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1 U.S. Department of Energy 

2 

3 

4 

5 Energy Conservation Test Procedures for 

6 Residential Furnaces 

7 

8 

9 

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

11 Thursday, March 26, 2015 

12 

13 1000 Independence Avenue, S.W. 

14 Room 8E-089 

15 Washington, D.C. 20585 

16 

17 

18 

19 

20 

21 

22 
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1 CONTENTS 

2 PAGE 

3 ASHLEY ARMSTRONG, Welcoming Comments 3 

4 VICTOR FRANCO, Proposed Updates 22 

5 ROSS DILLON, Proposed Updates 97 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 
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1 P R O C E E D I N G S 

2 MR. BROOKMAN: Let's start. Good 

3 afternoon, everyone, and welcome. This is the 

4 Test Procedure Notice of Proposed Rulemaking for 

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

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

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

8 Doug Brookman, Public Solutions, Baltimore. 

9 We're going to start with welcoming remarks from 

10 Ashley Armstrong. 

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

12 like to welcome you to the Department to talk 

13 about the proposed test methods for furnaces and 

14 boilers. Obviously, we welcome everyone today to 

15 not only hear an overview of our proposed method, 

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

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

18 feedback on our proposal, as we really value your 

19 feedback. So thank you for taking the time to 

20 come. 

21 MR. BROOKMAN: And we always start with 

22 introductions. Beginning to my immediate left 
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1 and looking over there toward Frank Stanonik. 

2 MR. STANONIK: Frank Stanonik, AHRI. 

3 MR. BROOKMAN: Thank you. 

4 And your microphone is on. And if you 

5 can get used to turning it on and off. 

6 And you're next, sir. 

7 MR. KLEISS: Jeff Kleiss, Lochinvar. 

8 MR. BROOKMAN: Thank you. 

9 MS. JENSEN: Elizabeth Jensen, Department 

10 of Justice. 

11 MS. JAKOBS: Diane Jakobs, Rheem. 

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

13 MR. BROOKMAN: Thank you. 

14 MR. WINNINGHAM: Dave Winningham, Allied 

15 Air. 

16 MR. VERSHAW: Jim VerShaw, Ingersoll 

17 Rand. 

18 MR. MATA: Ramiro Mata, CSA Group. 

19 MS. COCHRANE: Rosalyn Cochrane, Natural 

20 Resources, Canada. 

21 MR. BROOKMAN: Thank you. 

22 MR. HUNT: Marshall Hunt, Pacific Gas and 
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1 Electric Company. 

2 MR. STAS: Eric Stas, DOE General 

3 Counsel's Office. 

4 MS. ARMSTRONG: Ashley Armstrong, DOE. 

5 MR. BROOKMAN: Please, Greg. 

6 MR. ROSENQUIST: Greg Rosenquist, 

7 Lawrence Berkeley National Laboratory. 

8 THE COURT REPORTER: Do you have a 

9 microphone? 

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

11 -- 

12 THE COURT REPORTER: Fill it in. 

13 MR. BROOKMAN: Yes. 

14 MR. FRANCO: Victor Franco, Lawrence 

15 Berkeley National Laboratory. 

16 MR. DILLON: Ross Dillon, Lawrence 

17 Berkeley National Laboratory. 

18 MR. DARLINGTON: Adam Darlington, 

19 Navigant Consulting. 

20 MS. RIVEST: Catherine Rivest, Navigant 

21 Consulting. 

22 MR. McCABE: Michael McCabe, representing 
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1 myself. 

2 MR. YILMAZ: Ayk Yilmaz, AHRI. 

3 MS. MEDEPALLI: Sarah Medepalli, ICF 

4 International, on behalf of EPA ENERGY STAR. 

5 MR. McCRUDDEN: Charlie McCrudden, Air 

6 Conditioning Contractors of America. 

7 MR. WHITE: Charles White with the 

8 Plumbing Heating Cooling Contractors National 

9 Association. 

10 MR. LIN: Paul Lin with the Regal Beloit 

11 Corporation. 

12 MR. BROOKMAN: Okay. Thank you. Thanks 

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

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

15 All of you, hopefully, received a packet 

16 of information. This packet of information has 

17 the content that we hope to go through in 

18 considerable detail this afternoon. On page 1 of 

19 the packet is the agenda. Immediately following 

20 this overview, there's an opportunity for 

21 individuals that wish to make opening remarks -- 

22 we hope brief summary remarks about key issues, 
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1 from your perspective. 

2 Moving from there, we'll have 

3 presentation and the opportunity for comment. 

4 We're going to hear about regulatory history and 

5 the rulemaking overview. Moving on from there, 

6 the proposed DOE test procedure changes related 

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

8 round about 2:30 or so. 

9 Returning from the break, other proposed 

10 test procedure changes. And then at the end of 

11 the day, whenever we get there, another 

12 opportunity for remarks, closing comments, 

13 summary statements, things you don't think have 

14 been covered sufficiently during the course of 

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

16 Questions and comments about the agenda? 

17 (No audible response.) 

18 MR. BROOKMAN: I'd ask for your 

19 consideration. Please speak one at a time. And 

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

21 you get used to turning the microphone on and 

22 off, please say your name so that we have a 
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1 complete record of this meeting. There will be a 

2 transcript made available to all. 

3 If you could limit sidebar conversations 

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

5 helpful. And we welcome everyone joining us via 

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

7 EMILY: Twenty-five. 

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

9 That's a lot of saved airfare. 

10 (Laughter.) 

11 MR. BROOKMAN: That's wonderful. The 

12 Department of Energy is trying hard to make sure 

13 that these meetings are totally accessible to all 

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

15 could keep your telephones on mute, and if you 

16 raise your hand via the software provided, we can 

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

18 in the room, so you can participate in this 

19 conversation along with everyone else. 

20 And finally, one more thing. The 

21 Department of Energy encourages all, in addition 

22 to your responses, your comments here today, to 
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1 submit written comments. And I'm saying that 

2 specifically because that applies to those 

3 joining us via the Web as well. Please make 

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

5 you submit your comments. And Ashley Armstrong 

6 will be describing how that gets done as we 

7 proceed. 

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

9 slides, the purpose of public meetings. 

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

11 some, because you kind of already said them. 

12 The purpose of the public meetings 

13 generally is for us to describe our proposed 

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

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

16 questions and comments. Whether there are 

17 ambiguities or you have certain concerns, please 

18 feel free to speak up during any part of the 

19 presentation today. 

20 You will notice that there are certain 

21 comment boxes throughout today's presentation, 

22 where we specifically are seeking your comment on 
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1 certain issues, as we have teed them up 

2 throughout the presentation, as well as we have 

3 teed them up in the notice itself. But 

4 obviously, your comments are welcome on any part 

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

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

7 those here. 

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

9 back to you in case anybody wants to make opening 

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

11 MR. BROOKMAN: Remarks here at the 

12 outset? 

13 (No audible response.) 

14 MR. BROOKMAN: No? No comments here at 

15 the outset? 

16 (No audible response.) 

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

18 go straight into the content in the packet. 

19 MS. ARMSTRONG: All right. Moving right 

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

21 kind of how we got there. The statute authorizes 

22 or created the program, the Energy Standards 
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1 Program, as well as the Test Procedure Program, 

2 and it includes furnaces and boilers. It directs 

3 DOE to not only establish, but to consider 

4 revisions and updates to its test procedures over 

5 a certain period of time. 

6 EISA 2007 was amended, directed DOE to 

7 incorporate standby and off mode. And we did 

8 develop a test procedure that did just that back 

9 in September of 2009. So this just gives a 

10 little bit of overview of the history of how we 

11 got here. 

12 In 1997, DOE established a final rule 

13 that adapted generally ASHRAE Standard 103-1993 

14 as the test procedure for furnaces and boilers. 

15 Over the years, DOE has made subsequent 

16 amendments, you can see them on the slides, 

17 through different final rules, some being for 

18 standby and off, others being clarifications of 

19 certain methods that were in the Department's 

20 test procedure. 

21 We officially kicked this rulemaking off 

22 with a request for information back in January 
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1 2013. Many of the proposals you're going to see 

2 and hear about today are in response to some of 

3 the comments that we got and the key issues that 

4 were raised by stakeholders in response to that 

5 request for information. 

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

7 conducting this rulemaking to satisfy its 

8 requirements under the seven-year look-back that 

9 requires DOE to revise -- review and potentially 

10 revise its test procedures once every seven 

11 years. So that will satisfy this provision. 

12 So with that, some key dates you might be 

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

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

15 rule off with a request for information. Today 

16 is the public meeting, and the comment period 

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

18 final rule sometime later this year, probably 

19 towards the end of this year. Consider it a 

20 holiday present for you guys. And we look 

21 forward to getting your comments toward the end 

22 of May. So, yep. 
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1 MR. BROOKMAN: Frank Stanonik. 

2 MR. STANONIK: Frank Stanonik, AHRI. 

3 All right. Two questions and, well, one 

4 specifically related to this last side. But let 

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

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

7 Obviously, all of that was not something that was 

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

9 being repeated in the NOPR here, right? 

10 MS. ARMSTRONG: Correct. 

11 MR. STANONIK: I just wanted to confirm. 

12 Okay. 

13 And then the other question, on the 

14 schedule here, again, maybe asking an obvious 

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

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

17 would clearly indicate that it is DOE's intent 

18 that this revised test procedure will be used for 

19 both the ongoing residential furnace and 

20 residential boiler rulemakings, correct? 

21 MS. ARMSTRONG: That is correct. Thank 

22 you. 
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1 MR. BROOKMAN: Yes, please, Jim. 

2 MR. VERSHAW: Jim VerShaw, Ingersoll 

3 Rand. 

4 It looks like the rest of the program can 

5 be pretty technical. So I want to ask about 

6 regulatory burden. And did you consider the 

7 regulatory burden issues that this will bring in? 

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

9 procedure that goes into effect the middle of 

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

11 redesign and do testing for FER [fan efficiency 

12 rating] right on top of doing all of the 

13 commercial air conditioning and all of the other 

14 things. 

15 It just seems like one thing right after 

16 another, and this is just one more thing that 

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

18 for. 

19 MS. ARMSTRONG: So I think we can talk 

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

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

22 to need to retest all your products? Are you 
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1 testing to ASHRAE 103-1993 now? Are you testing 

2 towards to the new version? 

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

4 CFR [Code of Federal Regulations], whatever the 

5 numbers are. 

6 MS. ARMSTRONG: You've been trained. 

7 (Laughter.) 

8 MS. ARMSTRONG: That's the right 

9 response, Jim. 

10 (Laughter.) 

11 MS. ARMSTRONG: I think DOE has gotten 

12 some feedback that some people have moved to 

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

14 we were strongly urged to consider moving to the 

15 new ASHRAE to keep up with industry, for a 

16 variety of different reasons. 

17 So, obviously, we would look for your 

18 feedback on that. If there are certain aspects 

19 that you believe -- you know -- 

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

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

22 rules from a whole number to a tenth, and we have 
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1 to have statistically -- data that statistically 

2 gives us the rating point rounded to the nearest 

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

4 that when I test the new procedure will give me 

5 exactly that number. 

6 MS. ARMSTRONG: Okay. 

7 MR. VERSHAW: So therefore, it seems it 

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

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

10 great feedback. 

11 MR. VERSHAW: Yeah. Okay. 

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

13 further now, or maybe in your written comments, 

14 about suggesting what DOE might do about this 

15 condition the industry is in? 

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

17 was in charge, I would make this effective with 

18 the next change to the AFUE for furnaces. 

19 MR. BROOKMAN: Okay. 

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

21 concurrent with -- 

22 MR. VERSHAW: The one that we're going to 
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1 talk about tomorrow. 

2 MS. ARMSTRONG: Okay. That clarifies. 

3 Thank you. Okay. 

4 MR. BROOKMAN: Thanks, Jim. 

5 And, Diane, you wish to comment here? 

6 MS. JAKOBS: Well, so this is Diane 

7 Jakobs from Rheem. 

8 And we were just talking about, I think 

9 that -- 

10 MR. BROOKMAN: Is your microphone on? 

11 MS. JAKOBS: The light is on. 

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

13 MS. JAKOBS: Okay. We were just talking 

14 about whether we would -- are we required to 

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

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

17 thought it would only change the AFUE slightly, 

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

19 efficiency. 

20 So, I specifically looked at the timing 

21 for collecting condensate, and on one sample, we 

22 lost 0.5 percent AFUE. So, you know, that's kind 
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1 of within the realm of manufacturing tolerances. 

2 Is that your expectation that we would test 

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

4 do AEDM's [alternative efficiency determination 

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

6 that we could be verified against. And it would 

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

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

9 data with specific calculations, you know, that 

10 are in the current test procedure? Thank you. 

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

12 the question and get back to it this afternoon 

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

14 proposed impacts and potentially some of the 

15 feedback we might get on what the proposed 

16 changes may or may not do to your products. 

17 As we presented in the NOPR, we did test 

18 a subset of products to kind of get to our 

19 answers. And generally speaking, we found that 

20 we believe the current readings would more or 

21 less be substantiated, and it would not affect 

22 compliance with standards. 
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1 Now, that being said, we are here today 

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

3 proposals, let me listen to the feedback. And 

4 then let me tee up your question towards the end 

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

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

7 MR. BROOKMAN: Thank you. 

8 So, some productive conversation already. 

9 Yes, Diane, please. 

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

11 and I was telling Doug that my company uses a 

12 program that was developed by NIST [the National 

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

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

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

16 available for these updates. And I've been 

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

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

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

20 with programming in Fortran. 

21 (Laughter.) 

22 MS. JAKOBS: So it's kind of -- it's an 
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1 old, old program. So, I'm a little bit 

2 concerned. My first concern would be anyone 

3 checking our equipment, would they be using the 

4 same program? And then, the level playing field 

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

6 also be making the same assumptions and have the 

7 same program? 

8 And things that seem completely obvious 

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

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

11 will interpret the equations in the standard 

12 maybe differently when they programmed them. So 

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

14 reflects these changes. 

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

16 Yes, Mark. 

17 MR. KREBS: My main concern and reason 

18 for coming here is pretty similar to that of 

19 several manufacturers, some of whom have already 

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

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

22 test procedure going forward at the same time as 
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1 the NOPR for the furnaces [standard]. 

2 And at the bottom of page 11 of the pre3 Federal Register publication, it says, "DOE has 

4 tentatively determined that the proposed test 

5 procedure amendments would have a de minimis

6 impact on the product's measured efficiency." 

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

8 I would like to see how that tentative 

9 determination has been made, because frankly, 

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

11 comes down to. Thank you. 

12 MR. BROOKMAN: Okay. Thank you. 

13 So, these amount to additions to our 

14 opening statements, opening remarks. 

15 (Laughter.) 

16 MR. BROOKMAN: Which is good. Which is 

17 what we were hoping to achieve with that. 

18 Additional opening remarks as we then 

19 move on to proceed with the content here in the 

20 packet? 

21 (No audible response.) 

22 MR. BROOKMAN: Okay. Are we set? Okay. 
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1 Victor Franco is going to proceed. And 

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

3 this slide. 

4 (Laughter.) 

5 MR. BROOKMAN: A summary slide here right 

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

7 reviewed many of these packets over the years, I 

8 think the graphics in this packet are especially 

9 good. 

10 MR. FRANCO: Good afternoon. My name is 

11 Victor Franco. I'm from Lawrence Berkeley 

12 National Laboratory. And next we will be talking 

13 about the proposed updates to the Federal furnace 

14 and boiler test procedure. 

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

16 the proposed updates. We're proposing to update 

17 the industry references to the latest version of 

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

19 measurement of condensate under steady-state 

20 conditions. The electricity consumption of 

21 additional components is being considered, as 

22 well. 
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1 Doing the smoke stick test for verifying 

2 the flow through the heat exchanger, as well as 

3 the duct work for units that are installed 

4 without return ducts. Also, there are additional 

5 testing requirements for the multi-position 

6 configurations, and there is a proposal for the 

7 verification test for automatic means of 

8 adjusting for water temperature in boilers. 

9 The next few slides will be explaining in 

10 more detail these proposed changes. We will 

11 start the -- this gets a little bit more 

12 technical. We will start first with the updating 

13 the industry references to the latest ASHRAE 

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

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

16 have any questions at any time. 

17 This slide, the current Federal test 

18 procedure, incorporates by reference ASHRAE 103-

19 1993. In June 2007, ASHRAE published ASHRAE 

20 Standard 103-2007. DOE is currently proposing to 

21 update all references in the Federal test 

22 procedure from ASHRAE 103-1993 to ASHRAE 103-
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1 2007, with some modifications. This will result 

2 in the proposed test procedure adopting three 

3 main changes from the ASHRAE 2007, as follows: 

4 First, those would be a change in 

5 determining the AFUE [annual fuel utilization 

6 efficiency] for two-stage modulating products, 

7 which will require the recalculation of AFUE 

8 values for all two-stage and modulating products, 

9 including adding some new testing requirements 

10 for two-stage and modulating condensing products. 

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

12 test burden for two-stage products which have a 

13 calculated balance point temperature less than or 

14 equal to 5 degrees. 

15 Second, there is an update to, in ASHRAE 

16 103-2007, that will allow the calculation of off17 period flue losses for products with post-purge 

18 times greater than three minutes. 

19 Third, it will update the burner 

20 operating hours calculations, the annual fuel 

21 energy consumption, and annual electricity 

22 consumption calculations. This will also require 
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1 the recalculation of these values for all 

2 equipment that's currently being reported by 

3 manufacturers. 

4 The next few slides will expand on these 

5 three main modifications. So, please hold your 

6 questions for the next few slides. 

7 This slide is meant to give you a 

8 background about the changes in the determination 

9 of AFUE for two-stage and modulating products. 

10 In 2002, a NIST study reported issues on the 

11 proposed changes to the way AFUE was calculated 

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

13 there was a significant discrepancy between the 

14 AFUE of some two-stage and modulating models and 

15 the AFUE of those same models calculated as a 

16 single-stage unit at reduced fire. 

17 This difference was sometimes found to be 

18 as much as 1 percent or greater. Since most two19 stage and modulating models are operating almost 

20 all the time at the reduced operating mode, the 

21 AFUE values should be very close. The NIST study 

22 found that the main cause of this was how the on 
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1 and off times cycle values for two-stage and 

2 modulating units are determined in ASHRAE 103-

3 1993. 

4 The fixed values of 10 minutes for 

5 furnaces and 15 minutes for boilers shown in the 

6 table are determined based on the operating at an 

7 average of 50 percent of the rated capacity, as 

8 well as other assumptions. Yet most two-stage 

9 and modulating furnaces and boilers operate at 

10 different conditions than these. 

11 NIST’s proposed solution was to add a 

12 calculation method for determining the on- and 

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

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

15 proposed changes from the 2007 NIST report, with 

16 some additional modifications, which I will be 

17 describing in more detail in the next slide. 

18 This slide presents a summary of all the 

19 ASHRAE 103-2007 calculation and testing changes 

20 related to the AFUE determination for two-stage 

21 and modulating products. As stated in the 

22 previous slide, the main changes to the 
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1 calculation was to add a calculation method for 

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

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

4 details about this change will be presented in 

5 the next slide. 

6 In addition to this, ASHRAE 103-2007 did 

7 a number of other changes to the calculation 

8 method, including requiring all calculation at 

9 the reduced fire if the balance point temperature 

10 is less than or equal to 5 degrees Fahrenheit, 

11 replacing the design heating requirement, DHR 

12 [Design Heating Requirements], lookup table with 

13 equation of the output capacity of the maximum 

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

15 is the oversize factor of the maximum load. 

16 The calculations to the oversize factor 

17 were also changed. For the maximum operating 

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

19 same value used in the single-stage calculations. 

20 The oversize factor at the reduced operating mode 

21 is similar to the equation used before for the 

22 DHR, by replacing the DHR equation listed above, 
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1 mentioned previously. 

2 Lastly, the lookup tables for the average 

3 outdoor temperature and the fractional heating 

4 loads have been replaced with equations dependent 

5 to the balance point temperature. 

6 In addition to these calculation changes, 

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

8 testing conditions as well. For two-stage 

9 products with a balance point temperature less 

10 than or equal to 5 degrees Fahrenheit, testing is 

11 only required at the reduced operating load for a 

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

13 condensate cycle test. 

14 For a condensate cycle test, the on- and 

15 off-cycle times used are the calculated values 

16 instead of the fixed values used before. More 

17 details about these two testing changes will be 

18 presented in later slides. 

19 As mentioned in the previous slide, the 

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

21 of impact to the AFUE. This slide shows the 

22 proposed equations listed in sections 11.4.9.11 
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1 and 11.4.9.12 of ASHRAE 103-2007, to determine 

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

3 equations used to determine the fixed values 

4 similar to the ones used to determine the fixed 

5 values in ASHRAE 103-1993. 

6 One important thing to note here is that 

7 for the reduced operating mode, the on- and off8 times are dependent on the ratio of the output 

9 capacity of the reduced mode to the output 

10 capacity at the maximum mode. That will become 

11 important once we discuss some of the other 

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

13 sensible and infiltration heat losses in the AFUE 

14 calculations. 

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

16 also affects how the condensate cycle test is 

17 conducted for condensing two-stage and modulating 

18 products for this issue, too. The condensate 

19 cycle test described in section 9.8 of ASHRAE 

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

21 values to conduct the test. As discussed 

22 earlier, the on- and off-cycle times in ASHRAE 
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1 103-1993 were fixed. Now they will need to be 

2 calculated using equations in the previous slide 

3 before performing the condensate cycle test. 

4 Yes. 

5 MR. BROOKMAN: Marshall Hunt. 

6 MR. HUNT: Clarifying question. Marshall 

7 Hunt, PG and E. 

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

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

10 really fantastic fully-modulating products, 

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

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

13 two-stage and modulating. 

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

15 product with nine steps, I have to declare a low16 fire and a high-fire? 

17 MR. FRANCO: The test actually only 

18 requires reduced. And then there's a calculation 

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

20 those -- 

21 (Cross-talk.) 

22 MR. HUNT: Yeah. I'd let them know. 
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1 MR. BROOKMAN: Please, go ahead, Diane. 

2 MS. JAKOBS: So, this is Diane Jakobs 

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

4 But there is a little bit of a difference 

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

6 modulating, today there are two different 

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

8 And there are a couple of differences. 

9 But we always only tested at the maximum 

10 capacity and the minimum capacity. So even 

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

12 testing for AFUE, we're actually only running 

13 tests at maximum fire and minimum. 

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

15 Is it 20, 30 percent -- 

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

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

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

19 MR. HUNT: Okay. 

20 MS. JAKOBS: So. 

21 MR. HUNT: Thank you. 

22 MS. JAKOBS: Okay. 
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1 MR. BROOKMAN: Thanks, Diane. 

2 Yes, Harvey Sachs. 

3 MR. SACHS: Harvey Sachs, ACEEE. 

4 Am I to infer, Diane, that manufacturers 

5 are comfortable with approximating the modulating 

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

7 MS. JAKOBS: This is Diane Jakobs from 

8 Rheem. 

9 These equations are really old. So the 

10 papers were written actually before I was a 

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

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

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

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

15 had the first current modulating furnace with 

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

17 think. 

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

19 And I think our design was probably catered to 

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

21 when a request for information, me personally, if 

22 I wanted to characterize the operation of a 
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1 modulating furnace, I would be looking at steady2 state at 70 percent, because that's where it runs 

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

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

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

6 It spends more time probably at the 

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

8 -- you know, in a home, it's just running steady9 state at 70 percent, and it's just inching up or 

10 down, and meeting the load as it changes through 

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

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

13 that much. 

14 MR. BROOKMAN: Frank Stanonik. 

15 MR. STANONIK: Frank Stanonik, AHRI. 

16 But, Harvey, I think when the 2007 

17 edition of 103 was being developed, that issue 

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

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

20 the point at which there was consensus agreement. 

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

22 The lowest common denominator. Thanks, Frank. 
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1 MR. BROOKMAN: Ron Caudle, who is joining 

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

3 unmuted. 

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

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

6 MR. BROOKMAN: Okay. Well, you sound 

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

8 MR. CAUDLE: Okay. Thank you. 

9 MR. BROOKMAN: Thank you. 

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

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

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

13 standards team. Thank you. 

14 MR. BROOKMAN: Thank you. Okay. 

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

16 MR. KLEISS: Jeff Kleiss with Lochinvar. 

17 I would agree that there may be some more 

18 realism as far as the cycle times. And this 

19 would be an advantage to products like ours that 

20 have turndown rates. 

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

22 and t-offs, it will require us to do retesting on 
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1 cyclical condensate load, which if the impact of 

2 this ultimately is going to be a de minimis

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

4 the burden of having to go back and retest our 

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

6 efficiency caused by this. 

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

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

9 redo our cyclical condensate tests on reduced 

10 firing rate. 

11 MR. BROOKMAN: Okay. Thank you. 

12 Diane. 

13 MS. JAKOBS: This is Diane Jakobs from 

14 Rheem. 

15 Not to give you the impression that we 

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

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

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

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

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

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

22 another bin. And there were some strategic 
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1 things you could do to get a better number. 

2 So, that thing has disappeared. So that 

3 was one improvement that I completely support. 

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

5 ready, Victor. 

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

7 Victor Franco again. 

8 Going back to the slide we were at. So 

9 basically, since the calculations of on- and off10 times are dependent, as I mentioned before, on Q11 out and Q-out, R, which were the output at the 

12 maximum and the output of the reduced, then the 

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

14 be conducted before the condensate cyclic test. 

15 The exception to this is that in ASHRAE 

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

17 the reduced and at the maximum to be a substitute 

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

19 and at the maximum if the error between the two 

20 is not more than 2 percent. DOE found this 

21 condition to be true for most of models that it 

22 tested. 
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1 So this is the third major in terms of 

2 the AFUE determination of two-stage modulating 

3 products. And this is in regards to reduced 

4 burden. The two-stage furnaces and boilers have 

5 the following four tests that require only the 

6 reduced fire tests if the balance point 

7 temperature is less than or equal to 5 degrees 

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

9 optional tracer gas, and the condensate cycle, as 

10 I mentioned earlier. 

11 This reduces the burden, since the 

12 current test, ASHRAE 103-1993 test, requires 

13 these tests even though they have very little 

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

15 and boilers operate almost all the time at the 

16 reduced input rate. 

17 The balance point temperature, which is 

18 determined by the following equation, at the 

19 bottom of the slide, is less than 5 degrees 

20 Fahrenheit when the reduced output to maximum 

21 output ratio is approximately 0.59 or greater, 

22 which occurs for almost all two-stage furnaces 
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1 and boilers currently available in the market. 

2 MR. HUNT: Could you repeat that? 

3 MR. FRANCO: Yes. 

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

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

6 whole phrase or just the last part? 

7 MR. HUNT: The last part, statement. 

8 MR. FRANCO: It occurs almost always for 

9 two-stage furnaces and boilers currently 

10 available on the market. 

11 MR. HUNT: Less than 5 degrees. 

12 MR. FRANCO: Less than 5 degrees. And 

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

14 degrees or less. 

15 MR. KLEISS: Jeff Kleiss, Lochinvar. 

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

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

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

19 value. 

20 MR. FRANCO: Um-hm. 

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

22 down with respect to Q-out, then that is going to 
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1 make TC a larger number. So the higher the turn2 down rate, the higher TC is. 

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

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

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

6 (Cross-talk.) 

7 MR. KLEISS: So the more you turn down 

8 your appliance -- 

9 MR. FRANCO: Correct. 

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

11 MR. FRANCO: Larger, yeah. 

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

13 calculate that out, any unit that has an output 

14 at reduced rate that is greater than 58.8 percent 

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

16 than or equal to 5 degrees Fahrenheit? 

17 MR. KLEISS: Yeah. 

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

19 MR. KLEISS: Right. So the majority of 

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

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

22 gain any benefit from this. In fact, I don't 
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1 know of any products on the market that have low 

2 fire that's greater than 59 percent. 

3 MR. FRANCO: This is for two-stage 

4 products. And this is mainly in relation to 

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

6 and it might be different for -- 

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

8 MS. JAKOBS: This is Diane Jakobs from 

9 Rheem. 

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

11 we are digging into the equations, we realize 

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

13 and high fire. But the efficiency is actually a 

14 weighted average of the two operating conditions. 

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

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

17 weighting at all on the high fire. 

18 So even though we're running the test, 

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

20 difference in the final outcome. And when you 

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

22 as a minimum capacity, that really high fire has 
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1 no effect. So there's no reason for us to run 

2 high-fire tests. 

3 MR. KLEISS: Jeff Kleiss, Lochinvar. 

4 And I'm not arguing about the logic of 

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

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

7 running with this little turn-down, is basically 

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

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

10 legitimate. 

11 The only thing that I'm bringing issue 

12 with is the assumption that DOE has made that 

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

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

15 products that are actually going to receive a -- 

16 not have to run these tests because of this 

17 factor. 

18 MR. BROOKMAN: This factor will cause all 

19 of them to be retested? 

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

21 would allow -- 

22 MS. JAKOBS: It won't qualify. 
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1 MR. KLEISS: It would allow a product to 

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

3 high turn-down ratio. 

4 MR. BROOKMAN: Okay. 

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

6 know of any products in our industry that would 

7 actually get this benefit. 

8 MR. BROOKMAN: Jim. 

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

10 falsely assume that this would reduce the test 

11 burden, because it won't. 

12 MR. BROOKMAN: Jim. 

13 MR. VERSHAW: Yeah, Jim VerShaw, from 

14 Ingersoll Rand. 

15 The furnace, non-weatherized furnaces are 

16 quite a bit different from boilers. We have a 

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

18 to 70 percent is kind of the average. 

19 MS. ARMSTRONG: I think this will help. 

20 This is our testing. 

21 MR. BROOKMAN: This is Ashley. 

22 MS. ARMSTRONG: And you can see the 
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1 ratios supporting our conclusion. So while it 

2 may be different for boilers, I think this does 

3 somewhat support our conclusion for furnaces. 

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

5 to comment here? 

6 MS. JAKOBS: No. 

7 MR. BROOKMAN: Jim got it. Okay. 

8 Okay. Then, Victor. 

9 MR. FRANCO: Great. Thank you. Victor 

10 Franco again. 

11 Here we're representing the 14 different 

12 two-stage and modulating furnaces and boilers 

13 that DOE tested to look at the impact of these 

14 changes on AFUE. This table presents the 

15 different designs and controls of each of these. 

16 So we included five of the major product classes 

17 and 10 different manufacturers, both non18 condensing and condensing furnaces, two-stage and 

19 modulating controls. 

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

21 being calculated once we did the test for two22 stage equipment is around that ratio -- higher 
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1 than that ratio, as actually pointed out. For 

2 modulating equipment, it's lower, and for 

3 boilers, it's different as well. 

4 The cyclic times from the proposed test 

5 procedure also are listed here. One thing to 

6 note is that they are much lower than the 

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

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

9 minutes. 

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

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

12 we tested were around 20 percent at turn-down 

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

14 minutes that's being required. And now they 

15 would be tested at around 20 minutes. 

16 MR. BROOKMAN: Frank Stanonik. 

17 MR. STANONIK: Frank Stanonik, AHRI. 

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

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

20 and I would encourage you to recognize that 

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

22 says that most boiler models are not going to 
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1 benefit from this reduced test burden, because 

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

3 ratio, which was not convincing. 

4 But at least for the hot water boilers, 

5 all of the other ones would not trigger the magic 

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

7 break for them. So I would just be cautioned 

8 about a statement that says, which is the case 

9 for most two-stage furnace and boilers. 

10 MR. FRANCO: Just to clarify that, I 

11 forgot the previous slide to clarify it. The 

12 previous is just related to two-stage; it 

13 wouldn't impact modulating. Modulating for the 

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

15 (Cross-talk.) 

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

17 mean, let's be cautioned about extending 

18 conclusions here. So I understood. It's two19 stage. And you tested one two-stage boiler. So, 

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

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

22 one isn't enough to say that it's going to fit 
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1 all boilers. 

2 MR. FRANCO: No, you are definitely 

3 correct. Just from testing -- our previous 

4 statement is actually based on looking at actual 

5 models and looking at the -- from product 

6 literature. 

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

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

9 slides of results. The first slide presents the 

10 results of non-condensing furnaces and boilers. 

11 Obviously, the impacts would be much different 

12 from the condensing. So we might have to 

13 separate them out. 

14 Here, we have testing for four of the 

15 five products that we had models for. The first 

16 column lists the test at the current test 

17 procedure. The second column is at the proposed 

18 Federal test procedure. So there you can see the 

19 difference. 

20 The third column is actually the test as 

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

22 rating as a single-stage furnace. The difference 
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1 -- at the last column is the difference between 

2 the current and the proposed. For all these 

3 models, the differences are close to half an AFUE 

4 point. Some cases are going above one AFUE 

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

6 the single-stage reduced-fire testing. 

7 For boilers, the results were slightly 

8 different, and they're much lower than the 

9 results for furnaces. 

10 So now, let's go to the condensing 

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

12 that are going on. We're having the 

13 calculations, but we're also having the testing 

14 conditions that are being changed for the 

15 condensate cyclic test. 

16 So the same thing here. We have three 

17 different product classes for different models. 

18 The first column, again, is the current Federal 

19 test procedure standard; then the proposed 

20 Federal test procedure standard, measuring this 

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

22 then the difference. 
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1 For some of these models, the difference 

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

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

4 to the single-stage reduced-fire. 

5 MR. BROOKMAN: Yes, please, Jim. 

6 MR. VERSHAW: Jim VerShaw, Ingersoll 

7 Rand. 

8 If you look at line 2 of Manufacturer C, 

9 Model 1, and according to my earlier comments 

10 about having to retest and the new procedures, 

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

12 furnace that the new rule was 92 percent, I 

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

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

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

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

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

18 identified lab uncertainty that hasn't been 

19 factored into the tolerances that we're doing and 

20 how we set up our ratings. 

21 The other question I have -- and I 

22 couldn't find it in here. Did you recalculate 
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1 burner operating hours and show the difference 

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

3 got different on and off times. 

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

5 burner operating hours -- 

6 MR. VERSHAW: Okay, good. Thanks. 

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

8 MR. BROOKMAN: Yes, Frank Stanonik. 

9 MR. STANONIK: Frank Stanonik, AHRI. 

10 Well, I think Jim has certainly touched 

11 on one of the things that we are very concerned 

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

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

14 evaluating the effect of the revised test 

15 procedure. 

16 We are concerned that maybe enough 

17 testing has not been done to really get to that 

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

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

20 effect, and particularly an effect of lowering a 

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

22 translating -- what I like to call translating 
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1 the efficiency standard to reflect the new 

2 procedure. 

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

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

5 interesting to see, were all of these roughly the 

6 same input model? I mean, because at least 

7 historically, with the test procedure, your input 

8 gave you a slightly different number, right? 

9 MR. BROOKMAN: Jim. 

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

11 It would depend upon the house load it 

12 fell into. 

13 MR. STANONIK: Yeah, right, right. 

14 MR. VERSHAW: Yeah, yeah. 

15 MR. STANONIK: Thanks, and I know you 

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

17 evaluating whether this is a neutral change, we 

18 would need to look across the spectrum of inputs 

19 of products available just to make sure there's 

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

21 MS. ARMSTRONG: So, we would welcome the 

22 opportunity to work with AHRI to do just that. 
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1 We had a request to place some more details of 

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

3 do. So you can look for that file. 

4 But to the extent that all of you have 

5 test data, or if anyone has run the proposed 

6 method either during the ASHRAE process or 

7 otherwise, or if AHRI wants to work with us to 

8 set something up, we'd be happy to engage in that 

9 discussion. 

10 MR. BROOKMAN: Thank you, Ashley. Thank 

11 you. 

12 Yes, and one more. Just say your name 

13 for the record. 

14 MR. YILMAZ: Ayk Yilmaz, AHRI. 

15 A little bit of a specific question with 

16 relation to the test differences that you saw. 

17 You identified two different ways in which the 

18 different cycle times can change AFUE results, 

19 one being through the calculations which impact 

20 the L-S, on, L-S, off, and the infiltration 

21 losses. And then the other one, through the 

22 actual condensate cycling test that you did, 
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1 which also could create a different result for L2 sub-G, I think was the term. 

3 Did you identify, or were you able to 

4 identify which of those impacts actually created 

5 the differences that you saw? 

6 MR. FRANCO: Thank you for that question. 

7 Yes, that's a good clarification. 

8 So, as you can see from the results 

9 previously, which were only impacted by the 

10 calculations, they were pretty much all positive 

11 differences. Here, we're seeing all negative. 

12 So, the negative comes in from the 

13 calculations for the condensate cyclic test. 

14 Basically, what happens is you're measuring the 

15 condensate for a short period of time. So you 

16 have more of the impact of the cycling. At the 

17 beginning, usually, there's a little bit less 

18 cyclic. There's a little bit less inefficient. 

19 As you're going closer to the steady-state, it's 

20 more. 

21 MR. BROOKMAN: Jim? Comment? 

22 MR. VERSHAW: No. 
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1 MR. BROOKMAN: Okay. Additional 

2 thoughts, questions, comments? Jeff. 

3 MR. KLEISS: Jeff Kleiss, Lochinvar. 

4 I'm just trying to get my mind around the 

5 -- you've got calculated values for the proposed 

6 Federal test procedure, and then the single-stage 

7 at reduced firing AFUE rating. And then the 

8 footnote down there. 

9 And the differences that you're showing 

10 in the efficiencies are based on the difference 

11 between the current test procedure and the 

12 single-stage at reduced-firing AFUE? Is that -- 

13 am I reading this correctly? 

14 MR. FRANCO: No, no. Sorry about that. 

15 Sorry about the confusion. It's between the 

16 current Federal and the proposed. 

17 MS. ARMSTRONG: This is Ashley. There's 

18 three columns, right? The middle column is the 

19 proposed? 

20 (Pause.) 

21 MR. FRANCO: Correct. 

22 MS. ARMSTRONG: So what's the -- 
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1 MR. KLEISS: Just some of the numbers 

2 don't seem to be -- 

3 MS. ARMSTRONG: You're talking about the 

4 deltas on the last column? That's what you're 

5 asking? 

6 MR. KLEISS: Yeah. 

7 MS. ARMSTRONG: Okay. 

8 MR. KLEISS: Trying to find out what 

9 they're associated with. 

10 MS. ARMSTRONG: Okay. 

11 MR. BROOKMAN: Jim. 

12 MR. VERSHAW: Yeah, Jim VerShaw. 

13 I'm going to go back to my earlier 

14 statement on burden. I wish we had time to have 

15 a lot of numbers to show between this test method 

16 and this test method on furnaces. But we just 

17 finished changing the AFUE's on our packaged 

18 products and non-weatherized furnaces. We're 

19 working on FER and a myriad of other things. We 

20 haven't had time to go in and even look at this. 

21 And whatever we did back in 2006, well, 

22 different people -- that's all gone. We can't 
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1 find that data, because it wasn't necessary to 

2 keep it, right? So it's kind of lost. 

3 That was my whole point in the very 

4 beginning is that there's so much going on we 

5 have a hard time keeping up. 

6 MR. BROOKMAN: Diane. 

7 MS. JAKOBS: This is Diane Jakobs from 

8 Rheem. 

9 But just because I was so enthralled with 

10 the whole thing, that we never really -- we never 

11 tested our furnaces to the 2007 version versus 

12 the 1999. I was always arguing about the 

13 assumptions. So I was more interested in how 

14 thermostats work and the interaction between the 

15 thermostat and the furnace. 

16 But I would have to do testing now to -- 

17 I don't have anything. 

18 MR. BROOKMAN: Okay. 

19 Okay, Victor. 

20 MR. FRANCO: Thank you so much for those 

21 comments. 

22 The next proposal that's from ASHRAE 2007 
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1 was to changes for the on-cycle losses for 

2 products with long post-purge time. Basically, 

3 in that same 2002 NIST study, they found the 

4 issue that there are some, primarily oil-fired 

5 boilers at that time, that require long post6 purge times beyond three minutes. The existing 

7 test procedure produces small flue loss result. 

8 The cause of this was in the Federal test 

9 procedure, that limits the post-purge time to 

10 three minutes for the flue loss calculation. The 

11 ASHRAE 103-2007 proposed the changes to the flue 

12 loss calculations that are based on the NIST 

13 derivations of those equations. 

14 There are two changes. One is to the 

15 testing that now allows the post-purge time to be 

16 greater than three minutes. For units that have 

17 a post-purge time greater than three minutes, 

18 there's an additional flue gas temperature at the 

19 midpoint of that post-purge period of time. 

20 There's also calculation changes for 

21 units that are above three minutes that are in 

22 sections 11.2.10.6 and 11.2.10.8 of the ASHRAE 
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1 2007 standard. So, going back, this next slide 

2 presents the results not affecting AFUE, but 

3 affecting other products. 

4 MR. SACHS: Harvey Sachs, ACEEE. 

5 Victor, I'm a little confused about these 

6 long purge cycles. I haven't thought it all the 

7 way through, but my understanding is a large 

8 fraction of furnaces, both condensing and non9 condensing, are using inside air for combustion. 

10 That has to be replaced. So at some point, that 

11 infiltrated air has to be warmed before -- will 

12 be warmed before it gets to the furnace. And 

13 that has some heat content. 

14 And it would seem that there's got to be 

15 a point -- and I don't know if it's three minutes 

16 or three hours -- where the value gained by the 

17 long purge cycle is offset by the heating of that 

18 air, replacement air. 

19 MR. FRANCO: Yes. That -- 

20 MR. SACHS: Am I thinking wrong? 

21 MR. FRANCO: No, that is correct. This, 

22 I think the intent of this change was that there 
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1 were some boilers, actually, not furnaces, and 

2 oil equipment that had these long three-minute 

3 purge times. We're not aware of any furnaces 

4 that have these long purge times. And there are 

5 very few boilers that the post-purge time is 

6 greater than three minutes. It's set to that -- 

7 MR. SACHS: Thank you for the 

8 clarification. 

9 MR. FRANCO: Thank you for the question. 

10 So now, we get back to the burner 

11 operating hours, the annual fuel use, and the 

12 electricity, annual electricity use calculation 

13 changes. So again, to emphasize, these do not 

14 impact the AFUE. These are side calculations 

15 that are provided in the Federal test procedure. 

16 (Pause.) 

17 MR. BROOKMAN: Get a little closer to the 

18 mic. 

19 MR. FRANCO: Okay. 

20 FEMALE VOICE: That's much better. 

21 MR. FRANCO: Okay. Let me put this 

22 closer, too. Okay. Sorry about that. 
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1 So, let me say that again. This next 

2 slide is for the burner operating hours, annual 

3 fuel use, and annual electricity use 

4 calculations. These don't impact the AFUE 

5 calculations. These are primarily at a 

6 subsection of the test procedure for 

7 manufacturers to report if they wish. A lot of 

8 manufacturers of furnaces report these values, 

9 and boiler manufacturers report these values. 

10 So again, there's some of the -- this is 

11 based on this 2002 NIST study. They found that, 

12 for two-stage and modulating products, the burner 

13 operating hours are primarily based on the 

14 maximum input rate. To adjust for this, they 

15 actually introduced a multiplication factor, the 

16 R factor, to account for the useful heat of the 

17 electrical components at the two-stage. So, 

18 usually, two-stage equipment operates longer so 

19 that these components would be operating a longer 

20 period of time. 

21 What happens is it ignores the 

22 variability of the electrical component input for 
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1 multi-speed and variable speed, circulating and 

2 combustion blowers. So, many times, it over3 estimates the efficiency in terms of fuel use of 

4 these products. 

5 NIST proposed to change the burner 

6 operating hours calculation by calculating them 

7 at each operating mode. ASHRAE adopted these 

8 changes, but also did additional modifications 

9 primarily related to the modifications that we 

10 discussed previously. 

11 DOE proposes to adopt these changes, with 

12 modifications to account for the electronic 

13 ignition and standby and off-mode electricity 

14 use, which are already part of the existing 

15 Federal test procedure. 

16 This is a summary of the changes. So, in 

17 terms of -- again, in terms of operating hours, 

18 the biggest change is that all the burner 

19 operating hours are calculated for all operating 

20 modes. The correction factor, this R factor, has 

21 been removed because of the heat from the 

22 electricity of the burner -- in the burner 
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1 operating hours calculation is calculated 

2 separately for each operating mode. 

3 In addition to this, the fuel consumption 

4 is now being calculated separately for high and 

5 reduced fire. The electricity consumption also 

6 has separate on-time ratios for high- and low7 fire. 

8 In terms of the on-time ratios, which are 

9 the ratios between the electrical component on10 time to the burner operating on-time, these Y 

11 factors are based on the on-time cycle, the 

12 burner on-time cycle values that we were 

13 discussing previously for each operating mode. 

14 So, for two-stage, they are these calculated 

15 values that we discussed earlier. 

16 Similar to what we discussed before, the 

17 design heating requirement has been replaced by 

18 this equation, and the fractional heating loads 

19 are being replaced by an equation, depending on 

20 the balance point temperature. 

21 MR. BROOKMAN: Jim. 

22 MR. VERSHAW: So, how do they change? 
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1 MR. FRANCO: It is a little bit 

2 complicated. There are two factors to consider. 

3 One is that there's actually changes to the AFUE 

4 that impact for two-stage equipment, whether it 

5 increases or decreases. There's also the impact 

6 of these changes in terms of how these 

7 calculations impact if you had -- if you were 

8 calculating the same AFUE between the existing 

9 and the proposed. 

10 MR. VERSHAW: So, you don't have a table 

11 that says prior the BOH [burner operating hours] 

12 was this, now it's this? And prior, the EAE was 

13 this, and now it's this? Do you have that? 

14 MR. FRANCO: We don't currently have 

15 that, no. 

16 MR. VERSHAW: I'm getting ahead of 

17 myself. But when we did the analysis for the new 

18 AFUE standard, did you use this procedure? And 

19 doesn't how long the blower run play into how 

20 much energy is used by the furnace in the heating 

21 season? Wouldn't that make an effect on the 

22 numbers you got? 
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1 MR. FRANCO: Just do -- you're talking 

2 about the standard that -- 

3 MR. VERSHAW: I'm talking about 

4 tomorrow's meeting. 

5 MR. FRANCO: Tomorrow's meeting. Great, 

6 great. 

7 MR. VERSHAW: Yeah. 

8 MR. FRANCO: Yes. Actually, we do. We 

9 use these calculations. We actually have been 

10 using these calculations even in the previous 

11 rulemaking in 2011. Because these do -- are more 

12 accurate in terms of representing field 

13 conditions. 

14 MR. VERSHAW: But you don't know what the 

15 differences are? 

16 MR. FRANCO: Yes, we've -- 

17 MR. VERSHAW: Because I've only been 

18 looking at the old way of doing it. So. 

19 MR. FRANCO: We don't know in terms of 

20 the actual, your specific product. But overall, 

21 in terms of like an overall change, what it 

22 usually does is it decreases the fuel consumption 
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1 for -- it increases the fuel consumption for two2 stage and modulating products. 

3 MR. VERSHAW: For the gas or the 

4 electricity or both? 

5 MR. FRANCO: The gas. 

6 MR. VERSHAW: Yeah. 

7 MR. FRANCO: The gas, and it depends on 

8 the electricity, the fan, primarily, efficiency, 

9 whether it increases or decreases slightly. That 

10 would be dependent on your specific product. 

11 It's hard to be a little bit -- but the primary, 

12 there's an ACEEE paper that kind of explains the 

13 effect of just simply going and plugging these 

14 into kind of similar equations. 

15 (Cross-talk.) 

16 MR. VERSHAW: So Harvey has all this 

17 information? 

18 MS. ARMSTRONG: Yes. Harvey has all this 

19 information. And he's going to present next. 

20 MR. VERSHAW: Good. Okay. 

21 (Laughter.) 

22 MR. BROOKMAN: Harvey, to the podium, 
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1 please. 

2 (Laughter.) 

3 MR. FRANCO: The reference to that paper 

4 is in the notice itself if you wanted to go to -- 

5 into and read that. 

6 MS. ARMSTRONG: Well, we will talk lots 

7 more about this stuff tomorrow. 

8 MR. SACHS: Victor, can you cite the 

9 author of that paper? 

10 (Laughter.) 

11 MS. ARMSTRONG: Harvey, et al. 

12 MR. BROOKMAN: Frank Stanonik. 

13 MR. STANONIK: Frank Stanonik, AHRI. 

14 And I'm unfortunately not familiar with 

15 that paper. 

16 (Laughter.) 

17 MR. BROOKMAN: Me either. 

18 (Laughter.) 

19 MR. STANONIK: But, okay, so what I 

20 understood is that the general -- the conclusion 

21 is that you're going to see a little more 

22 increased fuel consumption. But that occurs 
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1 because it appears that you are not -- no longer 

2 over-estimating the contribution of the electric 

3 energy to the heating. 

4 MR. FRANCO: Correct. 

5 MR. STANONIK: If that's correct, then 

6 why isn't the second part of the conclusion that, 

7 in general, your electric consumption number goes 

8 down? Where does that break off? Or where does 

9 that disconnect? 

10 MR. FRANCO: Yeah. Let me explain a 

11 little bit further. The electricity consumption 

12 in the previous equation hasn't changed that 

13 much. The only change is from this slide, as you 

14 can see, is the addition of on-time ratios for 

15 the reduced fire, essentially. But the equation 

16 itself was basically calculated both for reduced 

17 and high. So that was not as big of a change. 

18 The biggest change was actually to the 

19 burner operating hours of it that were used to 

20 calculate in the fuel use, which is actually only 

21 calculated at the high-fire for two-stage and 

22 modulating equipment. And then doing all these 
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1 adjustments to adjust it so that it's applicable. 

2 So, this does approximate better the 

3 actual field conditions. And I just misspoke. 

4 The papers from ACEEE summer proceedings are 

5 actually not from ACEEE. It's actually by LBNL; 

6 it's from Lawrence Berkeley National Laboratory. 

7 (Laughter.) 

8 MR. FRANCO: So, I misspoke. 

9 MR. SACHS: The defense rests. 

10 (Laughter.) 

11 MR. FRANCO: Sorry about that. 

12 MR. HUNT: Marshall Hunt, PG and E. 

13 Now I'm confused. So are we saying -- 

14 MR. BROOKMAN: Wait a second. Okay, 

15 Marshall. Go ahead. 

16 MR. HUNT: Okay. Now I'm totally 

17 confused. Are we saying that a two-stage or 

18 modulating furnace will use more energy in the 

19 year, more gas? 

20 MR. FRANCO: No. That's what the 

21 equation incorrectly calculated, the equation 

22 that was used before. The current equation 
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1 actually shows that it's about the same 

2 consumption. If you have the same efficiency -- 

3 MR. HUNT: Yes. 

4 MR. FRANCO: -- furnace between a single5 stage and two-stage, and you calculate both the 

6 electricity and the fuel, you calculate about the 

7 same. If you did the old calculations, it came 

8 out to about 3 percent higher. 

9 MR. HUNT: Yes. 

10 MR. FRANCO: Or 3 percent less fuel 

11 consumption, which didn't seem to be -- 

12 MR. HUNT: So we're talking about a 

13 comfort product, a comfort feature rather than an 

14 efficiency feature. 

15 MR. FRANCO: Primarily. But there could 

16 be other -- again, in the calculations of the 

17 AFUE, you're doing these AFUE calculations at the 

18 reduced, that could also play a role. 

19 MR. HUNT: Thank you. 

20 MR. FRANCO: But it's primarily -- 

21 MR. BROOKMAN: Harvey Sachs. 

22 MR. SACHS: Marshall has just completed 
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1 my confusion. 

2 (Laughter.) 

3 MR. HUNT: Thanks. 

4 MR. SACHS: There seems to be some 

5 empirical evidence that suggests, or I've 

6 incorrectly inferred that a two-stage actually 

7 uses less gas over the season than a single8 stage. But you're telling me that we're getting 

9 the same AFUE. 

10 MR. FRANCO: Yeah. So that's a 

11 difference between how we're trying to kind of 

12 normalize everything in the test procedure and 

13 you might want to -- might see in the field. 

14 What happens in the field usually is a single15 stage furnace is usually oversized and usually 

16 significantly oversized. 

17 In the field, even if the two-stage 

18 furnace is oversized, that won't have as much of 

19 an impact. So there are many situations where 

20 you could see savings because of that. 

21 MR. SACHS: So, after 30 years of work to 

22 get a decent representation of actual gas use 
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1 that would allow us to compare models, we're 

2 still stuck with something that doesn't reflect 

3 what a consumer sees when he buys the appliance. 

4 Does this strike anybody else as being nuts? 

5 Pardon me. 

6 MR. FRANCO: Thank you for your comment. 

7 MR. BROOKMAN: Diane. 

8 MS. JAKOBS: So, this is Diane from 

9 Rheem. 

10 And I've worked on this. And I think 

11 this test procedure provides a good method to 

12 compare one product to another. I think what it 

13 does not do is estimate the consumption in a 

14 consumer's home. 

15 MR. SACHS: Harvey Sachs again. 

16 And, Diane, I appreciate what ASHRAE 

17 committees work like. I'm there. I've done it. 

18 But I'm translating your statement as the 

19 statement that this allows the comparison of your 

20 single-stage to Joe's single-stage. But it 

21 doesn't allow you to look for the value-added by 

22 buying a two-stage over a single-stage in terms 
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1 of your expected gas savings. 

2 MS. JAKOBS: Okay. Diane. 

3 If you're comparing single-stage to two4 stage, I think 2007 gives you better information 

5 for that. 

6 MR. SACHS: Does it -- 

7 MS. JAKOBS: Modulating is maybe another 

8 one. 

9 MR. BROOKMAN: Jeff, go ahead. 

10 MR. KLEISS: Jeff Kleiss, Lochinvar. 

11 If I'm understanding what I've heard 

12 correctly, it's that the current procedure that 

13 we're using, the 1993 ASHRAE 103 standards 

14 calculation has been overstating the savings for 

15 two-stage and modulating units as far as the 

16 energy consumption over the year. And what we're 

17 talking about in the 2007 calculation is a 

18 correction to that overstatement. 

19 MR. FRANCO: Correct. Thank you. Thank 

20 you for that clarification. 

21 MR. BROOKMAN: Thank you, Victor. 

22 Harvey. 
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1 MR. SACHS: The limited field -- this is 

2 Harvey Sachs. 

3 The limited field data with which I'm 

4 familiar is primarily Scott Pigg's pioneering 

5 study, I think 2001. And my inference and my 

6 memory, which is not perfect, is that we found 

7 substantial over-sizing in the two-stage furnaces 

8 as well as the single-stage. So consequently, we 

9 had a very high ratio of single-stage operation 

10 to two-stage. 

11 And again, I'm not an experienced furnace 

12 engineer. But that seems to me like it's saying 

13 there's a lot more BTU's -- a lot fewer BTU's per 

14 unit of heat transfer area, and it ought to use 

15 less fuel, run longer and use less fuel. 

16 MR. BROOKMAN: Diane. 

17 MS. JAKOBS: So, if you are taking out a 

18 single-stage furnace, you replace it with a two19 stage. And the other thing is we sell them 

20 according to input, not output. But we're kind 

21 of steering people towards not over-sizing quite 

22 as much. So there is a savings associated with 
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1 that. 

2 MR. SACHS: I don't mean to highjack 

3 this. But with all due respect to my good friend 

4 Charlie back there -- 

5 (Inaudible interjection and laughter.) 

6 MR. SACHS: -- I'd rather continue 

7 pushing rocks uphill than convince the contractor 

8 that he doesn't need the safety factor to keep 

9 from getting that call-back on a cold night. 

10 It's a really hard fight the efficiency programs 

11 have had for a decade or two, that the quality 

12 installation has had. And end of rant. 

13 MR. BROOKMAN: Do you wish to comment? 

14 Please. Microphone and say your name. 

15 MR. YILMAZ: Yeah. Ayk Yilmaz, AHRI 

16 again. 

17 I just wanted to clarify the error that 

18 is being corrected here. Is it something that's 

19 manifested in AFUE? Or is it limited to that EF 

20 that you're talking about? 

21 MR. FRANCO: Thank you for clarifying. 

22 It's related to EF. Once you recalculate your 
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1 AFUE values, those would be additional inputs to 

2 that calculation. So that might change a little 

3 bit. 

4 But these calculations, again, are 

5 separate from AFUE. They're not being used in 

6 calculating AFUE. 

7 MR. YILMAZ: Okay. So, I guess I'm just 

8 trying to maybe address Harvey's question there. 

9 When you're talking about comparing a single10 stage furnace to a modulating furnace that has 

11 the same AFUE, you're not talking about version A 

12 of the same furnace that’s single-stage, and 

13 version B of the same furnace that's modulating. 

14 You're talking about furnace one that's 

15 single-stage and a completely different furnace 

16 that's a different design that’s step-modulating, 

17 that when you do an AFUE test on it, you get the 

18 same efficiency result. And that's not because 

19 of any impact that is due to the modulating; it 

20 could be because of a completely different 

21 furnace design. 

22 MR. FRANCO: That is correct. Yes. And 
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1 that's a complication between actually comparing 

2 just a single unit and the change, because the 

3 change will have the impact of the AFUE 

4 difference from the other (inaudible). 

5 MR. YILMAZ: Okay. So then, I guess just 

6 to summarize then, the AFUE is an accurate 

7 representation of how -- or as accurate as we can 

8 expect to get of a single-stage furnace’s 

9 efficiency or a modulating furnace’s efficiency. 

10 But when we're talking about one that has the 

11 same AFUE, we are talking about something we'd 

12 expect to have the same fuel consumption over the 

13 course of the year. 

14 And it's really just about that EF number 

15 that ends up being different because of that 

16 error between how it's calculated for single17 stage and modulating? 

18 MR. FRANCO: Yes. 

19 MR. SACHS: This is Harvey. 

20 And I thank you very much. I have not 

21 reviewed the test procedures since the last time 

22 we did rulemaking, and you caught me. I had 
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1 forgotten that we go to a lot of work to compute 

2 something that's -- EF that's not used in AFUE. 

3 So. 

4 MR. YILMAZ: It's been over a decade. 

5 MR. BROOKMAN: Joanna Mauer, welcome. 

6 You are now unmuted. 

7 MS. MAUER: Thanks. I had two questions. 

8 One is just a basic question. For a two-stage 

9 furnace, how does the steady-state efficiency 

10 compare at low-fire and high-fire? 

11 MR. FRANCO: This is from -- you -- from 

12 our test data? 

13 MS. ARMSTRONG: Why don't we just let 

14 them answer? 

15 MR. BROOKMAN: Diane, please. 

16 MS. JAKOBS: That is a matter of the 

17 design. We have choices. 

18 MS. MAUER: So it's going to change. 

19 MS. JAKOBS: It's going to change. It 

20 depends. 

21 MS. ARMSTRONG: Okay. And it's not 

22 necessarily higher at the low-fire stage then? 
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1 MS. JAKOBS: We can design it that way. 

2 If -- 

3 MS. ARMSTRONG: They're shaking their 

4 heads no. You can't see them, but they're saying 

5 not, no. 

6 (Laughter.) 

7 MS. JAKOBS: Yeah. 

8 MS. MAUER: Okay. 

9 MS. ARMSTRONG: It's not necessarily. 

10 They can design it one way or the other; let's 

11 put it that way. 

12 MR. VERSHAW: Jim VerShaw from Trane. 

13 It's difficult to get the excess air 

14 level at the same level at low-fire and high-fire 

15 because it's difficult to get the inducer motor 

16 to slow down enough. And so, that's why actually 

17 on our condensing two-stage furnaces, we have an 

18 inverter-driven motor because we had to slow it 

19 down farther in order to get the numbers we want. 

20 Otherwise, the excess air goes up. The 

21 dew point goes way down. You can't condense 

22 anything. It's a little easier on non-condensing 
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1 furnaces. But it's just really kind of driven by 

2 what you can do with excess air. 

3 And as far as the numbers, they're pretty 

4 close. You know, it's a point one way or the 

5 other. It's not substantially higher on low6 fire. 

7 MR. BROOKMAN: Joanna, you said you had 

8 two questions? 

9 MS. MAUER: Victor, I did take a quick 

10 look at the LBNL paper that you mentioned. And I 

11 just wanted to make sure kind of I understood the 

12 kind of general conclusion, which seemed to be 

13 that there may not be gas savings in the field 

14 from two-stage furnaces. Is that correctly -- a 

15 correct interpretation? 

16 MR. FRANCO: That is correct. But again, 

17 that is comparing two models that are at 80-

18 percent AFUE that are tested. And it's not 

19 comparing the same model being tested as a 

20 single-stage and as a two-stage. So it is 

21 comparing two different models both at the same 

22 efficiency level. 
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1 MS. MAUER: I see. Okay. Thank you. 

2 MR. BROOKMAN: Thank you. 

3 MR. FRANCO: So, any last comments on 

4 this -- 

5 (Cross-talk.) 

6 MS. ARMSTRONG: Yeah. So we're going to 

7 close out the part relating to ASHRAE 103 before 

8 we do a summary of a couple of our other changes 

9 that are outside of ASHRAE 103. So at this time, 

10 if anyone has any other comments or issues or 

11 questions relating to ASHRAE 103 that they would 

12 like to bring up at this time, we welcome them. 

13 MR. BROOKMAN: Ayk, please. 

14 MR. YILMAZ: Ayk Yilmaz, AHRI. 

15 I was just waiting for this slide before 

16 I jumped back to the issue of the, what was item 

17 1.B), the off-cycle losses for products with long 

18 post-purge time. And I guess the comment was 

19 made that this is a type of -- the products that 

20 have post-purge times longer than three minutes 

21 tend to be oil boilers. And I noticed that an 

22 oil boiler was not one of those items that was 
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1 tested under the research. 

2 So, I guess, two-part question. Number 

3 one, has there been an analysis of the fraction 

4 of products that might be affected by this change 

5 by product class, not just looking at oil 

6 boilers, but other types? And number two, is 

7 there an understanding of what the impact on AFUE 

8 might be from this change? 

9 And I ask that question as trying to 

10 understand what the impact might be on the 

11 minimum efficiency standards from this change. 

12 MR. FRANCO: Thank you so much for that 

13 question. We weren't actually able to get a 

14 model that fit that description of the post-purge 

15 for oil boilers. And so, we don't know the exact 

16 impact in terms of magnitude, whether it was -- 

17 what it would be, if it was half an AFUE point, 

18 less than that. We don't know. 

19 MS. ARMSTRONG: Well, I think -- this is 

20 Ashley from DOE. 

21 I think what you're hearing is, no, we 

22 didn't test one. And we'd welcome data if you 
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1 have it, so, to help inform. 

2 MR. BROOKMAN: Jeff. 

3 MR. KLEISS: You could read my mind. 

4 Jeff Kleiss, Lochinvar. 

5 Just before we get off of the 2007 ASHRAE 

6 103 statement, I want to be clear about this, 

7 that it looks like what may -- by going to this 

8 standard, we may reduce the test burden for 

9 furnaces. But we will increase the test burden 

10 for boilers. And by that, I mean you would force 

11 us to go back and retest all of our existing 

12 products. 

13 And if there's some way -- I'm not 

14 opposed to updating to the newer standard if we 

15 can find a way to do that that does not force us 

16 to go back and retest existing product when we 

17 don't expect there to be a change in the AFUE's. 

18 So if -- 

19 MS. ARMSTRONG: Okay. So, that's a good 

20 lead-in, Jeff. Thanks. 

21 So I do want to confirm. You do not 

22 believe that any of the changes, at least with 
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1 regards to 2007 that we've proposed, will change 

2 your AFUE ratings as they exist today? 

3 MR. KLEISS: That's a bit of a dicey 

4 question from the -- I'm sorry; Jeff Kleiss, 

5 Lochinvar -- from the standpoint that we don't 

6 have a calculator to use right now. And the 

7 specifics of how that calculator works may affect 

8 our AFUE's and have changes of several tenths of 

9 a percent, which could be significant when it 

10 comes to whether or not we meet certain 

11 efficiency rebate thresholds. 

12 But that aside, I've run calculations on 

13 our products as they're updated. And I believe 

14 that they would be very small impacts. 

15 MS. ARMSTRONG: So, to answer, you know, 

16 when you're thinking about making your written 

17 comments with regards to DOE's proposal and the 

18 potential adoption of ASHRAE 103, the way we look 

19 at retesting, if you have a previously tested -- 

20 so this is going to answer Diane's question 

21 earlier, too. 

22 If you have a previously tested and 
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1 certified model, no retesting will be necessary 

2 as long as the rating is still valid. If you 

3 have a previously tested and certified model 

4 whose rating is no longer valid, then you must 

5 test to the next procedure, rerate, and recertify 

6 before 180 days, at least under the proposal the 

7 way it was written. 

8 MR. BROOKMAN: Diane. 

9 MS. ARMSTRONG: Hang on one second; one 

10 more. 

11 MR. BROOKMAN: Oh, I'm sorry. Yeah. No, 

12 this is good. 

13 MS. ARMSTRONG: And if you have a new 

14 model introduced post the effective date of the 

15 test procedure, clearly for those you would need 

16 to use the new test procedure to rate and certify 

17 before distribution in commerce. 

18 So, you know, if you can make the 

19 determination that your ratings would not change, 

20 you would fall into that first bucket for which 

21 previously tested and certified and no retesting 

22 is necessary. 
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1 MR. BROOKMAN: I want to make sure, Jeff, 

2 do you want to follow on, Jeff? 

3 MR. KLEISS: Yeah, Jeff Kleiss. 

4 I just want to know, where is that in the 

5 proposed rule? 

6 MS. ARMSTRONG: So, that's the way our 

7 regulations work generally. That's what it says 

8 with regards to adoption of a test procedure, 

9 which is effective 30 days and for which must be 

10 used after the 180-day representation point. But 

11 I did want to clarify the three buckets in a 

12 little bit more what I would call plain language 

13 that I understand a little better. Hopefully, 

14 it's helpful to you. 

15 MR. BROOKMAN: That was very helpful, I 

16 think. 

17 Diane, please. 

18 MS. JAKOBS: So, the way I would process 

19 things, I would say if you think that you would 

20 pass a verification test, that you would be okay 

21 and no one from DOE would expect to look at our 

22 records and see a test output that reflects the 
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1 new standard and was dated after the new test 

2 procedure. It's more like how -- it's more 

3 important how your appliance actually operates 

4 and whether or not you meet the regulation as it 

5 would be verified. 

6 MS. ARMSTRONG: Generally speaking, I 

7 think you've said it another way. And it goes to 

8 twofold with compliance and then, obviously, 

9 valid rating. So. Seemingly, though, if you 

10 have test data, historical test data that 

11 underlies your rating, your rating continues to 

12 be valid even though the test procedure has 

13 changed. You maintain that historical data, and 

14 you're good. 

15 MR. BROOKMAN: I wish to underline a 

16 little bit of this conversation. And I don't do 

17 this very often. Ashley, it strikes me that you 

18 were very careful the way you just stated all of 

19 that. 

20 MS. ARMSTRONG: I was. 

21 (Laughter.) 

22 MR. BROOKMAN: Okay. I just wanted to 
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1 make that as an underlined statement. 

2 Okay. Frank Stanonik. 

3 MR. STANONIK: Frank Stanonik, AHRI. 

4 All right. And the one thing that I 

5 would -- I want to rephrase in terms of what 

6 Ashley was saying is that she indicated that if 

7 your rating, I think you said doesn't change or 

8 is still valid -- I'm sorry, is still valid, that 

9 in fact no retesting would be required. 

10 And I would just want to emphasize, at 

11 least I understand that to mean that if this 

12 revised test just happened to, if you would, if 

13 you had run it, raised your rating by some points 

14 or whatever, that you could continue to use your 

15 old rating under the idea that you now are 

16 conservatively rating and it's still valid. 

17 MS. ARMSTRONG: That is correct. 

18 MR. STANONIK: Okay. 

19 MS. ARMSTRONG: Our regulations allow for 

20 that. 

21 MR. STANONIK: Right. And one follow-up. 

22 I certainly appreciate and agree with what Ashley 
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1 has presented, but I'm going to ask that, I 

2 think, we would need something a little more 

3 formal from the legal counsel side of this. 

4 Because, you know, again, the letter -- my 

5 reading of the regulations says that your new -- 

6 once a new test procedure, your rating has to be 

7 based on testing to the new procedure. 

8 And, Ashley, I think what you said would 

9 allow that that may not totally be the case. And 

10 so I think we would need to make sure that's 

11 clear. 

12 MR. BROOKMAN: Eric Stas. 

13 MR. STAS: Eric Stas. 

14 Will you please put that in your written 

15 comments? And it will be addressed in the final. 

16 MR. STANONIK: Okay. 

17 MS. ARMSTRONG: So, I just want to go 

18 back and address one point that Jim asked 

19 earlier. And you said with regards to the 

20 rounding, and I don't have a slide on this, and 

21 I'm completely high-jacking the middle of this 

22 presentation to go off key here. But, so excuse 
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1 that. 

2 But we actually got a request from AHRI 

3 to do that. And the comment came in from Lennox 

4 Carrier Rheem and AHRI supporting that, saying 

5 that that's currently common industry practice. 

6 That's why your comment at the beginning threw me 

7 a little off guard with regards to the rounding. 

8 MR. VERSHAW: Well, I try to do that 

9 whenever I can, you know. 

10 (Laughter.) 

11 MS. ARMSTRONG: Well, you fully 

12 accomplished it this time. 

13 MALE VOICE: Good work, Jim. 

14 MS. ARMSTRONG: Congratulations. 

15 So I will say, if for some other reason 

16 we misunderstood the request or the comments that 

17 came in with regards to the RFI, please, please 

18 do clarify that for us. Because that is not 

19 something I anticipated. 

20 MR. VERSHAW: Well, this is Jim VerShaw 

21 again. 

22 I guess if -- we try to follow the letter 
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1 of the law, which says that you have two tests. 

2 And if they're close enough together 

3 statistically, take the average, and that's your 

4 rating. And if we're rating something at 95.6 

5 and the new test procedure makes it 95.5, one6 tenth lower, it's no longer a legal rating, 

7 right? According to the way the rule is written. 

8 MR. BROOKMAN: Frank Stanonik. 

9 MR. STANONIK: I'm not going to ask -- 

10 answer that question. 

11 (Laughter.) 

12 MR. STANONIK: But in regards to the 

13 issue you've raised, Ashley -- and I'm going to 

14 look to Ayk to confirm. But my understanding for 

15 furnaces, we have continued to provide our 

16 certification point reports to the nearest tenth. 

17 Unfortunately, our friends at EPA and the 

18 ENERGY STAR for boilers gummed up the works on 

19 boilers. But on furnaces, we're still reporting 

20 to the nearest tenth to DOE. And it's been 

21 accepted. Well, because it was an influx thing. 

22 MR. VERSHAW: And you'll find ratings -- 
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1 this is Jim. 

2 You'll find ratings from our products 

3 that are in the tenths. Okay? 

4 MS. ARMSTRONG: Well, then you do have 

5 that test data. 

6 (Laughter.) 

7 MR. VERSHAW: And that's my concern. I 

8 don't have the test data, the 2007. And if it 

9 drops it by -- and if the average drops by a 

10 tenth, and according to this, you've got 0.8 plus 

11 just about -- it's about 0.3, 0.4 drop, on 

12 average, you know, I don't know how we could 

13 still rate it at that if it was down two-tenths. 

14 MS. ARMSTRONG: So, I think your point is 

15 taken. 

16 MR. VERSHAW: Yeah. 

17 MS. ARMSTRONG: So, given the discussion 

18 we just had about when you have to retest, the 

19 different, the three -- what I would call the 

20 three different conditions, the clarifications 

21 regarding rounding, think about it. And in your 

22 written comments, please clarify, you know, if 
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1 you do propose changes -- I mean if you do 

2 support the proposed changes, but, you know, 

3 believe -- you know, want more time, whatever it 

4 is. Clarify your desire. 

5 MR. VERSHAW: This is Jim again. 

6 And again, going back to burden, we don't 

7 know. We don't know if it's going to be higher 

8 or lower until we run the test. And so, it puts 

9 us in a real catch-22 if we're going to have to 

10 run the test to find out if we don't have to run 

11 the test. 

12 (Laughter.) 

13 MR. VERSHAW: And that's just -- that's 

14 just -- something's wrong there. You know? And 

15 then I guess, if you really want to gum up the 

16 things, ASHRAE 103-2015 is going to be improved 

17 over 2007, and there are some things in there 

18 that you ought to consider adopting when it comes 

19 out. 

20 MS. ARMSTRONG: Okay. 

21 MR. BROOKMAN: Thanks. 

22 Jeff, go ahead. 
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1 MR. KLEISS: Jeff Kleiss, Lochinvar. 

2 And just going back to the -- what the 

3 DOES does require and doesn't require in terms of 

4 existing data, I have folders behind my desk that 

5 have the test data and the lower confidence level 

6 calculation to verify our product ratings. 

7 So, if I have those and those tests are 

8 run to the old standard, and we adopt the new 

9 standard, then what legal verification do I have 

10 that those old ratings are valid to substantiate 

11 my product to DOE should that question ever be 

12 raised? 

13 MS. ARMSTRONG: This is Ashley from DOE. 

14 I think that gets to Frank's point, and 

15 asked a little earlier, that Eric asked him to 

16 put in writing with a little bit more detailed 

17 confirmation. I'll pass on your concern-slash18 question to the proper person, which is Laura, to 

19 potentially clarify as she may wish for you guys. 

20 Okay? 

21 MR. BROOKMAN: Okay. 

22 Final comments? 
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1 Frank, please. Final comments on this 

2 segment, questions? We're due for a break. 

3 Frank, before we go to break, go ahead. 

4 MR. STANONIK: Frank Stanonik, AHRI. 

5 One other question, because I didn't want 

6 to forget it. And -- okay. In this part, 

7 there's certainly a whole section where 

8 essentially it is just some recalculations. And 

9 I think it was Jeff or Diane, one of them 

10 mentioned that in fact we have a very old AFUE 

11 calculation tool. 

12 I'm just curious. By any chance, is 

13 there a tool that you use that might be available 

14 for simply running that little group of 

15 calculations to see what the difference is when 

16 you plug in numbers X, Y, and Z? Just a 

17 question. 

18 MS. ARMSTRONG: You've asked me this for 

19 a number of products now, Frank. 

20 (Laughter.) 

21 MS. ARMSTRONG: I think that's a great 

22 thing that AHRI should do for their members. 
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1 However, I will say that we did test at a 

2 third-party lab. We did get them to use -- so I 

3 have to go back and check. Typically, when we 

4 test at third-party labs, we make them use these 

5 like test data templates, which implement the 

6 equations and in Excel-based format. I don't 

7 know if we had one for this or if we actually had 

8 them write everything out. I can't remember off 

9 the top of my head. 

10 If we have one, it will be posted online. 

11 We make them all available online. If it's 

12 online, obviously, you're welcome to use it as 

13 you may wish. If we don't have one, I'm not sure 

14 if we will be creating one or not. Typically, we 

15 use them for all our verification enforcement 

16 testing. It helps us get some things -- a level 

17 of documentation there that both we desire, but 

18 other people desire when they look at the test 

19 data. 

20 So, I'll get back to you and let you 

21 know. 

22 MR. STANONIK: All right. And -- Frank 
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1 Stanonik, AHRI. 

2 I mean, to Ashley's point and some good3 natured ribbing there, I will tell you that AHRI 

4 certainly intends that, once we do have a revised 

5 test procedure, we will be looking at creating a 

6 new software tool, because it's time. Among 

7 other things. 

8 MS. ARMSTRONG: And we'd be happy to work 

9 with you. 

10 MR. STANONIK: Because the people who 

11 know Fortran are far and few between anymore. So 

12 we want to get it to at least the twentieth 

13 century. 

14 (Laughter.) 

15 MS. ARMSTRONG: Yeah. Like I said, we'd 

16 be happy to work with you on that. 

17 MR. BROOKMAN: Aniruddh. 

18 MR. ROY: Aniruddh Roy, Goodman. 

19 Victor, I just have a question for you on 

20 slide 26, on bullet 3. You mentioned standby and 

21 off mode. So that would be consistent with IEC 

22 62301 (Second Edition)? 
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1 MR. FRANCO: Second edition; that's 

2 correct, yes. 

3 MR. ROY: Okay. 

4 MR. FRANCO: And there's no proposed 

5 changes at this time. 

6 MR. ROY: Okay. Thanks. 

7 MS. ARMSTRONG: That's already in the 

8 current test procedure now. 

9 MR. BROOKMAN: Thank you, Ashley. 

10 Let's take a break. It's now 2:40 by 

11 that clock up there, which means we'll -- yeah. 

12 Let's try 10 minutes. Yeah. Let's see if we can 

13 do it in 10, which means at 2:51 we're going to 

14 resume here in this room. You know where the 

15 restrooms are. Make sure and wear your badges 

16 visible here in the Forestal Building. 

17 (Whereupon, at 2:40 p.m., a recess was 

18 taken, to resume at 2:54 p.m.) 

19 MR. BROOKMAN: Okay. Let's resume, then, 

20 please. 

21 I want to say that I think the 

22 conversation has been really productive this 
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1 afternoon already, and we hope that continues. 

2 And we're going to pick up where we left off. 

3 MR. DILLON: Great. Good afternoon. My 

4 name is Ross Dillon, from Lawrence Berkeley 

5 National Laboratory. 

6 Next I'll be talking about the -- can you 

7 hear me? 

8 (Pause.) 

9 MR. BROOKMAN: Thank you. Here we go. 

10 MR. DILLON: I will be talking about the 

11 measurement of condensate under steady-state 

12 conditions. 

13 The current test procedure requires the 

14 establishment of steady-state conditions during a 

15 minimum period of 30 minutes before measurement 

16 of condensate. The measurement of condensate 

17 requires an additional 30-minute period following 

18 the establishment of steady-state. DOE's 

19 proposed revision would allow the measurement of 

20 condensate during the establishment of steady21 state conditions. This change impacts the test 

22 procedure through a reduction in test burden 
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1 resulting from shorter overall test duration. 

2 The figures in this slide present the 

3 test results from DOE's product testing. These 

4 results reflect the condensate mass production of 

5 a single condensing hot water boiler. This is a 

6 single-stage unit. 

7 This figure represents the combined 

8 duration of the two tests per section 9.1 and 9.2 

9 of ASHRAE 103-1993, which is incorporated by 

10 reference. The orange shaded area is the first 

11 30-minute period during which steady-state 

12 conditions are established. Is that orange 

13 definitive? 

14 (Simultaneous speaking.) 

15 MR. DILLON: Okay. The second 30-minute 

16 period is the additional 30 minutes required by 

17 the current test procedure for the measurement of 

18 condensate. As you will notice, the rate at 

19 which condensate is produced remains constant 

20 between the two periods, and the overall 

21 collection distribution remains relatively 

22 consistent. 
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1 DOE requests comment on the proposal to 

2 allow the measurement of condensate during the 

3 establishment of steady-state conditions. 

4 MR. VERSHAW: Jim VerShaw. 

5 Am I reading it right, you've got 218 

6 grams after it ran for 30 minutes and then took 

7 it, versus 215 if you took it during the time? 

8 MR. DILLON: Correct. That's the total 

9 value during each period. 

10 MR. VERSHAW: So, is this going to be an 

11 optional shortening? If we want to just get 

12 every gram of water we could, we would wait and 

13 do 30 minutes and then do it? 

14 MR. DILLON: The test procedure will 

15 allow -- it proposes to allow it to collect 

16 condensate during the establishment of steady17 state. However, I believe your -- 

18 MR. VERSHAW: So, but if I don't want to 

19 shorten my time. If I want to get three more 

20 grams of water, can I establish steady-state, 

21 then take 30, then do a condensate collection? 

22 MR. DILLON: That's up to you. 
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1 MR. VERSHAW: Okay. 

2 MS. ARMSTRONG: I wouldn't -- so if 

3 that's what you want to do -- this is Ashley from 

4 DOE. 

5 The way I read the test procedure, it 

6 doesn't exclusively allow that. So if that's 

7 what you want the option of doing, you should 

8 make that clear. Sounds like that's a yes. 

9 MR. BROOKMAN: Diane. 

10 MR. VERSHAW: I'll make it clear. 

11 MS. ARMSTRONG: Okay. Thanks. 

12 MS. JAKOBS: This is Diane from Rheem. 

13 And that was the reaction I got in our 

14 lab, that it's more important to make sure 

15 everything is on the correct temperature. And 

16 they want to make sure that our tests are 

17 repeatable. And, you know. 

18 MS. ARMSTRONG: So you want the freedom 

19 to go longer if you want to? Recognizing that -- 

20 I will say, with this proposal, DOE would do the 

21 first 30. So that's okay for you? 

22 MR. VERSHAW: Well, I don't know about 
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1 that. 

2 (Laughter.) 

3 MS. ARMSTRONG: Fair enough. Thanks a 

4 lot. 

5 (Laughter.) 

6 MR. BROOKMAN: Yes, please, Ayk. 

7 MR. YILMAZ: Ayk Yilmaz, AHRI, again. 

8 I just want to clarify how this data was 

9 taken. Was it -- was all the water, or rather 

10 all the condensate collected cumulatively? And 

11 then the intervals are just subtractions between 

12 each measurement interval? 

13 MR. DILLON: No. It was 30-second 

14 interval measurements. 

15 MR. YILMAZ: So then, I mean, I guess, 

16 with regard to that cup that you're collecting it 

17 in, supposedly, are you emptying it after every 

18 30 seconds and then filling it back up and 

19 measuring it? 

20 MR. DILLON: I believe the interval 

21 measurement weight was the difference between the 

22 total weight at the initial 30 seconds and the 
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1 total weight at the following 60 seconds. 

2 MR. YILMAZ: I got you. But you're 

3 keeping all that water in the container? 

4 MR. DILLON: Correct. 

5 MR. YILMAZ: Okay. Thank you. 

6 MR. BROOKMAN: Judd Smith has a comment. 

7 Joining us online, Judd should now be unmuted. 

8 MR. SMITH: Hello. Can you hear me? 

9 MR. BROOKMAN: Yes. Sounds good. 

10 MR. SMITH: Yeah, as the test lab, I 

11 would prefer to do one or the other and not have 

12 an option. Because we might test it wrong. If 

13 one manufacturer wants the 30 minutes after 

14 steady-state, or the 30 minutes during steady15 state. We won't get that right. We'll adjust up 

16 to 15, we'll get 100 percent wrong. 

17 MR. BROOKMAN: Make sure and include it 

18 in your comments, Judd. 

19 MR. SMITH: Okay. 

20 MR. VERSHAW: This is Jim VerShaw again. 

21 MR. BROOKMAN: Jim, please. 

22 MR. VERSHAW: This is a boiler. Boilers 
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1 act a lot different than furnaces. You don't 

2 have any data on what happens if you do a furnace 

3 in 30 minutes during the heat-up cycle? Because, 

4 you know, the heat exchangers are getting boiler 

5 -- boiler, the water temperature stays about the 

6 same the whole time. And you've got a really 

7 nice condensing system there, and it's not going 

8 to make a whole lot of difference, I think, to 

9 the little bit I've done with boilers back in the 

10 1900s. 

11 (Laughter.) 

12 MR. VERSHAW: Yeah, they had rivets 

13 holding them all together. 

14 (Inaudible interjections and laughter.) 

15 MR. VERSHAW: But furnaces start off 

16 cold, and you might get more water than you would 

17 normally. That might -- you know, might be a 

18 good thing. Maybe I want to do the first 15 

19 minutes and not the next 30. I mean, I wish you 

20 had data for that to say this was really a good 

21 idea. I don't. I don't know. 

22 MS. ARMSTRONG: Okay. 
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1 MR. BROOKMAN: Thanks, Jim. 

2 Harvey Sachs. 

3 MR. SACHS: It's many decades ago that I 

4 took calculus and had to think about some of 

5 these things. But it seems to me that in 2015, 

6 you could define it by the trend becoming 

7 constant, that you're converging on a moving 

8 average, this within 1 percent of the same 

9 addition or X percent, and that that's really 

10 what you're trying to do. So you can truncate 

11 when you're confident instead of either arbitrary 

12 interval. 

13 And that would take care of Jim's 

14 concerns. It would take care of the boiler15 versus-furnace. And it could be written out as a 

16 pretty simple statement that would be available. 

17 MR. BROOKMAN: Okay. 

18 MR. SACHS: I can't write it out. 

19 MR. BROOKMAN: Okay. Thank you, though. 

20 Additional thoughts, comments on 

21 condensate? 

22 Yes. Diane. 
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1 MS. JAKOBS: I was just thinking if you 

2 can imagine we run a pilot run. We have a whole 

3 bunch of furnaces. We storm outside in the lean4 to. And it might even be cold in Arkansas. But 

5 there's a variety of temperatures, you know, and 

6 we just really -- it's an area of variation that 

7 we might not be familiar with now. And I guess 

8 we're a little worried about what it would 

9 introduce. So, thank you. 

10 MR. BROOKMAN: Okay. Thank you. 

11 MR. SACHS: This is Harvey. And, Diane, 

12 please accept my suggestion as for the next 

13 version of 103. 

14 (Laughter.) 

15 MR. BROOKMAN: Okay. We're moving on. 

16 MR. DILLON: The next topic is related to 

17 the electrical consumption of auxiliary 

18 components. The current test procedure does not 

19 capture all the electrical consumption of a 

20 boiler or furnace. The current test procedure 

21 measures only the blower or circulation pump 

22 power, the inducer, blower power, the ignition 
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1 power, and the standby mode and off mode power. 

2 These measurements may not capture all 

3 the electrical consumption of a boiler or 

4 furnace. DOE's proposed revision includes the 

5 measurement of additional electrical auxiliary 

6 components consisting of the secondary pump, if 

7 present, the gas valve, and the controls. 

8 Included in this slide is an example 

9 calculation of the average annual electrical 

10 energy consumption, expressed as E-sub-AE, for a 

11 single-stage furnace or boiler. The highlighted 

12 terms represent the measured power of the 

13 additional components, where B-s represents the 

14 measured electrical power of the secondary pump 

15 and E-sub-O represents the measured power of the 

16 other components, in other words, the gas valve 

17 and the controls. 

18 Also included are two additional Y terms, 

19 Y-S and Y-sub-O, which account for the ratio of 

20 the components’ on-time to the average burner on21 time. 

22 The figure in this slide presents the 
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1 test results from DOE's product testing related 

2 to the measurement of component electrical power 

3 for the high and reduced fire of a two-stage 

4 furnace model. The figure presents the measured 

5 power in watts for each of the electrical6 consuming components. According to these 

7 results, there is measureable auxiliary 

8 electrical power associated with components not 

9 captured by the current test procedure 

10 requirements. 

11 As noted by the red highlighted area, 

12 these components account for 7 percent and 11 

13 percent of the total electrical power for the 

14 high and reduced fire, respectively. 

15 DOE requests comment on the proposed 

16 changes, to include measurement of additional 

17 component electrical power for calculating the 

18 annual auxiliary electrical use. 

19 MR. BROOKMAN: Yes. Michael McCabe. 

20 MR. McCABE: Mike McCabe. 

21 It's more of a question, including for 

22 DOE ENERGY -- excuse me, EPA ENERGY STAR and the 
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1 FTC labeling. But do you know if those two 

2 programs include the requirement that 

3 manufacturers report not only AFUE but also 

4 annual energy use? 

5 MR. BROOKMAN: Diane. 

6 MS. JAKOBS: Diane. 

7 The E-sub-AE is used in the calculation 

8 of little e, which is part of the ENERGY STAR 

9 requirement. But it's a ratio. It's the 

10 electrical consumption over the sum of the 

11 electrical consumption and the gas consumption. 

12 So we get the 2 percent. But it's part of the 

13 calculation, but it's not specifically required. 

14 It's kind of a -- the number depends on the 

15 capacity. So it's hard to put it in perspective. 

16 MR. McCABE: Because if the manufacturers 

17 have to include in the AHRI directory, which 

18 satisfies the FTC labeling requirements -- have 

19 to include the annual energy use, then the 

20 addition of these additional electrical energy 

21 use is going to change the measure of annual 

22 energy use for most, if not all, products. Would 
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1 it not? 

2 MR. DILLON: It depends. It depends on 

3 how the electrical use is currently being 

4 measured by the manufacturer. 

5 MR. BROOKMAN: Frank Stanonik. 

6 MR. STANONIK: Frank Stanonik, AHRI. 

7 That may be the case. But certainly, 

8 presenting this information -- maybe not. I 

9 guess I'm trying to understand why it was felt 

10 that you needed to identify the electrical energy 

11 separately of the gas valve and the controls, 

12 because from my understanding, when you look at 

13 PE, the burner electrical power, and as it's 

14 measured, I don't see how you are not inherently 

15 measuring whatever energy is going on at the 

16 controls, because the controls have to be 

17 operating for the burner to operate. 

18 And that's electrical -- if there is 

19 electrical consumption, my understanding is that 

20 you'd be getting that -- you'd be getting that 

21 energy consumed as you measured PE. Is that not 

22 the case? 
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1 MR. BROOKMAN: I saw Diane first. 

2 MS. JAKOBS: This is Diane. 

3 And there is actually a diagram and how 

4 you wire up the test -- 

5 THE COURT REPORTER: Is your mic on? 

6 MS. JAKOBS: Oh. I turned it up. I 

7 don't know what I did. But anyway -- 

8 MR. BROOKMAN: There is actually a 

9 diagram. 

10 MS. JAKOBS: So it's Diane Jakobs. 

11 And I would say in our listings, E-sub-AE 

12 includes the control and the gas valve. It's 

13 everything else except the blower, is the way we 

14 have interpreted the standard. 

15 MR. BROOKMAN: Okay. Jeff. 

16 MR. KLEISS: Jeff Kleiss, Lochinvar. 

17 And I would say with all the burner -- or 

18 boiler manufacturers that I have worked for, we 

19 have done the total electrical power consumption 

20 at the hookup for the boilers. So that includes 

21 the controls, the gas valve, all the components 

22 are captured in that measurement. 
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1 So I would want to be clear that if 

2 adopting this change is not going to require us 

3 to go back and now hook up and read individual 

4 measurements. 

5 MR. BROOKMAN: Okay. Frank? 

6 MR. STANONIK: Well, I'll let DOE answer. 

7 Well, okay. I mean -- Frank Stanonik, AHRI. 

8 I mean, to Jeff's point, again, reading 

9 this slide and this example calculation, they are 

10 introducing EO, which would be a separate 

11 measurement of your gas valve consumption. So, 

12 to me, the intent clearly is they would make you 

13 measure that separately. And I guess -- 

14 MS. ARMSTRONG: I think -- so this is 

15 Ashley from DOE. 

16 I think the intent is, I think what we 

17 found is that people aren't doing it the same 

18 way. So what we are doing is making it explicit 

19 that it should be all electrical consuming, like 

20 you have been taking your measurements now. 

21 So, to Jeff's point, if he has been 

22 taking them that way all along, his ask is, DOE, 
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1 can you clarify that my measurement is valid? 

2 And so we will take that back. 

3 MR. BROOKMAN: Okay. Thank you for that 

4 clarification. 

5 Yes, Ayk. 

6 MR. YILMAZ: Ayk Yilmaz, AHRI, again. 

7 Just to address a different point, which 

8 is a secondary boiler pump electrical energy 

9 consumption, you had stated that we're going to 

10 be using a measured pump consumption for the BE. 

11 But in fact, under the current 103-2007, the 

12 primary energy BE is a nameplate pump energy; 

13 it's not a measured pump energy. 

14 And I guess I completely missed the 

15 addition on this when I was going through it, 

16 because there wasn't any addressing of test 

17 apparatus or test setup and how to measure pump 

18 power consumption. So, what I would, without 

19 having really thought about this too, too much, 

20 but what I would recommend is to consider 

21 defining secondary pump energy the same way 

22 primary pump energy is defined, which is by the 
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1 nameplate. 

2 MR. BROOKMAN: Thank you. Okay. 

3 Yes, Aniruddh. 

4 MR. ROY: Aniruddh Roy, Goodman. 

5 Just on slide 33, could you just explain 

6 the 7 and 11 percent, again? 

7 MR. DILLON: The 7 percent is related to 

8 the electrical power measurements of the high 

9 fire for the controlling gas valve. So it's 7 

10 percent of the total consumption and 11 percent 

11 of the reduced-fire electrical consumption, 

12 electrical power. 

13 MR. BROOKMAN: Are we ready to move on 

14 now? Okay. 

15 MR. DILLON: The next -- 

16 MR. BROOKMAN: Oh, pardon me, I missed -- 

17 okay, no. Please proceed. 

18 MR. DILLON: The next topic is the 

19 proposal of the smoke stick test for verifying 

20 flow through the heat exchanger. The current 

21 test procedure has three approaches for 

22 determining the value used for the off-cycle flue 
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1 gas draft factor. 

2 The first method measures the draft 

3 factor using the tracer gas test. However, the 

4 tracer gas test may produce unreliable results 

5 for a draft factor of less than 0.1. In place of 

6 conducting the tracer gas test, the DOE test 

7 procedure prescribes default draft factors. 

8 For units designed such that there is 

9 absolutely no air flow through the heat 

10 exchanger, a minimum default draft factor of 0.05 

11 is allowed. With respect to the use of the 

12 minimum default draft factor, the current test 

13 procedure does not provide a method for 

14 establishing absolutely no air flow. DOE's 

15 proposed revision prescribes the use of a smoke 

16 stick test to verify the absence of flow through 

17 the heat exchanger. 

18 Following execution of the smoke stick 

19 test, two paths will be followed. If no visual 

20 disturbance of smoke is demonstrated, the use of 

21 a minimum default draft factor is allowed. If a 

22 visual disturbance of smoke is demonstrated, then 
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1 either the tracer gas test would be performed or 

2 the default draft factor would be used. 

3 In addition to the smoke stick test, DOE 

4 is proposing to remove, in the test procedure, 

5 the term "absolutely" when referencing to no air 

6 flow through the heat exchanger. 

7 MR. BROOKMAN: Jim. 

8 MR. VERSHAW: Yeah, Jim VerShaw. 

9 Can you describe how that test would be 

10 run with the smoke stick and what a smoke stick 

11 is? 

12 (Inaudible interjections and laughter.) 

13 MR. BROOKMAN: For the record, Jim says 

14 they don't allow smoke in the building -- smoking 

15 in the building. 

16 MR. DILLON: Oftentimes, there is puffer, 

17 puffer sticks are used for smoke stick tests. 

18 And the test is described further in detail in 

19 Appendix N of the NOPR. 

20 And essentially, what the test prescribes 

21 is to, based on a minimum height and a minimum 

22 distance away from the combustion intake, you 
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1 place the stick following, I think it's two or 

2 three minutes after the boiler has been shut off. 

3 And you would visually observe to make sure that 

4 there's no induction of air into the combustion 

5 air intake. 

6 MR. BROOKMAN: Yes, Jeff. 

7 MR. KLEISS: Jeff Kleiss, Lochinvar. 

8 And I kind of get where you're going with 

9 that. But I personally say thank you for this. 

10 There's been some -- I've had arguments, 

11 discussions with third-party labs about a valid 

12 method, what they would accept for testing the 

13 presence of draft. And this clarification will 

14 be of significant value to us and help to 

15 simplify our testing. 

16 MS. ARMSTRONG: This is Ashley from DOE. 

17 And I think Jeff just explained very well 

18 why we ended up proposing it. We had similar 

19 issues with different things we were seeing at 

20 labs. So, perhaps Jim has a better way to do it. 

21 Open to it. But there was a problem that we were 

22 seeking a solution for, and this is the proposal 
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1 that we went out with. 

2 MR. BROOKMAN: So, Jeff, thanks for that 

3 comment. That's helpful. That is. 

4 Jim? 

5 MR. VERSHAW: I just missed this one. I 

6 was just asking questions about it. So that's 

7 all. Yeah, I was more concerned about air flow 

8 in the lab and how we're going to do that. 

9 MS. ARMSTRONG: So I -- 

10 MR. VERSHAW: And if somebody can fix 

11 their venting such that it doesn't -- you know -- 

12 MS. ARMSTRONG: So this is Ashley from 

13 DOE. Points well taken. We had issues with the 

14 tracer gas as well. So, I don't know that, you 

15 know... This was the best solution we came up with 

16 and that's why we proposed it. Obviously, we're 

17 open to other ones. But we did see a problem 

18 here that we were trying to fix. 

19 MR. BROOKMAN: Okay. We're moving on. 

20 MR. DILLON: The next topic applies to 

21 the test ductwork for units that are installed 

22 without a return duct. For units that have been 
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1 designed to be installed without a return duct, 

2 DOE believes that the test setup requirements are 

3 not sufficiently specific. 

4 The current test procedure specifies the 

5 use of a return duct for all furnaces according 

6 to the incorporated-by-reference section 7.2.1 of 

7 ASHRAE 103-1993. DOE proposes to not require a 

8 return duct during testing of units intended to 

9 be installed without a return duct. 

10 DOE requests comment on the proposal to 

11 add a provision to the test procedure, clarifying 

12 that the return duct is not required during 

13 testing for units intended to be installed 

14 without a return duct, according to the 

15 manufacturer's I and O manual. DOE requests -- 

16 MR. BROOKMAN: Comments? Comments here? 

17 (No audible response.) 

18 MR. BROOKMAN: Robert Glass asks, How 

19 does one calibrate a smoke stick under ISO lab 

20 certification? 

21 (Laughter.) 

22 MS. JAKOBS: Thank you, Robert. 
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1 (Laughter.) 

2 MR. BROOKMAN: I should note that there 

3 is a little bit of chuckling in the room. Okay. 

4 We'll get a move-on then. 

5 MR. DILLON: The next topic applies to 

6 the test requirements for multi-position 

7 configurations. It is common practice that some 

8 furnaces may be designed such that they can be 

9 installed in multiple configurations -- in other 

10 words, up-flow, down-flow, horizontal flow. For 

11 these types of furnaces, DOE believes that the 

12 test setup requirements in the current test 

13 procedure are not sufficiently specific. 

14 DOE proposes to require that the multi15 position furnaces be tested using, at a minimum, 

16 the least-efficient position. DOE is also 

17 proposing to allow testing using the blower door 

18 instead of one of the inlet openings for 

19 multiple-position furnaces shipped with no inlet 

20 opening. 

21 DOE requests comment on its proposal to 

22 allow testing of units configured with multiple 
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1 position installations to use a blower access 

2 door as an option instead of one of the inlet 

3 openings. 

4 MS. ARMSTRONG: So, this is Ashley from 

5 DOE, just to explain a little bit further where 

6 this came from. 

7 When we went to a lab to do furnace fan 

8 testing, these questions came out of it. And so, 

9 there were some questions provided to DOE about, 

10 what do we do for furnaces? Because there is 

11 some specificity in the furnace fan test 

12 procedure, and what this is aimed to do is 

13 provide some harmonization there. 

14 MR. VERSHAW: Well, this is Jim VerShaw. 

15 We go to a lot of lengths to make sure 

16 the blower door is not open when we run a 

17 furnace. On our furnaces, the upper door won't 

18 stay on if you have the lower door off. And then 

19 you have to tape or jumper out the door switch. 

20 We -- I'm not so sure, I'm not sure, I don't 

21 think I've seen a furnace without an inlet. 

22 MS. ARMSTRONG: So, there was one brought 
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1 up. So the question was asked; I can tell you 

2 that for certain. 

3 MR. VERSHAW: Okay. 

4 MS. ARMSTRONG: What would you do? So if 

5 you have one, we're going to use open inlet, no 

6 issue. But if you don't, the question was asked 

7 of DOE, "What do we do?" And so this is our 

8 clarification there. 

9 MR. BROOKMAN: Dave? 

10 MR. WINNINGHAM: This is Dave. 

11 There are some products where it's got 

12 like maybe a bottom knock-out, or, you know, 

13 where the side -- 

14 MR. VERSHAW: We've got a panel that you 

15 have to take out. Yeah. 

16 MS. ARMSTRONG: The panels and the knock17 outs, I wouldn't call -- 

18 MR. VERSHAW: It's not open. 

19 MS. ARMSTRONG: This wasn't a situation 

20 exactly we were dealing with. 

21 MR. VERSHAW: Okay. 

22 MS. ARMSTRONG: Fully. But this exact 
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1 question was asked of DOE. 

2 MR. BROOKMAN: Frank Stanonik. 

3 MR. STANONIK: Frank Stanonik, AHRI. 

4 Without knowing the magnitude of the 

5 effect, this one clearly is -- would require some 

6 models to be rerated, just assuming that since 

7 the requirement now spells out that you're going 

8 to have to test it at least, at a minimum, at the 

9 least-efficient position, which would suggest 

10 that it wasn't as clear before. 

11 This, you know, again, this seems to 

12 clearly would require rerating of some products. 

13 That is going to get into the issue of, you know, 

14 whether they are meeting the minimum. 

15 MS. ARMSTRONG: Yes. So this is Ashley 

16 from DOE. 

17 That is my understanding of what is done 

18 now. Obviously, I welcome comments on that. 

19 That is the suggestion we got for clarification 

20 from the industry. So, that was what I was 

21 understanding was being done today anyway. So it 

22 was our understanding that it would not impact 
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1 ratings, as you suggest. But like I said, I 

2 could be wrong. 

3 MR. STANONIK: Frank Stanonik, AHRI. 

4 Now, actually, I also believe that's what 

5 was being done today. And I was a little 

6 concerned because when DOE raised it, it raised 

7 the question, was somebody doing it differently? 

8 Okay. Okay. 

9 MS. ARMSTRONG: No, no. I think that's 

10 fair. Thanks. We agree. 

11 MR. BROOKMAN: Thanks, Frank. 

12 MR. DILLON: The next topic is the 

13 proposal of the verification test for automatic 

14 means for adjusting the water temperature in hot 

15 water boilers. In 2008, DOE published a 

16 technical amendment to add design requirements 

17 for hot water boilers consistent with the 

18 provisions of EISA 2007. 

19 The design requirements require an 

20 automatic means for adjusting the water 

21 temperature for gas-fired, oil-fired, and 

22 electric hot water boilers. DOE's proposed test 
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1 method would be used only in the case of 

2 assessment and enforcement testing by DOE, which 

3 is to be specified in 10 CFR 429.134. Currently, 

4 there is no test for functional verification of 

5 automatic means. DOE's proposed revision 

6 includes separate verification methods for hot 

7 water boilers with single-stage and two-stage 

8 modulating control. 

9 DOE believes this allows for the 

10 necessary verification of boiler automatic means 

11 functionality. Also, manufacturers do not have 

12 to conduct this testing. These verification 

13 methods will be used by DOE to determine if a 

14 given basic model complies with the applicable 

15 design requirements. 

16 MR. BROOKMAN: Jeff. 

17 MR. KLEISS: Jeff Kleiss, Lochinvar, of 

18 course. 

19 The first comment that I have about this 

20 is the test procedure that you have for single21 stage boilers is verification of whether or not 

22 there's -- the call for heat is satisfied by 
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1 residual heat in the boiler. That is an optional 

2 method for automatic means for single-stage 

3 appliances. It is not the only allowed means. 

4 And yet, the test procedure that you have 

5 written here, that is the only allowable means to 

6 verify automatic means -- compliance. That needs 

7 to be changed. 

8 MS. ARMSTRONG: So, explain to me what 

9 your options are now. 

10 MR. KLEISS: Currently, the requirement 

11 for automatic means is that you would adjust your 

12 temperature set point based on demand or heat 

13 load requirement, which is your test procedure 

14 that you have for multi-, two-stage, and 

15 modulating products. 

16 And then, there is an option within the 

17 automatic means clause that single-stage 

18 appliances may check for meeting the heating 

19 requirement with residual heat in the boiler. 

20 That is an option. 

21 So, what I'm saying is that the test to 

22 determine if you're complying with automatic 
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1 means for single-stage boilers should not only be 

2 based on residual heat in the boiler. But they 

3 should be allowed to be tested by the same test 

4 procedure as the two-stage and modulating 

5 boilers. 

6 MS. ARMSTRONG: All right. Thank you. 

7 MR. BROOKMAN: Yes, Frank. 

8 MR. STANONIK: Frank Stanonik, with AHRI. 

9 Again, I appreciate what's been said here 

10 as far as the impact. But again, I'm getting 

11 tangled up in what I believe are the regulations. 

12 So, it was mentioned at the end that 

13 manufacturers do not have to conduct this 

14 testing. It will be how DOE will determine if a 

15 model complies with the design requirements, but 

16 if I'm submitting a certification report to DOE, 

17 don't have to do it? 

18 MS. ARMSTRONG: Don't have to do it. 

19 MR. STANONIK: Don't have to do it. 

20 Okay. All right. Right. 

21 MS. ARMSTRONG: So, this is Ashley from 

22 DOE. 
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1 So, this is kind of new territory for DOE 

2 in the past couple of years. So perhaps I can 

3 explain a little bit. It is a design standard. 

4 As you certify today, you certify compliance with 

5 that design standard. It's more or less an 

6 affirmation that you've manufactured the product 

7 and it complies with that design standard. 

8 So, Frank, we're not looking for anything 

9 from the test. We're not even looking for the 

10 test data for you. However, if we get a 

11 complaint, if we purchase a product for 

12 assessment or verification purposes, we will run 

13 this test to assess whether you comply with that 

14 design standard. This is how we are going to 

15 gauge it. 

16 So this is so you know, so you don't have 

17 to run it. But if you want to know what we're 

18 going to do, and obviously you should know what 

19 we're going to do, this is a method we will be 

20 running. Does that help? 

21 MR. BROOKMAN: That was clear. That 

22 explains it. 
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1 Please, Jeff. 

2 MR. KLEISS: Jeff Kleiss, Lochinvar. 

3 To that end, there is -- the method is 

4 fairly vague as far as -- and I know that's 

5 intentional, because there's a wide variety of 

6 different methods of automatic -- satisfying 

7 automatic means. 

8 But within that, there is no -- nothing 

9 is listed as far as what is required to comply. 

10 There's a test method. And you get a result out 

11 of the test method of a certain time that it 

12 takes, the delay, for the burner to come on or 

13 something like that. But there's no indication 

14 of what does and does not constitute compliance. 

15 MS. ARMSTRONG: Got it. Thank you. 

16 MR. KLEISS: And if I may continue, I do 

17 have some concern as a participant in a VICP 

18 [voluntary industry certification program]. And 

19 we submit data, and we fill in a check-box to 

20 say, yes, we do have an automatic means. Is this 

21 something that will become a requirement that if 

22 you're participating in a VICP, that at some 
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1 point we're going to have to test to this rather 

2 than fill in our check-box? 

3 MR. BROOKMAN: Say what a VICP is. 

4 MR. KLEISS: Voluntary Industry 

5 Certification Program. 

6 MR. BROOKMAN: Got you. Thank you. 

7 MS. ARMSTRONG: So, I don't think that's 

8 for DOE to answer, per se. I think that's 

9 dependent upon your VICP. I mean, that's -- the 

10 VICPs are run by the industry programs. What 

11 we're just trying to do here is make it crystal 

12 clear in the cases of when we get into an 

13 assessment or an enforcement setting, how we are 

14 going to judge you. 

15 So your points are well taken about some 

16 of the ambiguities that may be in the test 

17 procedure as it was proposed, and we will look 

18 into that. But I don't think DOE has any comment 

19 on the requirements of a VICP. 

20 MR. KLEISS: Jeff Kleiss, Lochinvar. 

21 And just from that standpoint, DOE does 

22 have certain requirements to accept data from a 
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1 VICP, and I guess that's where I'm directing my 

2 question. 

3 MS. ARMSTRONG: Okay. So, this is Ashley 

4 from DOE. 

5 So that's just certification data. And 

6 so that would go back to Frank's question. This 

7 test is not being proposed as a certification 

8 test that you need to do in advance of certifying 

9 your products and distributing in commerce. It's 

10 still going to have a check-box. There was no 

11 companion change to the cert report here. 

12 But this is just purely a verification 

13 and enforcement test, which is why you see it 

14 located in 429.134 instead of in the Appendix 

15 with the test procedure. 

16 MR. BROOKMAN: Okay. Thank you, Ashley. 

17 Additional questions, comments, before we 

18 move on? 

19 (No audible response.) 

20 MR. BROOKMAN: Okay. 

21 MR. DILLON: All right. Great. 

22 The following slide includes details 
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1 related to the design requirements for hot water 

2 boilers and the known methods used to fulfill 

3 those requirements. The requirements and methods 

4 apply separately to the type of boiler, single5 stage and two-stage. The design requirement for 

6 single-stage hot water boilers specifies that the 

7 requirement may be satisfied by providing an 

8 automatic means that allows the burner or heating 

9 element to fire only when the means has 

10 determined that the inferred heat load cannot be 

11 met by the residual heat of the water in the 

12 system. 

13 DOE's understanding is that the common 

14 method for fulfilling this requirement is what is 

15 referred to as thermal pre-purge. This method 

16 delays burner activation until the residual heat 

17 of the boiler water cannot meet the heating load, 

18 thus using no fuel when operating using residual 

19 heat. 

20 The design requirement for two-stage and 

21 modulating hot water boilers specifies that 

22 controls will automatically adjust the 
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1 temperature of the water supplied by the boiler 

2 to ensure that an incremental change in inferred 

3 heat load produces a corresponding incremental 

4 change in the temperature of water supply. 

5 There are two commonly used methods for 

6 fulfilling this requirement -- outdoor reset and 

7 inferred load. The outdoor reset method adjusts 

8 supply water temperature in response to changes 

9 in outdoor air temperature, resulting in lower 

10 fuel input at higher outdoor air temperatures. 

11 The inferred load method uses outdoor and indoor 

12 temperature, thermostat demand, and/or burner 

13 cycling patterns to infer heating load and adjust 

14 the supply water temperature, resulting in lower 

15 fuel input at lower inferred loads. 

16 The figure in this slide presents the 

17 test results from DOE's product testing 

18 associated with the proposed test for 

19 verification of automatic means for single-stage 

20 hot water boilers. The intent of this test is 

21 for a boiler containing residual heat to verify a 

22 delay in burner ignition following a call for 
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1 heat. 

2 Supply water temperature is presented by 

3 the red dotted line. Inlet water temperature is 

4 presented by the blue dotted line, and gas 

5 consumption is presented by the green dotted 

6 line. 

7 After the boiler is set up according to 

8 the prescribed method, the warm-up and 

9 stabilization period occurs and is represented by 

10 the gradual increase in supply water temperature 

11 at the point of stabilization, which occurs at 

12 the first box. After temperature stabilization, 

13 the call for heat is terminated at the next box. 

14 The test method allows a delay of up to 

15 three minutes prior to re-initiating the call for 

16 heat. After the time delay, the call for heat is 

17 re-initiated. Immediately after the call for 

18 heat, the burner was monitored for ignition. A 

19 delay in burner ignition was observed of roughly 

20 45 seconds in this case, which is shown by the 

21 elapsed time between the call for heat and the 

22 burner ignition, the last two boxes. 
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1 The figure in this slide presents the 

2 test results from DOE's product testing, 

3 associated with the proposed test for 

4 verification of automatic means for two-stage and 

5 modulating hot water boilers, utilizing the 

6 outdoor temperature reset method. 

7 The purpose of this test is to observe 

8 the response in supply water temperature as a 

9 result in change in outdoor air temperature. 

10 Supply water temperature is presented by the red; 

11 inlet temperature presented by the purple line; 

12 gas consumption, by the orange; and simulated 

13 outdoor temperature, by the green. 

14 After the boiler is set up, warm-up 

15 initiated, and water temperature is stabilized 

16 according to the prescribed test method, the next 

17 step would be to activate the automatic means 

18 functionality, if that's necessary. 

19 At the first box, the next step was to 

20 establish the simulated low inferred load 

21 conditions as presented by the high outdoor air 

22 temperature, which is seen on the first arrow on 
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1 the green line. 

2 The next step was to establish the low -- 

3 pardon me. Following the simulation of low 

4 inferred load conditions, the supply water 

5 temperature was allowed to stabilize. Once 

6 stabilized, the next step consisted of 

7 establishing the high inferred load conditions, 

8 which occur down here at the second arrow on the 

9 green line. 

10 The high inferred load conditions were 

11 established by placing the outdoor air 

12 temperature sensor in an ice bath. Following 

13 placement of the outdoor temperature sensor into 

14 the ice bath, it was observed that the supply 

15 water temperature began increasing after a short 

16 delay. Once the supply temperature stabilized, 

17 the test was complete. 

18 (Pause.) 

19 MS. ARMSTRONG: I'm going to pause here. 

20 Does anyone have any last-minute questions on the 

21 verification procedures before we go to our 

22 closing remarks and kind of wrap up for the day? 
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1 Sure. 

2 MS. JAKOBS: This is Diane from Rheem. 

3 And on slide 32, I don't know if I wasn't 

4 paying attention. But you added a couple of new 

5 terms to the equation for E-sub-AE. And it's 

6 related to the ignition. Is that right? That's 

7 the way I -- 

8 MR. DILLON: This is Ross Dillon. 

9 The BE-sub-S term is for the secondary 

10 pump if present. And the E-sub-O term is for the 

11 gas valve and controls. 

12 MS. ARMSTRONG: So, Diane, to your point 

13 earlier -- this is Ashley -- you raised, said 

14 that's the way you were testing all along, that 

15 you were already incorporating that electrical 

16 consumption of your valves holistically into the 

17 terms. So we're going to take that back and take 

18 a look at it. 

19 MS. JAKOBS: Okay. But I think I -- 

20 well, I just want to clarify for myself. I 

21 thought you were going to take the electrical 

22 consumption during the ignition. So like our hot 
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1 surface ignition, or spark ignition, there's 

2 different electrical consumptions depending on 

3 how you light the gas. I might have read a lot 

4 more into it. 

5 MR. BROOKMAN: Frank? 

6 MS. ARMSTRONG: That's already in there, 

7 right? 

8 MR. STANONIK: Frank Stanonik, AHRI. 

9 Isn't there a term for that already? 

10 Yeah. 

11 MR. DILLON: There is a term for the 

12 ignition. That was wrong. 

13 MS. ARMSTRONG: That's already in there 

14 now. 

15 MS. JAKOBS: Okay. All right. Thank 

16 you. 

17 MS. ARMSTRONG: So, seemingly, we have 

18 some more ambiguities, perhaps, in this equation. 

19 We'll take it back and look at it. The intent, 

20 though, is to capture the electrical consumption 

21 wholesale. 

22 MR. HUNT: This is Marshall Hunt, PG and 
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1 E. 

2 But what I'm hearing is you can capture 

3 without breaking it out? 

4 MS. ARMSTRONG: Yep. 

5 MR. HUNT: Okay. 

6 MR. BROOKMAN: Diane, did you get 

7 everything you wanted to say said? 

8 MS. JAKOBS: I have to go home and read 

9 it again. 

10 (Laughter.) 

11 MR. BROOKMAN: Okay. 

12 MS. JAKOBS: Thank you. 

13 MR. BROOKMAN: You've got another five14 ten minutes if you want to look. 

15 Ayk. 

16 MR. YILMAZ: Ayk Yilmaz, AHRI, again. 

17 Is this the appropriate time to bring up 

18 topics about the test procedure that haven't been 

19 addressed in the public meeting? 

20 MR. BROOKMAN: I think so. Yes. 

21 MR. YILMAZ: Okay. I didn't hear much 

22 discussion about some of the modifications that 
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1 have been made to the setup of the gas and oil 

2 burners specifically with relation to the flue, 

3 O2 or CO2 adjustments. And it's on page, at 

4 least of the pre-publication, page 133 and 135. 

5 It's section 7.3 and 7.5 of the test procedure. 

6 And I guess I was just hoping to get some 

7 statement from the developers of this about how 

8 the 30th percentage range was arrived at and the 

9 default O2 or CO2 levels were arrived at in the 

10 absence of direction from the I and O manual of 

11 the appliance. 

12 MR. BROOKMAN: Just make sure that 

13 microphone is working there. 

14 Victor, is that you? 

15 (No audible response.) 

16 MR. BROOKMAN: Ayk, stay at that 

17 microphone. Stay there. 

18 (Pause.) 

19 MR. FRANCO: Is it on? 

20 MR. BROOKMAN: I think it's on, yes. 

21 MR. FRANCO: Could you repeat that 

22 question once again? 
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1 MR. YILMAZ: Sure. Sections 7.3 and 7.5 

2 of the test procedures relate to the setup of the 

3 gas and oil burners, respectively. And there's a 

4 modification to the ASHRAE 103-2007 test 

5 procedure with relation to that. 

6 And my question is specifically regarding 

7 the instructions to set up the burners to either 

8 the 30th percentile of the range specified in the 

9 furnace’s or boiler’s I and O manual, or in the 

10 absence of such a specification, a combustion air 

11 flow to provide a specified O2 or CO2; depending 

12 on whether it's a gas or oil burner, it changes. 

13 And I was hoping to get some explanation 

14 about how those procedures were arrived at. 

15 MR. BROOKMAN: Well, I see Frank has a 

16 comment here. 

17 MR. STANONIK: Dave and Mark, you're 

18 really not whispering. Thank you. We can hear, 

19 and it's disrupting the discussion here. Sorry. 

20 MR. BROOKMAN: So, thanks for restating 

21 the question. 

22 Victor? 
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1 MR. FRANCO: Yes. We don't have a 

2 response to that right this second. We will try 

3 to come up with that. 

4 MS. ARMSTRONG: How about this? This is 

5 Ashley. We'll look into it. Let me get back to 

6 you. That's the best way to do it. 

7 MR. BROOKMAN: Thanks. Now, Frank, 

8 please. 

9 MR. STANONIK: Frank Stanonik, AHRI. 

10 And I did not choreograph this. But I 

11 mean, there is two issues there. First of all, I 

12 mean, it is a change. Because right now, the 

13 procedure is kind of silent, and so they just 

14 need to find a number that's inside the range. 

15 And this is much more specific. 

16 But then, to that second point, what the 

17 hell is the middle of the 30th percentile? I 

18 don't understand that. So, if it's going to be 

19 specific, you know, I would hope that there would 

20 be some better language that would be clear on 

21 that. 

22 MR. BROOKMAN: Can you recommend 
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1 something off the top of your head? 

2 MR. STANONIK: Frank Stanonik. 

3 In this case, no. Because I'm not -- 

4 again, I'm not sure what they were telling us to 

5 do. 

6 MR. VERSHAW: Jim VerShaw. 

7 On furnaces, the ones that I'm familiar 

8 with, including Diane's and all the competitors, 

9 there's no air adjustment, not anymore. I mean, 

10 in the olden days you used to have shutters and 

11 such. But I mean, you set the gas, and it is 

12 what it is. Unless you go in and put a variac on 

13 the inducer or you start restricting things, 

14 you're changing orifices and taking things apart. 

15 So, and I don't think anybody puts a -- I 

16 don't think anybody puts a CO2 level in their I&O 

17 manual, because the gas is so different across 

18 the country in elevations and all that stuff. 

19 You'd have people going crazy trying to hit that. 

20 MR. BROOKMAN: Frank. 

21 MR. STANONIK: Frank Stanonik, AHRI. 

22 And, Jim, I'm sure what you're saying is, 
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1 you know, reflective of gas. Okay? Or at least 

2 gas furnaces. But it is a trap we all fall into. 

3 This also addresses oil. And it is very common 

4 for an oil burner to specify. And so this has -- 

5 MR. VERSHAW: This section was not a gas 

6 burner. 

7 MR. STANONIK: Well, no. It says the 

8 same thing for oil, though. I mean, in both 

9 cases they have established that -- 

10 MR. VERSHAW: Well, I'm pretty parochial 

11 in my comments. I'm worried about gas burners 

12 right now, okay? 

13 (Laughter.) 

14 MR. STANONIK: My comment was for both. 

15 MR. BROOKMAN: You're sticking by gas, 

16 and Frank is going for both. 

17 MS. ARMSTRONG: Thank you. We'll look 

18 into it, on both. 

19 MR. BROOKMAN: Jeff? 

20 MR. KLEISS: Yeah, Jeff Kleiss, 

21 Lochinvar. 

22 And I can say for many of our gas 
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1 products, air-fuel ratio is controllable and we 

2 do publish ranges. But to call out, to be in the 

3 middle of the range is -- that would be 

4 problematic. 

5 MS. ARMSTRONG: Okay. 

6 MR. KLEISS: That is, we do have 

7 procedures that have been written that do specify 

8 operating within published ranges for certain 

9 product classes. And that, I think, would be 

10 reasonable to discuss. But to force it to be 

11 into the middle is a significant change and 

12 something that we oppose. 

13 MS. ARMSTRONG: Okay. 

14 MR. BROOKMAN: Michael McCabe. 

15 MR. VERSHAW: This is Jim one more time. 

16 I would think that you would have some 

17 statement in there. If you can -- if it is field 

18 adjustable on the air side, then you do this for 

19 an air setup. 

20 MS. ARMSTRONG: Sure. 

21 MR. VERSHAW: But if it's not, then it is 

22 what it is. 
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1 MS. ARMSTRONG: Got it. Thanks. 

2 MR. BROOKMAN: Michael McCabe. 

3 MR. McCABE: It's Michael McCabe. 

4 A couple of housekeeping issues. The 

5 Department proposed amendments to section 430.23, 

6 N2, which is annual fuel utilization efficiency. 

7 This is the section that, for example, FTC refers 

8 to in what goes on the label. And in there, the 

9 Department proposed changes to the ASHRAE 

10 standards. 

11 It was referencing the rounding to one12 tenth of an AFUE. But they did not change a 

13 reference to section 10.1 of Appendix N. 10.1 of 

14 Appendix M is the heating seasonal efficiency of 

15 electric furnaces and boilers. That section 

16 reference, I believe, should be to section 10.2 

17 of the new Appendix N. The old Appendix N, it is 

18 an AFUE paragraph. 

19 Similarly, in the section above, which 

20 deals with the estimated annual operating cost, 

21 that section includes references to sections 

22 10.2.2 and 10.2.3 of Appendix N. In the proposed 
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1 Appendix N, those sections do not exist. My 

2 recommendation to the Department, on 430.23N is, 

3 look at all those sections and the references, 

4 because I believe most, if not all, need to be 

5 cleaned up and properly referred to in the new 

6 Appendix N. 

7 MR. BROOKMAN: Okay. Thank you, Michael. 

8 MR. McCABE: Similarly, in the proposed 

9 Appendix N, I'll just -- one example. And I 

10 believe it will apply to many sections 

11 throughout. I'm kind of looking at Eric, because 

12 Eric and I, we've had discussions about 

13 consistency. And where you lack consistency, 

14 that's where things tend to fall apart. 

15 And in section 10.5.1.3, which is for 

16 furnaces and boilers equipped with step 

17 modulating controls, there is an equation. 

18 Within the equation, there are three values which 

19 are not defined. X-sub-M, B-sub-M, and 2080. 

20 The first two, X-sub-M and B-sub-M, are not 

21 defined anywhere within Appendix N. The 2080 is 

22 defined elsewhere, but for most of the equations, 
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1 the Department tries to define all the values 

2 that are in there, but not all. 

3 And my recommendation is to go through 

4 the entire Appendix N that's being proposed and 

5 scrub it so that the equations and the 

6 definitions are consistent from one to the other. 

7 Otherwise, you know, there are going to be 

8 questions raised as to exactly what the 

9 Department is getting at. 

10 MR. BROOKMAN: Okay. Thank you. 

11 MS. ARMSTRONG: So, I want to make one 

12 comment in response to that. And this is Ashley 

13 from DOE. 

14 So those points are well taken, and we'll 

15 look back at it. I do want to say that FTC 

16 [Federal Trade Commission] updated their 

17 requirements lately. It's harmonized now with 

18 DOE's sampling provisions in 429, as well as the 

19 test procedures in part 430, so it no longer 

20 references 430.23. However, it's well taken that 

21 we should be consistent. 

22 As well as the submission of data that 
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1 was mentioned earlier, FTC also revised that. So 

2 there was a question about E-sub-AE and whether 

3 FTC collects that information. FTC's regs and -- 

4 I can't speak for Hampton. I'm just reading the 

5 regs from my cell phone. So, but FTC did revise 

6 to require submission for DOE-covered products to 

7 DOE through CCMS. And that is also consistent 

8 with the information that DOE collects, also is 

9 the same information that FTC is now requiring, 

10 because it cross-references our certification 

11 requirement. DOE does not collect E-sub-AE at 

12 this time. 

13 MR. BROOKMAN: Diane. 

14 MS. JAKOBS: Just to kind of follow on 

15 after Michael. It would be nice if we didn't 

16 have all these references back and forth to 

17 ASHRAE 103. It's really confusing. I mean, we 

18 do work with a program that's kind of a black 

19 box. And it's not that we're doing something 

20 wrong because an engineer doesn't understand it. 

21 But it would be good if everything was in one 

22 place and you could point a new employee to one 
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1 single document. It's just very complicated and 

2 confusing. 

3 MR. BROOKMAN: Okay. 

4 MS. JAKOBS: So, having it back and forth 

5 between two documents makes it worse. 

6 MR. BROOKMAN: Whose job is that? 

7 MS. ARMSTRONG: DOE's. 

8 (Laughter.) 

9 MS. ARMSTRONG: So, Diane, what I'm 

10 hearing from you is you're asking us to pull the 

11 applicable provisions from ASHRAE 103 into the 

12 CFR holistically. 

13 MR. BROOKMAN: Okay. Thanks, Ashley, and 

14 also Diane. 

15 We're reaching the point in the day where 

16 I think we're ready to take final comments, 

17 summary comments, closing remarks here at the 

18 end, as we move towards closure. Frank. 

19 MR. STANONIK: Frank Stanonik, AHRI. 

20 And this is an issue that we commented on 

21 in our response to the RFI. And it doesn't look 

22 like -- well, we don't know what DOE's response 
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1 is. And specifically, we do think, you know, 

2 that there should be an attempt in this revision 

3 to allow some means for calculations of ratings. 

4 You know, it's always been there. For 

5 the famous example, cast-iron sectional boilers, 

6 you know, we've got processes for commercial 

7 products. And since we are revising the 

8 procedure, and it would certainly have the 

9 benefit of reducing burden, you know, we had kind 

10 of suggested that there ought to be something to 

11 allow some process for rating of products through 

12 interpolation, extrapolation. 

13 And I guess, Ashley, I mean, one of the 

14 questions we have is, you know, we raised that in 

15 the RFI. And I don't even see it addressed in 

16 this. I guess, so is it just not now? Or is it 

17 not ever? Or -- sorry? Or what? 

18 MS. ARMSTRONG: This is Ashley from DOE. 

19 Never say never. 

20 (Laughter.) 

21 MS. ARMSTRONG: So, I think the answer is 

22 we're still thinking about it, which is why you 
151 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 don't see it there. You know, it's not typical 

2 practice to allow simulation AEDM-like methods 

3 for consumer products. There are a couple of 

4 exceptions to that -- CACs [central air 

5 conditioners] being one of them. You know, we're 

6 happy to continue the conversation, though. 

7 MR. STANONIK: Okay. Thanks. 

8 MS. ARMSTRONG: Okay? 

9 MR. STANONIK: Okay. 

10 MS. ARMSTRONG: So with that, I think I 

11 just want to thank you all for coming and 

12 participating today. It was very helpful to 

13 myself, so I appreciate you taking the time and 

14 effort. Just to remind you that the comment 

15 period closes in May. 

16 I do want to point out that if you do 

17 take this home with you on the flight, the docket 

18 number on the front is wrong. It's correct on 

19 that. Somehow we added the zero on the front. 

20 So if you happen to use that one through your 

21 searching, it won't actually -- it's fixed, 

22 though, in the actual docket. 
152 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 But thank you all for coming, and we'll 

2 talk to you later. 

3 (Pause.) 

4 MR. BROOKMAN: Okay. Thanks, everyone. 

5 (Whereupon, at 3:51 p.m., the meeting was 

6 adjourned.) 

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153 

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 

OLENDER REPO~TING , INC. 

1100 Conne c ticut Avenue NW, # 810 , Washington, DC 2003 6 

Was hingt on : 20 2-898-1108 • Balt imore: 410-752-3376 

~o ll Free: 88 8-4 45-33 76