Docket Number: EER

ConsumerCommWaterHtrs2015TP

Conversion Factor for Consumer and Commercial Water 
2

Welcome• Introductions (around the room)

• Role of the Facilitator• Ground Rules

– Speak one at a time.

– Say your name for the record – there will be a complete tra

this meeting.

– Be concise – share the ‘air‐time’.

– Keep the focus here – cell phones on silent; limit sidebar

conversations.

– Webinar participants turn phone on mute; “raise your hand

recognized to speak.

• Housekeeping Items• Agenda Review• Opening Remarks
3

Listening Via the Webcast• The Department is broadcasting this meeting live ov

Internet.

• DOE is providing the webcast to accommodate stake

that are unable to attend the public meeting in perso

• The web broadcast allows stakeholders to listen in an

the slides.

• All stakeholders are encouraged to submit written co

after the public meeting.
4

Purpose of the Public Meeting• Present DOE’s proposed conversions for Consumer a

Certain Commercial Water Heaters.

• Invite comment on the notice of proposed rulemakin

(NOPR) document.

• Discuss next steps in the rulemaking.

• Invite participants to provide summary comments or

statements and raise additional issues for discussion.
5

Issues for DiscussionIssue box numbering corresponds to the list of issues p

at the end of the NOPR document, available at:http://www.regulations.gov/#!documentDetail;D=EERE

BT‐TP‐0007‐0002The deadline for submitting comments is June 15, 2015

Issue Box: DOE welcomes comments, data, and information concerning its proposed conversions Consumer and Certain Commercial Water HeatersIssues that correspond to those raised in DOE’s published material will be numbered in accordancwith that material. Whether invited by an issue box not, comments are welcome on any part of DOE’s analysis.
6

Opening Remarks

Meeting participants are invited to provide opening rem

statements at this time.
7

Public Meeting Topics

1 Regulatory History2 Rulemaking Overview3 Description of Issues Addressed in the NOPR4 Closing Remarks
8

Regulatory History

• The Energy Policy and Conservation Act (EPCA) or 1975 (Pu

163), as amended

• Established the Energy Conservation Program for Consumer Produc

Automobiles, which includes residential water heaters

• Established the Energy Conservation Program for Certain Industrial 

which includes commercial water heaters

• Directs DOE to establish test procedures in conjunction with energy 

standards

• The American Energy Manufacturing and Technical Correcti

(AEMTCA) (Public Law 112‐210)

• Required that DOE publish a final rule establishing a uniform efficie

and accompanying test methods for covered water heaters and com

heating equipment

• Required that DOE publish a final rule establishing a mathematical c

factor for converting the measurement of efficiency for covered wa

from the existing metric to the uniform energy descriptor
9

Regulatory History• May 11, 1998 – Residential Test Procedure Final Rule

25996)

• January 12, 2001 – Commercial Energy Conservation

Standard Final Rule. (66 FR 3336)

• April 16, 2010 – Residential Energy Conservation Sta

Final Rule. (75 FR 20112)

• May 18, 2012 – Commercial Test Procedure Final Rul

28928)

• July 11, 2014 – Uniform Efficiency Descriptor Final Ru

FR 40541)
10

Public Meeting Topics

1 Regulatory History2 Rulemaking Overview3 Description of Issues Addressed in the NOPR4 Closing Remarks
11

Steps in the Rulemaking Process• DOE published a NOPR proposing the mathematical

conversion on April 14, 2015. (80 FR 20116)

• DOE is holding the NOPR public meeting today, May 

2015.

• DOE will accept comments on the NOPR from intere

parties.

• Oral comments from today’s meeting with be recorded 

transcribed.

• Interested parties can submit written comments until Ju

2015.

NOPR Final Rule
12

Public Meeting Topics

1 Regulatory History2 Rulemaking Overview3 Description of Issues Addressed in the NOPR4 Closing Remarks
13

Description of Issues Addressed in the NOPR

1 Purpose and Scope3 Mathematical Ratings Conversion2 Considerations for Testing Selection4 Energy Conservation Standards
14

Purpose and Scope of the Mathematical Convers

• Provide a method for converting existing ratings, wh

applicable.

• Convert the April 2015 standards equations to the ne

metric.

• DOE only developed conversion equations for catego

products subject to standards and where commercia

available units exist.
15

Summary of Key Dates and Requirements

Description of Date Date RequirementsTest ProcedureEffective Date

July 13, 2015 For new basic models introduced into 

or after July 13, 2015, manufacturers 

test and represent efficiency using the 

pursuant to the UEF test procedure a

plan (or an AEDM that is based on the 

procedure, where allowed).

Conversion FactorEffective Date

Date of publicationof the conversion

factor final rule in

the Federal Register

For basic models certified using the Ethermal efficiency and/or standby los

to July 13, 2015, manufacturers must 

their representations to UEF either by 

conversion equations or by using the 

procedure and sampling plan (or an A

based on the UEF test procedure, wh

Conversion FactorEnding Date

One year afterpublication ofconversion factor

final rule

All basic models must be rated in term

the UEF test procedure and sampling 

AEDM that is based on the UEF test p

where allowed.
16

Description of Issues Addressed in the NOPR

1 Purpose and Scope3 Mathematical Ratings Conversion2 Considerations for Testing Selection4 Energy Conservation Standards
17

Considerations for Testing Selection• DOE considered the following when selecting units t

• NOx Emissions (Standard, Low, or Ultra‐Low)

• Vent Type (Atmospheric or Power)

• Short or Tall• Standing Pilot or No Standing Pilot

• Condensing or Non‐Condensing

• DOE also attempted to test models that span the ran

available product offerings

• Rated Storage Volume and Input Rate• FHR or Max GPM• Recovery Efficiency and EF

• Thermal Efficiency and Standby Loss
18

Example: Consumer Gas Storage

• DOE examined basic models on the market and selected mode

testing in proportion to the market.
19

Water Heaters Tested for NOPR

Water Heater Category Product Type Number of U

Consumer Storage

Gas‐fired 22

Oil‐fired 2

Electric Resistance 11

Heat Pump 6

Tabletop 2

Consumer Instantaneous

Gas‐fired 17

Oil‐fired 0

Electric 5

Residential Duty Storage Gas‐fired 7

• DOE tested 72 water heaters for this NOPR
20

Description of Issues Addressed in the NOPR

1 Purpose and Scope3 Mathematical Ratings Conversion2 Considerations for Testing Selection4 Energy Conservation Standards
21

Conversion Methods• Conversions were developed for the ratings (i.e., first‐hour rati

Max GPM, and Uniform Energy Factor (UEF))

• 3 methods were examined for each water heater category

• Step Regression – Solely based on test data

• Every combination of independent variables (Rated Stora

Input Rate, FHR, Max GPM, EF, thermal efficiency, standby 

examined and compared to produce the best conversion

• Analytical – Solely based on modeling

• Equations which theoretically represent how the water he

• Regressed Analytical – based on combination of modeli

• Analytical equations applied and used as the independen

single term regression

• Root‐Mean‐Square (RMS) of the Error used to compare the res

different methods in order to choose the appropriate conversio
22

Analytical Methods Approach Overview• Delivery Capacity

• Max GPM method is based on a balance of energy inpu

delivered energy at 125°F and 135°F

• UEF

• Consumer Storage method is based on the Water Heate

Model (WHAM)

• Consumer Instantaneous method developed by DOE to 

for cycling losses and validated with test data

• Residential‐Duty Storage method is based on the WHAM 

where thermal efficiency and standby loss roughly repla

recovery efficiency and the standby loss coefficient (UA
23

Selected Conversion Methods• For most UEF conversions, analytical‐regression met

• Analytical model can capture the underlying physics

• Regression can correct for effects not fully captured by 

analytical model but revealed in physical testing.

• For the Heat Pump UEF conversion, regression meth

based on testing) was used because the ηr value is n

available in published databases.

• For FHR conversions, regression method used (solely 

testing)

• FHR used for Consumer and Q used for Residential‐Duty

• In certain cases, other parameters resulted in slightly be

values however these were never more than 1 gallon

• For Max GPM conversion, analytical method used (so

based on modeling)
24

Rated Value Conversions – Consumer Storage

Consumer Gas‐fired

Water Heater

Non‐Condensing,Standard NOx

ܨ ∗ 1.0085 ൌ ܴܪܨ	ݓܰ݁

ܷܨܧ ൌ 0.4736 ൅ 0.2726 ∗ ܷ

Non‐Condensing,Low NOx

0.911

൅ 4.6894 ൌ ܴܪܨ	ݓܰ݁

ܷܨܧ ൌ െ0.0126 ൅ 0.9966 ∗ 

Non‐Condensing,Ultra‐Low NOx

0.888

൅ 2.9267 ൌ ܴܪܨ	ݓܰ݁

ܷܨܧ ൌ 0.2673 ൅ 0.5811 ∗ ܷ

Condensing ܰ݁ݓ	ܪܨܴ ൌ െ0.7072 ൅ 0.97

ܷܨܧ ൌ 0.0409 ൅ 0.9164 ∗ ܷ

Consumer Oil‐fired

Water Heater

N/A ܰ݁ݓ	ܪܨܴ ൌ 1.1018 ∗ 

ܨ

ܷܨܧ ൌ െ0.0945 ൅ 1.1185 ∗ 

Consumer Electric

Water Heater

ElectricResistance

0.787

൅ 11.9239 ൌ ܴܪܨ	ݓܰ݁

ܷܨܧ ൌ 0.1227 ൅ 0.8673 ∗ ܷ

Heat Pump ܰ݁ݓ	ܪܨܴ ൌ െ2.3440 ൅ 0.98

1.548

൅ 1.1235െ ൌ ܨܧܷ

Tabletop Water

Heater

N/A ܰ݁ݓ	ܪܨܴ ൌ 11.9239 ൅ 0.787

ܷܨܧ ൌ 0.1227 ൅ 0.8673 ∗ ܷ
25

Conversion Results – Consumer Storage FHR

405060708090

100110120130

40 50 60 70 80 90 100 110 120 130

Regression New FHR, gallons

Measured New FHR, gallons

SlopS NOL NOUL NElecHeaTabOilShoNo PowCon
26

2

2.22.42.62.8

2 2.2 2.4 2.6 2.8

Conversion Results – Consumer Storage UEF

0.40.50.60.70.80.9

1

0.4 0.5 0.6 0.7 0.8 0.9 1

Analytical‐Regression UEF

Measured UEF

SlopS NOL NOUL NElecHeaTabOilShoNo PowCon

Heat Pump
27

Rated Value Conversions – Consumer Instanta

Instantaneous Gas‐fired Water

Heater

ݔܽܯ ∗ 1.1467 ൌ ܯܲܩ	ݔܽܯ	ݓܰ݁

ܨܧܷ ∗ 0.9052 ൅ 0.0783 ൌ ܨܧܷ

Instantaneous Electric Water

Heater

ݔܽܯ ∗ 1.1467 ൌ ܯܲܩ	ݔܽܯ	ݓܰ݁

௘ௗ௠௢ܨܧܷ ∗ 1.0079 ൌ ܨܧܷ
28

Conversion Results – Consumer Instantaneous 

0123456

0123456

Analytical New Max GPM

Measured New Max GPM
29

Conversion Results – Consumer Instantaneous 

0.75

0.8

0.85

0.9

0.95

1

1.05

0.75 0.8 0.85 0.9 0.95 1 1.05

Analytical‐Regression UEF

Measured UEF
30

Rated Value Conversions – Residential‐Duty St

Residential‐Duty Commercial

Gas‐fired Water Heater

1.022

൅ 39.8144 ൌ ܴܪܨ	ݓܰ݁

ܷܨܧ ൌ 0.1413 ൅ 0.7300 ∗ ܷܨܧ

Residential‐Duty Commercial

Oil‐fired Water Heater

1.022

൅ 39.8144 ൌ ܴܪܨ	ݓܰ݁

ܷܨܧ ൌ 0.1413 ൅ 0.7300 ∗ ܷܨܧ
31

Conversion Results – Residential‐Duty Storage 

60708090

100110120130140

60 70 80 90 100 110 120 130 140

Regression FHR, gallons

Measured New FHR, gallons

SlopS NOL NOUL NShorNo SPowCond
32

Conversion Results – Residential‐Duty Storage 

0.45

0.5

0.55

0.6

0.65

0.7

0.75

0.8

0.85

0.9

0.95

0.45 0.5 0.55 0.6 0.65 0.7 0.75 0.8 0.85 0.9 0.95

Analytical‐Regression UEF

Measured UEF

SlopS NOL NOUL NShorNo SPowCond
33

Description of Issues Addressed in the NOPR

1 Purpose and Scope3 Mathematical Ratings Conversion2 Considerations for Testing Selection4 Energy Conservation Standards
34

Energy Conservation Standards (ECS) ‐ Approa

1. Apply Conversion to get a UEF value for every unit on the mark

2. Find the current minimum EF or minimum Thermal Efficiency f

unit on the market

3. Find the Percent Difference from the current Energy Conservat

Standard

4. Calculate the associated UEFmin

5. Find the line through the UEFmin values

ൌ ܦܲ

௡௜௠,௙ܧ െ௙ ܧ

ൌ ܦܲ ௙ܧ

௡௜௠ܧܶ െ ܧܶ

ܧܶ

or
35

Energy Conservation Standard ‐ Example

Consumer Storage Gas

Medium Draw Pattern

0.5

0.55

0.6

0.65

0.7

20 25 30 35 40 45 50 55

UEF

Rated Storage Volume, gallons

UEFMin UStand
36

Energy Conservation Standards

Product Class Rated Storage Volume Draw Pattern Uniform Energ

Consumer Gas‐fired

Storage

≥ 20 gal and ≤ 55 gal Very Small 0.3263 െ ሺ

Low 0.5891 െ ሺMedium 0.6326 െ ሺHigh 0.7128 െ ሺ

> 55 gal and ≤ 100 gal Very Small 0.5352 െ ሺ

Low 0.7375 െ ሺMedium 0.7704 െ ሺHigh 0.7980 െ ሺ

Consumer Oil‐fired Storage ≤ 50 gal Very Small 0.2267 െ ሺ

Low 0.4867 െ ሺMedium 0.6016 െ ሺHigh 0.6529 െ ሺ

Consumer Electric Storage ≥ 20 gal and ≤ 55 gal Very Small 0.8268 െ ሺ

Low 0.9393 െ ሺMedium 0.9683 െ ሺHigh 0.9656 െ ሺ

> 55 gal and ≤ 120 gal Very Small 1.2701 െ ሺ

Low 1.9137 െ ሺMedium 2.0626 െ ሺHigh 2.1858 െ ሺ
37

Energy Conservation Standards ‐ Continued

Product Class Rated Storage Volume Draw Pattern Uniform Energ

Consumer TabletopStorage

≥ 20 gal and ≤ 100 gal Very Small 0.6808 െ ሺ

Low 0.8770 െ ሺMedium 0.9063 െ ሺHigh 0.9302 െ ሺ

Consumer Gas‐fired

Instantaneous

< 2 gal All 0.8036 െ ሺ

Consumer ElectricInstantaneous

< 2 gal All 0.9192 െ ሺ

Residential‐Duty Gas

Storage

All Very Small 0.3261 െ ሺ

Low 0.5219 െ ሺMedium 0.5585 െ ሺHigh 0.6044 െ ሺ

Residential‐Duty OilStorage

All Very Small 0.3206 െ ሺ

Low 0.5577 െ ሺMedium 0.6027 െ ሺHigh 0.6446 െ ሺ
38

Public Meeting Slides Topics

1 Regulatory History2 Rulemaking Overview3 Description of Issues Addressed in This NOPR4 Closing Remarks
39

Request for Additional Data• Driver for the conversion factor rulemaking is test da• DOE received AHRI test data on May 14, 2015

• DOE needs additional detail about the tested units in 

to properly incorporate into the analysis

• Any additional information must be submitted by Jun

2015 to be considered in the final rule.
40

Closing Remarks

Meeting participants are invited to provide closing

remarks at this time.
41

How to Submit Written Comments• In all correspondence, please refer to the conversion factor rul

by:

• Conversion Factor for Consumer and Commercial Water 

• Docket Number: EERE‐2015‐BT‐TP‐0007

• Regulatory Identification Number (RIN): 1904‐AC91

• Email: ConsumerCommWaterHtrs2015TP0007@ee.doe.gov

Comment period closes: June 15, 2015 – 11:59 PM EDT

http://www1.eere.energy.gov/buildings

Postal:Ms. Brenda EdwardsU.S. Department of EnergyBuilding Technologies Office, Mailstop EE‐5B

1000 Independence Avenue, SWWashington, DC 20585‐0121

Courier:

Ms. Brenda EdwardsU.S. Department of Ener

Building Technologies Of

950 L’Enfant Plaza, SW, 6

Washington, DC 20024Tel: (202) 586‐2945