a consensus (defined as no more than two 

dissenting votes) to adopt a recommendation, the following sections describe the 

recommendations voted upon by the Commercial Certification WG during the 2-day meetings

along with the voting results for each subsection. 

Pre-approval of the AEDM Prior to Use (Unanimous)

The Commercial Certification WG recommends that AEDMs are not pre-approved before use 

for any type of commercial HVAC, WH, or CRE equipment. This is consistent with DOE’s 

proposal (77 FR 32038). 

Applicable Products (Unanimous)

The Commercial Certification WG recommends allowance of the use of AEDMs for the following 

product types: 

• Commercial Air-Conditioning Equipment;

o Commercial packaged air-conditioning and heating equipment (air-cooled, 

water-cooled, evaporatively-cooled, and water-source)

o Packaged Terminal Air Conditioners and Heat Pumps

o Computer Room Air Conditioners

o Single Package Vertical Air Conditioners and Heat Pumps
o Variable Refrigerant Flow Systems

• Commercial Water Heaters, Hot Water Supply Boilers, and Unfired Hot Water Storage 

Tanks; 

• Commercial Packaged Boilers;

• Commercial Warm-Air Furnaces; and

• Commercial Refrigeration Equipment.

Validation (What does a manufacturer need to do to validate his or her 

AEDM prior to use?)

The Commercial Certification WG recommends the following requirements be met for selecting 

models for physical testing to the DOE test procedure for comparison to the AEDM prior to its 

use: 

For each AEDM, a manufacturer should select the minimum number of models that meet the 

following criteria for each of the validation classes to which the AEDM is going to apply, where 

a manufacturer distributes in commerce equipment falling into each of the validation classes. A 

manufacturer may elect to develop multiple AEDMs per validation class and each AEDM may 

span multiple validation classes, however, the minimum number of tests must be maintained 

per validation class for every AEDM a manufacturer chooses to develop. Each selection 

represents a single test conducted in accordance with the DOE test procedure (or applicable 

DOE TP waiver) at a manufacturer’s testing facility or a third-party testing facility, whose test 

result should be directly compared to the result from the AEDM. All documentation of test 

results for these models, the AEDM results, and subsequent comparisons to the AEDM should 

be maintained as part of both the test data underlying the certified rating and the AEDM 

validation package pursuant to 10 CFR Part 429.71.

1. Commercial HVAC Validation Classes (Unanimous)

Validation Class Minimum Number of Distinct Models that Must 

be Tested per AEDM

Air-Cooled, Split and Packaged ACs and HPs less 

than 65,000 Btu/h Cooling Capacity (3-Phase)

2 Models

Air-Cooled, Split and Packaged ACs and HPs 

greater than or equal to 65,000 Btu/h Cooling 

Capacity and Less than 760,000 Btu/h Cooling 

Capacity

2 Models

Water-Cooled, Split and Packaged ACs and HPs, All 

Cooling Capacities

2 Basic Models

Evaporatively-Cooled, Split and Packaged ACs and 

HPs, All Capacities

2 Basic Models

Water-Source HPs, All Capacities 2 Basic Models

Single Package Vertical ACs and HPs 2 Basic Models

Packaged Terminal ACs and HPs 2 Basic Models

Air-Cooled, Variable Refrigerant Flow ACs and HPs 2 Basic Models

Water-Cooled, Variable Refrigerant Flow ACs and 2 Basic Models
HPs

Computer Room Air Conditioners, Air Cooled 2 Basic Models

Computer Room Air Conditioners, Water-Cooled 2 Basic Models

2. Water Heaters Validation Classes (Unanimous)

Validation Class Minimum Number of Distinct Models that Must 

be Tested

Gas-fired Water Heaters and Hot Water Supply 

Boilers Less than 10 Gallons

2 Basic Models

Gas-fired Water Heaters and Hot Water Supply 

Boilers Greater than or Equal to 10 Gallons

2 Basic Models

Oil-fired Water Heaters and Hot Water Supply 

Boilers Less than 10 Gallons

2 Basic Models

Oil-fired Water Heaters and Hot Water Supply 

Boilers Greater than or Equal to 10 Gallons

2 Basic Models

Electric Water Heaters 2 Basic Models

Heat Pump Water Heaters 2 Basic Models

Unfired Hot Water Storage Tanks (A lot of 

Abstentions)

2 Basic Models

3. Commercial Packaged Boilers Validation Classes (1 person abstain, unanimous)

Validation Class Minimum Number of Distinct Models that Must 

be Tested

Gas-fired, Hot Water Only Commercial Packaged 

Boilers

2 Basic Models

Gas-fired, Steam Only Commercial Packaged 

Boilers

2 Basic Models

Gas-fired Hot Water/Steam Commercial Packaged 

Boilers

2 Basic Models

Oil-fired, Hot Water Only Commercial Packaged 

Boilers

2 Basic Models

Oil-fired, Steam Only Commercial Packaged Boilers 2 Basic Models

Oil-fired Hot Water/Steam Commercial Packaged 

Boilers

2 Basic Models

4. Commercial Furnaces Validation Classes (Unanimous)

Validation Class Minimum Number of Distinct Models that Must 

be Tested

Gas-fired Furnaces 2 Basic Models

Oil-fired Furnaces 2 Basic Models

5. Commercial Refrigeration Equipment Validation Classes (3 Abstentions, Unanimous)

Validation Class Minimum Number of Distinct Models that Must 

be Tested
Self-Contained Open Refrigerators 2 Basic Models

Self-Contained Open Freezers 2 Basic Models

Remote Condensing Open Refrigerators 2 Basic Models

Remote Condensing Open Freezers 2 Basic Models

Self-Contained Closed Refrigerators 2 Basic Models

Self-Contained Closed Freezers 2 Basic Models

Remote Condensing Closed Refrigerators 2 Basic Models

Remote Condensing Closed Freezers 2 Basic Models

* The minimum number of tests indicated above must be comprised of a transparent model, a solid model, a 

vertical model, a semi-vertical model, a horizontal model, and a service-over-the counter model, as applicable 

based on the equipment offering. However, manufacturers do not need to include all types of these models if it 

will increase the minimum number of tests that need to be conducted. 

AEDM Tolerances (Unanimous)

In order to validate the AEDM, the test results from each model required per the validation 

requirements above must be compared to the simulated results from the applicable AEDM. 

The Commercial Certification WG recommends the following tolerance requirements to 

validate the AEDM: 

• For energy consumption metrics, the AEDM Result for Model A must be greater than or 

equal to the test result for Model A * 0.95; and

• For energy-efficiency metrics, the AEDM Result for Model A must be less than or equal 

to the test result for Model A*1.05. 

Application of Validated AEDM and Certified Ratings (Unanimous)

Once an AEDM has been validated by meeting the validation requirements in terms of 

minimum number of models to be tested and the applicable tolerances associated with 

validating the simulated results, the AEDM may be applied to any model within a given 

validated substantiation class at the manufacturers’ discretion.

For each model distributed in commerce, manufacturers must determine the certified rating 

based on testing or use of an AEDM. Manufacturers may always conservatively rate. This 

means that at the manufacturer’s discretion, the manufacturer may elect to certify a rating that 

meets the following requirement:

• For energy consumption metrics: the AEDM Result for Model A < the certified rating for 

Model A < the Federal standard for Model A.

• For energy efficiency metric: the Federal standard for Model A ≤ the certified rating for 

Model A ≤ the AEDM Result for Model A.

DOE Verification
The Commercial Certification WG recommends the following process and tolerance for DOE 

verification of certified ratings.

DOE may select any model distributed in commerce and verify the equipment performance at 

any time. DOE verification will be conducted per the process set forth below. 

Certification – Elections for Verification: (Unanimous)

• A manufacturer must elect a pathway for witness testing upon certifying a model. The 

two options are:

o A manufacturer may elect to have a DOE representative and a manufacturer’s 

representative on site for the initial test for up to 10% of basic models it certifies. 

If this option is elected, a manufacturer gives up its right to an automatic retest 

for the models it has elected to witness initially. The results from the initial test 

would be used to make a definitive determination regarding the invalid rating.

o DOE will perform testing without manufacturer or DOE presence for all models 

that a manufacturer does not elect to witness based on the allowance above. 

Models that are initially tested without manufacturer witness are eligible for an 

automatic re-test at the manufacturer’s discretion based on the process outlined 

below.

Verification – Single Unit Spot-Check Process: (Unanimous)

• DOE selects a single unit for test either from retail or by obtaining a sample from a 

manufacturer.

• DOE conducts the test on a single unit of a given model at the lab of DOE’s choice and in 

accordance with the lab applicability requirements below without DOE or manufacturer 

on site unless:

o The model is specifically required to be started only by a factory-trained installer 

per the installation manual instructions. In which case, DOE and the 

manufacturer may be on site for set-up and DOE will coordinate. 

o The manufacturer has elected, as part of their certification of that model, to 

witness testing. In which case, DOE and the manufacturer may be on site for setup ant testing and DOE will coordinate.

o The model is a variable refrigerant flow system. In which case, DOE and the 

manufacturer may be on site for set-up and DOE will coordinate.

• DOE will supply the following additional information to the lab for testing:

o Any additional information that is needed regarding test set up or testing will be 

provided from the manufacturer (or its third party representative) to DOE 

through the certification process. DOE will then provide this information to the 

laboratory as long as it is in accordance with the applicable DOE test procedure

(or DOE TP waiver). The laboratory may not use any additional information 

during the testing process that has not been provided by DOE or shipped 

(packaged) with the unit upon arrival. 
• The laboratory may request from the Department additional information on set-up, 

installation, or testing, as needed. Upon receiving a request from the laboratory for 

additional information, DOE and the manufacturer will have a discussion with the lab to 

discuss additional details of the testing and additional testing instructions could be given 

as agreed on by the Department and manufacturer. The laboratory may not speak with 

the manufacturer without the Department present.

• If a unit is outside the tolerance (i.e., test result of a single unit of a given model 

compared to rated value for the given model evaluated per the tolerance below), DOE 

will initiate a discussion with the manufacturer showing all test set-up, test conditions, 

and test results for the unit.

• At that time, a manufacturer may present all claims regarding testing issues associated 

with the single unit and initiate a discussion regarding retesting. If the manufacturer 

was not previously on site for the initial test, a manufacturer can request a retest of the 

same unit (automatically) and DOE and the manufacturer can be on site for the retest. 

The retest can be conducted on a different unit of the same model if DOE and the 

manufacturer agree it is necessary.

Verification Laboratory Requirements (Unanimous)

All verification tests should be conducted at a third-party testing facility of DOE’s choice, except 

the commercial equipment which cannot be tested at a third-party facility and may be tested at 

a manufacturer’s facility upon DOE’s request. 

Verification Tolerances (Unanimous)

In order to verify the certified rating of a given model, the test results from a single unit test of 

a given model will be compared to the certified rating in accordance with the tolerances set 

forth below. The Commercial Certification WG recommends the following tolerance 

requirements to verify a certified rating of a given model:

• For energy consumption metrics, the test result for Model A must be less than or equal 

to the Certified Rating for Model A * (1 + the Applicable Tolerance); and

• For energy-efficiency metrics, the test result for Model A must be greater than or equal 

to the test result for Model A* (1 - the Applicable Tolerance). 

If the certified rating does not meet the above requirements, it is an invalid rating.

Equipment Applicable Tolerance and Associated Metric

Commercial Packaged Boilers 5% on Combustion or Thermal Efficiency

Commercial Water Heaters or Hot Water Supply 

Boilers

5% on Thermal Efficiency and 10% on Standby 

Loss

Unfired Storage Tanks 10% on R-Value

Air-Cooled, Split and Packaged ACs and HPs less 

than 65,000 Btu/h Cooling Capacity (3-Phase)

5% on SEER and HSPF and 10% on EER

Air-Cooled, Split and Packaged ACs and HPs 

greater than or equal to 65,000 Btu/h Cooling 

Capacity and Less than 760,000 Btu/h Cooling 

5% on EER and COP and 10% on IEER
Capacity

Water-Cooled, Split and Packaged ACs and HPs, All 

Cooling Capacities

5% on EER and COP and 10% on IEER

Evaporatively-Cooled, Split and Packaged ACs and 

HPs, All Capacities

5% on EER and COP and 10% on IEER

Water-Source HPs, All Capacities 5% on EER and COP and 10% on IEER

Single Package Vertical ACs and HPs 5% on EER and COP

Packaged Terminal ACs and HPs 5% on EER and COP

Variable Refrigerant Flow ACs and HPs 5% on EER and COP and 10% on IEER

Computer Room Air Conditioners 5% on SCOP

Commercial Warm-Air Furnaces 5% on Thermal Efficiency

Commercial Refrigeration Equipment 5% on Daily Energy Consumption

Invalid Rating Process: (Unanimous)

Once DOE has determined the model is outside of the tolerance based on going through the 

verification process above, the manufacturer has the option of:

• Rerating and recertifying based on the single DOE-test data only (conservative rating still 

allowed); or

• Discontinuing the model through the certification process; or

• Additional manufacturer testing – Certified rating will be based on all testing (including 

DOE test data and any additional manufacturer testing is conducted on additional units 

of the same model). All test documentation and subsequent calculations underlying the 

certified rating must be maintained.

Manufacturer will report pathway to DOE within 15 working days and determine through 

discussions with DOE a date at which the process will be completed. The process should not 

exceed 180 days.

Invalid Rating Consequences: (Unanimous)

A manufacturer will be subject to the following requirements based upon the number of invalid ratings 

that DOE has determined through testing:

Number of Individual 

Models DOE has Tested 

Within 24 rolling 

months, beginning with 

failure determination 

and ending with unit 

selection, that were 

Rated by the same 

AEDM** where DOE has 

Found the Certified 

Ratings Invalid

Consequences 
*A manufacturer may discuss with DOE’s Office of Enforcement whether existing test data on different basic 

models within the validation classes to which that specific AEDM was applied may be used to meet this 

requirement. 

**Where the same AEDM means a computer simulation or mathematical model that is identified by the 

manufacturer at the time of certification as having been used to rate a model or group of models.

Regaining AEDM Use: (Unanimous)

If, as a result of eight or more invalid ratings, a manufacturer has lost the privilege of using an AEDM for 

rating, the manufacturer may regain the ability to use an AEDM by:

• Investigating cause(s) for failures;

• Identifying root cause of failures;

• Taking corrective action to address root cause;

• Performing six new tests per validation class, a minimum of two of which must be performed by 

an independent, third part to laboratory to validate the AEDM;

• Obtain DOE authorization to resume use of the AEDM. 

DOE may, at its discretion, reduce or waive these requirements and will provide justification in writing.

2 Different testing to validate that AEDM within the validation classes to which it is 

applied.*

4 Additional validation testing (Double Minimum) within the validation classes to 

which the AEDM is applied.

6 Additional validation testing of minimum at third party lab and 1⁄2 of minimum at 

manufacturer’s facility (or third party lab at his/her discretion) within the validation 

classes to which the AEDM is applied. (1.5 total)

>=8 All rating for models within the validation classes to which the AEDM is applied 

should be rated through testing route (2 units per basic model)