UNITED STATES OF AMERICA

DEPARTMENT OF ENERGY 

PUBLIC MEETING 

ON

ENERGY CONSERVATION PROGAM FOR CONSUMER PRODUCTS:

TEST PROCEDURES FOR RESIDENTIAL WATER HEATER,

DIRECT HEATING EQUIPMENT, AND POOL HEATERS

U.S. Department of Energy

1000 Independence Avenue, SW

Washington, DC 20585

Room 8E-089

Friday

September 24, 2010

Chair:
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Doug Brookman 

Public Solutions

Baltimore, MD

Participants Identified: 

Jennifer Cleary

Association of Home Appliance Manufacturers

Harvey Sachs

Council for Energy Efficiency and Economy

Frank Stanonik

Air Conditioning, Heating, and Refrigeration Institute

Meg Waltner

National Resources Defense Council

Tom Stroud

Hearth, Patio and Barbecue Association

Hoi Yee Lam

Energetics, Incorporated

Ray Long

DNR International

David Ryan

DNR International

Jacob Talbot

American Council for an Energy Efficient Economy

Molly Trombley McCann

Pacific Gas and Electric

Phil Gauthier 

AHRI
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Participants from DOE:

Eric Stas

DOE General Counsel’s Office

Mohammed Khan

Department of Energy

Presenter:

John Talbott

Consultant with NIST
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I N D E X

AGENDA ITEMS PAGE

Welcoming Remarks 5

MR. KHAN

Introductions 7

MR. BROOKMAN

Agenda Review 9

MR. BROOKMAN

Opening Remarks 10

MR. BROOKMAN

Rulemaking Steps, Rulemaking History, 12

and Discussion of Proposed Amendments

MR. KHAN

Detailed Discussion of Proposed Amendments 20

MR. TALBOTT

Next Steps and Closing 51

MR. KHAN 
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2 9:04 a.m.

1 P R O C E E D I N G S

3 MR. BROOKMAN: Okay. Welcome, everybody. 

4 Good morning. Glad you could join us. This is the 

5 U.S. Department of Energy’s Public Meeting on Energy 

6 Conservation Program for Consumer Products Test 

7 Procedures for Residential Water Heater, Direct 

8 Heating Equipment and Pool Heaters. Today is 

Friday, September 24th

12 We’re going to start this morning with 

13 welcoming remarks by Mohammed Khan.

9 . Glad you could join us. My 

10 name is Doug Brookman from Public Solutions in 

11 Baltimore. 

14 Welcoming Remarks

15 MR. KHAN: Thanks, Doug. Good morning 

16 everybody. This is. First of all I want to say 

17 thank you for your participation today, and also to 

18 those folks who are participating via the Webinar

19 that we’re also doing simultaneously here. 

20 Let me mention that this is the 

21 Department’s, I guess second effort for a test 

22 procedure rulemaking involving products that burn 
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1 fossil fuel or combustion products. The first one, 

2 as you know or may know, involved furnaces, 

3 residential furnaces, and boilers. There was an

4 SNOPR, or a supplementary notice of proposed 

5 rulemaking, associated with that one, and as a 

6 result it was a bit controversial.

7 Now you’ll hear me throughout today 

8 mention and I’ll emphasize over and over that your 

9 comments and participation is very, very important. 

10 As an example, citing the SNOPR issue, the comments 

11 that were received from that helped the Department 

12 in a big way, to determine the direction that it 

13 really needed to go. That particular final rule has 

14 not been published yet, but I am of the 

15 understanding that it will be published very, very, 

16 very shortly.

17 Another thing I’d like to mention is that 

18 we’ve been trying to make an effort to make these 

19 public meetings less painful, or a little bit 

20 shorter. I think in our notice we indicated that 

21 we’re scheduled to go until 4 p.m., but our agenda 

22 indicates that we’re going to go until 12. So, 

23 based on the content, based on the anticipated 

24 questions or comments that we should be getting 

25 today, I think 12 o’clock is probably a very good 
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1 estimate.

2 The other thing I want to mention, too, is 

3 that this is -- this may be the second or third time 

4 that the Department has incorporated a Webinar in 

5 its public meeting, so the logistics of it aren’t 

6 100 percent mastered, I guess. So what we’re going 

7 to try to do, and as always we’ll go through the 

8 issues and have a discussion back and forth and 

9 answer questions as they arise, and at the end of 

10 the discussions here, we’ll look at the Webinar and 

11 see if there are any questions that are pertinent 

12 and those folks might want to have answered as well.

13 So with that, I guess we can get started, 

14 and again, I appreciate your time and interest 

15 today.

16 Introductions

17 MR. BROOKMAN: Thank you. It’s typical 

18 for us to do introductions around the room. Not all 

19 of this will be captured on the record, but all of 

20 you registered so we know who’s here, and hopefully 

21 you -- I’m not sure if we’re collecting business 

22 cards today or not. But let’s start with 

23 introductions, you name and organizational 

24 affiliation. And you need to push the button so the 

25 little green light comes on the microphone. 
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1 MS. CLEARY: Jennifer Cleary with the 

2 Association of Home Appliance Manufacturers.

3 MR. SACHS: Harvey Sachs, with the 

4 American Council for an Energy-Efficient Economy.

5 MR. STANONIK: Frank Stanonik, Air 

6 Conditioning, Heating, and Refrigeration Institute.

7 MS. WALTNER: Meg Waltner, National 

8 Resources Defense Council.

9 MR. STROUD: Tom Stroud, Hearth, Patio and 

10 Barbecue Association.

11 MR. STAS: Eric Stas, DOE General 

12 Counsel’s Office.

13 MR. KHAN: Mohammed Khan, Department of 

14 Energy.

15 MR. TALBOTT: John Talbot, Consultant with 

16 NIST.

17 MS. LAM: Hoi Yee Lam, Energetics, 

18 Incorporated.

19 MR. LONG: Ray Long, DNR International.

20 MR. RYAN: David Ryan, DNR International.

21 MR. TALBOT: Jacob Talbot, American 

22 Council for an Energy-Efficient Economy.

23 MR. GAUTHIER: Phil Gauthier, Air 

24 Conditioning, Heating, and Refrigeration Institute.

25
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1 Agenda Review

2 MR. BROOKMAN: Thank you. Once again, 

3 thanks to all of you, glad to have you here. I’m 

4 going to do a very brief agenda review, and then 

5 we’re going to launch into the content. 

6 All of you received a packet as you came 

7 in and registered to the Department of Energy today. 

8 The slides that will be the focal point for 

9 presentation and also for discussion, you have 

those, as well as the Federal Register

18 Immediately following that, rulemaking 

19 steps, rulemaking history, and discussion of 

20 proposed amendments. And then a detailed discussion 

21 of proposed amendments. And when that is done, 

22 another opportunity for final comments, and again, 

23 summary comments, brief comments, other issues that 

24 any individual feels he or she needs to raise. And 

25 we intend, as Mohammed said, to finish today 

10 notice. You 

11 can see in the agenda which you also have, that 

12 immediately following this agenda review, we’re 

13 going to have a rulemaking overview, and then 

14 there’s an opportunity for anybody that wishes to do 

15 so, to make brief opening remarks, key issues, 

16 things that matter to you that you’d like to 

17 emphasize here at the outset. 
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1 probably no later than noon. We may even make it 

2 earlier than that today. 

3 So that’s the general plan. Questions or 

4 comments on the agenda? I see none, so please, I’d 

5 ask for your consideration. Please speak one at a 

6 time. Please say your name for the record. Please 

7 -- each time you speak, say your name. You don’t 

8 need to say your organizational affiliation again, 

9 unless you have the habit of doing so and you can’t 

10 stop. Please be concise, share the air time.

11 I’m going to be cueing people, individuals 

12 by name as best I can. We also wish to encourage 

13 and the Department benefits from follow-on comments. 

14 Sometimes the exchange, the back and forth can be 

15 especially useful. 

16 And do you wish to introduce yourself 

17 right now? Your name and organizational 

18 affiliation.

19 MS. McCann: Molly Trombley McCann, 

20 Pacific Gas and Electric. 

21 MR. BROOKMAN: Thank you, Molly. So 

22 that’s all I have to say here at the outset, I 

23 think. We’re going to go then to Mohammed Khan.

24 Rulemaking Overview

25 MR. KHAN: It didn’t work.(Referring to 
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1 the failed slide advance) I told you we had 

2 logistic issues to master. (Laughter) Good morning, 

3 everyone, and thank you for participating in the

4 Department’s Public Meeting on test procedures for 

5 residential water heaters, direct heating equipment 

6 and pool heaters. My name again, is Mohammed Khan, 

7 and I’m the Department of Energy’s project manager 

8 for this rulemaking activity. I’m be providing an 

9 overview of the rulemaking, and John Talbot who is a 

10 consultant for the National Institute of Standards 

11 and Technology, will present details on the 

12 Department’s proposed approaches for the test 

13 procedure amendments. 

14 The purpose of the meeting. Today’s

15 meeting serves multiple purposes, mainly, and as 

16 always, our goal is to have a two-way discussion. 

17 We want to convey the key points and concepts 

18 associated with this rulemaking, and hear and listen 

19 to your thoughts and potential concerns.

20 First, the Department wants to present its 

21 approaches for amending the applicable test 

22 procedures. Second, this is a forum for all 

23 interested parties to hear and discuss the issues by 

24 both the Department and by others. And because your 

25 feedback is very important, I encourage everyone to 
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1 fully participate and urge you to submit any 

2 relevant data that will help the Department in its 

3 rulemaking.

4 Lastly, we want to describe the steps in 

5 the rulemaking process so that all interested 

6 parties are fully familiar and are able to 

7 contribute.

8 Doug had mentioned that we would provide 

9 an opportunity. I don’t think the Department 

10 received any formal requests to do so, but at this 

11 juncture, I’m just going to allow folks who may not 

12 have submitted such a request, but if you want to, 

13 feel free.

14 MR. BROOKMAN: No comments at this time? 

15 No opening remarks. Then let’s proceed.

16 Rulemaking Steps, Rulemaking History, 

17 and Discussion of Proposed Amendments

18 MR. KHAN: Steps in the procedure of 

19 rulemaking. This rulemaking includes a Notice of 

20 Proposed Rulemaking or NOPR for short, which was 

21 published on August 30, 2010. Today we’re holding 

22 the public meeting because it’s essential for the 

23 Department to provide this opportunity for an 

24 exchange of information. Correspondingly, the 

25 process includes a 75-day written comment period 
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which closes on November 15th

2 In order for the Department to develop and 

3 issue the most inclusive final rule possible, it 

4 reviews and fully considers all of the comments it 

5 receives. While we do not have an exact date for 

6 the publication of the final rule, I can assure you 

7 that it will be published as soon as possible 

8 following the comment period

1 . 

9 Okay, let me talk briefly about some 

10 pertinent regulatory history and what’s driving this 

11 effort. The test procedures that are the subject of 

12 this rulemaking are codified as 10 CFR Part 430, 

13 Subpart B. The applicable appendices for water 

14 heaters, direct heating equipment, vented direct 

15 heating equipment, and pool heaters are Appendices 

16 E, G, O, and P, respectively. 

17 The relevant final rule that amended 

18 standards for these products was published on April 

16, 2010, and let me be clear, the April 16th 19 final 

20 rule does not stipulate standards for standby and 

21 off mode energy use, and the current test procedure 

22 rulemaking will not change or affect the current 

23 standards. The Department is conducting 

24 this rulemaking because the Energy Independence and 

25 Security Act of 2007, or EISA 2007 for short, 
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1 charges DOE to incorporate protocols for measuring 

2 standby and off mode energy consumption into the

3 test procedures for the covered products. Again, 

4 just to be clear, this rulemaking does not impact 

5 current standards, but EISA requires that any new 

6 standard promulgated after July 1, 2010 must address 

7 standby mode and off mode energy consumption. 

8 EISA also requires DOE to integrate 

9 standby and off mode energy consumption into the 

10 existing regulating metric, unless, 

11 1. The Secretary determines that the current 

12 test procedures already fully account for and 

13 incorporate standby and off mode energy 

14 consumption, or, 

15 2. If such an integration is technically 

16 infeasible.

17 A final point concerning the EISA 

18 requirements is that the International 

19 Electrotechnical Commission standards, 62301, and 

20 62087, must be considered in developing the 

21 protocols for measuring standby mode and off mode 

22 energy consumption. DOE has determined that IEC 

23 standard 62301, titled “Household electrical 

24 appliances, measurement of standby power,” is 

25 relevant and proposes to incorporate standards 
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1 62301 by reference. 

2 However, DOE believes the scope of the IEC 

3 standard 62087, titled, “Methods of measurement for 

4 the power consumption of audio, video, and related 

5 equipment,” is limited and not relevant to this 

6 rulemaking.

7 EISA review and needed amendments. The 

8 first step in the process was for DOE to review the 

9 current test procedures to identify where possible 

10 changes were needed to address the EISA 

11 requirements. Based on its review, the Department 

12 has determined the following:

13 For water heaters, the current test 

14 procedures do not require modification. The current 

15 test procedure already fully accounts for standby 

16 energy consumption, and that measurements for off 

17 mode energy consumption is unnecessary since the 

18 operation of water heaters do not include off mode.

19 There are two types of direct heating 

20 equipment, vented and unvented. For vented heaters, 

21 DOE has determined that standby and off mode fossil 

22 fuel energy consumption are already fully accounted 

23 for in the current test procedure. However, DOE 

24 believes that it is necessary to introduce new 

25 measurement and calculation provisions for 
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1 electrical standby and off mode energy use.

2 For unvented heaters, DOE believes 

3 additional measurement provisions are needed for 

4 both fossil fuel standby and also electrical standby 

5 and off mode energy consumption. For unvented 

6 heaters, DOE also believes additional calculation 

7 provisions are not needed.

8 For pool heaters, DOE believes that both 

9 additional measurement and calculation provisions 

10 for both fossil fuel and electrical standby and off 

11 mode energy consumption are required. 

12 I’d like to know if there are any 

13 questions at this point. Mr. Sachs.

14 MR. SACHS: Harvey Sachs. Thank you, 

15 Mohammed. I just installed a water heater that has 

16 an off switch, and as I think about that water 

17 heater and others, it occurs to me that a 

18 manufacturer of advanced products could readily set 

19 it up so the vacation mode locks out the water 

20 heating function. It keeps alive whatever clocks 

21 and things it has. It shuts down the ability to 

22 heat water. Is that off mode or standby? It’s a 

23 small amount of energy, but it’s not clear to me 

24 that for advanced products there might not be an off 

25 mode.
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1 MR. TALBOTT: Well, the position taken --

2 MR. BROOKMAN: John Talbott.

3 MR. TALBOTT: John Talbott. The position 

4 taken in the proposal is that there already is a 

5 full accounting of all energy in the water heater 

6 test procedure, and they even have a term called 

7 “standby loss” and that was essentially consistent 

8 with what EISA wants. We do not know of products 

9 that would have additional energy consumption that 

10 EISA would ask us to include. But if you have 

11 information and products that might have that, that 

12 would be interesting in your comments.

13 MR. SACHS: I believe that -- Harvey SacHs 

14 -- I believe, John, that all home water heaters on 

15 the market today have a vacation mode whose energy 

16 consumption would be unlikely to be revealed in the 

17 24-hour cycle. I believe that some of the gas tank 

18 appliances similarly have a discrete vacation mode. 

19 I don’t know what it does.

20 MR. BROOKMAN: Thank you. Frank Stanonik.

21 MR. STANONIK: Frank Stanonik. Two 

22 points, the last thing Harvey mentioned, I think, 

23 certainly on gas storage water heater, if it had a 

24 vacation mode, essentially it’s just really turning 

25 the thermostat down. I mean, it’s different than 
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1 the -- you could set the gas control at pilot when, 

2 at which point it wouldn’t do any heating, but in 

3 the vacation mode it’s just really setting the 

4 thermostat very, very low where it probably won’t 

5 ever recycle, not that it can’t, but it probably 

6 won’t.

7 But the other point that certainly is 

8 different here -- again, there’s no question standby 

9 loss for water heaters of whatever variety is 

10 measured, and so something like a heat pump that 

11 would have a off mode, that consumption is actually 

12 less than the standby loss, because basically you’re 

13 not allowing the thing to reheat water for no 

14 purpose. And at least I’ll venture that 

15 philosophically, that’s very different than why 

16 we’re sitting here looking at standby and off mode 

17 consumption of products because the concern was that 

18 it was something -- it was some additional 

19 consumption that wasn’t being counted, I guess. But 

20 in this particular case, we’re actually talking 

21 about -- well, first of all, it isn’t measured in 

22 the test procedures -- this off mode isn’t measured. 

23 But it would be a significantly lower consumption 

24 than the standby that is measured, so certainly to 

25 us it’s kind of a, well, what are we really gaining 
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1 there, I guess, or what are we really finding out.

2 MR. SACHS: Thank you, Frank. This is 

3 Harvey Sachs again. I very much appreciate that. 

4 The hypothetical that I raised is not going to be a 

5 large energy consumption, it’s a couple watts 

6 against the 40 or 50 watts of standby radiated heat. 

7 The question really comes down to whether 

8 manufacturers are going to go to the legal eagles 

9 and everyone else to think about whether he’s going 

10 to have problems if he wants to do a mode that 

11 disables the water heating function, a mode that 

12 might keep the electronics alive, but would not 

13 allow the water heater to heat water. So it’s a 

14 theoretical thing, but I think it’s a possible 

15 category. I think we’ve beat that horse until it’s 

16 quite dead.

17 MR. BROOKMAN: Thank you, Harvey. Molly.

18 MS. TROMBLEY-McCANN: Molly Trombley19 McCann. Just to mention that if manufacturers are 

20 designing features that cause the units to use even 

21 less energy than they otherwise would have, we’d 

22 like to see that reflected in the test procedures so 

23 that those units can get adequate credit for those 

24 additional features, for having that off mode that 

25 allows them to save additional energy, even if it’s 
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1 a small amount.

2 MR. BROOKMAN: Thank you.

3 MR. KHAN: Well, thank you for the 

4 questions and comments, I’m going to turn the 

5 presentation over to John Talbot at this point.

6 Detailed Discussion of Proposed Amendments

7 MR. TALBOTT: 

8 What I’d like to do is present some of the 

9 details and just by coincidence, you just covered 

10 some of the details. We’re going to go product by 

11 product, and we’ll go in the order of which these 

12 three products are always listed. So water heaters 

13 first. I had keyed up here a question, is it 

14 appropriate to our current position of everything is 

15 okay in the water heater test procedure, but you’re 

16 hearing some discussion that perhaps it’s not. But 

17 wonder if it’s appropriate to bring that up as part 

18 of the EISA amendment provisions or not. 

19 What you’re talking about is something 

20 that applies to the overall existing test procedure 

21 for water heaters. And defining a off mode, all 

22 products, if you turn them off, they don’t use 

23 energy. Furnaces have the same situation. People 

24 don’t heat their houses, there will be less energy 

25 consumed. So this would be in that area. 
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1 The current version of the existing water 

2 heater test procedures defines a representative use 

3 cycle as 24/7, 365 days. And that is 

4 representative, at least. But if you want to expand 

5 that into others, that’s a whole different test 

6 procedure amendment process, rather than adding 

7 EISA.

8 And if we could, we could move on to 

9 vented heaters, unless Frank has a question.

10 MR. STANONIK: Well not -- Frank Stanonik. 

11 It’s not really a question but a comment. 

12 Certainly, I mean we agree with the preliminary 

13 conclusion here that you really don’t need to do any 

14 additional standby off mode testing for a water 

15 heater when it’s functioning. The intent is it’s 

16 supposed to be ready 24/7. And so we’ll certainly 

17 talk to some of our members. I understand what 

18 Harvey’s saying, but if the water heater has this 

19 feature of somehow allowing somebody to turn it off 

20 at the water heater as opposed to -- you know, it 

21 has electric supply. Most codes require you have to

22 have a nearby switch, but that’s not at the product, 

23 that’s your system. But if it does have that 

24 feature, I guess we’ll talk to our members just to 

25 kind of confirm that.
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1 The point I wanted to make is that when 

2 you’re doing a standby loss test on a water heater, 

3 when it’s ready to perform or function, you are 

4 going to measure that electric consumption of 

5 whatever electronics, and so again, in a sense we’re 

6 -- we’re looking at I’d say the maximum consumption 

7 that might be occurring in operational mode, and I 

8 think that’s the right thing to do, in that case 

9 there is no need for further amending the test 

10 procedures for this.

11 MR. BROOKMAN: Eric Stas.

12 MR. STAS: Eric Stas, DOE. This would 

13 apply to -- the semantics, and the definitions here 

14 get a little tricky, so even those in common terms 

15 or marketing, someone might be calling something off 

16 mode, and perhaps it really is a standby mode, and 

17 if it’s already captured, then we don’t need to bulk 

18 up the test procedures. That’s why it’s important 

19 to give us whatever data you can provide, or 

20 examples that they can analyze to see if anything 

21 more is really necessary.

22 MR. BROOKMAN: Harvey Sachs.

23 MR. SACHS: Thank you, Eric, and I very 

24 appreciate that, but we’re not trying to bulk up. 

25 From my perspective, clarity is required in order to 
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1 not discourage innovation. Ambiguity is the enemy 

2 of innovation in these areas. Or one enemy. So 

3 that -- it’s not going to be a large amount of 

4 energy, but I’ve tried to think out whether we have 

5 some issues.

6 MR. STAS: No, I’m agreeing with you. I’m 

7 just highlighting how tricky I think this area gets 

8 to be, and we want as much input as possible, 

9 because we want to get it right the first time. 

10 MR. BROOKMAN: Yes, tricky in the 

11 practical application.

12 MR. SACHS: Yes.

13 MR. BROOKMAN: Questions? More questions 

14 on this subject? Comments? So, John, you were 

15 suggesting a pathway based on what we’ve covered 

16 already. Restate that.

17 MR. TALBOTT: Well, some of the issues 

18 that are being raised affect the test procedure in 

19 general, and not the addition of standby and off 

20 mode. And that’s a serious discussion, and if you 

21 feel that test procedures need to be seriously 

22 expanded to accomplish these automatic off modes or 

23 other energy conservation designs, that’s you’re 

24 welcome to submit those comments, but they don’t 

25 exactly relate to the business before us today.
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1 MR. BROOKMAN: Thank you. 

2 MR. TALBOTT: All right. Vented heaters. 

3 Vented heaters, the test procedure is very similar 

4 to the furnace test procedure, and the amendments 

5 are very nearly the same as what was nearly 

6 finalized for the furnaces. With some 

7 clarification, the EISA concepts and definitions are 

8 applicable or workable within the vented heater test 

9 procedure. The on cycle and off cycle, that’s the 

10 terminology in the vented test procedure, is very 

11 similar to what’s described as standby mode or off 

12 mode. But we add definitions to clarify that.

13 In the test procedures for this product, 

14 fossil fuel energy consumption is accounted for over 

15 the full year cycle, and we believe that that,

16 therefore, satisfied the EISA 2007 requirements. 

17 This is the pilot light treatment, and even the 

18 summertime usage of the pilot light is accounted for 

19 in the vented heater test procedure. So I believe 

20 we’re covered there on the fossil fuel side.

21 However, provisions are needed and are 

22 proposed to be added to measure the electrical 

23 standby mode and off mode wattages, and we’ll 

24 utilize the international standard, 62301, with some 

25 clarifications, to accomplish those measurements.
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1 The key clarifications in the proposal for 

2 these measurements are that the existing test 

3 procedure specifications for ambient temperature and 

4 voltage shall apply in lieu of the international 

5 standard provisions. The accuracy and precision 

6 provisions in the IEC standard would apply. They 

7 seem reasonable, and it would provide some 

8 uniformity across all the products if we all use the 

9 same accuracy and precision specifications.

10 In addition, we have to take those 

11 measurements and then integrate them into the test 

12 procedure, and for this product, the energy 

13 consumption equations would be expanded to include 

14 the standby and off mode electrical energy 

15 consumption. 

16 And then the final thing that was 

17 determined was that the integration into the 

18 existing AFUE was determined as not feasible.

19 So let me explain the actual equations 

20 that we are modifying and expanding. In red are the 

21 added terms, so the existing test procedure had a 

22 calculation for the total annual electrical 

23 consumption E sub AE, and it was the product of the 

24 burner operating hours times what is now called the 

25 active mode electricity. So that’s the existing 

26 test procedure. What we’re doing is just adding one 
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1 term, and it’s called the energy in standby and off, 

2 and the next equation is all new, and this is the 

3 actual annualization of those wattage measurements. 

4 So you can see here that it uses existing test 

5 procedure numbers and values. It takes the wattage 

6 measurement, which is P sub SB (for standby wattage) 

7 and P sub OFF (for off mode wattage), and it 

8 multiplies it by the test procedure provided hours. 

9 Now for the standby mode, in heating season, which 

10 is defined in the test procedure as 4160 hours minus 

11 the active mode, which we’re approximating as the 

12 burner operating in hours, and then for the off 

13 mode, the rest of the year is assigned the off mode. 

14 So that’s 8760 full year accounting, and it’s pretty 

15 straightforward, and it uses a lot of the test 

16 procedure assignments that are already in, already 

17 available.

18 So that’s the vented heater expanded 

19 calculations, and for the same reasons as the 

20 furnace suggestion of integrating also into the 

21 efficiency metric, AFUE, it was determined for

22 vented heaters that is also de minimus and would not 

23 have a significant effect on the actual number of 

24 the efficiency, so we are tentatively concluding 

25 that it is appropriate not to integrate into the 
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1 AFUE for vented heaters. And so that’s the vented 

2 heater amendments. Any questions on vented heaters?

3 MR. STROUD: Tom Stroud. The difficulty 

4 that HPBA sees here is that some confusion was added 

5 in the final rule by including what have been seen 

6 as decorative products, the 2150 products, as well 

7 as the 2188 products. I think what's being 

8 discussed here really fits with the 88 products, 

9 which are hearth heaters. With the decorative 

10 products, these are typically attended appliances, 

11 not automated, and I think standby and off mode are 

12 very dissimilar with those products. And so if 

13 those products are going to continue to be included 

14 here, we've got to look at those in a completely 

15 different way.

16 MR. BROOKMAN: So the decorative products 

17 you're referring to, what are they?

18 MR. STROUD: Z2150 products are typically 

19 gas fireplaces that are not used for heating, but 

20 used for decorative purposes alone. And their 

21 typical use pattern may be two hours a month, or 

22 four hours a month, something like that.

23 MR. KHAN: Mohammed Khan, DOE. Tom, 

24 appreciate those comments very, very much, and the 

25 Department would appreciate it even more so if the 
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1 numbers you just mentioned could be confirmed by any 

2 kind of data that you would have.

3 MR. STROUD: We do have it.

4 MR. KHAN: Or be able to -- okay, great.

5 MR. STROUD: And we’ll get it to you.

6 MR. KHAN: Thank you very much.

7 MR. BROOKMAN: Thanks, Tom. Frank.

8 MR. STANONIK: Frank Stanonik. Just to 

9 address the questions on the slide here, we 

10 certainly agree that it’s not a good idea or not 

11 really practical to integrate these measurements 

12 into the AFUE. It becomes a little more difficult 

13 for direct heating equipment because you have all 

14 these different levels for the different product 

15 types. To me, there’s some greater sense to just 

16 keeping it as a separate measurement.

17 And as far as whether the proposed 

18 amendments are sufficient, I’ll say at this point, 

19 they appear to be sufficient, subject to more input 

20 from our members, but I think they are.

21 The one thing that I think I heard, and we 

22 will still provide comments on, is using the, I’ll 

23 call it the measurement method of the IEC standard, 

24 relative to the accuracy and repeated -- the need 

25 for, I’ll call them sampling measurements as opposed 
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1 to the rest of the test procedure where you just 

2 kind of take one measurement and move on to the next 

3 one. But that’s a minor point relative to these 

4 bigger issues which I think DOE has gotten right.

5 MR. BROOKMAN: Thank you. Yes, Molly.

6 MS. TROMBLEY-McCANN: Molly Trombley7 McCann. Just to say that we agree that we believe 

8 keeping those standby and off mode uses separate 

9 from the AFUE metric is appropriate and is the best 

10 way to effectively regulate both energy uses, so 

11 we’re very pleased to see that.

12 MR. BROOKMAN: Thank you, that’s helpful 

13 for the Department to hear affirmations like that.

14 MR. TALBOTT: Okay. Additional comments 

15 on this subject? We’ll move on to unvented heaters. 

16 This product was the subject of an industry inquiry 

17 which asked, if there is, in fact, standby loss or 

18 off mode energy consumption, and how best to account 

19 for it. The proposal that we --we did get comment 

20 back that said, yes, there is a possibility of 

21 electrical standby loss and fossil fuel standby 

22 loss, and that there’s probably a need for 

23 amendment, but they should be minimal. And so the 

24 proposal would add measurement provisions for both 

25 the pilot light and electrical consumption because 
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1 they are standby and off mode. Both of these added 

2 provisions would allow for exemption from 

3 measurement if there is a means to disconnect the 

4 power source when not in use, and instructions to do 

5 so are clearly visible. This exception is 

6 consistent with what is already in the test 

7 procedures for manually-controlled vented heaters, 

8 where this is truly a portable device, user 

9 discretion, and it’s appropriate not to account for 

10 the energy consumption that might be considered off 

11 mode or stand by mode.

12 So, consistent with what’s already in the 

13 test procedures. The exemption from measurement and 

14 even accounting for possible standby and off mode 

15 losses is accepted. 

16 And then finally for this product, because 

17 it is a special product that is by and large 

18 discretionary use, we are not proposing 

19 consideration or development of a representative use 

20 cycle for this product class. There was no 

21 representative use cycle in the existing test 

22 procedure, and the expansion to include standby and 

23 off mode was not compelling, or we could not get 

24 data from the industry to justify the creation of a 

25 representative use cycle.
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1 So the amendments are pretty 

2 straightforward, just go in, take a couple 

3 measurements, and obtain these values of P-sub SB 

4 electrical and P-sub OFF, and that’s it. 

5 So are there concerns with this decision 

6 not to go further and develop a representative use 

7 cycle? And are the amendments sufficient?

8 MR. BROOKMAN: Frank Stanonik.

9 MR. STANONIK: Frank Stanonik. Certainly,

10 we agree with the tenet of the decision that you 

11 don’t need to try to define a representative use 

12 cycle. And the proposed amendments we think are 

13 sufficient. 

14 There is just one question that kind of 

15 came up as I listened to John and look at the text 

16 here, the proposed text, and in the case of unvented 

17 heaters it becomes fairly important. It’s mentioned 

18 here that if there’s an instruction to turn off the 

19 unit on the gas control or whatever, I’m not going 

20 to be verbatim because I don’t remember exactly what 

21 John said, but what I heard was turn it off when not 

22 in use. And I guess I just want to make sure that 

23 it would be understood that I would think that --

24 well, I will say our preference, industry’s 

25 preference would be we’re talking about turning it 
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1 off in the non-heating season. We really don’t -- I 

2 think we really don’t want to get into a situation 

3 where every time that consumer, let’s say every day 

4 after -- let’s say they turn on their vent-free 

5 heater for a couple hours, and then every day they 

6 turned it off, then they would have to relight the 

7 pilot the next day, or whatever. I don’t think we 

8 want to get into a situation that would necessarily 

9 encourage that kind of a practice. 

10 And so if it would be understood, I think, 

11 that this instruction would talk about turning it 

12 off when you’re not going to be using it in the 

13 heating season, whatever that might be, I think with 

14 that clarification this makes sense. 

15 But my -- I’d say otherwise, if this was 

16 to be understood that it would have to mean that 

17 every time you -- every separate occasion you 

18 weren’t using it, the instruction would have to say 

19 you turn it off, then you’re probably going to have 

20 a lot of people misreading their pilot energy 

21 consumption.

22 MR. TALBOTT: That’s a good point because 

23 for this product, the pilot energy is not an energy 

24 waste, so during that season we don’t want to get 

25 into measuring pilot lights and then essentially not 
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1 -- for no purpose.

2 MR. STANONIK: Frank Stanonik. The other 

3 point is again, with this product, that pilot has a 

4 very significant safety function. The pilot is a 

5 critical component of the oxygen depletion sensing 

6 system, and so again there’s -- consumers being 

7 consumers, there’s some concern. We really don’t 

8 want consumers regularly fiddling around with the 

9 pilot, if you will.

10 MR. BROOKMAN: Mohammed Khan, and then to 

11 Harvey.

12 MR. KHAN: Mohammed Khan, DOE. I just 

13 wanted to comment or add to the point about Frank’s 

14 concern regarding unplugging the electric units. In 

15 the Notice, we report back what the Association of 

16 the Home Appliance Manufacturers, AHAM, provided to 

17 us in that regard, and number one, they suggested 

18 that the off mode be ignored entirely for portable 

19 electric heaters; and number two, I guess to provide 

20 us basis for that, they indicated that there was 

21 data collected by the Stevenson Group in 2004, 

22 reporting that 86 percent of the consumers unplugged 

23 their portable heaters per the safety instructions. 

24 So perhaps we can get comment today from the person 

25 representing AHAM on that as to whether or not we 
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1 have any information about when it’s unplugged for

2 the 86 percent.

3 MR. BROOKMAN: And Mohammed, maybe you 

4 could just say what page that reference is on?

5 MR. KHAN: Sure, that’s in the Federal 

Register

8 MR. BROOKMAN: Thank you. That’s helpful.

6 Notice, on Page 52899, first column, at the 

7 bottom. 

9 MS. CLEARY: This is Jennifer Cleary. I 

10 don’t have that data today, but I can certainly look 

11 into it. I think that we might be talking about a 

12 little bit different scenarios here, that the AHAM 

13 comments are directed only to the portable electric 

14 heaters and those, I think, our data indicates are 

15 unplugged when they’re not in use most of the time, 

16 and bear those instructions on the product.

17 MR. BROOKMAN: Okay. Harvey Sachs.

18 MR. SACHS: Harvey Sachs, and just one 

19 point of clarification or emphasis. I’m sure that 

20 John meant that with unvented heaters, the pilot is 

21 not wasted energy during the heating season.

22 MR. TALBOTT: Correct.

23 MR. BROOKMAN: John Talbot.

24 MR. TALBOTT: Yes, and of course then 

25 you’re left with the off mode possibility of a pilot 
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1 light, which means summer time burning, and we feel 

2 that if there is provisions that says there is an 

3 off switch, consistent with what we say for vented 

4 heaters, that precludes you from counting and 

5 measuring pilot light, because we expect that those 

6 units would be turned off.

7 MR. BROOKMAN: Additional comments on 

8 these points? I think this specificity is helpful 

9 to the Department. This is good. Okay. Then, 

10 John.

11 MR. TALBOTT: Okay. The final product. 

12 Pool heaters. For pool heaters, the amendments are 

13 a little more extensive. The existing pool heater 

14 test procedure was only half a page or a page. And

15 with the EISA charge, we felt that there was enough 

16 of a change needed that we are essentially replacing 

17 the old Appendix P with new Appendix P. So what’s 

18 proposed in the proposal is an entire, complete test 

19 procedure. And for this product, again similar to 

20 the other products, the existing test procedure 

21 terminology can be straightened out and be 

22 consistent with what EISA’s asked for.

23 But there are separate measurement and 

24 calculation provisions are added to quantify the 

25 standby and off mode for both fossil fuel and 
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1 electricity. The proposal adopts a similar approach 

2 as outlined in ASHRAE Standard 146 to measure the 

3 standby and off mode energy consumption. However, 

4 it’s not incorporated directly by a reference there. 

5 There’s enough terminology changes that we were 

6 required to live with because of EISA, that we 

7 essentially just adopt a similar approach and then 

8 develop an Appendix P that satisfies all of our 

9 statutory charges.

10 Again, the measurement of the electrical 

11 standby and off mode wattages would utilize the 

12 international standard and will make the same 

13 clarifications that the existing test procedure 

14 specs for ambient temperature and voltage shall 

15 apply, instead of the international standards.

16 Now, one of the big changes is that 

17 there’s a new energy descriptor. And because it is 

18 technically feasible to do so, for this product, we 

19 feel that we should integrate the standby and off 

20 mode into the thermal efficiency descriptor. And we

21 used the thermal efficiency descriptor to allow for 

22 the consistency within our statute that identifies 

23 thermal efficiency as the efficiency descriptor for 

24 this product.

25 So, describing the new integrated thermal 
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1 efficiency is essentially the same quotient as was 

2 in the existing test procedure. The energy out over 

3 the energy in, where the energy out is the same as 

4 it always was, it’s the seasonal output of heated 

5 water -- and this test procedure actually measures 

6 the heat content of the water that’s produced -- so 

7 that’s the same as the existing test procedure. 

8 However, the E sub IN, the input energy is the total 

9 annual input energy including fossil fuel, 

10 electricity, and in active mode, standby mode and 

11 off mode. So that’s the expansion.

12 Explaining further, again, the denominator 

13 of the ultimate equation of the integrated thermal 

14 efficiency is E-sub-IN, the input, and it’s the sum 

15 of the fossil fuel input and the electrical input. 

16 For the fossil fuel input -- and I show in black the 

17 existing test procedure -- it had some accounting of 

18 the pilot light in the standby mode, which would be 

19 the pool operating hours minus the burner operating 

20 hours, but it had no mention of off cycle. So we 

21 added the term to account for the possible off cycle 

22 of the pilot.

23 Again, so the total electricity, we have 

24 to add, for the electrical side, we have to add a 

25 whole new term. So the original test procedure just 
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1 had the active mode. It didn’t call it active mode.

2 It was just the burner operating hours times the 

3 electrical active mode electricity. And then we 

4 added the standby and off electricity accounting, 

5 and here again, we used the test procedure 

6 assignments for pool operating hours, that’s the 

7 pool heating season, and the burner operating hours, 

8 and that difference would define the standby loss 

9 for the electricity. And then, again, the off mode 

10 is the non-pool operating hours. 

11 And that’s the integration that we feel 

12 EISA directs us to do, and so we integrated here 

13 into consumption equations, and we integrated into 

14 the efficiency equation. And NIST has done some 

15 testing on what’s the effect of the integrated 

16 thermal efficiency, and it has found that the 

17 integration does result in two, three, four 

18 percentage point changes. So we don’t feel that we 

19 can make the argument that it’s deminimus. 

20 And so for this product, we feel that we 

21 should do the total integration that EISA asks for. 

22 And so the questions also the line, we’ve actually 

23 updated the standard that was the basis of the 

24 original thermal efficiency, and we found that there 

25 were no substantive differences, but we ask for 
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1 comment on that. And are we sufficient with these 

2 amendments? And the determination, in particular, 

3 of the need to integrate into the thermal efficiency 

4 these standby losses?

5 MR. STANONIK: Frank Stanonik. John, one 

6 question first that -- you mentioned that you had 

7 done some testing and showed that in fact these 

8 other consumptions do change the -- give you a 

9 different value for the integrated thermal 

10 efficiency. Would that be the case -- I assume that 

11 was both off and standby.

12 MR. TALBOTT: Yes.

13 MR. STANONIK: Okay, so if I had this pool 

14 heater that had instructions to turn off during the 

15 non-pool heating season, I don’t include off, right?

16 MR. TALBOTT: Right.

17 MR. STANONIK: Okay. So in that 

18 circumstance is -- does your testing show that just 

19 the standby consumption would be enough to change 

20 the thermal efficiency -- the number?

21 MR. TALBOTT: Since you’re dealing with a 

22 smaller total energy, it’s likely that it will. 

23 It’s much less -- how to say this -- it’s much more 

24 magnitude relative to the total consumption than it 

25 would be on a furnace or a vented heater. So we 
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1 don’t have a formal report on that early testing, 

2 but it does show some movement, and I don’t know if 

3 the off mode was discounted or not.

4 MR. BROOKMAN: With that -- well, 

5 obviously, I would be interested if you have some 

6 additional information on that. 

7 MR. STANONIK: But I think looking at the 

8 questions again presented here, I’ll just say as far 

9 as being sufficient, I don’t think we need any more

10 amendments. And I know we have no issues --

11 nothing’s been related to us -- as far as issues 

12 updating to the current edition of Z2056. 

13 But on the last point of this additional 

14 metric, at this point, not necessarily disagreeing 

15 that DOE may have to do this -- again we need to 

16 look at the numbers ourselves to see what kind of 

17 energies we’re talking about, but I do have a very 

18 fundamental concern about calling it thermal 

19 efficiency. Even if you say integrated, okay. 

20 Thermal efficiency, when we talk about water heating 

21 products, historically, at least to the cognizant 

22 people who deal with these products and design them 

23 and everything else -- thermal efficiency is 

24 immediately recognized -- that’s, you know, energy 

25 into the water. And so now again, not arguing that 
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1 we’re going to measure these other things, these 

2 consumptions have been going on when no water is 

3 being heated, but I would -- I think our preference 

4 would be not to call -- not to associate that as 

5 thermal efficiency. It -- I’m going to say it 

6 becomes a misnomer.

7 MR. TALBOTT: Well, what else would you 

8 call it?

9 MR. STANONIK: Well, I guess that would --

10 we’ll have to give that some thought, but I believe 

11 DOE would have the latitude, if they’re going to 

12 create a new descriptor, they could perhaps call it 

13 something else, and maybe it’s -- I don’t know, it 

14 wouldn’t be AFUE -- no, but if there is going to be 

15 this added descriptor, and we’ll give it some 

16 thought. I would prefer to have it something other 

17 than thermal efficiency, because in fact, 

18 classically, this new thermal descriptor is not 

19 thermal efficiency. We’ve inserted consumptions 

20 that have nothing -- have no benefit to the water. 

21 Again, not contesting whether that’s right or wrong, 

22 but it’s going to -- I’d rather avoid an unnecessary 

23 confusion.

24 MR. BROOKMAN: Let’s hear from Eric Stas, 

25 General Counsel’s Office. 
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1 MR. KHAN: First it would be me.

2 MR. BROOKMAN: Mohammed first.

3 MR. KHAN: Mohammed Khan, DOE. Frank, as 

4 a mechanical engineer, I certainly appreciate those 

5 concerns about terminology that you just made. And 

6 as Doug already asked, whether or not there would be 

7 any kind of suggestions that you might be able to 

8 provide. But, I want to point out that statutorily, 

9 we’re required to integrate with the existing 

10 descriptors that are on the books, and if it is, 

11 according to EISA, technically feasible to do so, 

12 then I don’t think we have really any alternative. 

13 I’m going to let Eric Stas add to this.

14 MR. STAS: And EPCA specifically provides 

15 that for pool heaters, the efficiency descriptor, 

16 the regulatory metric shall be thermal efficiency, 

17 so, you know, this is an integrated thermal 

18 efficiency, and it keeps us within our statutory 

19 boundaries. So we support all your efforts to 

20 clarify your members that the duck that’s walking 

21 like a duck is indeed a duck. 

22 MR. BROOKMAN: Thermal efficiency sub 

23 something, perhaps. Harvey, go ahead.

24 MR. SACHS: Harvey Sachs. I’m really 

25 guilty of attempting to practice law, but it seems 
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1 to me that the Secretary’s authority extends to some 

2 discretion in naming. I think to answer Frank’s 

3 concerns, we ought to change the name to something 

4 neutral. I recommend giraffe.

5 MR. STANONIK: I was thinking duck. It 

6 looks like a duck.

7 MR. STAS: Quite seriously, I think some 

8 of Frank’s concerns might be addressed by referring 

9 to it as augmented instead of integrated. 

10 Augmented, expanded, there are a variety of other 

11 modifiers that do not have quite the same weight as 

12 the term integrated.

13 MR. BROOKMAN: Good. Thank you. I think 

14 he’s not objecting to calling it integrated, I think 

15 he’s objecting to using thermal efficiency, right?

16 MR. STANONIK: I think we wouldn’t mind 

17 augmented, but it’s when you throw out the whole 

18 term thermal efficiency that there’s more concern.

19 MR. BROOKMAN: Frank, I think the 

20 Department’s taking you up on your offer to give 

21 this some thought, but Molly, please.

22 MS. TROMBLEY-McCANN: I was just going to 

23 make a facetious suggestion that we always put it in 

24 square quotes. 

25 MR. BROOKMAN: One benefit, we’ll have a 
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1 complete discussion of this on the record. It never 

2 needs to be reinterpreted.

3 MR. TALBOTT: Just to clarify further, 

4 there’s been considerable time that has elapsed 

5 since these original provisions were put on into the 

6 statute, and if you have background -- I’m playing 

7 the lawyer now -- but if you have background that 

8 tells us why the efficiency descriptor was added to 

9 the Federal code, specifically for those four 

10 products that identified this terminology. I have a 

11 good memory, but I don’t remember.

12 MR. STANONIK: Such as legislative history 

13 or something like that, yes.

14 MR. TALBOTT: Yes.

15 MR. STANONIK: I’ve got you. Okay. 

16 MR. BROOKMAN: So additional comments on 

17 this subject? I think we’ve covered this one. Yes, 

18 Meg.

19 MS. WALTNER: Meg Waltner. I just have a 

20 quick question. I know from the original or the 

21 existing test procedure, but I’m curious how the 

22 burning operating hours and the pool operating hours 

23 were derived, where those numbers came from, besides 

24 the fact that they’re from the existing test 

25 procedure.
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1 MR. TALBOTT: Okay. There was an ASHRAE

2 standard that was in place that assigned pool 

3 operating hours, and that’s where it came from. And 

4 the actual numbers -- it’s an actual fixed number, 

5 it’s not pool operating hours, it’s just 41-

6 something, and there’s an ASHRAE standard that has a 

7 regional effect, it’s standard 146 that describes in 

8 different areas, there would be different pool 

9 operating hours, so there would be an adjustment if 

10 you went that far in the equation. So a 

11 representative value was picked decades ago, and 

12 that’s in the test procedure.

13 MR. BROOKMAN: So final questions and 

14 comments on this segment?

15 MR. TALBOTT: That’s it for the technical 

16 details.

17 MR. BROOKMAN: And then there’s a summary 

18 slide, isn’t there?

19 MR. TALBOTT: Yes, it’s here.

20 MR. BROOKMAN: And let me also, for those 

21 of you who have joined this meeting on-line, we’re 

22 running ahead of schedule. If you have questions 

23 that haven’t been addressed during the course of the 

24 meeting today, you can send them in now, and we’ll 

25 try, as an experiment, to see if we can answer a few 
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1 of them if any are especially unique than have come 

2 up so far. 

3 So John, you want to set up this slide or 

4 do you not need to do it?

5 MR. TALBOTT: Well, this is your -- any 

6 summary comments and here’s a list of the big issues 

7 that apply to all the products. I’ll give you an 

8 opportunity to think about any of these and get it 

9 on record.

10 Final Comments

11 MR. BROOKMAN: I think it’s good. I think 

12 we’ll list them, clarify that it’s use of IEC 62301 

13 standard, the proposed energy accounting, how to 

14 address standby mode and off mode energy use and 

15 energy conservations standards. So those are focal 

16 points for additional comment. Frank Stanonik.

17 MR. STANONIK: I apologize, I’m going to 

18 to backtrack a little bit, just because I’m taking 

19 advantage of this opportunity. Getting back to this 

20 last discussion about the legislation and what it 

21 specified relative to the pool heaters, two points. 

22 One of them is that when that legislation was 

23 written, it also -- and I think it has some -- it 

24 does have some bearing -- at that same time it also 

25 was one of the rare instances where in fact the 
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1 legislation allowed States to, if they so chose, ban 

2 standing pilots on pool heaters. If you go back to 

3 the original NAECA legislation, it did say the 

4 requirement was going to be thermal efficiency, but 

5 I would say it did recognize that they had a 

6 separate consideration for the pilot consumption of 

7 a pool heater, and essentially made an exception 

8 that would allow a State, if it so chose, to ban 

9 pilots on pool heaters in the State gas fire laws.

10 The other point I wanted to raise is 

11 percolating somewhere but -- at some point I believe 

12 there’s going to be regulations for heat pump pool 

13 heaters, and when we get to that point, I don’t 

14 think the measurement or heat from pool heaters, 

15 thermal efficiency. So I guess my point is both, I 

16 think we may be able to find some information in the 

17 legislative history that will answer that question, 

18 but I think Harvey’s point, things are also changing 

19 and so even if it said that back in 19-whatever it 

20 was-87, I guess we’re going to try to make a strong 

21 argument that you can come up with some other words.

22 MR. BROOKMAN: Thank you. Harvey Sachs.

23 MR. SACHS: Harvey Sachs. Completely 

24 independent of this process and its work, the 

25 Department has floated out a proposal to move 
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1 towards the use of source energy descriptors, in 

2 fact beyond that, to full fuel cycle. And we’re 

3 looking at our electrical energy in terms of site 

4 energy, and I guess I’m sort of asking if the 

5 Department is setting this up in a way that would 

6 allow easy conversion if the Department’s notice 

7 winds up getting traction.

8 MR. BROOKMAN: Mohammed Khan.

9 MR. KHAN: Mohammed Khan, DOE. With our 

10 energy conservation standards rulemakings, the 

11 Department is certainly taking an effort or making 

12 an effort to look at the two types of energy. I 

13 think to best answer your question at this point is 

14 that we may have to reevaluate this at that time. 

15 I’m not really sure exactly how much of an impact it 

16 would have, but it’s something we might have to look 

17 at.

18 MR. SACHS: Harvey Sachs, as sort of 

19 follow-up. This is really a smaller question that 

20 works towards the much larger question of the

21 differentiation in performance metrics for heat 

22 pumps relative to fossil-fuel equipment. That 

23 carries over not just to pool heaters, but to a 

24 variety of other equipment, including space heaters. 

25 So we have some work cut out for us. I assume you 
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1 all are starting to plan for that.

2 MR. BROOKMAN: Thank you. Yes.

3 MR. GAUTHIER: Phil Gauthier with AHRI. 

4 MR. BROOKMAN: Please use the microphone, 

5 and say your name again, Phil.

6 MR. GAUTHIER: Phil Gauthier with AHRI. 

7 The traditional energy efficiency descriptor for 

8 thermal efficiency is E-sub-T, even though the new 

9 descriptor for integrated thermal efficiency may 

10 morph into something else, it’s used in the formulas 

11 and in the slide here as TE-sub-I. Was that 

12 deliberate or an error?

13 MR. BROOKMAN: John.

14 MR. TALBOTT: I believe the old 

15 terminology of E-sub-T is used in the equations, and 

16 it means steady-state efficiency as previously -- in 

17 the test procedure. And then we, just for editorial 

18 choice, we used the TE-sub-I format to describe the 

19 more comprehensive annualized thermal efficiency. 

20 So, yes, we probably should have maybe extended it 

21 E-sub-TEI, might have been a better editorial 

22 choice.

23 MR. GAUTHIER: Just something to consider.

24 MR. TALBOTT: Yes.

25 MR. BROOKMAN: Thank you. Molly, yes.
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1 MS. TROMBLEY-McCANN: Molly Trombley2 McCann. I just wanted to follow on quickly to 

3 Frank’s comment. It is true that States do have the 

4 authority to ban standing pilots, and I know that 

5 because California did it. In California, standing 

6 pilots are illegal.

7 MR. BROOKMAN: So now is an opportunity 

8 for anybody that wishes to do so to make closing 

9 remarks, raise additional issues that are relevant 

10 to this subject and so we’ll hear from anybody else 

11 who has closing remarks.

12 I see none. Then do we have any questions 

13 coming in from our lines? Okay. Well, that worked 

14 perfectly. 

15 MR. STANONIK: Did we have any?

16 MS. LAM: Yes, we had 22 [participants, 

17 not questions].

18 MR. BROOKMAN: Evaluation form -- please 

19 take the 30 seconds to a minute it takes to fill it 

20 out. Then turn it back to Mohammed Khan for closing 

21 remarks. 

22 MS. LAM: (Comment off mic)

23 MR. BROOKMAN: Oh, you’re really good. 

24 Thank you. I think that’s helpful. Thank you. Who 

25 -- from a colleague in San Francisco. Okay. So 
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1 progress here. Technology that works. 

2 Next Steps and Closing

3 MR. KHAN: Well, as I said at the onset 

4 this morning, that we were making an effort to try 

5 to make these meetings more efficient, and looks 

6 like we’re concluding in just over an hour, so this 

7 might be a record for us. (Laughter)

8 This slide here provides some very 

9 important information, and again, as I said at the 

10 onset, your comments, your data, and concerns that 

11 you need to voice is very important for us to know 

12 about and to receive. So this is the method whereby 

13 you can submit such information and data. We have 

14 the postal and courier addresses, as well as the e15 mail addresses. And also what’s important too is so 

16 that it helps us to properly catalog the information 

17 as we receive it, to include the docket number and 

18 the RIN number for identification purposes.

19 And again, let me remind you that comment 

period closes on November 15th

21 And again, I’d like to say thank you very 

22 much for your participation. We got some very good 

23 comments, and I’m hoping that we receive some good 

24 data with respect to some of those comments. Again, 

25 thank you very much.

20 . 
Executive Court Reporters

(301) 565-0064

52

1 (Whereupon, at 10:12 a.m., the meeting in 

2 the above-captioned matter was adjourned.)