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BUILDING TECHNOLOGIES PROGRAM

Direct Heating EquipmentEnergy Conservation StandardsNotice of Proposed Rulemaking

John CymbaU.S. Department Energy Efficiency DHE-2011-STD-0

September 1, 2011
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Welcome and Introduction

• Introductions• Role of the Facilitator• Ground Rules (norms)

– Listen as an ally– Use short, succinct statements/keep to the point– Hold sidebar conversations outside the room– Focus on issues, not personalities– One person speak at a time (raise hand to be recogniz

your name for the record)

– Set cell phones to silent/vibrate

• Housekeeping Items
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Public Meeting Agenda

4 Analysis of National Energy Savings2 Regulatory History

Proposed Amended Definition of Vented Hearth Heater 3

1 Introduction

5 Small Business Impacts

6 Closing Remarks
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Introduction

4 Analysis of National Energy Savings2 Regulatory History

Proposed Amended Definition of Vented Hearth Heater 3

1 Introduction

5 Small Business Impacts

6 Closing Remarks
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• Purpose of this Public Meeting:

– Present the analysis and justification for amending the 

of “vented hearth heater”;

– Inform interested parties and facilitate the rulemaking – Provide a forum for public comment on rulemaking iss– Encourage interested parties to submit data, informati

written comments.

Introduction
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Introduction

Issue Box: DOE welcomes comment on its Notice of Proposed Rulemaking for Direct Heating Equipment. Throughout this presentation, specific issues will be raiscomment on slides with issue boxes such as this, with identifying numbers corresponding to those in the Nof Proposed Rulemaking. Nonetheless, comments concerning any part of that document or this presentatiowelcome.

• Issue Boxes:
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• At this time DOE welcomes opening statements 

Interested Parties.

Introduction
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Regulatory History

4 Analysis of National Energy Savings2 Regulatory History

Proposed Amended Definition of Vented Hearth Heater 3

1 Introduction

5 Small Business Impacts

6 Closing Remarks
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Regulatory History

• Energy Policy and Conservation Act 

(EPCA) of 1975 (Public Law 94-163)

– Prior to being amended in 1987, EPCA 

included “home heating equipment” as covered products.

– The National Appliance Energy Conservation 

Act of 1987 (NAECA; Pub. L. 100-12) amended EPCA to replace the term “home heating equipment” with “direct heating equipment,” establish standards for the direct heating equipment, and require that DOE determine whether these standards should be amended. (42 U.S.C. 6295(e)(3)-(4)).
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• DOE amended the statutorily-prescribed standards f

heating equipment (DHE) for the first time in a final rpublished on April 16, 2010. 75 FR 20112. 

• The April 2010 final rule:

– Created a definition for “vented hearth heater”– Established product classes for gas hearth direct heating 

(i.e., vented hearth heaters)

– Amended the minimum standards for direct heating equi

including gas hearth direct heating equipment.

• EPCA does not define “direct heating equipment.” D

established definitions for: (1) “direct heating equipm“vented home heating equipment” or “vented heater”“vented hearth heater.”

Regulatory History
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Regulatory History

Issue #1: Given the lack of a statutory definition for “direheating equipment,” DOE requests comment on whetheDOE’s interpretation that decorative vented hearth prodand vented gas log sets are types of direct heating equiis reasonable.

• DOE interprets the term “vented hearth heater” a

including vented heating hearth products, decorhearth products, and gas log sets.

– DOE believes that because these products provide he

living space, they meet the definition of “direct heating equipment.”
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Proposed Amended Definition of Vented Hearth Heater

4 Analysis of National Energy Savings2 Regulatory History

Proposed Amended Definition of Vented Hearth Heater 3

1 Introduction

5 Small Business Impacts

6 Closing Remarks
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• Upon further consideration of the April 2010 fina

DOE developed its current proposal, which it bewould result in significant additional energy savipreserve consumer choice, and reduce the burdthe industry.

• DOE is proposing to amend the criteria for a ven

hearth product or vented gas log set to be considecorative in nature, and thereby eligible for excfrom DOE energy conservation standards for vehearth heaters. 

Proposed Amended Definition of Vented Hearth Heater
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• The proposed exclusion criteria are:

– Certified to ANSI Z21.50 and not ANSI Z21.88 (for ven

hearth products only [e.g., gas fireplaces, gas fireplace 

gas stoves]);

– Certified to ANSI Z21.60 (for vented gas log sets only)– Sold without a thermostat and with a warranty provisio

expressly voiding all manufacturer warranties in the evproduct is used with a thermostat;

– Expressly and conspicuously identified on its rating pla

all manufacturer's advertising and product literature as "Decorative Product: Not For Use As A Heating Applia

– With respect to products manufactured after July 1, 20

equipped with a standing pilot light or other continuousignition source.

Proposed Amended Definition of Vented Hearth Heater
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• The proposed definition of “Vented Hearth Heater” reads a

Vented Hearth Heater means a vented appliance which simulates a solid fuel firedesigned to furnish warm air, with or without duct connections, to the space in whinstalled. The circulation of heated room air may be by gravity or mechanical mehearth heater may be freestanding, recessed, zero clearance, or a gas fireplace istove. The following products are not subject to the energy conservation standarhearth heaters:

1. Vented gas log sets that meet all of the following four criteria:

a. Certified to ANSI Standard Z21.60;b. Sold without a thermostat and with a warranty provision expressly voidi

manufacturer warranties in the event the product is used with a thermo

c. Expressly and conspicuously identified on its rating plate and in all man

advertising and product literature as a "Decorative Product: Not For UsAppliance"; and

d. With respect to products manufactured after July 1, 2014, not equipped 

pilot light or other continuously-burning ignition source; and

2. Vented gas hearth products that meet all of the following four criteria:

a. Certified to ANSI Standard Z21.50 and not to ANSI Standard Z21.88; b. Sold without a thermostat and with a warranty provision expressly voidi

manufacturer warranties in the event the product is used with a thermo

c. Expressly and conspicuously identified on its rating plate and in all man

advertising and product literature as a "Decorative Product: Not For UsAppliance"; and

d. With respect to products manufactured after July 1, 2014, not equipped 

pilot light or other continuously-burning ignition source.

Proposed Amended Definition of Vented Hearth Heater
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Proposed Amended Definition of Vented Hearth Heater

Issue #2: The proposed compliance date (i.e., July 1, 2for vented gas hearth products and vented gas log sets remove standing pilot lights or other continuously-burninignition in order to qualify for the exclusion. DOE seeks information regarding what manufacturers will need to dmeet that date, or whether a different date would be preferable. If suggesting a different date, DOE is interesspecific rationales and accompanying data as to why a different timeline for eliminating standing pilots or other continuously-burning ignition sources from decorative ghearth products and/or vented gas log sets may be warIssue #3: The proposed requirements for exclusion from energy conservation standard as a decorative vented heproduct or vented gas log set.
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National Energy Savings Analysis

4 Analysis of National Energy Savings2 Regulatory History

Proposed Amended Definition of Vented Hearth Heater 3

1 Introduction

5 Small Business Impacts

6 Closing Remarks
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• Energy Use Estimates

– Average continuous standing pilot energy use:

• 350 Btu/h for decorative vented hearth products (April 2010 Heating Produc

• 1,250 Btu/h for vented gas logs (models information)

– Operating hours of continuous pilot lights:

• 75% operate year round (8,760 hours/year)• 25% operate one-fourth of the year (2,190 hours/year)

– Average unit energy consumption:

• 2.67 million Btu per unit for decorative vented hearth products

• 9.53 million Btu per unit for vented gas logs

• Shipments

– Annual average shipment estimates:

• 460,000 decorative vented hearth products (70% of vented hearth products 

report to the Hearth, Patio, & Barbecue Association (HPBA) and HPBA histo

• 103,000 vented gas logs units (HPBA historical shipments data)

– Fraction of shipments with standing pilot lights:

• 38 percent of vented decorative hearth models (models information)• 20 percent of vented gas logs (1997 GTI study)

• Lifetime - 15 year on average (April 2010 Heating Products Final Rule)• National Energy Savings (2013-2042)

– 0.17 quads for decorative hearth products– 0.07 quads for vented gas log sets– 0.12 quads net additional NES accounting for April 2010 Heating Produ

National Energy Savings Analysis
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Small Business Impacts

4 Analysis of National Energy Savings2 Regulatory History

Proposed Amended Definition of Vented Hearth Heater 3

1 Introduction

5 Small Business Impacts

6 Closing Remarks
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• Residential direct heating equipment (including hear

product) manufacturing is classified under NAICS 33“Heating Equipment (except Warm Air Furnaces) Manufacturing.”

– The size threshold for a small business is 500 employees – DOE identified 10 vented gas hearth DHE small business 

manufacturers in the April 2010 final rule. DOE identified manufacturers of vented gas log sets, 3 of which also mavented gas hearth products.

• DOE estimated manufacturer compliance costs of th

amended definition based on analysis done in the Apfinal rule.

– DOE assumed the primary cost of compliance will be to r

products to the applicable ANSI standards if they are momeet the exclusion. DOE estimated the compliance costs approximately $693,000.

Small Business Impacts
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Small Business Impacts

Issue #4: The impacts of the proposed amended definit“vented hearth heater” on small business manufacturers decorative vented hearth products or vented gas log set
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Closing Remarks

4 Analysis of National Energy Savings2 Regulatory History

Proposed Amended Definition of Vented Hearth Heater 3

1 Introduction

5 Small Business Impacts

6 Closing Remarks
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Closing Remarks

• In all correspondence, please refer to the Direct Heat

Equipment rulemaking by:

– Direct Heating Equipment Rulemaking,– Docket Number EERE–2011–BT–STD–0047, and– Regulatory Identification Number (RIN) 1904-AC56

• Email: DHE-2011-STD-0047@ee.doe.gov• Comment period closes September 20, 2011.

Postal: Courier:Ms. Brenda EdwardsU.S. Department of EnergyBuilding Technologies Program, Mailstop EE-2J1000 Independence Avenue, SWWashington, DC 20585-0121

Ms. Brenda EdwardsU.S. Department of EnBuilding Technologies P950 L’Enfant Plaza, SWWashington, DC 2002Tel: 202-586-2945

• Instructions for Submitting Written Comments:
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• Relevant URLs:

– DOE Appliance Standards:

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

– Residential Direct Heating Equipment webpage:

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

dential/direct_heating.html

– Direct Heating Equipment NOPR Public Meeting webp

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

dential/residential_direct_heating_equipment_public_m9_01_11.html

Closing Remarks