1 |Building Technologies Programeere.energy.govBUILDING TECHNOLOGIES PROGRAMDirect Heating EquipmentEnergy Conservation StandardsNotice of Proposed RulemakingJohn CymbalskyU.S. Department of EnergyEnergy Efficiency & Renewable EnergyDHE-2011-STD-0047@ee.doe.govSeptember 1, 20112 |Building Technologies Programeere.energy.govWelcome 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 recognized; stateyour name for the record)– Set cell phones to silent/vibrate• Housekeeping Items3 |Building Technologies Programeere.energy.govPublic Meeting AgendaAnalysis of National Energy Savings4Regulatory History2Proposed Amended Definition of VentedHearth Heater31IntroductionSmall Business Impacts5Closing Remarks64 |Building Technologies Programeere.energy.govIntroductionAnalysis of National Energy Savings4Regulatory History2Proposed Amended Definition of VentedHearth Heater31IntroductionSmall Business Impacts5Closing Remarks65 |Building Technologies Programeere.energy.gov• Purpose of this Public Meeting:– Present the analysis and justification for amending the definitionof “vented hearth heater”;– Inform interested parties and facilitate the rulemaking process;– Provide a forum for public comment on rulemaking issues; and– Encourage interested parties tosubmit data, information, andwritten comments.Introduction6 |Building Technologies Programeere.energy.govIntroductionIssue Box:DOE welcomes comment on its Notice ofProposed Rulemaking for Direct Heating Equipment.Throughout this presentation, specific issues will be raised forcomment on slides with issue boxes such as this,withidentifying numbers corresponding to those in the Noticeof Proposed Rulemaking. Nonetheless, commentsconcerning any part of that document or this presentation arewelcome.• Issue Boxes:7 |Building Technologies Programeere.energy.gov• At this time DOE welcomes opening statements fromInterested Parties.Introduction8 |Building Technologies Programeere.energy.govRegulatory HistoryAnalysis of National Energy Savings4Regulatory History2Proposed Amended Definition of VentedHearth Heater31IntroductionSmall Business Impacts5Closing Remarks69 |Building Technologies Programeere.energy.govRegulatory History• Energy Policy and Conservation Act(EPCA) of 1975 (Public Law 94-163)– Prior to being amended in 1987, EPCAincluded “home heating equipment” as coveredproducts.– The National Appliance Energy ConservationAct of 1987 (NAECA; Pub. L. 100-12)amended EPCA to replace the term “homeheating equipment” with “direct heatingequipment,” establish standards for the directheating equipment, and require that DOEdetermine whether these standards should beamended. (42 U.S.C. 6295(e)(3)-(4)).10 |Building Technologies Programeere.energy.gov• DOE amended the statutorily-prescribed standards for directheating equipment (DHE) for the first time in a final rulepublished 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 equipment(i.e., vented hearth heaters)– Amended the minimum standards for direct heating equipment,including gas hearth direct heating equipment.• EPCA does not define “direct heating equipment.” DOEestablished definitions for: (1) “direct heating equipment”; (2)“vented home heating equipment” or “vented heater”; and (3)“vented hearth heater.”Regulatory History11 |Building Technologies Programeere.energy.govRegulatory HistoryIssue #1:Given the lack of a statutory definition for “directheating equipment,” DOE requests comment on whetherDOE’s interpretation that decorative vented hearth productsand vented gas log sets are typesof direct heating equipmentis reasonable.• DOE interprets the term “vented hearth heater” asincluding vented heating hearth products, decorativehearth products, and gas log sets.– DOE believes that because these products provide heat to theliving space, they meet thedefinition of “direct heatingequipment.”12 |Building Technologies Programeere.energy.govProposed Amended Definition ofVented Hearth HeaterAnalysis of National Energy Savings4Regulatory History2Proposed Amended Definition of VentedHearth Heater31IntroductionSmall Business Impacts5Closing Remarks613 |Building Technologies Programeere.energy.gov• Upon further consideration of the April 2010 final rule,DOE developed its current proposal, which it believeswould result in significant additional energy savings,preserve consumer choice, and reduce the burden onthe industry.• DOE is proposing to amend the criteria for a vented gashearth product or vented gas log set to be considereddecorative in nature, and thereby eligible for exclusionfrom DOE energy conservation standards for ventedhearth heaters.Proposed Amended Definition ofVented Hearth Heater14 |Building Technologies Programeere.energy.gov• The proposed exclusion criteria are:– Certified to ANSI Z21.50 and not ANSI Z21.88 (for vented gashearth products only [e.g., gas fireplaces, gas fireplace inserts,gas stoves]);– Certified to ANSI Z21.60 (for vented gas log sets only);– Sold without a thermostat and with a warranty provisionexpressly voiding all manufacturer warranties in the event theproduct is used with a thermostat;– Expressly and conspicuously identified on its rating plate and inall manufacturer's advertising and product literature as a"Decorative Product: Not For Use As A Heating Appliance” and– With respect to products manufactured after July 1, 2014, notequipped with a standing pilot light or other continuously-burningignition source.Proposed Amended Definition ofVented Hearth Heater15 |Building Technologies Programeere.energy.gov• The proposed definition of “Vented Hearth Heater” reads as follows:Vented Hearth Heatermeans a vented appliance which simulates a solid fuel fireplace and isdesigned to furnish warm air, with or withoutduct connections, to the space in which it isinstalled. The circulation of heated room air may be by gravity or mechanical means. A ventedhearth heater may be freestanding, recessed, zero clearance, or a gas fireplace insert orstove. The following products are not subject to the energy conservation standards for ventedhearth 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 witha warranty provision expressly voiding allmanufacturer warranties in the event the product is used with a thermostat;c. Expressly and conspicuously identified onits rating plate and in all manufacturer'sadvertising and product literature as a "Decorative Product: Not For Use As A HeatingAppliance"; andd. With respect to products manufactured afterJuly 1, 2014, not equipped with a standingpilot light or other continuously-burning ignition source; and2. Vented gas hearth products that meet all of the following four criteria:a. Certified to ANSI Standard Z21.50and not to ANSI Standard Z21.88;b. Sold without a thermostat and with awarranty provision expressly voiding allmanufacturer warranties in the event the product is used with a thermostat;c. Expressly and conspicuously identified onits rating plate and in all manufacturer'sadvertising and product literature as a "Decorative Product: Not For Use As A HeatingAppliance"; andd. With respect to products manufactured afterJuly 1, 2014, not equipped with a standingpilot light or other continuously-burning ignition source.Proposed Amended Definition ofVented Hearth Heater16 |Building Technologies Programeere.energy.govProposed Amended Definition ofVented Hearth HeaterIssue #2:The proposed compliance date (i.e., July 1, 2014)for vented gas hearth productsand vented gas log sets toremove standing pilot lights or other continuously-burningignition in order to qualify for the exclusion. DOE seeksinformation regarding what manufacturers will need to do tomeet that date, or whether a different date would bepreferable. If suggesting a different date, DOE is interested inspecific rationales and accompanying data as to why adifferent timeline for eliminating standing pilots or othercontinuously-burning ignition sources from decorative gashearth products and/or vented gaslog sets may be warranted.Issue #3:The proposed requirements for exclusion from theenergy conservation standard as a decorative vented hearthproduct or vented gas log set.17 |Building Technologies Programeere.energy.govNational Energy Savings AnalysisAnalysis of National Energy Savings4Regulatory History2Proposed Amended Definition of VentedHearth Heater31IntroductionSmall Business Impacts5Closing Remarks618 |Building Technologies Programeere.energy.gov• Energy Use Estimates– Average continuous standing pilot energy use:• 350 Btu/h for decorative vented hearth products (April 2010 HeatingProducts Final Rule)• 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 ventedhearth 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 hearthproducts from James Houckreport to the Hearth, Patio, &Barbecue Association (HPBA) and HPBA historical shipments data)• 103,000 vented gas logs units (HPBA historical shipments data)– Fraction of shipments with standing pilot lights:• 38 percent of vented decorativehearth models (models information)• 20 percent of vented gas logs (1997 GTI study)• Lifetime- 15 year on average (April2010 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 Products Final RuleNational Energy Savings Analysis19 |Building Technologies Programeere.energy.govSmall Business ImpactsAnalysis of National Energy Savings4Regulatory History2Proposed Amended Definition of VentedHearth Heater31IntroductionSmall Business Impacts5Closing Remarks620 |Building Technologies Programeere.energy.gov• Residential direct heating equipment (including hearthproduct) manufacturing is classified under NAICS 333414,“Heating Equipment (except Warm Air Furnaces)Manufacturing.”– The size threshold for a small business is 500 employees or fewer.– DOE identified 10 vented gas hearth DHE small businessmanufacturers in the April 2010 final rule. DOE identified 7manufacturers of vented gas log sets, 3 of which also manufacturevented gas hearth products.• DOE estimated manufacturer compliance costs of theamended definition based on analysis done in the April 2010final rule.– DOE assumed the primary cost of compliance will be to recertifyproducts to the applicable ANSI standards if they are modified tomeet the exclusion. DOE estimated the compliance costs will beapproximately $693,000.Small Business Impacts21 |Building Technologies Programeere.energy.govSmall Business ImpactsIssue #4:The impacts of the proposed amended definition of“vented hearth heater” on small business manufacturers ofdecorative vented hearth productsor vented gas log sets.22 |Building Technologies Programeere.energy.govClosing RemarksAnalysis of National Energy Savings4Regulatory History2Proposed Amended Definition of VentedHearth Heater31IntroductionSmall Business Impacts5Closing Remarks623 |Building Technologies Programeere.energy.govClosing Remarks• In all correspondence, please refer to the Direct HeatingEquipment 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 20585-0121Ms. Brenda EdwardsU.S. Department of EnergyBuilding Technologies Program, 6th Floor950 L’Enfant Plaza, SWWashington, DC 20024Tel: 202-586-2945• Instructions for Submitting Written Comments:24 |Building Technologies Programeere.energy.gov• Relevant URLs:– DOE Appliance Standards:http://www1.eere.energy.gov/buildings/appliance_standards– Residential Direct Heating Equipment webpage:http://www1.eere.energy.gov/buildings/appliance_standards/residential/direct_heating.html– Direct Heating Equipment NOPR Public Meeting webpage:http://www1.eere.energy.gov/buildings/appliance_standards/residential/residential_direct_heating_equipment_public_meeting_09_01_11.htmlClosing Remarks