Building Technologies Program eere.energy.gov 1 BUILDING TECHNOLOGIES PROGRAM

Test Procedures for Residential Water Heaters,

Direct Heating Equipment, and Pool Heaters Incorporation of Provisions for Addressing Energy Use in Standby Mode and Off Mode Notice of Proposed Rulemaking (NOPR) Public Meeting Mohammed Khan Department of Energy Energy Efficiency & Renewable Energy EISA- Heat- Equip -2010 -TP - 0013@ee.doe.gov September 24, 2010Building Technologies Program eere.energy.gov 2 

### • 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; state your name for the record)

– Set cell phones to silent/vibrate 

### • Housekeeping Items 

## Welcome and IntroductionBuilding Technologies Program eere.energy.gov 3 

## Agenda **9:00 -**  **9:05 am Welcome**  U.S. Department of Energy **9:05 -**  **9:15 am Opening Remarks, Introduction and Agenda**  **Review** Doug Brookman **9:15 -**  **9:25 am Rulemaking Overview (slide 5)** Mohammed Khan This is an overview of the purposes of the public meeting and the statutory authority and requirements DOE has for addressing the EISA 2007 requirements. **9:25 -**  **10:00 am Brief Opening Remarks from Interested Parties (as applicable) (slide6)**  Doug Brookman Interested parties are invited to make brief summary comments regarding the NOPR content proposed test procedures.Building Technologies Program eere.energy.gov 4 

## Agenda (Continued) 10:00 – 10:15 am Rulemaking Steps, Rulemaking History, and Discussion of Proposed Amendments (slides 7 - 10) Mohammed Khan Summary presentation of rulemaking steps, history, and discussion regarding the approach used and factors considered for the determination of scope and test procedure revisions. 10:15 – 11:30 am Discussion of Proposed Amendments (slides 11 - 20) John Talbott Summary of proposed amendments and technical details of the key assumptions and positions taken.

. **11:30 –**  **11:45 pm Final Comments from Interested Parties**  11:45 - 12:00noon Next Steps and Closing (slide 21) Mohammed Khan Adjournment of the public meeting.Building Technologies Program eere.energy.gov 5 

## Purpose of the Public Meeting

• Present the Department’s proposed test procedure amendments.
• Seek comment from participants on the proposed test procedure amendments.
• Discuss specific issues or questions related to the proposed amendments.

• Describe the next steps.Building Technologies Program eere.energy.gov 6 

## Opening Remarks and Comments from Interested Parties

• Opening Remarks

– At this time, DOE welcomes opening remarks from interested parties on the NOPR for Residential Water Heaters, Direct Heating Equipment, and Pool Heaters . • Comments from Participants

– Participants are invited to provide summary comments or statements;

– Participants are invited to raise additional issues for discussion today; and

– Participants are invited to submit comments during the NOPR comment period, which is open through November 15, 2010.Building Technologies Program eere.energy.gov 7 

## Steps in Test Procedure Rulemaking

• NOPR issued by DOE on August 30, 2010 • NOPR Public Meeting today, September 24, 2010 • Comments on NOPR from interested parties

– Transcript of oral comments from today’s public meeting.

– Written comments (comment period closes 75 days after publication in the Federal Register November 15, 2010). • DOE reviews and considers all comments. • Final Rule Publication.

– Final Rule will be issued as soon as possible after the close of the comment period.Building Technologies Program eere.energy.gov 8 

## Regulatory History

• Test Procedures : DOE’s current test procedures for the subject products are found at 10 CFR part 430, subpart B, appendix E, for residential water heaters, appendix G for unvented direct heating equipment, appendix O for vented direct heating equipment, and, appendix P for pool heaters. These procedures include energy efficiency, energy use descriptors, (e.g. annual fuel utilization efficiency (AFUE) for vented heaters), annual fuel and electric energy consumption and annual operating cost. • Energy Conservation Standards : DOE has amended the standards for these products in its recent Final Rule published April 16, 2010. NOTE: This final rule does not stipulate requirements for standby and off mode energy use.Building Technologies Program eere.energy.gov 9 

## Regulatory History - continued

– Energy Independence and Security Act of 2007 (EISA 2007) Directs DOE to incorporate a measure of standby- and off - mode energy consumption into its test procedures.

– EISA 2007 also directs DOE to integrate such energy consumption into the energy efficiency, energy consumption, or other energy descriptor unless the Secretary determines that current test procedures already fully account and incorporate the standby and off mode energy consumption or such an integrated test procedure is technically infeasible.

– DOE must consider the most current versions of IEC Standards 62301 and 62087. IEC Standard 62301, Household electrical appliances–Measurement of standby power, First Edition 2005- 06, and IEC Standard 62087, Methods of measurement for the power consumption of audio, video and related equipment, First Edition 2002- 03Building Technologies Program eere.energy.gov 10 

## EISA Review of Amendments Needed to Existing Test Procedures

• Current test procedures for water heaters already fully account for and incorporate measurement of standby mode energy consumption, as required by EISA 2007. Off mode of operation does not apply. Therefore, no amendments are needed.
• Current test procedure for vented heaters would require additional measurement and calculation provisions in order to account for electrical standby mode and off mode energy use. Fossil-fuel standby mode and off mode energy use are already integrated into the vented heater test procedure.
• Current test procedure for unvented heaters would require additional measurement provisions to account for electric and fossil -fuel standby mode and off mode energy use. Additional calculations provisions are deemed not needed.
• Current test procedures for pool heaters would require additional measurement and calculation provisions to account for both electric and fossil -fuel energy consumption in standby mode and off mode.Building Technologies Program eere.energy.gov 11 

## Proposed Amendments for Vented Heater Test Procedure - continued DOE Seeks Comments on Proposed Amendments
• The appropriateness of DOE’s conclusion to not amend the test procedures for water heaters?Building Technologies Program eere.energy.gov 12 Proposed Amendments for Vented Heater Test Procedure (Discussion item III B)

• With some clarification, the EISA 2007 concepts and definitions are applicable and workable within the existing vented heater test procedure.
• In the existing test procedure, fossil -fuel energy consumption is accounted for over a full -year cycle, thereby satisfying EISA 2007 requirements for inclusion of fossil -fuel standby mode and off mode energy consumption.
• Provisions are added to measure standby mode and off mode wattages utilizing the IEC 62301standard with clarifications.Building Technologies Program eere.energy.gov 13 Proposed Amendments for Vented Heater Test Procedure - continued

• A key clarification in the proposed added measurement section is that the existing test procedure specifications for ambient temperature and voltage shall apply in lieu of the IEC 62301 standard’s provisions for these parameters.
• Energy consumption equations would be expanded to include standby mode and off mode electrical energy consumption.

• Integrated AFUE for Vented Heaters determined not feasible.Building Technologies Program eere.energy.gov 14 Proposed Amendments for Vented Heater Test Procedure - continued 

### E AE 

### = BOH*PE + E SO 

### where: BOH = burner operating hours PE = active mode electrical wattage E SO 

### = ((P SB 

### * (4160 - BOH)) + (P OFF 

### * 4600)) where: P SB 

### = vented heater standby mode power, in watts, 4160 = average heating season hours per year P OFF 

### = vented heater off mode power, in watts 4600 = average non - heating season hours per yearBuilding Technologies Program eere.energy.gov 15 

## Proposed Amendments for Vented Heater Test Procedure - continued DOE Seeks Comments on Proposed Amendments
• Is DOE’s conclusion accurate regarding the technical infeasibility of integrating standby and off mode energy consumption into the current metric, AFUE?
• Are the proposed amendments sufficient?Building Technologies Program eere.energy.gov 16 Proposed Amendments for Unvented Heaters (Discussion Item III.C)

• Proposal would add measurement provisions for both pilot light and electrical consumption in standby mode and off mode.
• Both of these added provisions would allow for exemption from measurement if there is means to disconnect the power source when not in use and instructions to do so are clearly visible.
• Annual accounting is not proposed considering the difficulty in defining a representative use cycle for this product sub - class.Building Technologies Program eere.energy.gov 17 

## Proposed Amendments for Unvented Heater Test Procedure DOE Seeks Comments on Proposed Amendments
• Are there issues or concerns with the tentative decision not to define a representative use cycle?
• Are the proposed amendments sufficient?Building Technologies Program eere.energy.gov 18 Proposed Amendments for Pool Heaters (Discussion item III.D)

• Definition section would be added to the test procedure to clarify the EISA 2007 definitions of “active mode,” “standby mode,” and “off mode,” as applied to pool heaters.
• Separate measurement and calculation provisions would be added to allow separate quantification of standby mode and off mode energy consumption. These added provisions would apply to both electrical and fossil fuel energy consumption.
• The NOPR would adopt a similar approach as outlined in ASHRAE Standard 146 to measure stand - by mode and off mode energy consumption.
• The measure of electrical standby mode and off mode wattages would utilize the IEC 62301 standard with clarifications. A key clarification would be that the existing test procedure specifications for ambient temperature and voltage shall apply in lieu of the IEC 62301 standard’s provisions for these parameters.Building Technologies Program eere.energy.gov 19 Proposed Amendments for Pool Heaters - continued

• New Efficiency Descriptor Integrated Thermal Efficiency (TE I ), is proposed to allow for integration of standby mode and off mode energy consumption into a single efficiency measure. The term integrated thermal efficiency is used to maintain consistency with the statute. This approach would allow for the integration called for in 42 U.S.C. 6295(gg)(2)(A), TE I = 100(E OUT/E IN ) where: E OUT = Seasonal output of heated water as defined in 5.4.1 of this appendix E IN = Total annual input including fossil fuel and electricity (in equivalent Btu units) E in would include active mode, standby mode, and off mode energy consumption 100 = conversion factor, from fraction to percentBuilding Technologies Program eere.energy.gov 20 Proposed Amendments for Pool Heaters - continued

• E IN = E F + E AE (Total Annual Fuel Consumption + Total Annual Electric Consumption)
• E F = BOH*Q IN + (POH – BOH)Q PR + (8760 – POH) Q OFF,R • E AE = E AE,active + E AE,standby,off • (2) E AE,active = BOH * PE • (3) E AE,standby,off = (POH – BOH) E s,aux + (8760 – POH) E off,aux • where: • Q PR = fossil fuel energy consumption rate in standby mode • Q OFF,R = fossil fuel energy consumption rate in off mode • E AE,active = auxiliary electrical consumption in the active mode • E AE,standby,off = auxiliary electrical consumption in the standby and off mode • PE = Electrical power (Active) • POH = Pool operating hours • BOH = Burner operating hoursBuilding Technologies Program eere.energy.gov 21 

## Proposed Amendments for Pool Heater Test Procedure DOE Seeks Comments on Proposed Amendments
•Are the proposed amendments sufficient?
•Are there problems or concerns with the update of Z21.56 standard?
•Are there problems or concerns with the integrated thermal efficiency metric?Building Technologies Program eere.energy.gov 22 

## Closing Remarks and Comments At this time, DOE welcomes any additional remarks or questions from interested parties on the NOPR including the following:

– Clarifying edits

– Use of the IEC 62301 standard

– The proposed energy accounting

– How to address standby mode and off mode energy use in energy conservation standardsBuilding Technologies Program eere.energy.gov 23 

## How to Submit Written Comments

• In all correspondence, please refer to the Residential Water Heater, rulemaking by:

– Residential Water Heater, Direct Heating Equipment, and Pool Heater Rulemaking,

– Docket Number EERE–2009–BT–TP–0013 , and

– Regulatory Identification Number (RIN) 1904 -AB95
• Email : EISA-Heat-Equip - 2010- TP- 0013@ee.doe.gov

• Comment period closes: November 15, 2010 Postal : Courier : Ms. Brenda Edwards U.S. Department of Energy Building Technologies Program, Mailstop EE -2J 1000 Independence Avenue, SW Washington, DC 20585 -0121 Ms. Brenda Edwards U.S. Department of Energy Building Technologies Program, 6th Floor 950 L’Enfant Plaza, SW Washington, DC 20024 Tel: 202 586-2945