1

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### U.S. Department of Energy 1

2

3

4 

### Energy Conservation Test Procedures for 5 

### Residential Furnaces 6

7

8

9 

### 1:03 to 3:51 p.m. 10 

### Thursday, March 26, 2015 11

12 

### 1000 Independence Avenue, S.W. 13 

### Room 8E-089 14 

### Washington, D.C. 20585 15

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### CONTENTS 1


### PAGE 2 

### ASHLEY ARMSTRONG, Welcoming Comments 3 3 

### VICTOR FRANCO, Proposed Updates 22 4 

### ROSS DILLON, Proposed Updates 97 5

6

7

8

9

10

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

### MR. BROOKMAN: Let's start. Good 2 

### afternoon, everyone, and welcome. This is the 3 

### Test Procedure Notice of Proposed Rulemaking for 4 

### Furnaces and Boilers. Today is March 26th, 2015, 5 

### here in the Forestal Building in Washington, D.C. 6 

### Good to see you here this afternoon. My name is 7 

### Doug Brookman, Public Solutions, Baltimore. 8 

### We're going to start with welcoming remarks from 9 

### Ashley Armstrong. 10 

### MS. ARMSTRONG: Hi, everyone. I'd just 11 

### like to welcome you to the Department to talk 12 

### about the proposed test methods for furnaces and 13 

### boilers. Obviously, we welcome everyone today to 14 

### not only hear an overview of our proposed method, 15 

### but really we're here for a dialog. So we hope 16 

### that you ask questions, give us comments, give us 17 

### feedback on our proposal, as we really value your 18 

### feedback. So thank you for taking the time to 19



### come. 20 

### MR. BROOKMAN: And we always start with 21 

### introductions. Beginning to my immediate left 224

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### and looking over there toward Frank Stanonik. 1 

### MR. STANONIK: Frank Stanonik, AHRI. 2 

### MR. BROOKMAN: Thank you. 3 

### And your microphone is on. And if you 4 

### can get used to turning it on and off. 5 

### And you're next, sir. 6 

### MR. KLEISS: Jeff Kleiss, Lochinvar. 7 

### MR. BROOKMAN: Thank you. 8 

### MS. JENSEN: Elizabeth Jensen, Department 9 

### of Justice. 10 

### MS. JAKOBS: Diane Jakobs, Rheem. 11 

### MR. KREBS: Mark Krebs, the Laclede Group. 12 

### MR. BROOKMAN: Thank you. 13 

### MR. WINNINGHAM: Dave Winningham, Allied 14 

### Air. 15 

### MR. VERSHAW: Jim VerShaw, Ingersoll 16 

### Rand. 17 

### MR. MATA: Ramiro Mata, CSA Group. 18 

### MS. COCHRANE: Rosalyn Cochrane, Natural 19 

### Resources, Canada. 20 

### MR. BROOKMAN: Thank you. 21 

### MR. HUNT: Marshall Hunt, Pacific Gas and 225

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### Electric Company. 1 

### MR. STAS: Eric Stas, DOE General 2 

### Counsel's Office. 3 

### MS. ARMSTRONG: Ashley Armstrong, DOE. 4 

### MR. BROOKMAN: Please, Greg. 5 

### MR. ROSENQUIST: Greg Rosenquist, 6 

### Lawrence Berkeley National Laboratory. 7 

### THE COURT REPORTER: Do you have a 8 

### microphone? 9 

### MR. BROOKMAN: No, it's okay. We'll just 10



### -- 11 

### THE COURT REPORTER: Fill it in. 12


### MR. BROOKMAN: Yes. 13 

### MR. FRANCO: Victor Franco, Lawrence 14 

### Berkeley National Laboratory. 15 

### MR. DILLON: Ross Dillon, Lawrence 16 

### Berkeley National Laboratory. 17 

### MR. DARLINGTON: Adam Darlington, 18 

### Navigant Consulting. 19 

### MS. RIVEST: Catherine Rivest, Navigant 20 

### Consulting. 21 

### MR. McCABE: Michael McCabe, representing 226

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### myself. 1 

### MR. YILMAZ: Ayk Yilmaz, AHRI. 2 

### MS. MEDEPALLI: Sarah Medepalli, ICF 3 

### International, on behalf of EPA ENERGY STAR. 4 

### MR. McCRUDDEN: Charlie McCrudden, Air 5 

### Conditioning Contractors of America. 6 

### MR. WHITE: Charles White with the 7 

### Plumbing Heating Cooling Contractors National 8 

### Association. 9 

### MR. LIN: Paul Lin with the Regal Beloit 10 

### Corporation. 11 

### MR. BROOKMAN: Okay. Thank you. Thanks 12 

### to all of you. Did everyone get a chance to 13 

### introduce him or herself? I guess so. Okay. 14 

### All of you, hopefully, received a packet 15 

### of information. This packet of information has 16 

### the content that we hope to go through in 17 

### considerable detail this afternoon. On page 1 of 18 

### the packet is the agenda. Immediately following 19 

### this overview, there's an opportunity for 20 

### individuals that wish to make opening remarks -- 21 

### we hope brief summary remarks about key issues, 227

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### from your perspective. 1 

### Moving from there, we'll have 2 

### presentation and the opportunity for comment. 3 

### We're going to hear about regulatory history and 4 

### the rulemaking overview. Moving on from there, 5 

### the proposed DOE test procedure changes related 6 

### to ASHRAE 103. We'll take a break mid-afternoon 7 

### round about 2:30 or so. 8 

### Returning from the break, other proposed 9 

### test procedure changes. And then at the end of 10 

### the day, whenever we get there, another 11 

### opportunity for remarks, closing comments, 12 

### summary statements, things you don't think have 13 

### been covered sufficiently during the course of 14 

### this meeting. That's the general plan for today. 15 

### Questions and comments about the agenda? 16 

### (No audible response.) 17 

### MR. BROOKMAN: I'd ask for your 18 

### consideration. Please speak one at a time. And 19 

### if you'd say your name each time you speak, as 20 

### you get used to turning the microphone on and 21 

### off, please say your name so that we have a 228

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### complete record of this meeting. There will be a 1 

### transcript made available to all. 2 

### If you could limit sidebar conversations 3 

### and turn your cell phones on mute, that would be 4 

### helpful. And we welcome everyone joining us via 5 

### the Web. How many folks via the Web, about? 6 

### EMILY: Twenty-five. 7 

### MR. BROOKMAN: Twenty-five via the Web. 8 

### That's a lot of saved airfare. 9 

### (Laughter.) 10 

### MR. BROOKMAN: That's wonderful. The 11 

### Department of Energy is trying hard to make sure 12 

### that these meetings are totally accessible to all 13 

### via the Web. If all of you joining via the Web 14 

### could keep your telephones on mute, and if you 15 

### raise your hand via the software provided, we can 16 

### un-mute you and we ought to be able to hear you 17 

### in the room, so you can participate in this 18 

### conversation along with everyone else. 19 

### And finally, one more thing. The 20 

### Department of Energy encourages all, in addition 21 

### to your responses, your comments here today, to 229

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### submit written comments. And I'm saying that 1 

### specifically because that applies to those 2 

### joining us via the Web as well. Please make 3 

### certain, if you're joining us via the Web, that 4 

### you submit your comments. And Ashley Armstrong 5 

### will be describing how that gets done as we 6 

### proceed. 7 

### So now we're going to go to the next 8 

### slides, the purpose of public meetings. 9 

### MS. ARMSTRONG: I'm just going to skip 10 

### some, because you kind of already said them. 11 

### The purpose of the public meetings 12 

### generally is for us to describe our proposed 13 

### methods, at least at a high-level overview. But 14 

### really, we're looking for your feedback, both 15 

### questions and comments. Whether there are 16 

### ambiguities or you have certain concerns, please 17 

### feel free to speak up during any part of the 18 

### presentation today. 19 

### You will notice that there are certain 20 

### comment boxes throughout today's presentation, 21 

### where we specifically are seeking your comment on 2210

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### certain issues, as we have teed them up 1 

### throughout the presentation, as well as we have 2 

### teed them up in the notice itself. But 3 

### obviously, your comments are welcome on any part 4 

### of the proposal, as well as any part during the 5 

### day of the presentation. They're not limited to 6 

### those here. 7 

### So at this time, I'm going to turn it 8 

### back to you in case anybody wants to make opening 9 

### remarks. You're welcome to do so at this time. 10 

### MR. BROOKMAN: Remarks here at the 11


### outset? 12 

### (No audible response.) 13 

### MR. BROOKMAN: No? No comments here at 14 

### the outset? 15 

### (No audible response.) 16 

### MR. BROOKMAN: Okay. Then we're going to 17 

### go straight into the content in the packet. 18 

### MS. ARMSTRONG: All right. Moving right 19 

### along. So, just a brief overview of history, 20 

### kind of how we got there. The statute authorizes 21 

### or created the program, the Energy Standards 2211

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### Program, as well as the Test Procedure Program, 1 

### and it includes furnaces and boilers. It directs 2 

### DOE to not only establish, but to consider 3 

### revisions and updates to its test procedures over 4 

### a certain period of time. 5 

### EISA 2007 was amended, directed DOE to 6 

### incorporate standby and off mode. And we did 7 

### develop a test procedure that did just that back 8 

### in September of 2009. So this just gives a 9 

### little bit of overview of the history of how we 10 

### got here. 11 

### In 1997, DOE established a final rule 12 

### that adapted generally ASHRAE Standard 103-1993 13 

### as the test procedure for furnaces and boilers. 14 

### Over the years, DOE has made subsequent 15 

### amendments, you can see them on the slides, 16 

### through different final rules, some being for 17 

### standby and off, others being clarifications of 18 

### certain methods that were in the Department's 19 

### test procedure. 20 

### We officially kicked this rulemaking off 21 

### with a request for information back in January 2212

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### 2013. Many of the proposals you're going to see 1 

### and hear about today are in response to some of 2 

### the comments that we got and the key issues that 3 

### were raised by stakeholders in response to that 4 

### request for information. 5 

### And then, I just want to note that DOE is 6 

### conducting this rulemaking to satisfy its 7 

### requirements under the seven-year look-back that 8 

### requires DOE to revise -- review and potentially 9 

### revise its test procedures once every seven 10 

### years. So that will satisfy this provision. 11 

### So with that, some key dates you might be 12 

### wondering about. Right now, we're at the 13 

### proposed rule stage. As I noted, we kicked the 14 

### rule off with a request for information. Today 15 

### is the public meeting, and the comment period 16 

### closes on May 26th. We do expect to issue a 17 

### final rule sometime later this year, probably 18 

### towards the end of this year. Consider it a 19 

### holiday present for you guys. And we look 20 

### forward to getting your comments toward the end 21 

### of May. So, yep. 2213

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### MR. BROOKMAN: Frank Stanonik. 1 

### MR. STANONIK: Frank Stanonik, AHRI. 2 

### All right. Two questions and, well, one 3 

### specifically related to this last side. But let 4 

### me first ask. Okay, so the amendments that were 5 

### in July 2013, I just want to confirm this. 6 

### Obviously, all of that was not something that was 7 

### in ASHRAE 103. So it is, those amendments are 8 

### being repeated in the NOPR here, right? 9


### MS. ARMSTRONG: Correct. 10 

### MR. STANONIK: I just wanted to confirm. 11 

### Okay. 12 

### And then the other question, on the 13 

### schedule here, again, maybe asking an obvious 14 

### question. But so, with this schedule, having the 15 

### final rule finished by the end of the year, this 16 

### would clearly indicate that it is DOE's intent 17 

### that this revised test procedure will be used for 18 

### both the ongoing residential furnace and 19 

### residential boiler rulemakings, correct? 20 

### MS. ARMSTRONG: That is correct. Thank 21


### you. 2214

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### MR. BROOKMAN: Yes, please, Jim. 1 

### MR. VERSHAW: Jim VerShaw, Ingersoll 2 

### Rand. 3 

### It looks like the rest of the program can 4 

### be pretty technical. So I want to ask about 5 

### regulatory burden. And did you consider the 6 

### regulatory burden issues that this will bring in? 7 

### If you're bringing in a change to the AFUE test 8 

### procedure that goes into effect the middle of 9 

### 2016, right on top of that time we're trying to 10 

### redesign and do testing for FER [fan efficiency 11 

### rating] right on top of doing all of the 12 

### commercial air conditioning and all of the other 13 

### things. 14 

### It just seems like one thing right after 15 

### another, and this is just one more thing that 16 

### we're going to have to retest all of our products 17 

### for. 18 

### MS. ARMSTRONG: So I think we can talk 19 

### about that today. I think that's something we'd 20 

### like your feedback on in terms of, are you going 21 

### to need to retest all your products? Are you 2215

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### testing to ASHRAE 103-1993 now? Are you testing 1 

### towards to the new version? 2 

### MR. VERSHAW: Well, we're testing to the 3 

### CFR [Code of Federal Regulations], whatever the 4 

### numbers are. 5 

### MS. ARMSTRONG: You've been trained. 6 

### (Laughter.) 7 

### MS. ARMSTRONG: That's the right 8 

### response, Jim. 9 

### (Laughter.) 10 

### MS. ARMSTRONG: I think DOE has gotten 11 

### some feedback that some people have moved to 12 

### ASHRAE [standard]. That's not, you know -- and 13 

### we were strongly urged to consider moving to the 14 

### new ASHRAE to keep up with industry, for a 15 

### variety of different reasons. 16 

### So, obviously, we would look for your 17 

### feedback on that. If there are certain aspects 18 

### that you believe -- you know -- 19 

### MR. VERSHAW: Well, just let me say one 20 

### thing. If we're going to change the rounding 21 

### rules from a whole number to a tenth, and we have 2216

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### to have statistically -- data that statistically 1 

### gives us the rating point rounded to the nearest 2 

### tenth, I probably don't have numbers in the files 3 

### that when I test the new procedure will give me 4 

### exactly that number. 5 

### MS. ARMSTRONG: Okay. 6 

### MR. VERSHAW: So therefore, it seems it 7 

### behooves us, we'd have to retest everything. 8 

### MS. ARMSTRONG: Okay. So I think that's 9 

### great feedback. 10 

### MR. VERSHAW: Yeah. Okay. 11 

### MR. BROOKMAN: And, Jim, would you go 12 

### further now, or maybe in your written comments, 13 

### about suggesting what DOE might do about this 14 

### condition the industry is in? 15 

### MR. VERSHAW: Well, if I had my -- if I 16 

### was in charge, I would make this effective with 17 

### the next change to the AFUE for furnaces. 18 

### MR. BROOKMAN: Okay. 19 

### MS. ARMSTRONG: So the one that's -- so 20 

### concurrent with -- 21 

### MR. VERSHAW: The one that we're going to 2217

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### talk about tomorrow. 1 

### MS. ARMSTRONG: Okay. That clarifies. 2 

### Thank you. Okay. 3 

### MR. BROOKMAN: Thanks, Jim. 4 

### And, Diane, you wish to comment here? 5 

### MS. JAKOBS: Well, so this is Diane 6 

### Jakobs from Rheem. 7 

### And we were just talking about, I think 8 

### that -- 9 

### MR. BROOKMAN: Is your microphone on? 10 

### MS. JAKOBS: The light is on. 11 

### MR. BROOKMAN: Great. Okay. Thank you. 12 

### MS. JAKOBS: Okay. We were just talking 13 

### about whether we would -- are we required to 14 

### test? Because there was a line in the NOPR about 15 

### that they thought it -- you know, that you 16 

### thought it would only change the AFUE slightly, 17 

### but it wouldn't be on products that were minimum 18 

### efficiency. 19 

### So, I specifically looked at the timing 20 

### for collecting condensate, and on one sample, we 21 

### lost 0.5 percent AFUE. So, you know, that's kind 2218

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### of within the realm of manufacturing tolerances. 1 

### Is that your expectation that we would test 2 

### everything? It's kind of -- I mean, if we could 3 

### do AEDM's [alternative efficiency determination 4 

### methods], we could come up with some good numbers 5 

### that we could be verified against. And it would 6 

### be -- you know, there wouldn't be a problem. But 7 

### are we, you know, required to have specific test 8 

### data with specific calculations, you know, that 9 

### are in the current test procedure? Thank you. 10 

### MS. ARMSTRONG: So, I'm going to table 11 

### the question and get back to it this afternoon 12 

### after I hear the discussion about, you know, the 13 

### proposed impacts and potentially some of the 14 

### feedback we might get on what the proposed 15 

### changes may or may not do to your products. 16 

### As we presented in the NOPR, we did test 17 

### a subset of products to kind of get to our 18 

### answers. And generally speaking, we found that 19 

### we believe the current readings would more or 20 

### less be substantiated, and it would not affect 21 

### compliance with standards. 2219

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### Now, that being said, we are here today 1 

### to talk about that. So as we go through the 2 

### proposals, let me listen to the feedback. And 3 

### then let me tee up your question towards the end 4 

### of the day. And please ping me if we haven't 5 

### gotten there by the end of the day. Okay? 6 

### MR. BROOKMAN: Thank you. 7 

### So, some productive conversation already. 8 

### Yes, Diane, please. 9 

### MS. JAKOBS: I have just one other issue, 10 

### and I was telling Doug that my company uses a 11 

### program that was developed by NIST [the National 12 

### Institute of Standards and Technology]. And I've 13 

### been on the ASHRAE 103 committee for 15 years, I 14 

### think. And I don't think there's a program 15 

### available for these updates. And I've been 16 

### through ASHRAE 103, and it's very complicated. 17 

### And the NIST one is written in Fortran, and only 18 

### old people like me know, you know, are familiar 19 

### with programming in Fortran. 20 

### (Laughter.) 21 

### MS. JAKOBS: So it's kind of -- it's an 2220

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### old, old program. So, I'm a little bit 1 

### concerned. My first concern would be anyone 2 

### checking our equipment, would they be using the 3 

### same program? And then, the level playing field 4 

### that all my -- you know, all my competitors would 5 

### also be making the same assumptions and have the 6 

### same program? 7 

### And things that seem completely obvious 8 

### to me, when I go to an ASHRAE meeting people 9 

### disagree with me. So, my feeling is that people 10 

### will interpret the equations in the standard 11 

### maybe differently when they programmed them. So 12 

### that's a concern, that there's no program that 13 

### reflects these changes. 14 

### MR. BROOKMAN: Okay. Thank you, Diane. 15 

### Yes, Mark. 16 

### MR. KREBS: My main concern and reason 17 

### for coming here is pretty similar to that of 18 

### several manufacturers, some of whom have already 19 

### spoken up, regarding what seems to me to be, you 20 

### know, a big rush in the fact that we have this 21 

### test procedure going forward at the same time as 2221

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### the NOPR for the furnaces [standard]. 1 

### And at the bottom of page 11 of the pre2 

### Federal Register publication, it says, "DOE has 3 

### tentatively determined that the proposed test 4 

### procedure amendments would have a de minimis 5 

### impact on the product's measured efficiency." 6 

### You know, and I would like to see how -- 7 

### I would like to see how that tentative 8 

### determination has been made, because frankly, 9 

### you're just asking us to trust you, is what it 10 

### comes down to. Thank you. 11 

### MR. BROOKMAN: Okay. Thank you. 12 

### So, these amount to additions to our 13 

### opening statements, opening remarks. 14 

### (Laughter.) 15 

### MR. BROOKMAN: Which is good. Which is 16 

### what we were hoping to achieve with that. 17 

### Additional opening remarks as we then 18 

### move on to proceed with the content here in the 19 

### packet? 20 

### (No audible response.) 21 

### MR. BROOKMAN: Okay. Are we set? Okay. 2222

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### Victor Franco is going to proceed. And 1 

### we are on about slide 15 now. By the way, I like 2 

### this slide. 3 

### (Laughter.) 4 

### MR. BROOKMAN: A summary slide here right 5 

### at the outset. And I also want to say, having 6 

### reviewed many of these packets over the years, I 7 

### think the graphics in this packet are especially 8 

### good. 9 

### MR. FRANCO: Good afternoon. My name is 10 

### Victor Franco. I'm from Lawrence Berkeley 11 

### National Laboratory. And next we will be talking 12 

### about the proposed updates to the Federal furnace 13 

### and boiler test procedure. 14 

### Here in this slide, there's a summary of 15 

### the proposed updates. We're proposing to update 16 

### the industry references to the latest version of 17 

### ASHRAE Standard 103-2007. Also proposing to do a 18 

### measurement of condensate under steady-state 19 

### conditions. The electricity consumption of 20 

### additional components is being considered, as 21 

### well. 2223

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### Doing the smoke stick test for verifying 1 

### the flow through the heat exchanger, as well as 2 

### the duct work for units that are installed 3 

### without return ducts. Also, there are additional 4 

### testing requirements for the multi-position 5 

### configurations, and there is a proposal for the 6 

### verification test for automatic means of 7 

### adjusting for water temperature in boilers. 8 

### The next few slides will be explaining in 9 

### more detail these proposed changes. We will 10 

### start the -- this gets a little bit more 11 

### technical. We will start first with the updating 12 

### the industry references to the latest ASHRAE 13 

### [Standard 103-] 2007. There's a few slides here 14 

### that will be technical, so please stop me if you 15 

### have any questions at any time. 16 

### This slide, the current Federal test 17 

### procedure, incorporates by reference ASHRAE 103- 18 

### 1993. In June 2007, ASHRAE published ASHRAE 19 

### Standard 103-2007. DOE is currently proposing to 20 

### update all references in the Federal test 21 

### procedure from ASHRAE 103-1993 to ASHRAE 103- 2224

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### 2007, with some modifications. This will result 1 

### in the proposed test procedure adopting three 2 

### main changes from the ASHRAE 2007, as follows: 3 

### First, those would be a change in 4 

### determining the AFUE [annual fuel utilization 5 

### efficiency] for two-stage modulating products, 6 

### which will require the recalculation of AFUE 7 

### values for all two-stage and modulating products, 8 

### including adding some new testing requirements 9 

### for two-stage and modulating condensing products. 10 

### At the same time, there will also be a reduced 11 

### test burden for two-stage products which have a 12 

### calculated balance point temperature less than or 13 

### equal to 5 degrees. 14 

### Second, there is an update to, in ASHRAE 15 

### 103-2007, that will allow the calculation of off16 

### period flue losses for products with post-purge 17 

### times greater than three minutes. 18 

### Third, it will update the burner 19 

### operating hours calculations, the annual fuel 20 

### energy consumption, and annual electricity 21 

### consumption calculations. This will also require 2225

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### the recalculation of these values for all 1 

### equipment that's currently being reported by 2 

### manufacturers. 3 

### The next few slides will expand on these 4 

### three main modifications. So, please hold your 5 

### questions for the next few slides. 6 

### This slide is meant to give you a 7 

### background about the changes in the determination 8 

### of AFUE for two-stage and modulating products. 9 

### In 2002, a NIST study reported issues on the 10 

### proposed changes to the way AFUE was calculated 11 

### in ASHRAE 103-1993. The main issue was that 12 

### there was a significant discrepancy between the 13 

### AFUE of some two-stage and modulating models and 14 

### the AFUE of those same models calculated as a 15 

### single-stage unit at reduced fire. 16 

### This difference was sometimes found to be 17 

### as much as 1 percent or greater. Since most two18 

### stage and modulating models are operating almost 19 

### all the time at the reduced operating mode, the 20 

### AFUE values should be very close. The NIST study 21 

### found that the main cause of this was how the on 2226

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### and off times cycle values for two-stage and 1 

### modulating units are determined in ASHRAE 103- 2 

### 1993. 3 

### The fixed values of 10 minutes for 4 

### furnaces and 15 minutes for boilers shown in the 5 

### table are determined based on the operating at an 6 

### average of 50 percent of the rated capacity, as 7 

### well as other assumptions. Yet most two-stage 8 

### and modulating furnaces and boilers operate at 9 

### different conditions than these. 10 

### NIST’s proposed solution was to add a 11 

### calculation method for determining the on- and 12 

### off-times for each two-stage and modulating model 13 

### tested. In ASHRAE 103-2007, they adopted the 14 

### proposed changes from the 2007 NIST report, with 15 

### some additional modifications, which I will be 16 

### describing in more detail in the next slide. 17 

### This slide presents a summary of all the 18 

### ASHRAE 103-2007 calculation and testing changes 19 

### related to the AFUE determination for two-stage 20 

### and modulating products. As stated in the 21 

### previous slide, the main changes to the 2227

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### calculation was to add a calculation method for 1 

### on- and off-times, t-on and t-off, compared to 2 

### using fixed values in the ASHRAE 103-1993. More 3 

### details about this change will be presented in 4 

### the next slide. 5 

### In addition to this, ASHRAE 103-2007 did 6 

### a number of other changes to the calculation 7 

### method, including requiring all calculation at 8 

### the reduced fire if the balance point temperature 9 

### is less than or equal to 5 degrees Fahrenheit, 10 

### replacing the design heating requirement, DHR 11 

### [Design Heating Requirements], lookup table with 12 

### equation of the output capacity of the maximum 13 

### operating mode divided by one-plus-alpha, which 14 

### is the oversize factor of the maximum load. 15 

### The calculations to the oversize factor 16 

### were also changed. For the maximum operating 17 

### mode, the oversized factor was set to 0.7, the 18 

### same value used in the single-stage calculations. 19 

### The oversize factor at the reduced operating mode 20 

### is similar to the equation used before for the 21 

### DHR, by replacing the DHR equation listed above, 2228

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### mentioned previously. 1 

### Lastly, the lookup tables for the average 2 

### outdoor temperature and the fractional heating 3 

### loads have been replaced with equations dependent 4 

### to the balance point temperature. 5 

### In addition to these calculation changes, 6 

### ASHRAE 103-2007 did a number of changes to the 7 

### testing conditions as well. For two-stage 8 

### products with a balance point temperature less 9 

### than or equal to 5 degrees Fahrenheit, testing is 10 

### only required at the reduced operating load for a 11 

### cool-down, heat-up, optional tracer gas, and 12 

### condensate cycle test. 13 

### For a condensate cycle test, the on- and 14 

### off-cycle times used are the calculated values 15 

### instead of the fixed values used before. More 16 

### details about these two testing changes will be 17 

### presented in later slides. 18 

### As mentioned in the previous slide, the 19 

### main change is to the on- and off-times in terms 20 

### of impact to the AFUE. This slide shows the 21 

### proposed equations listed in sections 11.4.9.11 2229

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### and 11.4.9.12 of ASHRAE 103-2007, to determine 1 

### the on- and off-times, which were based on 2 

### equations used to determine the fixed values 3 

### similar to the ones used to determine the fixed 4 

### values in ASHRAE 103-1993. 5 

### One important thing to note here is that 6 

### for the reduced operating mode, the on- and off7 

### times are dependent on the ratio of the output 8 

### capacity of the reduced mode to the output 9 

### capacity at the maximum mode. That will become 10 

### important once we discuss some of the other 11 

### changes. The on- and off-times impact the 12 

### sensible and infiltration heat losses in the AFUE 13 

### calculations. 14 

### The change to the on- and off-cycle times 15 

### also affects how the condensate cycle test is 16 

### conducted for condensing two-stage and modulating 17 

### products for this issue, too. The condensate 18 

### cycle test described in section 9.8 of ASHRAE 19 

### 103-2007 requires the on- and off-cycle time 20 

### values to conduct the test. As discussed 21 

### earlier, the on- and off-cycle times in ASHRAE 2230

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### 103-1993 were fixed. Now they will need to be 1 

### calculated using equations in the previous slide 2 

### before performing the condensate cycle test. 3


### Yes. 4 

### MR. BROOKMAN: Marshall Hunt. 5 

### MR. HUNT: Clarifying question. Marshall 6 

### Hunt, PG and E. 7 

### So, this cycle -- what we're looking at 8 

### here is only two-stage? Even though we have some 9 

### really fantastic fully-modulating products, 10 

### they're forced into a two-stage test? 11 

### MR. FRANCO: No, no. This is proposed 12 

### two-stage and modulating. 13 

### MR. HUNT: So, if I have a wonderful 14 

### product with nine steps, I have to declare a low15 

### fire and a high-fire? 16 

### MR. FRANCO: The test actually only 17 

### requires reduced. And then there's a calculation 18 

### for what's called the modulating mode, based on 19 

### those -- 20 

### (Cross-talk.) 21 

### MR. HUNT: Yeah. I'd let them know. 2231

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### MR. BROOKMAN: Please, go ahead, Diane. 1 

### MS. JAKOBS: So, this is Diane Jakobs 2 

### from Rheem, and I'm on the ASHRAE 103 committee. 3 

### But there is a little bit of a difference 4 

### -- well, actually for the two-stage and 5 

### modulating, today there are two different 6 

### classes. But in 2007, we combined them into one. 7 

### And there are a couple of differences. 8 

### But we always only tested at the maximum 9 

### capacity and the minimum capacity. So even 10 

### though my modulating furnace has 13, when we're 11 

### testing for AFUE, we're actually only running 12 

### tests at maximum fire and minimum. 13 

### MR. HUNT: And the minimum is quite low. 14 

### Is it 20, 30 percent -- 15 

### MS. JAKOBS: It's 40, 40 percent. 16 

### MR. HUNT: Oh, it is 40. Yeah. 17 

### MS. JAKOBS: For mine. Some go lower. 18 

### MR. HUNT: Okay. 19


### MS. JAKOBS: So. 20 

### MR. HUNT: Thank you. 21 

### MS. JAKOBS: Okay. 2232

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### MR. BROOKMAN: Thanks, Diane. 1 

### Yes, Harvey Sachs. 2 

### MR. SACHS: Harvey Sachs, ACEEE. 3 

### Am I to infer, Diane, that manufacturers 4 

### are comfortable with approximating the modulating 5 

### with this two-step high-fire, low-fire? 6 

### MS. JAKOBS: This is Diane Jakobs from 7 

### Rheem. 8 

### These equations are really old. So the 9 

### papers were written actually before I was a 10 

### heating engineer. So, I don't know. You know 11 

### what? No, furnaces are -- Rheem had a modulating 12 

### furnace in the '70s. But so, we did predate 13 

### these equations. But the -- we had the -- Rheem 14 

### had the first current modulating furnace with 15 

### these 13 stages. And we had that around 2000, I 16 

### think. 17 

### So, I think we learned to work with it. 18 

### And I think our design was probably catered to 19 

### what -- I mean, we were working to the task. And 20 

### when a request for information, me personally, if 21 

### I wanted to characterize the operation of a 2233

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### modulating furnace, I would be looking at steady1 

### state at 70 percent, because that's where it runs 2 

### most of the time. It doesn't run at 100 percent 3 

### unless you have a setback thermostat and you're, 4 

### you know, it's a short period of time. 5 

### It spends more time probably at the 6 

### lowest capacity. But most of the time, in a real 7 

### -- you know, in a home, it's just running steady8 

### state at 70 percent, and it's just inching up or 9 

### down, and meeting the load as it changes through 10 

### the day. So, modulating furnace, when you have 11 

### so many steps, it doesn't really go on and off 12 

### that much. 13 

### MR. BROOKMAN: Frank Stanonik. 14 

### MR. STANONIK: Frank Stanonik, AHRI. 15 

### But, Harvey, I think when the 2007 16 

### edition of 103 was being developed, that issue 17 

### was debated quite a bit. And so I think that 18 

### what we see in 2007 is reflective of, let's say, 19 

### the point at which there was consensus agreement. 20 

### MR. SACHS: Thank you. This is Harvey. 21 

### The lowest common denominator. Thanks, Frank. 2234

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### MR. BROOKMAN: Ron Caudle, who is joining 1 

### us online, has a comment. Ron, you should now be 2 

### unmuted. 3 

### MR. CAUDLE: I'm sorry. I had my hand up 4 

### prematurely. I'm sorry. Can you hear me? 5 

### MR. BROOKMAN: Okay. Well, you sound 6 

### great. We'll wait for you to join us later. 7 

### MR. CAUDLE: Okay. Thank you. 8 

### MR. BROOKMAN: Thank you. 9 

### MR. HUNT: I might mention -- this is 10 

### Marshall Hunt, PG and E -- Ron Caudle is with 11 

### SoCal Gas. He's part of our statewide codes and 12 

### standards team. Thank you. 13 

### MR. BROOKMAN: Thank you. Okay. 14 

### So then, let's, yes, please, Jeff. 15 

### MR. KLEISS: Jeff Kleiss with Lochinvar. 16 

### I would agree that there may be some more 17 

### realism as far as the cycle times. And this 18 

### would be an advantage to products like ours that 19 

### have turndown rates. 20 

### However, the -- if we change these t-on 21 

### and t-offs, it will require us to do retesting on 2235

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### cyclical condensate load, which if the impact of 1 

### this ultimately is going to be a de minimis 2 

### change to the AFUE's, I would rather not impose 3 

### the burden of having to go back and retest our 4 

### products when there's going to be no net gain in 5 

### efficiency caused by this. 6 

### And changing the t-on and t-off will 7 

### require us to, at the very least, go back and 8 

### redo our cyclical condensate tests on reduced 9 

### firing rate. 10 

### MR. BROOKMAN: Okay. Thank you. 11 

### Diane. 12 

### MS. JAKOBS: This is Diane Jakobs from 13 

### Rheem. 14 

### Not to give you the impression that we 15 

### did -- you know, that -- we did good things, too. 16 

### But one of the things is on slide 18, there is an 17 

### alpha. And the way the 1993 test standard is, 18 

### there is a table. And it's kind of a step, where 19 

### you can go from a capacity of one number, and 20 

### then like one more BTU per hour, you end up in 21 

### another bin. And there were some strategic 2236

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### things you could do to get a better number. 1 

### So, that thing has disappeared. So that 2 

### was one improvement that I completely support. 3 

### MR. BROOKMAN: Okay. I guess we're 4 

### ready, Victor. 5 

### MR. FRANCO: Great. Thank you. This is 6 

### Victor Franco again. 7 

### Going back to the slide we were at. So 8 

### basically, since the calculations of on- and off9 

### times are dependent, as I mentioned before, on Q10 

### out and Q-out, R, which were the output at the 11 

### maximum and the output of the reduced, then the 12 

### high- and low-fire steady-state test will need to 13 

### be conducted before the condensate cyclic test. 14 

### The exception to this is that in ASHRAE 15 

### 103-2007, it does allow the ratio of the Q-in at 16 

### the reduced and at the maximum to be a substitute 17 

### for that other ratio of the Q-out at the reduced 18 

### and at the maximum if the error between the two 19 

### is not more than 2 percent. DOE found this 20 

### condition to be true for most of models that it 21 

### tested. 2237

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### So this is the third major in terms of 1 

### the AFUE determination of two-stage modulating 2 

### products. And this is in regards to reduced 3 

### burden. The two-stage furnaces and boilers have 4 

### the following four tests that require only the 5 

### reduced fire tests if the balance point 6 

### temperature is less than or equal to 5 degrees 7 

### Fahrenheit: the cool-down, the heat-up, the 8 

### optional tracer gas, and the condensate cycle, as 9 

### I mentioned earlier. 10 

### This reduces the burden, since the 11 

### current test, ASHRAE 103-1993 test, requires 12 

### these tests even though they have very little 13 

### impact on AFUE due to the fact that the two-stage 14 

### and boilers operate almost all the time at the 15 

### reduced input rate. 16 

### The balance point temperature, which is 17 

### determined by the following equation, at the 18 

### bottom of the slide, is less than 5 degrees 19 

### Fahrenheit when the reduced output to maximum 20 

### output ratio is approximately 0.59 or greater, 21 

### which occurs for almost all two-stage furnaces 2238

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### and boilers currently available in the market. 1 

### MR. HUNT: Could you repeat that? 2


### MR. FRANCO: Yes. 3 

### MR. HUNT: Give it a little more volume. 4 

### MR. FRANCO: Oh, sorry about that. The 5 

### whole phrase or just the last part? 6 

### MR. HUNT: The last part, statement. 7 

### MR. FRANCO: It occurs almost always for 8 

### two-stage furnaces and boilers currently 9 

### available on the market. 10 

### MR. HUNT: Less than 5 degrees. 11 

### MR. FRANCO: Less than 5 degrees. And 12 

### it's the ratio -- it's 0.59 that gives you the 5 13 

### degrees or less. 14 

### MR. KLEISS: Jeff Kleiss, Lochinvar. 15 

### I'm sorry. I need to take issue with 16 

### that, I think. If the -- if I go through this 17 

### equation, the alpha is 0.7. That's a fixed 18 

### value. 19 

### MR. FRANCO: Um-hm. 20 

### MR. KLEISS: So, as our Q-out, R, goes 21 

### down with respect to Q-out, then that is going to 2239

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### make TC a larger number. So the higher the turn1 

### down rate, the higher TC is. 2 

### MR. FRANCO: The lower -- the lower. The 3 

### other way around. The lower the rate. So if you 4 

### go down to like 5.5, then that becomes -- 5 

### (Cross-talk.) 6 

### MR. KLEISS: So the more you turn down 7 

### your appliance -- 8


### MR. FRANCO: Correct. 9 

### MR. KLEISS: -- then the TC gets larger? 10 

### MR. FRANCO: Larger, yeah. 11 

### MR. KLEISS: Right. So, so, and when you 12 

### calculate that out, any unit that has an output 13 

### at reduced rate that is greater than 58.8 percent 14 

### of the full firing rate would be a TC that's less 15 

### than or equal to 5 degrees Fahrenheit? 16 

### MR. KLEISS: Yeah. 17 

### MR. FRANCO: It's 0.59, yeah. 18 

### MR. KLEISS: Right. So the majority of 19 

### the products that are on the market, they're at 20 

### low fire, is 50 percent or less, and would not 21 

### gain any benefit from this. In fact, I don't 2240

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### know of any products on the market that have low 1 

### fire that's greater than 59 percent. 2 

### MR. FRANCO: This is for two-stage 3 

### products. And this is mainly in relation to 4 

### furnaces. It might be different for other, but, 5 

### and it might be different for -- 6 

### MR. BROOKMAN: Let's hear from Diane. 7 

### MS. JAKOBS: This is Diane Jakobs from 8 

### Rheem. 9 

### And this is a part I worked on. But when 10 

### we are digging into the equations, we realize 11 

### that -- so we're running this test at low fire 12 

### and high fire. But the efficiency is actually a 13 

### weighted average of the two operating conditions. 14 

### And based on the capacity, as TC goes up or down 15 

### -- anyway, for a two-stage, there's hardly any 16 

### weighting at all on the high fire. 17 

### So even though we're running the test, 18 

### we're plugging in the numbers, it made like no 19 

### difference in the final outcome. And when you 20 

### looked at it, unless you get to 0.59 or greater, 21 

### as a minimum capacity, that really high fire has 2241

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### no effect. So there's no reason for us to run 1 

### high-fire tests. 2 

### MR. KLEISS: Jeff Kleiss, Lochinvar. 3 

### And I'm not arguing about the logic of 4 

### this calculation at all. I think it's very 5 

### smart. Basically, we're saying that a unit, 6 

### running with this little turn-down, is basically 7 

### going to act like an on-off unit because of over 8 

### -- the oversize factor, which I think is totally 9 

### legitimate. 10 

### The only thing that I'm bringing issue 11 

### with is the assumption that DOE has made that 12 

### this is going to be a reduction in test burden. 13 

### Because I believe that there are few, if any, 14 

### products that are actually going to receive a -- 15 

### not have to run these tests because of this 16 

### factor. 17 

### MR. BROOKMAN: This factor will cause all 18 

### of them to be retested? 19 

### MR. KLEISS: This factor will not -- it 20 

### would allow -- 21 

### MS. JAKOBS: It won't qualify. 2242

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### MR. KLEISS: It would allow a product to 1 

### not have to run a test if it did not have a very 2 

### high turn-down ratio. 3 

### MR. BROOKMAN: Okay. 4 

### MR. KLEISS: The issue is that I don't 5 

### know of any products in our industry that would 6 

### actually get this benefit. 7 

### MR. BROOKMAN: Jim. 8 

### MR. KLEISS: So I don't want DOE to 9 

### falsely assume that this would reduce the test 10 

### burden, because it won't. 11 

### MR. BROOKMAN: Jim. 12 

### MR. VERSHAW: Yeah, Jim VerShaw, from 13 

### Ingersoll Rand. 14 

### The furnace, non-weatherized furnaces are 15 

### quite a bit different from boilers. We have a 16 

### lot of two-stage products around 65 percent; 65 17 

### to 70 percent is kind of the average. 18 

### MS. ARMSTRONG: I think this will help. 19 

### This is our testing. 20 

### MR. BROOKMAN: This is Ashley. 21 

### MS. ARMSTRONG: And you can see the 2243

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### ratios supporting our conclusion. So while it 1 

### may be different for boilers, I think this does 2 

### somewhat support our conclusion for furnaces. 3 

### MR. BROOKMAN: Okay. Diane, do you want 4 

### to comment here? 5


### MS. JAKOBS: No. 6 

### MR. BROOKMAN: Jim got it. Okay. 7 

### Okay. Then, Victor. 8 

### MR. FRANCO: Great. Thank you. Victor 9 

### Franco again. 10 

### Here we're representing the 14 different 11 

### two-stage and modulating furnaces and boilers 12 

### that DOE tested to look at the impact of these 13 

### changes on AFUE. This table presents the 14 

### different designs and controls of each of these. 15 

### So we included five of the major product classes 16 

### and 10 different manufacturers, both non17 

### condensing and condensing furnaces, two-stage and 18 

### modulating controls. 19 

### And as you can see, the ratio here that's 20 

### being calculated once we did the test for two21 

### stage equipment is around that ratio -- higher 2244

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### than that ratio, as actually pointed out. For 1 

### modulating equipment, it's lower, and for 2 

### boilers, it's different as well. 3 

### The cyclic times from the proposed test 4 

### procedure also are listed here. One thing to 5 

### note is that they are much lower than the 6 

### previous test procedure. The t-on was around 10 7 

### minutes. There we're seeing around four to five 8 

### minutes. 9 

### For boilers, it depends on whether it's a 10 

### modulating or two-stage. A lot of boilers that 11 

### we tested were around 20 percent at turn-down 12 

### ratio. So they're actually higher than the 15 13 

### minutes that's being required. And now they 14 

### would be tested at around 20 minutes. 15 

### MR. BROOKMAN: Frank Stanonik. 16 

### MR. STANONIK: Frank Stanonik, AHRI. 17 

### So, well, I am going to pick a point a 18 

### little bit. I mean, if you look at that data, 19 

### and I would encourage you to recognize that 20 

### furnaces are not boilers. In fact, your own data 21 

### says that most boiler models are not going to 2245

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### benefit from this reduced test burden, because 1 

### there's only one there that hit the 65 percent 2 

### ratio, which was not convincing. 3 

### But at least for the hot water boilers, 4 

### all of the other ones would not trigger the magic 5 

### 0.59 number, and they don't -- so there's no 6 

### break for them. So I would just be cautioned 7 

### about a statement that says, which is the case 8 

### for most two-stage furnace and boilers. 9 

### MR. FRANCO: Just to clarify that, I 10 

### forgot the previous slide to clarify it. The 11 

### previous is just related to two-stage; it 12 

### wouldn't impact modulating. Modulating for the 13 

### tests are not required to be tested at high fire. 14 

### (Cross-talk.) 15 

### MR. STANONIK: Point taken. And again, I 16 

### mean, let's be cautioned about extending 17 

### conclusions here. So I understood. It's two18 

### stage. And you tested one two-stage boiler. So, 19 

### you know, again, I think if -- it may be, you 20 

### know, may be correct. But at the moment, testing 21 

### one isn't enough to say that it's going to fit 2246

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### all boilers. 1 

### MR. FRANCO: No, you are definitely 2 

### correct. Just from testing -- our previous 3 

### statement is actually based on looking at actual 4 

### models and looking at the -- from product 5 

### literature. 6 

### So now, let's take a look at the results 7 

### that we found. And I'll go over, there's two 8 

### slides of results. The first slide presents the 9 

### results of non-condensing furnaces and boilers. 10 

### Obviously, the impacts would be much different 11 

### from the condensing. So we might have to 12 

### separate them out. 13 

### Here, we have testing for four of the 14 

### five products that we had models for. The first 15 

### column lists the test at the current test 16 

### procedure. The second column is at the proposed 17 

### Federal test procedure. So there you can see the 18 

### difference. 19 

### The third column is actually the test as 20 

### if it was in a low-fire, at the reduced-fire AFUE 21 

### rating as a single-stage furnace. The difference 2247

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### -- at the last column is the difference between 1 

### the current and the proposed. For all these 2 

### models, the differences are close to half an AFUE 3 

### point. Some cases are going above one AFUE 4 

### point. In all cases, the results are closer to 5 

### the single-stage reduced-fire testing. 6 

### For boilers, the results were slightly 7 

### different, and they're much lower than the 8 

### results for furnaces. 9 

### So now, let's go to the condensing 10 

### furnaces. So here, obviously, we have two things 11 

### that are going on. We're having the 12 

### calculations, but we're also having the testing 13 

### conditions that are being changed for the 14 

### condensate cyclic test. 15 

### So the same thing here. We have three 16 

### different product classes for different models. 17 

### The first column, again, is the current Federal 18 

### test procedure standard; then the proposed 19 

### Federal test procedure standard, measuring this 20 

### furnace as a single-stage at reduced fire; and 21 

### then the difference. 2248

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### For some of these models, the difference 1 

### is small. For some of them, it's larger than one 2 

### [percent] AFUE. And they all seem to be closer 3 

### to the single-stage reduced-fire. 4 

### MR. BROOKMAN: Yes, please, Jim. 5 

### MR. VERSHAW: Jim VerShaw, Ingersoll 6 

### Rand. 7 

### If you look at line 2 of Manufacturer C, 8 

### Model 1, and according to my earlier comments 9 

### about having to retest and the new procedures, 10 

### you can see that if I had today a 92-percent 11 

### furnace that the new rule was 92 percent, I 12 

### wouldn't qualify anymore, with the new standard. 13 

### I don't know whose furnace that is. But 14 

### that's significant. That's a real issue. And 15 

### that just tells me that we don't know for sure 16 

### where we all stand on this. Or you've just 17 

### identified lab uncertainty that hasn't been 18 

### factored into the tolerances that we're doing and 19 

### how we set up our ratings. 20 

### The other question I have -- and I 21 

### couldn't find it in here. Did you recalculate 2249

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### burner operating hours and show the difference 1 

### between the old and new methods? Because you've 2 

### got different on and off times. 3 

### MR. FRANCO: We're going to be talking 4 

### burner operating hours -- 5 

### MR. VERSHAW: Okay, good. Thanks. 6 

### MR. FRANCO: -- in just one second. 7 

### MR. BROOKMAN: Yes, Frank Stanonik. 8 

### MR. STANONIK: Frank Stanonik, AHRI. 9 

### Well, I think Jim has certainly touched 10 

### on one of the things that we are very concerned 11 

### about, is that -- and we very much wanted to see 12 

### what tests had been done to this point as far as 13 

### evaluating the effect of the revised test 14 

### procedure. 15 

### We are concerned that maybe enough 16 

### testing has not been done to really get to that 17 

### conclusion that, let's say, the test provisions 18 

### are neutral. And obviously, if they do have an 19 

### effect, and particularly an effect of lowering a 20 

### minimum, then DOE has to look at the issue of 21 

### translating -- what I like to call translating 2250

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### the efficiency standard to reflect the new 1 

### procedure. 2 

### But I think one of the -- and just as an 3 

### example, it's not here. But it would be 4 

### interesting to see, were all of these roughly the 5 

### same input model? I mean, because at least 6 

### historically, with the test procedure, your input 7 

### gave you a slightly different number, right? 8 

### MR. BROOKMAN: Jim. 9 

### MR. VERSHAW: Yeah, it's Jim VerShaw. 10 

### It would depend upon the house load it 11 

### fell into. 12 

### MR. STANONIK: Yeah, right, right. 13 

### MR. VERSHAW: Yeah, yeah. 14 

### MR. STANONIK: Thanks, and I know you 15 

### tried. But I think, again in terms of really 16 

### evaluating whether this is a neutral change, we 17 

### would need to look across the spectrum of inputs 18 

### of products available just to make sure there's 19 

### no weird effect that we didn't know about. 20 

### MS. ARMSTRONG: So, we would welcome the 21 

### opportunity to work with AHRI to do just that. 2251

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### We had a request to place some more details of 1 

### our test data in the docket, which we're going to 2 

### do. So you can look for that file. 3 

### But to the extent that all of you have 4 

### test data, or if anyone has run the proposed 5 

### method either during the ASHRAE process or 6 

### otherwise, or if AHRI wants to work with us to 7 

### set something up, we'd be happy to engage in that 8 

### discussion. 9 

### MR. BROOKMAN: Thank you, Ashley. Thank 10


### you. 11 

### Yes, and one more. Just say your name 12 

### for the record. 13 

### MR. YILMAZ: Ayk Yilmaz, AHRI. 14 

### A little bit of a specific question with 15 

### relation to the test differences that you saw. 16 

### You identified two different ways in which the 17 

### different cycle times can change AFUE results, 18 

### one being through the calculations which impact 19 

### the L-S, on, L-S, off, and the infiltration 20 

### losses. And then the other one, through the 21 

### actual condensate cycling test that you did, 2252

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### which also could create a different result for L1 

### sub-G, I think was the term. 2 

### Did you identify, or were you able to 3 

### identify which of those impacts actually created 4 

### the differences that you saw? 5 

### MR. FRANCO: Thank you for that question. 6 

### Yes, that's a good clarification. 7 

### So, as you can see from the results 8 

### previously, which were only impacted by the 9 

### calculations, they were pretty much all positive 10 

### differences. Here, we're seeing all negative. 11 

### So, the negative comes in from the 12 

### calculations for the condensate cyclic test. 13 

### Basically, what happens is you're measuring the 14 

### condensate for a short period of time. So you 15 

### have more of the impact of the cycling. At the 16 

### beginning, usually, there's a little bit less 17 

### cyclic. There's a little bit less inefficient. 18 

### As you're going closer to the steady-state, it's 19



### more. 20 

### MR. BROOKMAN: Jim? Comment? 21


### MR. VERSHAW: No. 2253

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### MR. BROOKMAN: Okay. Additional 1 

### thoughts, questions, comments? Jeff. 2 

### MR. KLEISS: Jeff Kleiss, Lochinvar. 3 

### I'm just trying to get my mind around the 4 

### -- you've got calculated values for the proposed 5 

### Federal test procedure, and then the single-stage 6 

### at reduced firing AFUE rating. And then the 7 

### footnote down there. 8 

### And the differences that you're showing 9 

### in the efficiencies are based on the difference 10 

### between the current test procedure and the 11 

### single-stage at reduced-firing AFUE? Is that -- 12 

### am I reading this correctly? 13 

### MR. FRANCO: No, no. Sorry about that. 14 

### Sorry about the confusion. It's between the 15 

### current Federal and the proposed. 16 

### MS. ARMSTRONG: This is Ashley. There's 17 

### three columns, right? The middle column is the 18 

### proposed? 19 

### (Pause.) 20


### MR. FRANCO: Correct. 21 

### MS. ARMSTRONG: So what's the -- 2254

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### MR. KLEISS: Just some of the numbers 1 

### don't seem to be -- 2 

### MS. ARMSTRONG: You're talking about the 3 

### deltas on the last column? That's what you're 4 

### asking? 5 

### MR. KLEISS: Yeah. 6 

### MS. ARMSTRONG: Okay. 7 

### MR. KLEISS: Trying to find out what 8 

### they're associated with. 9 

### MS. ARMSTRONG: Okay. 10 

### MR. BROOKMAN: Jim. 11 

### MR. VERSHAW: Yeah, Jim VerShaw. 12 

### I'm going to go back to my earlier 13 

### statement on burden. I wish we had time to have 14 

### a lot of numbers to show between this test method 15 

### and this test method on furnaces. But we just 16 

### finished changing the AFUE's on our packaged 17 

### products and non-weatherized furnaces. We're 18 

### working on FER and a myriad of other things. We 19 

### haven't had time to go in and even look at this. 20 

### And whatever we did back in 2006, well, 21 

### different people -- that's all gone. We can't 2255

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### find that data, because it wasn't necessary to 1 

### keep it, right? So it's kind of lost. 2 

### That was my whole point in the very 3 

### beginning is that there's so much going on we 4 

### have a hard time keeping up. 5 

### MR. BROOKMAN: Diane. 6 

### MS. JAKOBS: This is Diane Jakobs from 7 

### Rheem. 8 

### But just because I was so enthralled with 9 

### the whole thing, that we never really -- we never 10 

### tested our furnaces to the 2007 version versus 11 

### the 1999. I was always arguing about the 12 

### assumptions. So I was more interested in how 13 

### thermostats work and the interaction between the 14 

### thermostat and the furnace. 15 

### But I would have to do testing now to -- 16 

### I don't have anything. 17 

### MR. BROOKMAN: Okay. 18 

### Okay, Victor. 19 

### MR. FRANCO: Thank you so much for those 20


### comments. 21 

### The next proposal that's from ASHRAE 2007 2256

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### was to changes for the on-cycle losses for 1 

### products with long post-purge time. Basically, 2 

### in that same 2002 NIST study, they found the 3 

### issue that there are some, primarily oil-fired 4 

### boilers at that time, that require long post5 

### purge times beyond three minutes. The existing 6 

### test procedure produces small flue loss result. 7 

### The cause of this was in the Federal test 8 

### procedure, that limits the post-purge time to 9 

### three minutes for the flue loss calculation. The 10 

### ASHRAE 103-2007 proposed the changes to the flue 11 

### loss calculations that are based on the NIST 12 

### derivations of those equations. 13 

### There are two changes. One is to the 14 

### testing that now allows the post-purge time to be 15 

### greater than three minutes. For units that have 16 

### a post-purge time greater than three minutes, 17 

### there's an additional flue gas temperature at the 18 

### midpoint of that post-purge period of time. 19 

### There's also calculation changes for 20 

### units that are above three minutes that are in 21 

### sections 11.2.10.6 and 11.2.10.8 of the ASHRAE 2257

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### 2007 standard. So, going back, this next slide 1 

### presents the results not affecting AFUE, but 2 

### affecting other products. 3 

### MR. SACHS: Harvey Sachs, ACEEE. 4 

### Victor, I'm a little confused about these 5 

### long purge cycles. I haven't thought it all the 6 

### way through, but my understanding is a large 7 

### fraction of furnaces, both condensing and non8 

### condensing, are using inside air for combustion. 9 

### That has to be replaced. So at some point, that 10 

### infiltrated air has to be warmed before -- will 11 

### be warmed before it gets to the furnace. And 12 

### that has some heat content. 13 

### And it would seem that there's got to be 14 

### a point -- and I don't know if it's three minutes 15 

### or three hours -- where the value gained by the 16 

### long purge cycle is offset by the heating of that 17 

### air, replacement air. 18 

### MR. FRANCO: Yes. That -- 19 

### MR. SACHS: Am I thinking wrong? 20 

### MR. FRANCO: No, that is correct. This, 21 

### I think the intent of this change was that there 2258

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### were some boilers, actually, not furnaces, and 1 

### oil equipment that had these long three-minute 2 

### purge times. We're not aware of any furnaces 3 

### that have these long purge times. And there are 4 

### very few boilers that the post-purge time is 5 

### greater than three minutes. It's set to that -- 6 

### MR. SACHS: Thank you for the 7 

### clarification. 8 

### MR. FRANCO: Thank you for the question. 9 

### So now, we get back to the burner 10 

### operating hours, the annual fuel use, and the 11 

### electricity, annual electricity use calculation 12 

### changes. So again, to emphasize, these do not 13 

### impact the AFUE. These are side calculations 14 

### that are provided in the Federal test procedure. 15 

### (Pause.) 16 

### MR. BROOKMAN: Get a little closer to the 17 

### mic. 18 

### MR. FRANCO: Okay. 19 

### FEMALE VOICE: That's much better. 20 

### MR. FRANCO: Okay. Let me put this 21 

### closer, too. Okay. Sorry about that. 2259

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### So, let me say that again. This next 1 

### slide is for the burner operating hours, annual 2 

### fuel use, and annual electricity use 3 

### calculations. These don't impact the AFUE 4 

### calculations. These are primarily at a 5 

### subsection of the test procedure for 6 

### manufacturers to report if they wish. A lot of 7 

### manufacturers of furnaces report these values, 8 

### and boiler manufacturers report these values. 9 

### So again, there's some of the -- this is 10 

### based on this 2002 NIST study. They found that, 11 

### for two-stage and modulating products, the burner 12 

### operating hours are primarily based on the 13 

### maximum input rate. To adjust for this, they 14 

### actually introduced a multiplication factor, the 15 

### R factor, to account for the useful heat of the 16 

### electrical components at the two-stage. So, 17 

### usually, two-stage equipment operates longer so 18 

### that these components would be operating a longer 19 

### period of time. 20 

### What happens is it ignores the 21 

### variability of the electrical component input for 2260

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### multi-speed and variable speed, circulating and 1 

### combustion blowers. So, many times, it over2 

### estimates the efficiency in terms of fuel use of 3 

### these products. 4 

### NIST proposed to change the burner 5 

### operating hours calculation by calculating them 6 

### at each operating mode. ASHRAE adopted these 7 

### changes, but also did additional modifications 8 

### primarily related to the modifications that we 9 

### discussed previously. 10 

### DOE proposes to adopt these changes, with 11 

### modifications to account for the electronic 12 

### ignition and standby and off-mode electricity 13 

### use, which are already part of the existing 14 

### Federal test procedure. 15 

### This is a summary of the changes. So, in 16 

### terms of -- again, in terms of operating hours, 17 

### the biggest change is that all the burner 18 

### operating hours are calculated for all operating 19 

### modes. The correction factor, this R factor, has 20 

### been removed because of the heat from the 21 

### electricity of the burner -- in the burner 2261

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### operating hours calculation is calculated 1 

### separately for each operating mode. 2 

### In addition to this, the fuel consumption 3 

### is now being calculated separately for high and 4 

### reduced fire. The electricity consumption also 5 

### has separate on-time ratios for high- and low6 

### fire. 7 

### In terms of the on-time ratios, which are 8 

### the ratios between the electrical component on9 

### time to the burner operating on-time, these Y 10 

### factors are based on the on-time cycle, the 11 

### burner on-time cycle values that we were 12 

### discussing previously for each operating mode. 13 

### So, for two-stage, they are these calculated 14 

### values that we discussed earlier. 15 

### Similar to what we discussed before, the 16 

### design heating requirement has been replaced by 17 

### this equation, and the fractional heating loads 18 

### are being replaced by an equation, depending on 19 

### the balance point temperature. 20 

### MR. BROOKMAN: Jim. 21 

### MR. VERSHAW: So, how do they change? 2262

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### MR. FRANCO: It is a little bit 1 

### complicated. There are two factors to consider. 2 

### One is that there's actually changes to the AFUE 3 

### that impact for two-stage equipment, whether it 4 

### increases or decreases. There's also the impact 5 

### of these changes in terms of how these 6 

### calculations impact if you had -- if you were 7 

### calculating the same AFUE between the existing 8 

### and the proposed. 9 

### MR. VERSHAW: So, you don't have a table 10 

### that says prior the BOH [burner operating hours] 11 

### was this, now it's this? And prior, the EAE was 12 

### this, and now it's this? Do you have that? 13 

### MR. FRANCO: We don't currently have 14 

### that, no. 15 

### MR. VERSHAW: I'm getting ahead of 16 

### myself. But when we did the analysis for the new 17 

### AFUE standard, did you use this procedure? And 18 

### doesn't how long the blower run play into how 19 

### much energy is used by the furnace in the heating 20 

### season? Wouldn't that make an effect on the 21 

### numbers you got? 2263

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### MR. FRANCO: Just do -- you're talking 1 

### about the standard that -- 2 

### MR. VERSHAW: I'm talking about 3 

### tomorrow's meeting. 4 

### MR. FRANCO: Tomorrow's meeting. Great, 5 

### great. 6 

### MR. VERSHAW: Yeah. 7 

### MR. FRANCO: Yes. Actually, we do. We 8 

### use these calculations. We actually have been 9 

### using these calculations even in the previous 10 

### rulemaking in 2011. Because these do -- are more 11 

### accurate in terms of representing field 12 

### conditions. 13 

### MR. VERSHAW: But you don't know what the 14 

### differences are? 15 

### MR. FRANCO: Yes, we've -- 16 

### MR. VERSHAW: Because I've only been 17 

### looking at the old way of doing it. So. 18 

### MR. FRANCO: We don't know in terms of 19 

### the actual, your specific product. But overall, 20 

### in terms of like an overall change, what it 21 

### usually does is it decreases the fuel consumption 2264

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### for -- it increases the fuel consumption for two1 

### stage and modulating products. 2 

### MR. VERSHAW: For the gas or the 3 

### electricity or both? 4 

### MR. FRANCO: The gas. 5 

### MR. VERSHAW: Yeah. 6 

### MR. FRANCO: The gas, and it depends on 7 

### the electricity, the fan, primarily, efficiency, 8 

### whether it increases or decreases slightly. That 9 

### would be dependent on your specific product. 10 

### It's hard to be a little bit -- but the primary, 11 

### there's an ACEEE paper that kind of explains the 12 

### effect of just simply going and plugging these 13 

### into kind of similar equations. 14 

### (Cross-talk.) 15 

### MR. VERSHAW: So Harvey has all this 16 

### information? 17 

### MS. ARMSTRONG: Yes. Harvey has all this 18 

### information. And he's going to present next. 19 

### MR. VERSHAW: Good. Okay. 20 

### (Laughter.) 21 

### MR. BROOKMAN: Harvey, to the podium, 2265

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### please. 1 

### (Laughter.) 2 

### MR. FRANCO: The reference to that paper 3 

### is in the notice itself if you wanted to go to -- 4 

### into and read that. 5 

### MS. ARMSTRONG: Well, we will talk lots 6 

### more about this stuff tomorrow. 7 

### MR. SACHS: Victor, can you cite the 8 

### author of that paper? 9 

### (Laughter.) 10 

### MS. ARMSTRONG: Harvey, et al

. 11 

### MR. BROOKMAN: Frank Stanonik. 12 

### MR. STANONIK: Frank Stanonik, AHRI. 13 

### And I'm unfortunately not familiar with 14 

### that paper. 15 

### (Laughter.) 16 

### MR. BROOKMAN: Me either. 17 

### (Laughter.) 18 

### MR. STANONIK: But, okay, so what I 19 

### understood is that the general -- the conclusion 20 

### is that you're going to see a little more 21 

### increased fuel consumption. But that occurs 2266

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### because it appears that you are not -- no longer 1 

### over-estimating the contribution of the electric 2 

### energy to the heating. 3


### MR. FRANCO: Correct. 4 

### MR. STANONIK: If that's correct, then 5 

### why isn't the second part of the conclusion that, 6 

### in general, your electric consumption number goes 7 

### down? Where does that break off? Or where does 8 

### that disconnect? 9 

### MR. FRANCO: Yeah. Let me explain a 10 

### little bit further. The electricity consumption 11 

### in the previous equation hasn't changed that 12 

### much. The only change is from this slide, as you 13 

### can see, is the addition of on-time ratios for 14 

### the reduced fire, essentially. But the equation 15 

### itself was basically calculated both for reduced 16 

### and high. So that was not as big of a change. 17 

### The biggest change was actually to the 18 

### burner operating hours of it that were used to 19 

### calculate in the fuel use, which is actually only 20 

### calculated at the high-fire for two-stage and 21 

### modulating equipment. And then doing all these 2267

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### adjustments to adjust it so that it's applicable. 1 

### So, this does approximate better the 2 

### actual field conditions. And I just misspoke. 3 

### The papers from ACEEE summer proceedings are 4 

### actually not from ACEEE. It's actually by LBNL; 5 

### it's from Lawrence Berkeley National Laboratory. 6 

### (Laughter.) 7 

### MR. FRANCO: So, I misspoke. 8 

### MR. SACHS: The defense rests. 9 

### (Laughter.) 10 

### MR. FRANCO: Sorry about that. 11 

### MR. HUNT: Marshall Hunt, PG and E. 12 

### Now I'm confused. So are we saying -- 13 

### MR. BROOKMAN: Wait a second. Okay, 14 

### Marshall. Go ahead. 15 

### MR. HUNT: Okay. Now I'm totally 16 

### confused. Are we saying that a two-stage or 17 

### modulating furnace will use more energy in the 18 

### year, more gas? 19 

### MR. FRANCO: No. That's what the 20 

### equation incorrectly calculated, the equation 21 

### that was used before. The current equation 2268

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### actually shows that it's about the same 1 

### consumption. If you have the same efficiency -- 2


### MR. HUNT: Yes. 3 

### MR. FRANCO: -- furnace between a single4 

### stage and two-stage, and you calculate both the 5 

### electricity and the fuel, you calculate about the 6 

### same. If you did the old calculations, it came 7 

### out to about 3 percent higher. 8


### MR. HUNT: Yes. 9 

### MR. FRANCO: Or 3 percent less fuel 10 

### consumption, which didn't seem to be -- 11 

### MR. HUNT: So we're talking about a 12 

### comfort product, a comfort feature rather than an 13 

### efficiency feature. 14 

### MR. FRANCO: Primarily. But there could 15 

### be other -- again, in the calculations of the 16 

### AFUE, you're doing these AFUE calculations at the 17 

### reduced, that could also play a role. 18 

### MR. HUNT: Thank you. 19 

### MR. FRANCO: But it's primarily -- 20 

### MR. BROOKMAN: Harvey Sachs. 21 

### MR. SACHS: Marshall has just completed 2269

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### my confusion. 1 

### (Laughter.) 2 

### MR. HUNT: Thanks. 3 

### MR. SACHS: There seems to be some 4 

### empirical evidence that suggests, or I've 5 

### incorrectly inferred that a two-stage actually 6 

### uses less gas over the season than a single7 

### stage. But you're telling me that we're getting 8 

### the same AFUE. 9 

### MR. FRANCO: Yeah. So that's a 10 

### difference between how we're trying to kind of 11 

### normalize everything in the test procedure and 12 

### you might want to -- might see in the field. 13 

### What happens in the field usually is a single14 

### stage furnace is usually oversized and usually 15 

### significantly oversized. 16 

### In the field, even if the two-stage 17 

### furnace is oversized, that won't have as much of 18 

### an impact. So there are many situations where 19 

### you could see savings because of that. 20 

### MR. SACHS: So, after 30 years of work to 21 

### get a decent representation of actual gas use 2270

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### that would allow us to compare models, we're 1 

### still stuck with something that doesn't reflect 2 

### what a consumer sees when he buys the appliance. 3 

### Does this strike anybody else as being nuts? 4 

### Pardon me. 5 

### MR. FRANCO: Thank you for your comment. 6 

### MR. BROOKMAN: Diane. 7 

### MS. JAKOBS: So, this is Diane from 8 

### Rheem. 9 

### And I've worked on this. And I think 10 

### this test procedure provides a good method to 11 

### compare one product to another. I think what it 12 

### does not do is estimate the consumption in a 13 

### consumer's home. 14 

### MR. SACHS: Harvey Sachs again. 15 

### And, Diane, I appreciate what ASHRAE 16 

### committees work like. I'm there. I've done it. 17 

### But I'm translating your statement as the 18 

### statement that this allows the comparison of your 19 

### single-stage to Joe's single-stage. But it 20 

### doesn't allow you to look for the value-added by 21 

### buying a two-stage over a single-stage in terms 2271

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### of your expected gas savings. 1 

### MS. JAKOBS: Okay. Diane. 2 

### If you're comparing single-stage to two3 

### stage, I think 2007 gives you better information 4 

### for that. 5 

### MR. SACHS: Does it -- 6 

### MS. JAKOBS: Modulating is maybe another 7



### one. 8 

### MR. BROOKMAN: Jeff, go ahead. 9 

### MR. KLEISS: Jeff Kleiss, Lochinvar. 10 

### If I'm understanding what I've heard 11 

### correctly, it's that the current procedure that 12 

### we're using, the 1993 ASHRAE 103 standards 13 

### calculation has been overstating the savings for 14 

### two-stage and modulating units as far as the 15 

### energy consumption over the year. And what we're 16 

### talking about in the 2007 calculation is a 17 

### correction to that overstatement. 18 

### MR. FRANCO: Correct. Thank you. Thank 19 

### you for that clarification. 20 

### MR. BROOKMAN: Thank you, Victor. 21 

### Harvey. 2272

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### MR. SACHS: The limited field -- this is 1 

### Harvey Sachs. 2 

### The limited field data with which I'm 3 

### familiar is primarily Scott Pigg's pioneering 4 

### study, I think 2001. And my inference and my 5 

### memory, which is not perfect, is that we found 6 

### substantial over-sizing in the two-stage furnaces 7 

### as well as the single-stage. So consequently, we 8 

### had a very high ratio of single-stage operation 9 

### to two-stage. 10 

### And again, I'm not an experienced furnace 11 

### engineer. But that seems to me like it's saying 12 

### there's a lot more BTU's -- a lot fewer BTU's per 13 

### unit of heat transfer area, and it ought to use 14 

### less fuel, run longer and use less fuel. 15 

### MR. BROOKMAN: Diane. 16 

### MS. JAKOBS: So, if you are taking out a 17 

### single-stage furnace, you replace it with a two18 

### stage. And the other thing is we sell them 19 

### according to input, not output. But we're kind 20 

### of steering people towards not over-sizing quite 21 

### as much. So there is a savings associated with 2273

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### that. 1 

### MR. SACHS: I don't mean to highjack 2 

### this. But with all due respect to my good friend 3 

### Charlie back there -- 4 

### (Inaudible interjection and laughter.) 5 

### MR. SACHS: -- I'd rather continue 6 

### pushing rocks uphill than convince the contractor 7 

### that he doesn't need the safety factor to keep 8 

### from getting that call-back on a cold night. 9 

### It's a really hard fight the efficiency programs 10 

### have had for a decade or two, that the quality 11 

### installation has had. And end of rant. 12 

### MR. BROOKMAN: Do you wish to comment? 13 

### Please. Microphone and say your name. 14 

### MR. YILMAZ: Yeah. Ayk Yilmaz, AHRI 15 

### again. 16 

### I just wanted to clarify the error that 17 

### is being corrected here. Is it something that's 18 

### manifested in AFUE? Or is it limited to that EF 19 

### that you're talking about? 20 

### MR. FRANCO: Thank you for clarifying. 21 

### It's related to EF. Once you recalculate your 2274

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### AFUE values, those would be additional inputs to 1 

### that calculation. So that might change a little 2 

### bit. 3 

### But these calculations, again, are 4 

### separate from AFUE. They're not being used in 5 

### calculating AFUE. 6 

### MR. YILMAZ: Okay. So, I guess I'm just 7 

### trying to maybe address Harvey's question there. 8 

### When you're talking about comparing a single9 

### stage furnace to a modulating furnace that has 10 

### the same AFUE, you're not talking about version A 11 

### of the same furnace that’s single-stage, and 12 

### version B of the same furnace that's modulating. 13 

### You're talking about furnace one that's 14 

### single-stage and a completely different furnace 15 

### that's a different design that’s step-modulating, 16 

### that when you do an AFUE test on it, you get the 17 

### same efficiency result. And that's not because 18 

### of any impact that is due to the modulating; it 19 

### could be because of a completely different 20 

### furnace design. 21 

### MR. FRANCO: That is correct. Yes. And 2275

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### that's a complication between actually comparing 1 

### just a single unit and the change, because the 2 

### change will have the impact of the AFUE 3 

### difference from the other (inaudible). 4 

### MR. YILMAZ: Okay. So then, I guess just 5 

### to summarize then, the AFUE is an accurate 6 

### representation of how -- or as accurate as we can 7 

### expect to get of a single-stage furnace’s 8 

### efficiency or a modulating furnace’s efficiency. 9 

### But when we're talking about one that has the 10 

### same AFUE, we are talking about something we'd 11 

### expect to have the same fuel consumption over the 12 

### course of the year. 13 

### And it's really just about that EF number 14 

### that ends up being different because of that 15 

### error between how it's calculated for single16 

### stage and modulating? 17


### MR. FRANCO: Yes. 18 

### MR. SACHS: This is Harvey. 19 

### And I thank you very much. I have not 20 

### reviewed the test procedures since the last time 21 

### we did rulemaking, and you caught me. I had 2276

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### forgotten that we go to a lot of work to compute 1 

### something that's -- EF that's not used in AFUE. 2


### So. 3 

### MR. YILMAZ: It's been over a decade. 4 

### MR. BROOKMAN: Joanna Mauer, welcome. 5 

### You are now unmuted. 6 

### MS. MAUER: Thanks. I had two questions. 7 

### One is just a basic question. For a two-stage 8 

### furnace, how does the steady-state efficiency 9 

### compare at low-fire and high-fire? 10 

### MR. FRANCO: This is from -- you -- from 11 

### our test data? 12 

### MS. ARMSTRONG: Why don't we just let 13 

### them answer? 14 

### MR. BROOKMAN: Diane, please. 15 

### MS. JAKOBS: That is a matter of the 16 

### design. We have choices. 17 

### MS. MAUER: So it's going to change. 18 

### MS. JAKOBS: It's going to change. It 19 

### depends. 20 

### MS. ARMSTRONG: Okay. And it's not 21 

### necessarily higher at the low-fire stage then? 2277

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### MS. JAKOBS: We can design it that way. 1


### If -- 2 

### MS. ARMSTRONG: They're shaking their 3 

### heads no. You can't see them, but they're saying 4 

### not, no. 5 

### (Laughter.) 6 

### MS. JAKOBS: Yeah. 7 

### MS. MAUER: Okay. 8 

### MS. ARMSTRONG: It's not necessarily. 9 

### They can design it one way or the other; let's 10 

### put it that way. 11 

### MR. VERSHAW: Jim VerShaw from Trane. 12 

### It's difficult to get the excess air 13 

### level at the same level at low-fire and high-fire 14 

### because it's difficult to get the inducer motor 15 

### to slow down enough. And so, that's why actually 16 

### on our condensing two-stage furnaces, we have an 17 

### inverter-driven motor because we had to slow it 18 

### down farther in order to get the numbers we want. 19 

### Otherwise, the excess air goes up. The 20 

### dew point goes way down. You can't condense 21 

### anything. It's a little easier on non-condensing 2278

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### furnaces. But it's just really kind of driven by 1 

### what you can do with excess air. 2 

### And as far as the numbers, they're pretty 3 

### close. You know, it's a point one way or the 4 

### other. It's not substantially higher on low5 

### fire. 6 

### MR. BROOKMAN: Joanna, you said you had 7 

### two questions? 8 

### MS. MAUER: Victor, I did take a quick 9 

### look at the LBNL paper that you mentioned. And I 10 

### just wanted to make sure kind of I understood the 11 

### kind of general conclusion, which seemed to be 12 

### that there may not be gas savings in the field 13 

### from two-stage furnaces. Is that correctly -- a 14 

### correct interpretation? 15 

### MR. FRANCO: That is correct. But again, 16 

### that is comparing two models that are at 80- 17 

### percent AFUE that are tested. And it's not 18 

### comparing the same model being tested as a 19 

### single-stage and as a two-stage. So it is 20 

### comparing two different models both at the same 21 

### efficiency level. 2279

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### MS. MAUER: I see. Okay. Thank you. 1 

### MR. BROOKMAN: Thank you. 2 

### MR. FRANCO: So, any last comments on 3 

### this -- 4 

### (Cross-talk.) 5 

### MS. ARMSTRONG: Yeah. So we're going to 6 

### close out the part relating to ASHRAE 103 before 7 

### we do a summary of a couple of our other changes 8 

### that are outside of ASHRAE 103. So at this time, 9 

### if anyone has any other comments or issues or 10 

### questions relating to ASHRAE 103 that they would 11 

### like to bring up at this time, we welcome them. 12 

### MR. BROOKMAN: Ayk, please. 13 

### MR. YILMAZ: Ayk Yilmaz, AHRI. 14 

### I was just waiting for this slide before 15 

### I jumped back to the issue of the, what was item 16 

### 1.B), the off-cycle losses for products with long 17 

### post-purge time. And I guess the comment was 18 

### made that this is a type of -- the products that 19 

### have post-purge times longer than three minutes 20 

### tend to be oil boilers. And I noticed that an 21 

### oil boiler was not one of those items that was 2280

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### tested under the research. 1 

### So, I guess, two-part question. Number 2 

### one, has there been an analysis of the fraction 3 

### of products that might be affected by this change 4 

### by product class, not just looking at oil 5 

### boilers, but other types? And number two, is 6 

### there an understanding of what the impact on AFUE 7 

### might be from this change? 8 

### And I ask that question as trying to 9 

### understand what the impact might be on the 10 

### minimum efficiency standards from this change. 11 

### MR. FRANCO: Thank you so much for that 12 

### question. We weren't actually able to get a 13 

### model that fit that description of the post-purge 14 

### for oil boilers. And so, we don't know the exact 15 

### impact in terms of magnitude, whether it was -- 16 

### what it would be, if it was half an AFUE point, 17 

### less than that. We don't know. 18 

### MS. ARMSTRONG: Well, I think -- this is 19 

### Ashley from DOE. 20 

### I think what you're hearing is, no, we 21 

### didn't test one. And we'd welcome data if you 2281

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### have it, so, to help inform. 1 

### MR. BROOKMAN: Jeff. 2 

### MR. KLEISS: You could read my mind. 3 

### Jeff Kleiss, Lochinvar. 4 

### Just before we get off of the 2007 ASHRAE 5 

### 103 statement, I want to be clear about this, 6 

### that it looks like what may -- by going to this 7 

### standard, we may reduce the test burden for 8 

### furnaces. But we will increase the test burden 9 

### for boilers. And by that, I mean you would force 10 

### us to go back and retest all of our existing 11 

### products. 12 

### And if there's some way -- I'm not 13 

### opposed to updating to the newer standard if we 14 

### can find a way to do that that does not force us 15 

### to go back and retest existing product when we 16 

### don't expect there to be a change in the AFUE's. 17 

### So if -- 18 

### MS. ARMSTRONG: Okay. So, that's a good 19 

### lead-in, Jeff. Thanks. 20 

### So I do want to confirm. You do not 21 

### believe that any of the changes, at least with 2282

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### regards to 2007 that we've proposed, will change 1 

### your AFUE ratings as they exist today? 2 

### MR. KLEISS: That's a bit of a dicey 3 

### question from the -- I'm sorry; Jeff Kleiss, 4 

### Lochinvar -- from the standpoint that we don't 5 

### have a calculator to use right now. And the 6 

### specifics of how that calculator works may affect 7 

### our AFUE's and have changes of several tenths of 8 

### a percent, which could be significant when it 9 

### comes to whether or not we meet certain 10 

### efficiency rebate thresholds. 11 

### But that aside, I've run calculations on 12 

### our products as they're updated. And I believe 13 

### that they would be very small impacts. 14 

### MS. ARMSTRONG: So, to answer, you know, 15 

### when you're thinking about making your written 16 

### comments with regards to DOE's proposal and the 17 

### potential adoption of ASHRAE 103, the way we look 18 

### at retesting, if you have a previously tested -- 19 

### so this is going to answer Diane's question 20 

### earlier, too. 21 

### If you have a previously tested and 2283

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### certified model, no retesting will be necessary 1 

### as long as the rating is still valid. If you 2 

### have a previously tested and certified model 3 

### whose rating is no longer valid, then you must 4 

### test to the next procedure, rerate, and recertify 5 

### before 180 days, at least under the proposal the 6 

### way it was written. 7 

### MR. BROOKMAN: Diane. 8 

### MS. ARMSTRONG: Hang on one second; one 9



### more. 10 

### MR. BROOKMAN: Oh, I'm sorry. Yeah. No, 11 

### this is good. 12 

### MS. ARMSTRONG: And if you have a new 13 

### model introduced post the effective date of the 14 

### test procedure, clearly for those you would need 15 

### to use the new test procedure to rate and certify 16 

### before distribution in commerce. 17 

### So, you know, if you can make the 18 

### determination that your ratings would not change, 19 

### you would fall into that first bucket for which 20 

### previously tested and certified and no retesting 21 

### is necessary. 2284

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### MR. BROOKMAN: I want to make sure, Jeff, 1 

### do you want to follow on, Jeff? 2 

### MR. KLEISS: Yeah, Jeff Kleiss. 3 

### I just want to know, where is that in the 4 

### proposed rule? 5 

### MS. ARMSTRONG: So, that's the way our 6 

### regulations work generally. That's what it says 7 

### with regards to adoption of a test procedure, 8 

### which is effective 30 days and for which must be 9 

### used after the 180-day representation point. But 10 

### I did want to clarify the three buckets in a 11 

### little bit more what I would call plain language 12 

### that I understand a little better. Hopefully, 13 

### it's helpful to you. 14 

### MR. BROOKMAN: That was very helpful, I 15 

### think. 16 

### Diane, please. 17 

### MS. JAKOBS: So, the way I would process 18 

### things, I would say if you think that you would 19 

### pass a verification test, that you would be okay 20 

### and no one from DOE would expect to look at our 21 

### records and see a test output that reflects the 2285

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### new standard and was dated after the new test 1 

### procedure. It's more like how -- it's more 2 

### important how your appliance actually operates 3 

### and whether or not you meet the regulation as it 4 

### would be verified. 5 

### MS. ARMSTRONG: Generally speaking, I 6 

### think you've said it another way. And it goes to 7 

### twofold with compliance and then, obviously, 8 

### valid rating. So. Seemingly, though, if you 9 

### have test data, historical test data that 10 

### underlies your rating, your rating continues to 11 

### be valid even though the test procedure has 12 

### changed. You maintain that historical data, and 13 

### you're good. 14 

### MR. BROOKMAN: I wish to underline a 15 

### little bit of this conversation. And I don't do 16 

### this very often. Ashley, it strikes me that you 17 

### were very careful the way you just stated all of 18 

### that. 19


### MS. ARMSTRONG: I was. 20 

### (Laughter.) 21 

### MR. BROOKMAN: Okay. I just wanted to 2286

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### make that as an underlined statement. 1 

### Okay. Frank Stanonik. 2 

### MR. STANONIK: Frank Stanonik, AHRI. 3 

### All right. And the one thing that I 4 

### would -- I want to rephrase in terms of what 5 

### Ashley was saying is that she indicated that if 6 

### your rating, I think you said doesn't change or 7 

### is still valid -- I'm sorry, is still valid, that 8 

### in fact no retesting would be required. 9 

### And I would just want to emphasize, at 10 

### least I understand that to mean that if this 11 

### revised test just happened to, if you would, if 12 

### you had run it, raised your rating by some points 13 

### or whatever, that you could continue to use your 14 

### old rating under the idea that you now are 15 

### conservatively rating and it's still valid. 16 

### MS. ARMSTRONG: That is correct. 17 

### MR. STANONIK: Okay. 18 

### MS. ARMSTRONG: Our regulations allow for 19 

### that. 20 

### MR. STANONIK: Right. And one follow-up. 21 

### I certainly appreciate and agree with what Ashley 2287

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### has presented, but I'm going to ask that, I 1 

### think, we would need something a little more 2 

### formal from the legal counsel side of this. 3 

### Because, you know, again, the letter -- my 4 

### reading of the regulations says that your new -- 5 

### once a new test procedure, your rating has to be 6 

### based on testing to the new procedure. 7 

### And, Ashley, I think what you said would 8 

### allow that that may not totally be the case. And 9 

### so I think we would need to make sure that's 10 

### clear. 11 

### MR. BROOKMAN: Eric Stas. 12 

### MR. STAS: Eric Stas. 13 

### Will you please put that in your written 14 

### comments? And it will be addressed in the final. 15 

### MR. STANONIK: Okay. 16 

### MS. ARMSTRONG: So, I just want to go 17 

### back and address one point that Jim asked 18 

### earlier. And you said with regards to the 19 

### rounding, and I don't have a slide on this, and 20 

### I'm completely high-jacking the middle of this 21 

### presentation to go off key here. But, so excuse 2288

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### that. 1 

### But we actually got a request from AHRI 2 

### to do that. And the comment came in from Lennox 3 

### Carrier Rheem and AHRI supporting that, saying 4 

### that that's currently common industry practice. 5 

### That's why your comment at the beginning threw me 6 

### a little off guard with regards to the rounding. 7 

### MR. VERSHAW: Well, I try to do that 8 

### whenever I can, you know. 9 

### (Laughter.) 10 

### MS. ARMSTRONG: Well, you fully 11 

### accomplished it this time. 12 

### MALE VOICE: Good work, Jim. 13 

### MS. ARMSTRONG: Congratulations. 14 

### So I will say, if for some other reason 15 

### we misunderstood the request or the comments that 16 

### came in with regards to the RFI, please, please 17 

### do clarify that for us. Because that is not 18 

### something I anticipated. 19 

### MR. VERSHAW: Well, this is Jim VerShaw 20 

### again. 21 

### I guess if -- we try to follow the letter 2289

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### of the law, which says that you have two tests. 1 

### And if they're close enough together 2 

### statistically, take the average, and that's your 3 

### rating. And if we're rating something at 95.6 4 

### and the new test procedure makes it 95.5, one5 

### tenth lower, it's no longer a legal rating, 6 

### right? According to the way the rule is written. 7 

### MR. BROOKMAN: Frank Stanonik. 8 

### MR. STANONIK: I'm not going to ask -- 9 

### answer that question. 10 

### (Laughter.) 11 

### MR. STANONIK: But in regards to the 12 

### issue you've raised, Ashley -- and I'm going to 13 

### look to Ayk to confirm. But my understanding for 14 

### furnaces, we have continued to provide our 15 

### certification point reports to the nearest tenth. 16 

### Unfortunately, our friends at EPA and the 17 

### ENERGY STAR for boilers gummed up the works on 18 

### boilers. But on furnaces, we're still reporting 19 

### to the nearest tenth to DOE. And it's been 20 

### accepted. Well, because it was an influx thing. 21 

### MR. VERSHAW: And you'll find ratings -- 2290

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### this is Jim. 1 

### You'll find ratings from our products 2 

### that are in the tenths. Okay? 3 

### MS. ARMSTRONG: Well, then you do have 4 

### that test data. 5 

### (Laughter.) 6 

### MR. VERSHAW: And that's my concern. I 7 

### don't have the test data, the 2007. And if it 8 

### drops it by -- and if the average drops by a 9 

### tenth, and according to this, you've got 0.8 plus 10 

### just about -- it's about 0.3, 0.4 drop, on 11 

### average, you know, I don't know how we could 12 

### still rate it at that if it was down two-tenths. 13 

### MS. ARMSTRONG: So, I think your point is 14 

### taken. 15 

### MR. VERSHAW: Yeah. 16 

### MS. ARMSTRONG: So, given the discussion 17 

### we just had about when you have to retest, the 18 

### different, the three -- what I would call the 19 

### three different conditions, the clarifications 20 

### regarding rounding, think about it. And in your 21 

### written comments, please clarify, you know, if 2291

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### you do propose changes -- I mean if you do 1 

### support the proposed changes, but, you know, 2 

### believe -- you know, want more time, whatever it 3 

### is. Clarify your desire. 4 

### MR. VERSHAW: This is Jim again. 5 

### And again, going back to burden, we don't 6 

### know. We don't know if it's going to be higher 7 

### or lower until we run the test. And so, it puts 8 

### us in a real catch-22 if we're going to have to 9 

### run the test to find out if we don't have to run 10 

### the test. 11 

### (Laughter.) 12 

### MR. VERSHAW: And that's just -- that's 13 

### just -- something's wrong there. You know? And 14 

### then I guess, if you really want to gum up the 15 

### things, ASHRAE 103-2015 is going to be improved 16 

### over 2007, and there are some things in there 17 

### that you ought to consider adopting when it comes 18


### out. 19 

### MS. ARMSTRONG: Okay. 20 

### MR. BROOKMAN: Thanks. 21 

### Jeff, go ahead. 2292

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### MR. KLEISS: Jeff Kleiss, Lochinvar. 1 

### And just going back to the -- what the 2 

### DOES does require and doesn't require in terms of 3 

### existing data, I have folders behind my desk that 4 

### have the test data and the lower confidence level 5 

### calculation to verify our product ratings. 6 

### So, if I have those and those tests are 7 

### run to the old standard, and we adopt the new 8 

### standard, then what legal verification do I have 9 

### that those old ratings are valid to substantiate 10 

### my product to DOE should that question ever be 11 

### raised? 12 

### MS. ARMSTRONG: This is Ashley from DOE. 13 

### I think that gets to Frank's point, and 14 

### asked a little earlier, that Eric asked him to 15 

### put in writing with a little bit more detailed 16 

### confirmation. I'll pass on your concern-slash17 

### question to the proper person, which is Laura, to 18 

### potentially clarify as she may wish for you guys. 19 

### Okay? 20 

### MR. BROOKMAN: Okay. 21 

### Final comments? 2293

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### Frank, please. Final comments on this 1 

### segment, questions? We're due for a break. 2 

### Frank, before we go to break, go ahead. 3 

### MR. STANONIK: Frank Stanonik, AHRI. 4 

### One other question, because I didn't want 5 

### to forget it. And -- okay. In this part, 6 

### there's certainly a whole section where 7 

### essentially it is just some recalculations. And 8 

### I think it was Jeff or Diane, one of them 9 

### mentioned that in fact we have a very old AFUE 10 

### calculation tool. 11 

### I'm just curious. By any chance, is 12 

### there a tool that you use that might be available 13 

### for simply running that little group of 14 

### calculations to see what the difference is when 15 

### you plug in numbers X, Y, and Z? Just a 16 

### question. 17 

### MS. ARMSTRONG: You've asked me this for 18 

### a number of products now, Frank. 19 

### (Laughter.) 20 

### MS. ARMSTRONG: I think that's a great 21 

### thing that AHRI should do for their members. 2294

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### However, I will say that we did test at a 1 

### third-party lab. We did get them to use -- so I 2 

### have to go back and check. Typically, when we 3 

### test at third-party labs, we make them use these 4 

### like test data templates, which implement the 5 

### equations and in Excel-based format. I don't 6 

### know if we had one for this or if we actually had 7 

### them write everything out. I can't remember off 8 

### the top of my head. 9 

### If we have one, it will be posted online. 10 

### We make them all available online. If it's 11 

### online, obviously, you're welcome to use it as 12 

### you may wish. If we don't have one, I'm not sure 13 

### if we will be creating one or not. Typically, we 14 

### use them for all our verification enforcement 15 

### testing. It helps us get some things -- a level 16 

### of documentation there that both we desire, but 17 

### other people desire when they look at the test 18 

### data. 19 

### So, I'll get back to you and let you 20 

### know. 21 

### MR. STANONIK: All right. And -- Frank 2295

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### Stanonik, AHRI. 1 

### I mean, to Ashley's point and some good2 

### natured ribbing there, I will tell you that AHRI 3 

### certainly intends that, once we do have a revised 4 

### test procedure, we will be looking at creating a 5 

### new software tool, because it's time. Among 6 

### other things. 7 

### MS. ARMSTRONG: And we'd be happy to work 8 

### with you. 9 

### MR. STANONIK: Because the people who 10 

### know Fortran are far and few between anymore. So 11 

### we want to get it to at least the twentieth 12 

### century. 13 

### (Laughter.) 14 

### MS. ARMSTRONG: Yeah. Like I said, we'd 15 

### be happy to work with you on that. 16 

### MR. BROOKMAN: Aniruddh. 17 

### MR. ROY: Aniruddh Roy, Goodman. 18 

### Victor, I just have a question for you on 19 

### slide 26, on bullet 3. You mentioned standby and 20 

### off mode. So that would be consistent with IEC 21 

### 62301 (Second Edition)? 2296

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### MR. FRANCO: Second edition; that's 1 

### correct, yes. 2 

### MR. ROY: Okay. 3 

### MR. FRANCO: And there's no proposed 4 

### changes at this time. 5 

### MR. ROY: Okay. Thanks. 6 

### MS. ARMSTRONG: That's already in the 7 

### current test procedure now. 8 

### MR. BROOKMAN: Thank you, Ashley. 9 

### Let's take a break. It's now 2:40 by 10 

### that clock up there, which means we'll -- yeah. 11 

### Let's try 10 minutes. Yeah. Let's see if we can 12 

### do it in 10, which means at 2:51 we're going to 13 

### resume here in this room. You know where the 14 

### restrooms are. Make sure and wear your badges 15 

### visible here in the Forestal Building. 16 

### (Whereupon, at 2:40 p.m., a recess was 17 

### taken, to resume at 2:54 p.m.) 18 

### MR. BROOKMAN: Okay. Let's resume, then, 19 

### please. 20 

### I want to say that I think the 21 

### conversation has been really productive this 2297

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### afternoon already, and we hope that continues. 1 

### And we're going to pick up where we left off. 2 

### MR. DILLON: Great. Good afternoon. My 3 

### name is Ross Dillon, from Lawrence Berkeley 4 

### National Laboratory. 5 

### Next I'll be talking about the -- can you 6 

### hear me? 7 

### (Pause.) 8 

### MR. BROOKMAN: Thank you. Here we go. 9 

### MR. DILLON: I will be talking about the 10 

### measurement of condensate under steady-state 11 

### conditions. 12 

### The current test procedure requires the 13 

### establishment of steady-state conditions during a 14 

### minimum period of 30 minutes before measurement 15 

### of condensate. The measurement of condensate 16 

### requires an additional 30-minute period following 17 

### the establishment of steady-state. DOE's 18 

### proposed revision would allow the measurement of 19 

### condensate during the establishment of steady20 

### state conditions. This change impacts the test 21 

### procedure through a reduction in test burden 2298

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### resulting from shorter overall test duration. 1 

### The figures in this slide present the 2 

### test results from DOE's product testing. These 3 

### results reflect the condensate mass production of 4 

### a single condensing hot water boiler. This is a 5 

### single-stage unit. 6 

### This figure represents the combined 7 

### duration of the two tests per section 9.1 and 9.2 8 

### of ASHRAE 103-1993, which is incorporated by 9 

### reference. The orange shaded area is the first 10 

### 30-minute period during which steady-state 11 

### conditions are established. Is that orange 12 

### definitive? 13 

### (Simultaneous speaking.) 14 

### MR. DILLON: Okay. The second 30-minute 15 

### period is the additional 30 minutes required by 16 

### the current test procedure for the measurement of 17 

### condensate. As you will notice, the rate at 18 

### which condensate is produced remains constant 19 

### between the two periods, and the overall 20 

### collection distribution remains relatively 21 

### consistent. 2299

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### DOE requests comment on the proposal to 1 

### allow the measurement of condensate during the 2 

### establishment of steady-state conditions. 3 

### MR. VERSHAW: Jim VerShaw. 4 

### Am I reading it right, you've got 218 5 

### grams after it ran for 30 minutes and then took 6 

### it, versus 215 if you took it during the time? 7 

### MR. DILLON: Correct. That's the total 8 

### value during each period. 9 

### MR. VERSHAW: So, is this going to be an 10 

### optional shortening? If we want to just get 11 

### every gram of water we could, we would wait and 12 

### do 30 minutes and then do it? 13 

### MR. DILLON: The test procedure will 14 

### allow -- it proposes to allow it to collect 15 

### condensate during the establishment of steady16 

### state. However, I believe your -- 17 

### MR. VERSHAW: So, but if I don't want to 18 

### shorten my time. If I want to get three more 19 

### grams of water, can I establish steady-state, 20 

### then take 30, then do a condensate collection? 21 

### MR. DILLON: That's up to you. 22100

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### MR. VERSHAW: Okay. 1 

### MS. ARMSTRONG: I wouldn't -- so if 2 

### that's what you want to do -- this is Ashley from 3


### DOE. 4 

### The way I read the test procedure, it 5 

### doesn't exclusively allow that. So if that's 6 

### what you want the option of doing, you should 7 

### make that clear. Sounds like that's a yes. 8 

### MR. BROOKMAN: Diane. 9 

### MR. VERSHAW: I'll make it clear. 10 

### MS. ARMSTRONG: Okay. Thanks. 11 

### MS. JAKOBS: This is Diane from Rheem. 12 

### And that was the reaction I got in our 13 

### lab, that it's more important to make sure 14 

### everything is on the correct temperature. And 15 

### they want to make sure that our tests are 16 

### repeatable. And, you know. 17 

### MS. ARMSTRONG: So you want the freedom 18 

### to go longer if you want to? Recognizing that -- 19 

### I will say, with this proposal, DOE would do the 20 

### first 30. So that's okay for you? 21 

### MR. VERSHAW: Well, I don't know about 22101

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### that. 1 

### (Laughter.) 2 

### MS. ARMSTRONG: Fair enough. Thanks a 3 

### lot. 4 

### (Laughter.) 5 

### MR. BROOKMAN: Yes, please, Ayk. 6 

### MR. YILMAZ: Ayk Yilmaz, AHRI, again. 7 

### I just want to clarify how this data was 8 

### taken. Was it -- was all the water, or rather 9 

### all the condensate collected cumulatively? And 10 

### then the intervals are just subtractions between 11 

### each measurement interval? 12 

### MR. DILLON: No. It was 30-second 13 

### interval measurements. 14 

### MR. YILMAZ: So then, I mean, I guess, 15 

### with regard to that cup that you're collecting it 16 

### in, supposedly, are you emptying it after every 17 

### 30 seconds and then filling it back up and 18 

### measuring it? 19 

### MR. DILLON: I believe the interval 20 

### measurement weight was the difference between the 21 

### total weight at the initial 30 seconds and the 22102

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### total weight at the following 60 seconds. 1 

### MR. YILMAZ: I got you. But you're 2 

### keeping all that water in the container? 3


### MR. DILLON: Correct. 4 

### MR. YILMAZ: Okay. Thank you. 5 

### MR. BROOKMAN: Judd Smith has a comment. 6 

### Joining us online, Judd should now be unmuted. 7 

### MR. SMITH: Hello. Can you hear me? 8 

### MR. BROOKMAN: Yes. Sounds good. 9 

### MR. SMITH: Yeah, as the test lab, I 10 

### would prefer to do one or the other and not have 11 

### an option. Because we might test it wrong. If 12 

### one manufacturer wants the 30 minutes after 13 

### steady-state, or the 30 minutes during steady14 

### state. We won't get that right. We'll adjust up 15 

### to 15, we'll get 100 percent wrong. 16 

### MR. BROOKMAN: Make sure and include it 17 

### in your comments, Judd. 18 

### MR. SMITH: Okay. 19 

### MR. VERSHAW: This is Jim VerShaw again. 20 

### MR. BROOKMAN: Jim, please. 21 

### MR. VERSHAW: This is a boiler. Boilers 22103

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### act a lot different than furnaces. You don't 1 

### have any data on what happens if you do a furnace 2 

### in 30 minutes during the heat-up cycle? Because, 3 

### you know, the heat exchangers are getting boiler 4 

### -- boiler, the water temperature stays about the 5 

### same the whole time. And you've got a really 6 

### nice condensing system there, and it's not going 7 

### to make a whole lot of difference, I think, to 8 

### the little bit I've done with boilers back in the 9 

### 1900s. 10 

### (Laughter.) 11 

### MR. VERSHAW: Yeah, they had rivets 12 

### holding them all together. 13 

### (Inaudible interjections and laughter.) 14 

### MR. VERSHAW: But furnaces start off 15 

### cold, and you might get more water than you would 16 

### normally. That might -- you know, might be a 17 

### good thing. Maybe I want to do the first 15 18 

### minutes and not the next 30. I mean, I wish you 19 

### had data for that to say this was really a good 20 

### idea. I don't. I don't know. 21 

### MS. ARMSTRONG: Okay. 22104

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### MR. BROOKMAN: Thanks, Jim. 1 

### Harvey Sachs. 2 

### MR. SACHS: It's many decades ago that I 3 

### took calculus and had to think about some of 4 

### these things. But it seems to me that in 2015, 5 

### you could define it by the trend becoming 6 

### constant, that you're converging on a moving 7 

### average, this within 1 percent of the same 8 

### addition or X percent, and that that's really 9 

### what you're trying to do. So you can truncate 10 

### when you're confident instead of either arbitrary 11 

### interval. 12 

### And that would take care of Jim's 13 

### concerns. It would take care of the boiler14 

### versus-furnace. And it could be written out as a 15 

### pretty simple statement that would be available. 16 

### MR. BROOKMAN: Okay. 17 

### MR. SACHS: I can't write it out. 18 

### MR. BROOKMAN: Okay. Thank you, though. 19 

### Additional thoughts, comments on 20 

### condensate? 21 

### Yes. Diane. 22105

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### MS. JAKOBS: I was just thinking if you 1 

### can imagine we run a pilot run. We have a whole 2 

### bunch of furnaces. We storm outside in the lean3 

### to. And it might even be cold in Arkansas. But 4 

### there's a variety of temperatures, you know, and 5 

### we just really -- it's an area of variation that 6 

### we might not be familiar with now. And I guess 7 

### we're a little worried about what it would 8 

### introduce. So, thank you. 9 

### MR. BROOKMAN: Okay. Thank you. 10 

### MR. SACHS: This is Harvey. And, Diane, 11 

### please accept my suggestion as for the next 12 

### version of 103. 13 

### (Laughter.) 14 

### MR. BROOKMAN: Okay. We're moving on. 15 

### MR. DILLON: The next topic is related to 16 

### the electrical consumption of auxiliary 17 

### components. The current test procedure does not 18 

### capture all the electrical consumption of a 19 

### boiler or furnace. The current test procedure 20 

### measures only the blower or circulation pump 21 

### power, the inducer, blower power, the ignition 22106

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### power, and the standby mode and off mode power. 1 

### These measurements may not capture all 2 

### the electrical consumption of a boiler or 3 

### furnace. DOE's proposed revision includes the 4 

### measurement of additional electrical auxiliary 5 

### components consisting of the secondary pump, if 6 

### present, the gas valve, and the controls. 7 

### Included in this slide is an example 8 

### calculation of the average annual electrical 9 

### energy consumption, expressed as E-sub-AE, for a 10 

### single-stage furnace or boiler. The highlighted 11 

### terms represent the measured power of the 12 

### additional components, where B-s represents the 13 

### measured electrical power of the secondary pump 14 

### and E-sub-O represents the measured power of the 15 

### other components, in other words, the gas valve 16 

### and the controls. 17 

### Also included are two additional Y terms, 18 

### Y-S and Y-sub-O, which account for the ratio of 19 

### the components’ on-time to the average burner on20 

### time. 21 

### The figure in this slide presents the 22107

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### test results from DOE's product testing related 1 

### to the measurement of component electrical power 2 

### for the high and reduced fire of a two-stage 3 

### furnace model. The figure presents the measured 4 

### power in watts for each of the electrical5 

### consuming components. According to these 6 

### results, there is measureable auxiliary 7 

### electrical power associated with components not 8 

### captured by the current test procedure 9 

### requirements. 10 

### As noted by the red highlighted area, 11 

### these components account for 7 percent and 11 12 

### percent of the total electrical power for the 13 

### high and reduced fire, respectively. 14 

### DOE requests comment on the proposed 15 

### changes, to include measurement of additional 16 

### component electrical power for calculating the 17 

### annual auxiliary electrical use. 18 

### MR. BROOKMAN: Yes. Michael McCabe. 19 

### MR. McCABE: Mike McCabe. 20 

### It's more of a question, including for 21 

### DOE ENERGY -- excuse me, EPA ENERGY STAR and the 22108

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### FTC labeling. But do you know if those two 1 

### programs include the requirement that 2 

### manufacturers report not only AFUE but also 3 

### annual energy use? 4 

### MR. BROOKMAN: Diane. 5 

### MS. JAKOBS: Diane. 6 

### The E-sub-AE is used in the calculation 7 

### of little e, which is part of the ENERGY STAR 8 

### requirement. But it's a ratio. It's the 9 

### electrical consumption over the sum of the 10 

### electrical consumption and the gas consumption. 11 

### So we get the 2 percent. But it's part of the 12 

### calculation, but it's not specifically required. 13 

### It's kind of a -- the number depends on the 14 

### capacity. So it's hard to put it in perspective. 15 

### MR. McCABE: Because if the manufacturers 16 

### have to include in the AHRI directory, which 17 

### satisfies the FTC labeling requirements -- have 18 

### to include the annual energy use, then the 19 

### addition of these additional electrical energy 20 

### use is going to change the measure of annual 21 

### energy use for most, if not all, products. Would 22109

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### it not? 1 

### MR. DILLON: It depends. It depends on 2 

### how the electrical use is currently being 3 

### measured by the manufacturer. 4 

### MR. BROOKMAN: Frank Stanonik. 5 

### MR. STANONIK: Frank Stanonik, AHRI. 6 

### That may be the case. But certainly, 7 

### presenting this information -- maybe not. I 8 

### guess I'm trying to understand why it was felt 9 

### that you needed to identify the electrical energy 10 

### separately of the gas valve and the controls, 11 

### because from my understanding, when you look at 12 

### PE, the burner electrical power, and as it's 13 

### measured, I don't see how you are not inherently 14 

### measuring whatever energy is going on at the 15 

### controls, because the controls have to be 16 

### operating for the burner to operate. 17 

### And that's electrical -- if there is 18 

### electrical consumption, my understanding is that 19 

### you'd be getting that -- you'd be getting that 20 

### energy consumed as you measured PE. Is that not 21 

### the case? 22110

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### MR. BROOKMAN: I saw Diane first. 1 

### MS. JAKOBS: This is Diane. 2 

### And there is actually a diagram and how 3 

### you wire up the test -- 4 

### THE COURT REPORTER: Is your mic on? 5 

### MS. JAKOBS: Oh. I turned it up. I 6 

### don't know what I did. But anyway -- 7 

### MR. BROOKMAN: There is actually a 8 

### diagram. 9 

### MS. JAKOBS: So it's Diane Jakobs. 10 

### And I would say in our listings, E-sub-AE 11 

### includes the control and the gas valve. It's 12 

### everything else except the blower, is the way we 13 

### have interpreted the standard. 14 

### MR. BROOKMAN: Okay. Jeff. 15 

### MR. KLEISS: Jeff Kleiss, Lochinvar. 16 

### And I would say with all the burner -- or 17 

### boiler manufacturers that I have worked for, we 18 

### have done the total electrical power consumption 19 

### at the hookup for the boilers. So that includes 20 

### the controls, the gas valve, all the components 21 

### are captured in that measurement. 22111

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### So I would want to be clear that if 1 

### adopting this change is not going to require us 2 

### to go back and now hook up and read individual 3


### measurements. 4 

### MR. BROOKMAN: Okay. Frank? 5 

### MR. STANONIK: Well, I'll let DOE answer. 6 

### Well, okay. I mean -- Frank Stanonik, AHRI. 7 

### I mean, to Jeff's point, again, reading 8 

### this slide and this example calculation, they are 9 

### introducing EO, which would be a separate 10 

### measurement of your gas valve consumption. So, 11 

### to me, the intent clearly is they would make you 12 

### measure that separately. And I guess -- 13 

### MS. ARMSTRONG: I think -- so this is 14 

### Ashley from DOE. 15 

### I think the intent is, I think what we 16 

### found is that people aren't doing it the same 17 

### way. So what we are doing is making it explicit 18 

### that it should be all electrical consuming, like 19 

### you have been taking your measurements now. 20 

### So, to Jeff's point, if he has been 21 

### taking them that way all along, his ask is, DOE, 22112

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### can you clarify that my measurement is valid? 1 

### And so we will take that back. 2 

### MR. BROOKMAN: Okay. Thank you for that 3 

### clarification. 4 

### Yes, Ayk. 5 

### MR. YILMAZ: Ayk Yilmaz, AHRI, again. 6 

### Just to address a different point, which 7 

### is a secondary boiler pump electrical energy 8 

### consumption, you had stated that we're going to 9 

### be using a measured pump consumption for the BE. 10 

### But in fact, under the current 103-2007, the 11 

### primary energy BE is a nameplate pump energy; 12 

### it's not a measured pump energy. 13 

### And I guess I completely missed the 14 

### addition on this when I was going through it, 15 

### because there wasn't any addressing of test 16 

### apparatus or test setup and how to measure pump 17 

### power consumption. So, what I would, without 18 

### having really thought about this too, too much, 19 

### but what I would recommend is to consider 20 

### defining secondary pump energy the same way 21 

### primary pump energy is defined, which is by the 22113

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### nameplate. 1 

### MR. BROOKMAN: Thank you. Okay. 2 

### Yes, Aniruddh. 3 

### MR. ROY: Aniruddh Roy, Goodman. 4 

### Just on slide 33, could you just explain 5 

### the 7 and 11 percent, again? 6 

### MR. DILLON: The 7 percent is related to 7 

### the electrical power measurements of the high 8 

### fire for the controlling gas valve. So it's 7 9 

### percent of the total consumption and 11 percent 10 

### of the reduced-fire electrical consumption, 11 

### electrical power. 12 

### MR. BROOKMAN: Are we ready to move on 13 

### now? Okay. 14 

### MR. DILLON: The next -- 15 

### MR. BROOKMAN: Oh, pardon me, I missed -- 16 

### okay, no. Please proceed. 17 

### MR. DILLON: The next topic is the 18 

### proposal of the smoke stick test for verifying 19 

### flow through the heat exchanger. The current 20 

### test procedure has three approaches for 21 

### determining the value used for the off-cycle flue 22114

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### gas draft factor. 1 

### The first method measures the draft 2 

### factor using the tracer gas test. However, the 3 

### tracer gas test may produce unreliable results 4 

### for a draft factor of less than 0.1. In place of 5 

### conducting the tracer gas test, the DOE test 6 

### procedure prescribes default draft factors. 7 

### For units designed such that there is 8 

### absolutely no air flow through the heat 9 

### exchanger, a minimum default draft factor of 0.05 10 

### is allowed. With respect to the use of the 11 

### minimum default draft factor, the current test 12 

### procedure does not provide a method for 13 

### establishing absolutely no air flow. DOE's 14 

### proposed revision prescribes the use of a smoke 15 

### stick test to verify the absence of flow through 16 

### the heat exchanger. 17 

### Following execution of the smoke stick 18 

### test, two paths will be followed. If no visual 19 

### disturbance of smoke is demonstrated, the use of 20 

### a minimum default draft factor is allowed. If a 21 

### visual disturbance of smoke is demonstrated, then 22115

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### either the tracer gas test would be performed or 1 

### the default draft factor would be used. 2 

### In addition to the smoke stick test, DOE 3 

### is proposing to remove, in the test procedure, 4 

### the term "absolutely" when referencing to no air 5 

### flow through the heat exchanger. 6 

### MR. BROOKMAN: Jim. 7 

### MR. VERSHAW: Yeah, Jim VerShaw. 8 

### Can you describe how that test would be 9 

### run with the smoke stick and what a smoke stick 10 

### is? 11 

### (Inaudible interjections and laughter.) 12 

### MR. BROOKMAN: For the record, Jim says 13 

### they don't allow smoke in the building -- smoking 14 

### in the building. 15 

### MR. DILLON: Oftentimes, there is puffer, 16 

### puffer sticks are used for smoke stick tests. 17 

### And the test is described further in detail in 18 

### Appendix N of the NOPR. 19 

### And essentially, what the test prescribes 20 

### is to, based on a minimum height and a minimum 21 

### distance away from the combustion intake, you 22116

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### place the stick following, I think it's two or 1 

### three minutes after the boiler has been shut off. 2 

### And you would visually observe to make sure that 3 

### there's no induction of air into the combustion 4 

### air intake. 5 

### MR. BROOKMAN: Yes, Jeff. 6 

### MR. KLEISS: Jeff Kleiss, Lochinvar. 7 

### And I kind of get where you're going with 8 

### that. But I personally say thank you for this. 9 

### There's been some -- I've had arguments, 10 

### discussions with third-party labs about a valid 11 

### method, what they would accept for testing the 12 

### presence of draft. And this clarification will 13 

### be of significant value to us and help to 14 

### simplify our testing. 15 

### MS. ARMSTRONG: This is Ashley from DOE. 16 

### And I think Jeff just explained very well 17 

### why we ended up proposing it. We had similar 18 

### issues with different things we were seeing at 19 

### labs. So, perhaps Jim has a better way to do it. 20 

### Open to it. But there was a problem that we were 21 

### seeking a solution for, and this is the proposal 22117

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### that we went out with. 1 

### MR. BROOKMAN: So, Jeff, thanks for that 2 

### comment. That's helpful. That is. 3 

### Jim? 4 

### MR. VERSHAW: I just missed this one. I 5 

### was just asking questions about it. So that's 6 

### all. Yeah, I was more concerned about air flow 7 

### in the lab and how we're going to do that. 8


### MS. ARMSTRONG: So I -- 9 

### MR. VERSHAW: And if somebody can fix 10 

### their venting such that it doesn't -- you know -- 11 

### MS. ARMSTRONG: So this is Ashley from 12 

### DOE. Points well taken. We had issues with the 13 

### tracer gas as well. So, I don't know that, you 14 

### know... This was the best solution we came up with 15 

### and that's why we proposed it. Obviously, we're 16 

### open to other ones. But we did see a problem 17 

### here that we were trying to fix. 18 

### MR. BROOKMAN: Okay. We're moving on. 19 

### MR. DILLON: The next topic applies to 20 

### the test ductwork for units that are installed 21 

### without a return duct. For units that have been 22118

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### designed to be installed without a return duct, 1 

### DOE believes that the test setup requirements are 2 

### not sufficiently specific. 3 

### The current test procedure specifies the 4 

### use of a return duct for all furnaces according 5 

### to the incorporated-by-reference section 7.2.1 of 6 

### ASHRAE 103-1993. DOE proposes to not require a 7 

### return duct during testing of units intended to 8 

### be installed without a return duct. 9 

### DOE requests comment on the proposal to 10 

### add a provision to the test procedure, clarifying 11 

### that the return duct is not required during 12 

### testing for units intended to be installed 13 

### without a return duct, according to the 14 

### manufacturer's I and O manual. DOE requests -- 15 

### MR. BROOKMAN: Comments? Comments here? 16 

### (No audible response.) 17 

### MR. BROOKMAN: Robert Glass asks, How 18 

### does one calibrate a smoke stick under ISO lab 19 

### certification? 20 

### (Laughter.) 21 

### MS. JAKOBS: Thank you, Robert. 22119

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### (Laughter.) 1 

### MR. BROOKMAN: I should note that there 2 

### is a little bit of chuckling in the room. Okay. 3 

### We'll get a move-on then. 4 

### MR. DILLON: The next topic applies to 5 

### the test requirements for multi-position 6 

### configurations. It is common practice that some 7 

### furnaces may be designed such that they can be 8 

### installed in multiple configurations -- in other 9 

### words, up-flow, down-flow, horizontal flow. For 10 

### these types of furnaces, DOE believes that the 11 

### test setup requirements in the current test 12 

### procedure are not sufficiently specific. 13 

### DOE proposes to require that the multi14 

### position furnaces be tested using, at a minimum, 15 

### the least-efficient position. DOE is also 16 

### proposing to allow testing using the blower door 17 

### instead of one of the inlet openings for 18 

### multiple-position furnaces shipped with no inlet 19 

### opening. 20 

### DOE requests comment on its proposal to 21 

### allow testing of units configured with multiple 22120

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### position installations to use a blower access 1 

### door as an option instead of one of the inlet 2 

### openings. 3 

### MS. ARMSTRONG: So, this is Ashley from 4 

### DOE, just to explain a little bit further where 5 

### this came from. 6 

### When we went to a lab to do furnace fan 7 

### testing, these questions came out of it. And so, 8 

### there were some questions provided to DOE about, 9 

### what do we do for furnaces? Because there is 10 

### some specificity in the furnace fan test 11 

### procedure, and what this is aimed to do is 12 

### provide some harmonization there. 13 

### MR. VERSHAW: Well, this is Jim VerShaw. 14 

### We go to a lot of lengths to make sure 15 

### the blower door is not open when we run a 16 

### furnace. On our furnaces, the upper door won't 17 

### stay on if you have the lower door off. And then 18 

### you have to tape or jumper out the door switch. 19 

### We -- I'm not so sure, I'm not sure, I don't 20 

### think I've seen a furnace without an inlet. 21 

### MS. ARMSTRONG: So, there was one brought 22121

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### up. So the question was asked; I can tell you 1 

### that for certain. 2 

### MR. VERSHAW: Okay. 3 

### MS. ARMSTRONG: What would you do? So if 4 

### you have one, we're going to use open inlet, no 5 

### issue. But if you don't, the question was asked 6 

### of DOE, "What do we do?" And so this is our 7 

### clarification there. 8


### MR. BROOKMAN: Dave? 9 

### MR. WINNINGHAM: This is Dave. 10 

### There are some products where it's got 11 

### like maybe a bottom knock-out, or, you know, 12 

### where the side -- 13 

### MR. VERSHAW: We've got a panel that you 14 

### have to take out. Yeah. 15 

### MS. ARMSTRONG: The panels and the knock16 

### outs, I wouldn't call -- 17 

### MR. VERSHAW: It's not open. 18 

### MS. ARMSTRONG: This wasn't a situation 19 

### exactly we were dealing with. 20 

### MR. VERSHAW: Okay. 21 

### MS. ARMSTRONG: Fully. But this exact 22122

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### question was asked of DOE. 1 

### MR. BROOKMAN: Frank Stanonik. 2 

### MR. STANONIK: Frank Stanonik, AHRI. 3 

### Without knowing the magnitude of the 4 

### effect, this one clearly is -- would require some 5 

### models to be rerated, just assuming that since 6 

### the requirement now spells out that you're going 7 

### to have to test it at least, at a minimum, at the 8 

### least-efficient position, which would suggest 9 

### that it wasn't as clear before. 10 

### This, you know, again, this seems to 11 

### clearly would require rerating of some products. 12 

### That is going to get into the issue of, you know, 13 

### whether they are meeting the minimum. 14 

### MS. ARMSTRONG: Yes. So this is Ashley 15 

### from DOE. 16 

### That is my understanding of what is done 17 

### now. Obviously, I welcome comments on that. 18 

### That is the suggestion we got for clarification 19 

### from the industry. So, that was what I was 20 

### understanding was being done today anyway. So it 21 

### was our understanding that it would not impact 22123

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### ratings, as you suggest. But like I said, I 1 

### could be wrong. 2 

### MR. STANONIK: Frank Stanonik, AHRI. 3 

### Now, actually, I also believe that's what 4 

### was being done today. And I was a little 5 

### concerned because when DOE raised it, it raised 6 

### the question, was somebody doing it differently? 7 

### Okay. Okay. 8 

### MS. ARMSTRONG: No, no. I think that's 9 

### fair. Thanks. We agree. 10 

### MR. BROOKMAN: Thanks, Frank. 11 

### MR. DILLON: The next topic is the 12 

### proposal of the verification test for automatic 13 

### means for adjusting the water temperature in hot 14 

### water boilers. In 2008, DOE published a 15 

### technical amendment to add design requirements 16 

### for hot water boilers consistent with the 17 

### provisions of EISA 2007. 18 

### The design requirements require an 19 

### automatic means for adjusting the water 20 

### temperature for gas-fired, oil-fired, and 21 

### electric hot water boilers. DOE's proposed test 22124

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### method would be used only in the case of 1 

### assessment and enforcement testing by DOE, which 2 

### is to be specified in 10 CFR 429.134. Currently, 3 

### there is no test for functional verification of 4 

### automatic means. DOE's proposed revision 5 

### includes separate verification methods for hot 6 

### water boilers with single-stage and two-stage 7 

### modulating control. 8 

### DOE believes this allows for the 9 

### necessary verification of boiler automatic means 10 

### functionality. Also, manufacturers do not have 11 

### to conduct this testing. These verification 12 

### methods will be used by DOE to determine if a 13 

### given basic model complies with the applicable 14 

### design requirements. 15 

### MR. BROOKMAN: Jeff. 16 

### MR. KLEISS: Jeff Kleiss, Lochinvar, of 17



### course. 18 

### The first comment that I have about this 19 

### is the test procedure that you have for single20 

### stage boilers is verification of whether or not 21 

### there's -- the call for heat is satisfied by 22125

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### residual heat in the boiler. That is an optional 1 

### method for automatic means for single-stage 2 

### appliances. It is not the only allowed means. 3 

### And yet, the test procedure that you have 4 

### written here, that is the only allowable means to 5 

### verify automatic means -- compliance. That needs 6 

### to be changed. 7 

### MS. ARMSTRONG: So, explain to me what 8 

### your options are now. 9 

### MR. KLEISS: Currently, the requirement 10 

### for automatic means is that you would adjust your 11 

### temperature set point based on demand or heat 12 

### load requirement, which is your test procedure 13 

### that you have for multi-, two-stage, and 14 

### modulating products. 15 

### And then, there is an option within the 16 

### automatic means clause that single-stage 17 

### appliances may check for meeting the heating 18 

### requirement with residual heat in the boiler. 19 

### That is an option. 20 

### So, what I'm saying is that the test to 21 

### determine if you're complying with automatic 22126

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### means for single-stage boilers should not only be 1 

### based on residual heat in the boiler. But they 2 

### should be allowed to be tested by the same test 3 

### procedure as the two-stage and modulating 4 

### boilers. 5 

### MS. ARMSTRONG: All right. Thank you. 6 

### MR. BROOKMAN: Yes, Frank. 7 

### MR. STANONIK: Frank Stanonik, with AHRI. 8 

### Again, I appreciate what's been said here 9 

### as far as the impact. But again, I'm getting 10 

### tangled up in what I believe are the regulations. 11 

### So, it was mentioned at the end that 12 

### manufacturers do not have to conduct this 13 

### testing. It will be how DOE will determine if a 14 

### model complies with the design requirements, but 15 

### if I'm submitting a certification report to DOE, 16 

### don't have to do it? 17 

### MS. ARMSTRONG: Don't have to do it. 18 

### MR. STANONIK: Don't have to do it. 19 

### Okay. All right. Right. 20 

### MS. ARMSTRONG: So, this is Ashley from 21


### DOE. 22127

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### So, this is kind of new territory for DOE 1 

### in the past couple of years. So perhaps I can 2 

### explain a little bit. It is a design standard. 3 

### As you certify today, you certify compliance with 4 

### that design standard. It's more or less an 5 

### affirmation that you've manufactured the product 6 

### and it complies with that design standard. 7 

### So, Frank, we're not looking for anything 8 

### from the test. We're not even looking for the 9 

### test data for you. However, if we get a 10 

### complaint, if we purchase a product for 11 

### assessment or verification purposes, we will run 12 

### this test to assess whether you comply with that 13 

### design standard. This is how we are going to 14 

### gauge it. 15 

### So this is so you know, so you don't have 16 

### to run it. But if you want to know what we're 17 

### going to do, and obviously you should know what 18 

### we're going to do, this is a method we will be 19 

### running. Does that help? 20 

### MR. BROOKMAN: That was clear. That 21 

### explains it. 22128

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### Please, Jeff. 1 

### MR. KLEISS: Jeff Kleiss, Lochinvar. 2 

### To that end, there is -- the method is 3 

### fairly vague as far as -- and I know that's 4 

### intentional, because there's a wide variety of 5 

### different methods of automatic -- satisfying 6 

### automatic means. 7 

### But within that, there is no -- nothing 8 

### is listed as far as what is required to comply. 9 

### There's a test method. And you get a result out 10 

### of the test method of a certain time that it 11 

### takes, the delay, for the burner to come on or 12 

### something like that. But there's no indication 13 

### of what does and does not constitute compliance. 14 

### MS. ARMSTRONG: Got it. Thank you. 15 

### MR. KLEISS: And if I may continue, I do 16 

### have some concern as a participant in a VICP 17 

### [voluntary industry certification program]. And 18 

### we submit data, and we fill in a check-box to 19 

### say, yes, we do have an automatic means. Is this 20 

### something that will become a requirement that if 21 

### you're participating in a VICP, that at some 22129

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### point we're going to have to test to this rather 1 

### than fill in our check-box? 2 

### MR. BROOKMAN: Say what a VICP is. 3 

### MR. KLEISS: Voluntary Industry 4 

### Certification Program. 5 

### MR. BROOKMAN: Got you. Thank you. 6 

### MS. ARMSTRONG: So, I don't think that's 7 

### for DOE to answer, per se . I think that's 8 

### dependent upon your VICP. I mean, that's -- the 9 

### VICPs are run by the industry programs. What 10 

### we're just trying to do here is make it crystal 11 

### clear in the cases of when we get into an 12 

### assessment or an enforcement setting, how we are 13 

### going to judge you. 14 

### So your points are well taken about some 15 

### of the ambiguities that may be in the test 16 

### procedure as it was proposed, and we will look 17 

### into that. But I don't think DOE has any comment 18 

### on the requirements of a VICP. 19 

### MR. KLEISS: Jeff Kleiss, Lochinvar. 20 

### And just from that standpoint, DOE does 21 

### have certain requirements to accept data from a 22130

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### VICP, and I guess that's where I'm directing my 1 

### question. 2 

### MS. ARMSTRONG: Okay. So, this is Ashley 3 

### from DOE. 4 

### So that's just certification data. And 5 

### so that would go back to Frank's question. This 6 

### test is not being proposed as a certification 7 

### test that you need to do in advance of certifying 8 

### your products and distributing in commerce. It's 9 

### still going to have a check-box. There was no 10 

### companion change to the cert report here. 11 

### But this is just purely a verification 12 

### and enforcement test, which is why you see it 13 

### located in 429.134 instead of in the Appendix 14 

### with the test procedure. 15 

### MR. BROOKMAN: Okay. Thank you, Ashley. 16 

### Additional questions, comments, before we 17


### move on? 18 

### (No audible response.) 19 

### MR. BROOKMAN: Okay. 20 

### MR. DILLON: All right. Great. 21 

### The following slide includes details 22131

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### related to the design requirements for hot water 1 

### boilers and the known methods used to fulfill 2 

### those requirements. The requirements and methods 3 

### apply separately to the type of boiler, single4 

### stage and two-stage. The design requirement for 5 

### single-stage hot water boilers specifies that the 6 

### requirement may be satisfied by providing an 7 

### automatic means that allows the burner or heating 8 

### element to fire only when the means has 9 

### determined that the inferred heat load cannot be 10 

### met by the residual heat of the water in the 11 

### system. 12 

### DOE's understanding is that the common 13 

### method for fulfilling this requirement is what is 14 

### referred to as thermal pre-purge. This method 15 

### delays burner activation until the residual heat 16 

### of the boiler water cannot meet the heating load, 17 

### thus using no fuel when operating using residual 18 

### heat. 19 

### The design requirement for two-stage and 20 

### modulating hot water boilers specifies that 21 

### controls will automatically adjust the 22132

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### temperature of the water supplied by the boiler 1 

### to ensure that an incremental change in inferred 2 

### heat load produces a corresponding incremental 3 

### change in the temperature of water supply. 4 

### There are two commonly used methods for 5 

### fulfilling this requirement -- outdoor reset and 6 

### inferred load. The outdoor reset method adjusts 7 

### supply water temperature in response to changes 8 

### in outdoor air temperature, resulting in lower 9 

### fuel input at higher outdoor air temperatures. 10 

### The inferred load method uses outdoor and indoor 11 

### temperature, thermostat demand, and/or burner 12 

### cycling patterns to infer heating load and adjust 13 

### the supply water temperature, resulting in lower 14 

### fuel input at lower inferred loads. 15 

### The figure in this slide presents the 16 

### test results from DOE's product testing 17 

### associated with the proposed test for 18 

### verification of automatic means for single-stage 19 

### hot water boilers. The intent of this test is 20 

### for a boiler containing residual heat to verify a 21 

### delay in burner ignition following a call for 22133

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### heat. 1 

### Supply water temperature is presented by 2 

### the red dotted line. Inlet water temperature is 3 

### presented by the blue dotted line, and gas 4 

### consumption is presented by the green dotted 5 

### line. 6 

### After the boiler is set up according to 7 

### the prescribed method, the warm-up and 8 

### stabilization period occurs and is represented by 9 

### the gradual increase in supply water temperature 10 

### at the point of stabilization, which occurs at 11 

### the first box. After temperature stabilization, 12 

### the call for heat is terminated at the next box. 13 

### The test method allows a delay of up to 14 

### three minutes prior to re-initiating the call for 15 

### heat. After the time delay, the call for heat is 16 

### re-initiated. Immediately after the call for 17 

### heat, the burner was monitored for ignition. A 18 

### delay in burner ignition was observed of roughly 19 

### 45 seconds in this case, which is shown by the 20 

### elapsed time between the call for heat and the 21 

### burner ignition, the last two boxes. 22134

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### The figure in this slide presents the 1 

### test results from DOE's product testing, 2 

### associated with the proposed test for 3 

### verification of automatic means for two-stage and 4 

### modulating hot water boilers, utilizing the 5 

### outdoor temperature reset method. 6 

### The purpose of this test is to observe 7 

### the response in supply water temperature as a 8 

### result in change in outdoor air temperature. 9 

### Supply water temperature is presented by the red; 10 

### inlet temperature presented by the purple line; 11 

### gas consumption, by the orange; and simulated 12 

### outdoor temperature, by the green. 13 

### After the boiler is set up, warm-up 14 

### initiated, and water temperature is stabilized 15 

### according to the prescribed test method, the next 16 

### step would be to activate the automatic means 17 

### functionality, if that's necessary. 18 

### At the first box, the next step was to 19 

### establish the simulated low inferred load 20 

### conditions as presented by the high outdoor air 21 

### temperature, which is seen on the first arrow on 22135

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### the green line. 1 

### The next step was to establish the low -- 2 

### pardon me. Following the simulation of low 3 

### inferred load conditions, the supply water 4 

### temperature was allowed to stabilize. Once 5 

### stabilized, the next step consisted of 6 

### establishing the high inferred load conditions, 7 

### which occur down here at the second arrow on the 8 

### green line. 9 

### The high inferred load conditions were 10 

### established by placing the outdoor air 11 

### temperature sensor in an ice bath. Following 12 

### placement of the outdoor temperature sensor into 13 

### the ice bath, it was observed that the supply 14 

### water temperature began increasing after a short 15 

### delay. Once the supply temperature stabilized, 16 

### the test was complete. 17 

### (Pause.) 18 

### MS. ARMSTRONG: I'm going to pause here. 19 

### Does anyone have any last-minute questions on the 20 

### verification procedures before we go to our 21 

### closing remarks and kind of wrap up for the day? 22136

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### Sure. 1 

### MS. JAKOBS: This is Diane from Rheem. 2 

### And on slide 32, I don't know if I wasn't 3 

### paying attention. But you added a couple of new 4 

### terms to the equation for E-sub-AE. And it's 5 

### related to the ignition. Is that right? That's 6 

### the way I -- 7 

### MR. DILLON: This is Ross Dillon. 8 

### The BE-sub-S term is for the secondary 9 

### pump if present. And the E-sub-O term is for the 10 

### gas valve and controls. 11 

### MS. ARMSTRONG: So, Diane, to your point 12 

### earlier -- this is Ashley -- you raised, said 13 

### that's the way you were testing all along, that 14 

### you were already incorporating that electrical 15 

### consumption of your valves holistically into the 16 

### terms. So we're going to take that back and take 17 

### a look at it. 18 

### MS. JAKOBS: Okay. But I think I -- 19 

### well, I just want to clarify for myself. I 20 

### thought you were going to take the electrical 21 

### consumption during the ignition. So like our hot 22137

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### surface ignition, or spark ignition, there's 1 

### different electrical consumptions depending on 2 

### how you light the gas. I might have read a lot 3 

### more into it. 4 

### MR. BROOKMAN: Frank? 5 

### MS. ARMSTRONG: That's already in there, 6 

### right? 7 

### MR. STANONIK: Frank Stanonik, AHRI. 8 

### Isn't there a term for that already? 9 

### Yeah. 10 

### MR. DILLON: There is a term for the 11 

### ignition. That was wrong. 12 

### MS. ARMSTRONG: That's already in there 13



### now. 14 

### MS. JAKOBS: Okay. All right. Thank 15


### you. 16 

### MS. ARMSTRONG: So, seemingly, we have 17 

### some more ambiguities, perhaps, in this equation. 18 

### We'll take it back and look at it. The intent, 19 

### though, is to capture the electrical consumption 20 

### wholesale. 21 

### MR. HUNT: This is Marshall Hunt, PG and 22138

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### E. 1 

### But what I'm hearing is you can capture 2 

### without breaking it out? 3 

### MS. ARMSTRONG: Yep. 4 

### MR. HUNT: Okay. 5 

### MR. BROOKMAN: Diane, did you get 6 

### everything you wanted to say said? 7 

### MS. JAKOBS: I have to go home and read 8 

### it again. 9 

### (Laughter.) 10 

### MR. BROOKMAN: Okay. 11 

### MS. JAKOBS: Thank you. 12 

### MR. BROOKMAN: You've got another five13 

### ten minutes if you want to look. 14 

### Ayk. 15 

### MR. YILMAZ: Ayk Yilmaz, AHRI, again. 16 

### Is this the appropriate time to bring up 17 

### topics about the test procedure that haven't been 18 

### addressed in the public meeting? 19 

### MR. BROOKMAN: I think so. Yes. 20 

### MR. YILMAZ: Okay. I didn't hear much 21 

### discussion about some of the modifications that 22139

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### have been made to the setup of the gas and oil 1 

### burners specifically with relation to the flue, 2 

### O2 or CO2 adjustments. And it's on page, at 3 

### least of the pre-publication, page 133 and 135. 4 

### It's section 7.3 and 7.5 of the test procedure. 5 

### And I guess I was just hoping to get some 6 

### statement from the developers of this about how 7 

### the 30th percentage range was arrived at and the 8 

### default O2 or CO2 levels were arrived at in the 9 

### absence of direction from the I and O manual of 10 

### the appliance. 11 

### MR. BROOKMAN: Just make sure that 12 

### microphone is working there. 13 

### Victor, is that you? 14 

### (No audible response.) 15 

### MR. BROOKMAN: Ayk, stay at that 16 

### microphone. Stay there. 17 

### (Pause.) 18 

### MR. FRANCO: Is it on? 19 

### MR. BROOKMAN: I think it's on, yes. 20 

### MR. FRANCO: Could you repeat that 21 

### question once again? 22140

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### MR. YILMAZ: Sure. Sections 7.3 and 7.5 1 

### of the test procedures relate to the setup of the 2 

### gas and oil burners, respectively. And there's a 3 

### modification to the ASHRAE 103-2007 test 4 

### procedure with relation to that. 5 

### And my question is specifically regarding 6 

### the instructions to set up the burners to either 7 

### the 30th percentile of the range specified in the 8 

### furnace’s or boiler’s I and O manual, or in the 9 

### absence of such a specification, a combustion air 10 

### flow to provide a specified O2 or CO2; depending 11 

### on whether it's a gas or oil burner, it changes. 12 

### And I was hoping to get some explanation 13 

### about how those procedures were arrived at. 14 

### MR. BROOKMAN: Well, I see Frank has a 15 

### comment here. 16 

### MR. STANONIK: Dave and Mark, you're 17 

### really not whispering. Thank you. We can hear, 18 

### and it's disrupting the discussion here. Sorry. 19 

### MR. BROOKMAN: So, thanks for restating 20 

### the question. 21 

### Victor? 22141

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### MR. FRANCO: Yes. We don't have a 1 

### response to that right this second. We will try 2 

### to come up with that. 3 

### MS. ARMSTRONG: How about this? This is 4 

### Ashley. We'll look into it. Let me get back to 5 

### you. That's the best way to do it. 6 

### MR. BROOKMAN: Thanks. Now, Frank, 7 

### please. 8 

### MR. STANONIK: Frank Stanonik, AHRI. 9 

### And I did not choreograph this. But I 10 

### mean, there is two issues there. First of all, I 11 

### mean, it is a change. Because right now, the 12 

### procedure is kind of silent, and so they just 13 

### need to find a number that's inside the range. 14 

### And this is much more specific. 15 

### But then, to that second point, what the 16 

### hell is the middle of the 30th percentile? I 17 

### don't understand that. So, if it's going to be 18 

### specific, you know, I would hope that there would 19 

### be some better language that would be clear on 20 

### that. 21 

### MR. BROOKMAN: Can you recommend 22142

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### something off the top of your head? 1 

### MR. STANONIK: Frank Stanonik. 2 

### In this case, no. Because I'm not -- 3 

### again, I'm not sure what they were telling us to 4 

### do. 5 

### MR. VERSHAW: Jim VerShaw. 6 

### On furnaces, the ones that I'm familiar 7 

### with, including Diane's and all the competitors, 8 

### there's no air adjustment, not anymore. I mean, 9 

### in the olden days you used to have shutters and 10 

### such. But I mean, you set the gas, and it is 11 

### what it is. Unless you go in and put a variac on 12 

### the inducer or you start restricting things, 13 

### you're changing orifices and taking things apart. 14 

### So, and I don't think anybody puts a -- I 15 

### don't think anybody puts a CO2 level in their I&O 16 

### manual, because the gas is so different across 17 

### the country in elevations and all that stuff. 18 

### You'd have people going crazy trying to hit that. 19 

### MR. BROOKMAN: Frank. 20 

### MR. STANONIK: Frank Stanonik, AHRI. 21 

### And, Jim, I'm sure what you're saying is, 22143

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### you know, reflective of gas. Okay? Or at least 1 

### gas furnaces. But it is a trap we all fall into. 2 

### This also addresses oil. And it is very common 3 

### for an oil burner to specify. And so this has -- 4 

### MR. VERSHAW: This section was not a gas 5 

### burner. 6 

### MR. STANONIK: Well, no. It says the 7 

### same thing for oil, though. I mean, in both 8 

### cases they have established that -- 9 

### MR. VERSHAW: Well, I'm pretty parochial 10 

### in my comments. I'm worried about gas burners 11 

### right now, okay? 12 

### (Laughter.) 13 

### MR. STANONIK: My comment was for both. 14 

### MR. BROOKMAN: You're sticking by gas, 15 

### and Frank is going for both. 16 

### MS. ARMSTRONG: Thank you. We'll look 17 

### into it, on both. 18 

### MR. BROOKMAN: Jeff? 19 

### MR. KLEISS: Yeah, Jeff Kleiss, 20 

### Lochinvar. 21 

### And I can say for many of our gas 22144

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### products, air-fuel ratio is controllable and we 1 

### do publish ranges. But to call out, to be in the 2 

### middle of the range is -- that would be 3 

### problematic. 4 

### MS. ARMSTRONG: Okay. 5 

### MR. KLEISS: That is, we do have 6 

### procedures that have been written that do specify 7 

### operating within published ranges for certain 8 

### product classes. And that, I think, would be 9 

### reasonable to discuss. But to force it to be 10 

### into the middle is a significant change and 11 

### something that we oppose. 12 

### MS. ARMSTRONG: Okay. 13 

### MR. BROOKMAN: Michael McCabe. 14 

### MR. VERSHAW: This is Jim one more time. 15 

### I would think that you would have some 16 

### statement in there. If you can -- if it is field 17 

### adjustable on the air side, then you do this for 18 

### an air setup. 19


### MS. ARMSTRONG: Sure. 20 

### MR. VERSHAW: But if it's not, then it is 21 

### what it is. 22145

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### MS. ARMSTRONG: Got it. Thanks. 1 

### MR. BROOKMAN: Michael McCabe. 2 

### MR. McCABE: It's Michael McCabe. 3 

### A couple of housekeeping issues. The 4 

### Department proposed amendments to section 430.23, 5 

### N2, which is annual fuel utilization efficiency. 6 

### This is the section that, for example, FTC refers 7 

### to in what goes on the label. And in there, the 8 

### Department proposed changes to the ASHRAE 9 

### standards. 10 

### It was referencing the rounding to one11 

### tenth of an AFUE. But they did not change a 12 

### reference to section 10.1 of Appendix N. 10.1 of 13 

### Appendix M is the heating seasonal efficiency of 14 

### electric furnaces and boilers. That section 15 

### reference, I believe, should be to section 10.2 16 

### of the new Appendix N. The old Appendix N, it is 17 

### an AFUE paragraph. 18 

### Similarly, in the section above, which 19 

### deals with the estimated annual operating cost, 20 

### that section includes references to sections 21 

### 10.2.2 and 10.2.3 of Appendix N. In the proposed 22146

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### Appendix N, those sections do not exist. My 1 

### recommendation to the Department, on 430.23N is, 2 

### look at all those sections and the references, 3 

### because I believe most, if not all, need to be 4 

### cleaned up and properly referred to in the new 5 

### Appendix N. 6 

### MR. BROOKMAN: Okay. Thank you, Michael. 7 

### MR. McCABE: Similarly, in the proposed 8 

### Appendix N, I'll just -- one example. And I 9 

### believe it will apply to many sections 10 

### throughout. I'm kind of looking at Eric, because 11 

### Eric and I, we've had discussions about 12 

### consistency. And where you lack consistency, 13 

### that's where things tend to fall apart. 14 

### And in section 10.5.1.3, which is for 15 

### furnaces and boilers equipped with step 16 

### modulating controls, there is an equation. 17 

### Within the equation, there are three values which 18 

### are not defined. X-sub-M, B-sub-M, and 2080. 19 

### The first two, X-sub-M and B-sub-M, are not 20 

### defined anywhere within Appendix N. The 2080 is 21 

### defined elsewhere, but for most of the equations, 22147

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### the Department tries to define all the values 1 

### that are in there, but not all. 2 

### And my recommendation is to go through 3 

### the entire Appendix N that's being proposed and 4 

### scrub it so that the equations and the 5 

### definitions are consistent from one to the other. 6 

### Otherwise, you know, there are going to be 7 

### questions raised as to exactly what the 8 

### Department is getting at. 9 

### MR. BROOKMAN: Okay. Thank you. 10 

### MS. ARMSTRONG: So, I want to make one 11 

### comment in response to that. And this is Ashley 12 

### from DOE. 13 

### So those points are well taken, and we'll 14 

### look back at it. I do want to say that FTC 15 

### [Federal Trade Commission] updated their 16 

### requirements lately. It's harmonized now with 17 

### DOE's sampling provisions in 429, as well as the 18 

### test procedures in part 430, so it no longer 19 

### references 430.23. However, it's well taken that 20 

### we should be consistent. 21 

### As well as the submission of data that 22148

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### was mentioned earlier, FTC also revised that. So 1 

### there was a question about E-sub-AE and whether 2 

### FTC collects that information. FTC's regs and -- 3 

### I can't speak for Hampton. I'm just reading the 4 

### regs from my cell phone. So, but FTC did revise 5 

### to require submission for DOE-covered products to 6 

### DOE through CCMS. And that is also consistent 7 

### with the information that DOE collects, also is 8 

### the same information that FTC is now requiring, 9 

### because it cross-references our certification 10 

### requirement. DOE does not collect E-sub-AE at 11 

### this time. 12 

### MR. BROOKMAN: Diane. 13 

### MS. JAKOBS: Just to kind of follow on 14 

### after Michael. It would be nice if we didn't 15 

### have all these references back and forth to 16 

### ASHRAE 103. It's really confusing. I mean, we 17 

### do work with a program that's kind of a black 18 

### box. And it's not that we're doing something 19 

### wrong because an engineer doesn't understand it. 20 

### But it would be good if everything was in one 21 

### place and you could point a new employee to one 22149

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### single document. It's just very complicated and 1 

### confusing. 2 

### MR. BROOKMAN: Okay. 3 

### MS. JAKOBS: So, having it back and forth 4 

### between two documents makes it worse. 5 

### MR. BROOKMAN: Whose job is that? 6 

### MS. ARMSTRONG: DOE's. 7 

### (Laughter.) 8 

### MS. ARMSTRONG: So, Diane, what I'm 9 

### hearing from you is you're asking us to pull the 10 

### applicable provisions from ASHRAE 103 into the 11 

### CFR holistically. 12 

### MR. BROOKMAN: Okay. Thanks, Ashley, and 13 

### also Diane. 14 

### We're reaching the point in the day where 15 

### I think we're ready to take final comments, 16 

### summary comments, closing remarks here at the 17 

### end, as we move towards closure. Frank. 18 

### MR. STANONIK: Frank Stanonik, AHRI. 19 

### And this is an issue that we commented on 20 

### in our response to the RFI. And it doesn't look 21 

### like -- well, we don't know what DOE's response 22150

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### is. And specifically, we do think, you know, 1 

### that there should be an attempt in this revision 2 

### to allow some means for calculations of ratings. 3 

### You know, it's always been there. For 4 

### the famous example, cast-iron sectional boilers, 5 

### you know, we've got processes for commercial 6 

### products. And since we are revising the 7 

### procedure, and it would certainly have the 8 

### benefit of reducing burden, you know, we had kind 9 

### of suggested that there ought to be something to 10 

### allow some process for rating of products through 11 

### interpolation, extrapolation. 12 

### And I guess, Ashley, I mean, one of the 13 

### questions we have is, you know, we raised that in 14 

### the RFI. And I don't even see it addressed in 15 

### this. I guess, so is it just not now? Or is it 16 

### not ever? Or -- sorry? Or what? 17 

### MS. ARMSTRONG: This is Ashley from DOE. 18 

### Never say never. 19 

### (Laughter.) 20 

### MS. ARMSTRONG: So, I think the answer is 21 

### we're still thinking about it, which is why you 22151

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### don't see it there. You know, it's not typical 1 

### practice to allow simulation AEDM-like methods 2 

### for consumer products. There are a couple of 3 

### exceptions to that -- CACs [central air 4 

### conditioners] being one of them. You know, we're 5 

### happy to continue the conversation, though. 6 

### MR. STANONIK: Okay. Thanks. 7 

### MS. ARMSTRONG: Okay? 8 

### MR. STANONIK: Okay. 9 

### MS. ARMSTRONG: So with that, I think I 10 

### just want to thank you all for coming and 11 

### participating today. It was very helpful to 12 

### myself, so I appreciate you taking the time and 13 

### effort. Just to remind you that the comment 14 

### period closes in May. 15 

### I do want to point out that if you do 16 

### take this home with you on the flight, the docket 17 

### number on the front is wrong. It's correct on 18 

### that. Somehow we added the zero on the front. 19 

### So if you happen to use that one through your 20 

### searching, it won't actually -- it's fixed, 21 

### though, in the actual docket. 22152

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### But thank you all for coming, and we'll 1 

### talk to you later. 2 

### (Pause.) 3 

### MR. BROOKMAN: Okay. Thanks, everyone. 4 

### (Whereupon, at 3:51 p.m., the meeting was 5 

### adjourned.) 6

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22153

1 

### CERTIFICATE OF COURT REPORTER

2 

### I, Linda D. Metcalf, Notary Public in and

3 

### for the District of Columbia, the officer before

4 

### whom the foregoing testimony was taken, do hereby

5 

### certify that the testimony which appears in the

6 

### foregoing transcript was taken by me and

7 

### thereafter reduced to typewriting under my

8 

### direction; that said testimony is a true record

9 

### of the testimony given; that I 

### am neither counsel

10 

### for, related to, nor employed by any of the

11 

### parties to the proceedings in which this

12 

### testimony is taken; and further, that I 

### am not a

13 

### relative or employee of any of the parties

14 

### hereto, nor financially or otherwise interested

15 

### in the outcome of the proceedings.

16

17

IB 

### LINDA D. METCALF,

19 

### Notary Public in and for

20 

### The District of Columbia

21 

### My commission expires June 30, 2018

22

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ashington : 202-898-1108 • Baltimore: 4 10-752-3376**~o ll**  Free: 88 8-4 45-33 76