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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, 2010

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• 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 Introduction

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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. 

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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.

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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.

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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.

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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.

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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. 

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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 2002-03

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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. 

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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?

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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.

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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.

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Proposed Amendments for Vented Heater Test 

Procedure -continued

EAE = BOH*PE + ESO

where:

BOH = burner operating hours 

PE = active mode electrical wattage

ESO = ((PSB * (4160 - BOH)) + (POFF * 4600))

where:

PSB = vented heater standby mode power, in watts, 

4160 = average heating season hours per year

POFF = vented heater off mode power, in watts

4600 = average non-heating season hours per year

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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?

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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. 

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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?

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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. 

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Proposed Amendments for Pool Heaters -

continued

• New Efficiency Descriptor

Integrated Thermal Efficiency (TEI ), 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), 

TEI = 100(EOUT/EIN)

where:

EOUT = Seasonal output of heated water as defined in 5.4.1 of this 

appendix 

EIN = Total annual input including fossil fuel and electricity (in equivalent 

Btu units) Ein would include active mode, standby mode, and off 

mode energy consumption

100 = conversion factor, from fraction to percent

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Proposed Amendments for Pool Heaters -

continued

• EIN = EF + EAE (Total Annual Fuel Consumption + Total Annual Electric 

Consumption) 

• EF = BOH*QIN + (POH–BOH)QPR + (8760 – POH) QOFF,R

• EAE = EAE,active + EAE,standby,off 

• (2) EAE,active = BOH * PE 

• (3) EAE,standby,off = (POH – BOH) Es,aux + (8760 – POH) Eoff,aux

• where: 

• QPR = fossil fuel energy consumption rate in standby mode

• QOFF,R = fossil fuel energy consumption rate in off mode

• EAE,active = auxiliary electrical consumption in the active mode 

• EAE,standby,off = auxiliary electrical consumption in the standby and off mode

• PE = Electrical power (Active)

• POH = Pool operating hours

• BOH = Burner operating hours 

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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?

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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 standards

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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

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