Department of Energy

Washington, DC 20585

March 23, 2009

Mr. Dalbir Sandev

President

Empire Comfort System, Inc.

P.O. Box 529

Belleville, IL 62222-0529

RE: Request for information regarding possible standby and offmode energy use for unvented

heaters

Dear Mr. Sandev:

As you may know, section 310 ofthe Energy Independence and Security Act of2007

(EISA 2007), Pub. L. 110-140, amended the Energy Policy and Conservation Act (EPCA). In

the relevant part, EISA 2007 requires the U.S. Department of Energy (DOE) to amend, if

technically feasible, all DOE test procedures for covered consumer products to account for

standby mode and offmode energy consumption. (A brief description of EISA 2007, along with

the relevant legislative language, is provided as Attachment A.) Of particular note here, the

legislation requires DOE to amend the test procedure for direct heating equipment (of which

unvented heaters are one subcategory) by March 31, 20 IO.

By way of background, the unvented heater test procedure is found at Title 10 ofthe

Code of Federal Regulations (10 CFR) 430.23(g) and 10 CFR part 430, subpart B, appendix G.

This procedure applies to both electric and fossil-fueled unvented heaters. This procedure only

requires measurement ofinput energy rate (e.g. Btu'slhour). Output energy rate is simply

equated to input energy rate. This energy rate is converted by mathematical constants to either

dollars per million Btu's output and/or annual energy consumption. (Annual energy

consumption is calculated only for electric heaters that are the primary heating source for the

entire house. Supplemental heaters and unvented heaters using either natural gas, propane, or oil

only require calculation of dollars per million Btu's.) As currently written, this procedure

generally reflects the lack of any appreciable energy performance difference among models of

this product subcategory. To date, this product subcategory has not been subject to any labeling

requirements or energy conservation standards. As mentioned above, pursuant to EISA 2007,

DOE must now include provisions to measure standby and offmode energy use in the test

procedures used for these and many other products. This brings up the question of whether

unvented heaters use energy in standby offmodes. DOE anticipates that such test procedure

amendments could identitY an opportunity for energy performance improvements in unvented

heater models. DOE is interested in gathering information that will help it to fulfill the

requirements of EPCA, as amended, without causing undue burden to the industry.

DOE realizes that this product subcategory presents a unique set of circumstances when

addressing EISA 2007, particularly regarding the EISA 2007 provisions on energy conservation

standards. First, unlike other test procedures, appendix G does not include energy efficiency or

energy use metrics that would allow for the integration ofstandby and offmode energy use. As

*Printed with soy ink on recycled paper
a consequence, there currently exists no basis to establish what EISA 2007 would call a single or

integrated standard for unvented heaters.

Second, standby mode energy use (defined as energy use during the heating season when

the heater is not on) could be considered as effective in heating the space as active mode energy

use. Therefore, DOE is evaluating the appropriateness ofmeasuring this energy use or its

possible inclusion in an energy conservation standard.

Finally, offmode energy consumption (defined as non-heating season energy

consumption) could be considered energy use and, accordingly, could be minimized by

prescribing a separate energy conservation standard. However, defining a representative off

mode for this subcategory is difficult because ofthe lack of data on consumer use. Specifically,

DOE is not currently aware of data on the fraction ofthe year heaters are unplugged or otherwise

disconnected from the energy source, and the extent to which pilot lights are turned off during

the non-heating season. This unique set of circumstances forms the basis ofthis inquiry.

Definitions

To aid in responding to the questions below, the following definitions of "active mode,"

"standby mode," and "off mode" apply:

• "Active mode" is the period during the heating season when the burner or heating

element is on.

• "Standby mode" is the period during the heating season when the main burner or heating

element is not on.

• "Off mode" is the entire non-heating season, unless there is disconnection from the

energy source.

The duration ofthe heating and non-heating seasons for these products can be assumed to be

the same as the representative values used for all other DOE test procedures for heating

products, i.e., 4 I60 hours heating season and 4600 hours non-heating season. One

complication for this subcategory is the possibility ofthe product being placed out ofservice

during the heating season. This possibility would impact the accounting ofoff mode and

standby mode. For example, these out-of-service hours during the heating season could be

debated as more appropriately off mode rather that standby mode. Nonetheless, rather than

sorting out this complication at this time, DOE believes the above proposed simplified

definitions are sufficient to allow for informative answers to the following questions.

However, your views on this complication are welcome.

Questions

In light ofthe above, DOE would appreciate your answers to the following questions:

I. Do you manufacture, and are you aware of other manufacturer models of, fossil-fueled

unvented heaters that have measurable fossil-fueled standby and offmode energy use (e.g.,

pilot lights)? Ifso, what is your estimate ofthe range ofthe energy use rates for such models

(btulhour)?
2. Do you manufacture, and are you aware of other manufacturer models of, fossil-fueled

unvented heaters that have measurable electrical standby and off mode energy use? lfso

what is your estimate ofthe range of energy use rate (walts)?

3. Do you manufacture, and are you aware of other manufacturer models of, electric unvented

heaters that have measurable electric standby and off mode energy use? Ifso what is your

estimate ofthe range of energy use rate (watts)?

4. Ideally, the ranges of energy use rates above could be converted to ranges of annual

consumption values if a reasonably representative range of annual hours of offmode usage

can be defined. Are you aware of data or studies that would aid DOE in defining

representative annual hours of offmode use for the types of products discussed above? If

so, please identify them and add your thoughts on the accuracy and relevance ofthe data.

5. Absent DOE-prescribed representative hours ofoff mode, what is your view about a limited

test procedure that only requires measurement and disclosure of energy use rate (i.e., wattage

and/or pilot light btu/hour)? Additionally, what is your view on a potential subsequent

regulation based only on energy use rate?

6. Is the Standard 62301 ofthe International Electrotechnical Commission, Household

Electrical Appliances - Measurement ofStandby Power, sufficient and appropriate to

measure electric standby and/or off mode energy use rate? In your answer, please explain

why they are, or not, sufficient.

DOE requests that answers be provided not later than April 8, 2009, in order to allow the

Department sufficient time to incorporate such information into its test procedure rulemaking for

direct heating equipment, which is being conducted pursuant to EISA 2007. It is important to

note that the current ongoing standards rulemaking for direct heating equipment will not be

impacted by the possible test procedure amendments discussed here. Should you have any

questions, please feel free to contact Mohammed Khan ofmy staff at (202) 586-7892.

Sincerely,

~~/;;;~ Supervisor--Regulatory

Appliance Standards

Building Technologies Program

Energy Efficiency and Renewable Energy

Enclosure
ATTACHMENT A

The Energy Independence and Security Act of2007 (EISA 2007), Pub. L. 110-140,

amended the Energy Policy and Conservation Act (42 U.S.C. 6291 et seq.; EPCA), and in

relevant part, directs DOE to amend its test procedures to include measures ofstandby mode and

offmode energy consumption, unless such measures are already fully incorporated in the current

test procedure or would be technically infeasible to prescribe (EISA 2007, section 310; 42 U.S.c.

6295(gg)(2)(A)). The EISA 2007 amendments to EPCA further direct DOE to amend the test

procedures to integrate such energy consumption into the overall energy efficiency, energy

consumption, or other energy descriptor for that product. Ifamending the test procedure in this

manner is technically infeasible, DOE must prescribe a separate standby mode and off mode

energy use test procedure, iftechnically feasible. Any such amendment must consider the most

current versions ofthe International Electrotechnical Commission (IEC) Standard 62301 and

IEC Standard 62087. For residential water heaters, direct heating equipment, and pool heaters,

DOE must prescribe any such amendment to the test procedures by March 31,2010. (EISA

2007, section 310; 42 U.S.C. 6295(gg)(2)(B)(v))

Unvented heaters are a class of direct heating equipment. DOE's test procedure currently

does not include provisions for measuring or accounting for "standby mode" or "offmode"

energy use, as defined by EISA 2007. Accordingly, the test procedure would need to be

amended to include such accounting.

Legislative language from EISA 2007
"(2) TEST PROCEDURES

"(A) TN GENERAL.--Test proceduresfor all covered products shall be amended pursuant to

section 323 to include standby mode and offmode energy consumption, taking into consideration

the most current versions o{Standards 62301 and 62087 ofthe International Electrotechnical

Commission, with such energy consumption integrated into the overall energy efficiency, energy

consumption, or other

energy descriptorfor each covered product, unless the SecretOlY determines that

"(i) the current test proceduresfor a covered product alreadyfully account for and incorporate

the standby mode and offmode energy consumption ofthe covered product; or

"(Ii) such an integrated test procedure is technically infeasible for a particular covered product,

in which case the Secretary shall prescribe a separate standby mode and offmode energy use

test procedure for the covered product, iftechnically feasible.

"(B) DEADLINES--The test procedure amendments required by subparagraph (A) shall be

prescribed in afinal rule no later than the following dates:

"(i) December 31, 2008,for battery chargers and external power supplies.

"(Ii) March 31, 2009,for clothes dryers, room air conditioners, andfluorescent lamp ballasts.

"(iii) June 30, 2009, for residential clothes washers.

"(iv) September 30, 2009,for residentialfurnaces and boilers.

"(v) March 31, 20l0,for residential water heaters, direct heating equipment, and pool heaters.

"(vi) March 31, 2011, for residential dishwashers, ranges and ovens, microwave ovens, and

dehumidifiers.

"(C) PRIOR PRODUCT STANDARDS--The test procedure amendments adopted pursuant to

subparagraph (B) shall not be used to determine compliance with product standards established

prior to the adoption ofthe amended test procedures.
"(3) INCORPORATION INTO STANDARD.

"(A) IN GENERAL.--Subject to subparagraph (8), based on the test procedures required under

paragraph (2), any final rule establishing or revising a standardfor a covered product, adopted

after July I, 2010, shall incorporate standby mode and offmode energy use into a single

amended or new standard, pursuant to subsection (0), iffeasible.

"(B) SEPARATE STANDARDS.--ljnotfeasible. the Secretary shall prescribe within the final

rule a separate standardfor standby mode and offmode energy consumption, ifjustified under

subsection (0).
Department of Energy

Washington, DC 20585

March 23, 2009

Mr. Bill Lasko

President

Lasko Products, INC

620 Lincoln Ave

West Chester, PA 19380-4469

RE: Request for infonnation regarding possible standby and off mode energy use for unvented

heaters

Dear Mr. Lasko:

As you may know, section 310 ofthe Energy Independence and Security Act of 2007

(EISA 2007), Pub. L. 110-140, amended the Energy Policy and Conservation Act (EPCA). In

the relevant part, EISA 2007 requires the U.S. Department of Energy (DOE) to amend, if

technically feasible, all DOE test procedures for covered consumer products to account for

standby mode and offmode energy consumption. (A brief description of EISA 2007, along with

the relevant legislative language, is provided as Attachment A.) Of particular note here, thc

legislation requires DOE to amend the test procedure for direct heating equipment (of which

unvented heaters are one subcategory) by March 31, 20 JO.

By way of background, the unvented heater test procedure is found at Title 10 ofthe

Code of Federal Regulations (10 CFR) 430.23(g) and 10 CFR part 430, subpart B, appendix G.

This procedure applies to both electric and fossil-fueled unvented heaters. This procedure only

requires measurement ofinput energy rate (e.g. Btu's!hour). Output energy rate is simply

equated to input energy rate. This energy rate is converted by mathematical constants to either

dollars per million Btu's output and/or annual energy consumption. (Annual energy

consumption is calculated only for electric heaters that are the primary heating source for the

entire house. Supplemental heaters and unvented heaters using either natural gas, propane, or oil

only reqllire calculation of dollars per million Btu's.) As currently written, this procedure

generally reflects the lack of any appreciable energy perfonnance difference among models of

this product subcategory. To date, this product subcategory has not been subject to any labeling

requirements or energy conservation standards. As mentioned above, pursuant to EISA 2007,

DOE must now include provisions to measure standby and off mode energy use in the test

procedures used for these and many other products. This brings up the question ofwhether

unvented heaters use energy in standby offmodes. DOE anticipates that such test procedure

amendments could identify an opportunity for energy perfonnance improvements in unvented

heater models. DOE is interested in gathering infonnation that will help it to fulfill the

requirements of EPCA, as amended, without causing undue burden to the industry.

DOE realizes that this product subcategory presents a unique set of circumstances when

addressing EISA 2007, particularly regarding the EISA 2007 provisions on energy conservation

standards. First, unlike other test procedures, appendix G does not include energy efficiency or

energy use metrics that would allow for the integration ofstandby and off mode energy use. As

*Printed with soy ink on recycled paper
a consequence, there currently exists no basis to establish what EISA 2007 would call a single or

integrated standard for unvented heaters.

Second, standby mode cnergy use (defined as energy use during the heating season when

the heater is not on) could be considered as effective in heating the space as active mode energy

use. Therefore, DOE is evaluating the appropriateness of measuring this energy use or its

possible inclusion in an energy conservation standard.

Finally, off mode energy consumption (defined as non-heating season energy

consumption) could be considered energy use and, accordingly, could be minimized by

prescribing a separate energy conservation standard. However, defining a representative off

mode for this subcategory is difficult because ofthe lack of data on consumer use. Specifically,

DOE is not currently aware of data on the fraction ofthe year heaters are unplugged or otherwise

disconnected from the energy source, and the extent to which pilot lights are turned off during

the non-heating season. This unique set of circumstances forms the basis ofthis inquiry.

Definitions

To aid in responding to the questions below, the following definitions of "active mode,"

"standby mode," and "off mode" apply:

• "Active mode" is the period during the heating season when the burner or heating

element is on.

• "Standby mode" is the period during the heating season when the main burner or heating

element is not on.

• "Off mode" is the entire non-heating season, unless there is disconnection from the

energy source.

The duration ofthe heating and non-heating seasons for these products can be assumed to be

the same as the representative values used for all other DOE test procedures for heating

products, i.e., 4160 hours heating season and 4600 hours non-heating season. One

complication for this subcategory is the possibility ofthe product being placed out ofservice

during the heating season. This possibility would impact the accounting of off mode and

standby mode. For example, these out-of-serviee hours during the heating season could be

debated as more appropriately off mode rather that standby mode. Nonetheless, rather than

sorting out this complication at this time, DOE believes the above proposed simplified

definitions are sufficient to allow for informative answers to the following questions.

However, your views on this complication are welcome.

Ouestions

In light ofthe above, DOE would appreciate your answers to the following questions:

I. Do you manufacture, and are you aware of other manufacturer models of, fossil-fueled

unvented heaters that have measurable fossil-fueled standby and off mode enerl,'Y use (e.g.,

pilot lights)? Ifso, what is your estimate ofthe range ofthe energy use rates for such models

(btu/hour)?
2. Do you manufacture, and are you aware of other manufacturer models of, fossil-fueled

unvented heaters that have measurable electrical standby and off mode energy use? Ifso

what is your estimate ofthe range of energy use rate (watts)?

3. Do you manufacture, and are you aware of other manufacturer models of, electric unvented

heaters that have measurable electric standby and offmode energy use? Ifso what is your

estimate ofthe range of energy use rate (watts)?

4. Ideally, the ranges of energy use rates above could be converted to ranges of annual

consumption values if a reasonably representative range of annual hours of off mode usage

can be defined. Are you aware of data or studies that would aid DOE in defining

representative annual hours of offmode use for the types of products discussed above? If

so, please identify them and add your thoughts on the accuracy and relevance ofthe data.

5. Absent DOE-prescribed representative hours of offmode, what is your view about a limited

test procedure that only requires measurement and disclosure of energy use rate (i.e., wattage

and/or pilot light btu/hour)? Additionally, what is your view on a potential subsequent

regulation based only on energy use rate?

6. Is the Standard 62301 ofthe International Electrotechnical Commission, Household

Electrical Appliances - Measurement ofStandby Power, sufficient and appropriate to

measure electric standby and/or offmode energy use rate? In your answer, please explain

why they are, or not, sufficient.

DOE requests that answers be provided not later than April 8, 2009, in order to allow the

Department sufficient time to incorporate such infonnation into its test procedure rulemaking for

direct heating equipment, which is being conducted pursuant to EISA 2007. It is important to

note that the current ongoing standards rulemaking for direct heating equipment will not be

impacted by the possible test procedure amendments discussed here. Should you have any

questions, please feel free to contact Mohammed Khan ofmy staff at (202) 586-7892.

Sincerely,

Ronald P. Lewis

Supervisor--Regulatory

Appliance Standards

Building Technologies Program

Energy Efficiency and Renewable Energy

Enclosure
ATTACHMENT A

The Energy Independence and Security Act of2007 (EISA 2007), Pub. L. 110-140,

amended the Energy Policy and Conservation Act (42 U.S.C. 6291 et seq.; EPCA), and in

relevant part, directs DOE to amend its test procedures to include measures ofstandby mode and

offmode energy consumption, unless such measures are already fully incorporated in the current

test procedure or would be technically infeasible to prescribe (EISA 2007, section 310; 42 U.S.c.

6295(gg)(2)(A)). The EISA 2007 amendments to EPCA further direct DOE to amend the test

procedures to integrate such energy consumption into the overall energy efficiency, energy

consumption, or other energy descriptor for that product. Ifamending the test procedure in this

manner is technically infeasible, DOE must prescribe a separate standby mode and off mode

energy use test procedure, iftechnically feasible. Any such amendment must consider the most

current versions ofthe International Electrotechnical Commission (IEC) Standard 62301 and

IEC Standard 62087. For residential water heaters, direct heating equipment, and pool heaters,

DOE must prescribe any such amendment to the test procedures by March 31,2010. (EISA

2007, section 310; 42 U.S.C. 6295(gg)(2)(B)(v))

Unvented heaters are a class of direct heating equipment. DOE's test procedure currently

does not include provisions for measuring or accounting for "standby mode" or "offmode"

energy use, as defined by EISA 2007. Accordingly, the test procedure would need to be

amended to include such accounting.

Legislative language from EISA 2007
"(2) TEST PROCEDURES

"(A) TN GENERAL.--Test proceduresfor all covered products shall be amended pursuant to

section 323 to include standby mode and offmode energy consumption, taking into consideration

the most current versions o{Standards 62301 and 62087 ofthe International Electrotechnical

Commission, with such energy consumption integrated into the overall energy efficiency, energy

consumption, or other

energy descriptorfor each covered product, unless the SecretOlY determines that

"(i) the current test proceduresfor a covered product alreadyfully account for and incorporate

the standby mode and offmode energy consumption ofthe covered product; or

"(Ii) such an integrated test procedure is technically infeasible for a particular covered product,

in which case the Secretary shall prescribe a separate standby mode and offmode energy use

test procedure for the covered product, iftechnically feasible.

"(B) DEADLINES--The test procedure amendments required by subparagraph (A) shall be

prescribed in afinal rule no later than the following dates:

"(i) December 31, 2008,for battery chargers and external power supplies.

"(Ii) March 31, 2009,for clothes dryers, room air conditioners, andfluorescent lamp ballasts.

"(iii) June 30, 2009, for residential clothes washers.

"(iv) September 30, 2009,for residentialfurnaces and boilers.

"(v) March 31, 20l0,for residential water heaters, direct heating equipment, and pool heaters.

"(vi) March 31, 2011, for residential dishwashers, ranges and ovens, microwave ovens, and

dehumidifiers.

"(C) PRIOR PRODUCT STANDARDS--The test procedure amendments adopted pursuant to

subparagraph (B) shall not be used to determine compliance with product standards established

prior to the adoption ofthe amended test procedures.
"(3) INCORPORATION INTO STANDARD.

"(A) IN GENERAL.--Subject to subparagraph (8), based on the test procedures required under

paragraph (2), any final rule establishing or revising a standardfor a covered product, adopted

after July I, 2010, shall incorporate standby mode and offmode energy use into a single

amended or new standard, pursuant to subsection (0), iffeasible.

"(B) SEPARATE STANDARDS.--ljnotfeasible. the Secretary shall prescribe within the final

rule a separate standardfor standby mode and offmode energy consumption, ifjustified under

subsection (0).
Department of Energy

Washington, DC 20585

March 23, 2009

Mr. Richard Mudd

President

Louisville Tin and Stove Company, Inc.

P.O. Box 2767

Louisville, KY 40201-2767

RE: Request for information regarding possible standby and offmode energy use for unvented

heaters

Dear Mr. Mudd:

As you may know, section 310 ofthe Energy Independence and Security Act of2007

(EISA 2007), Pub. L. 110-140, amended the Energy Policy and Conservation Act (EPCA). In

the relevant part, EISA 2007 requires the U.S. Department of Energy (DOE) to amend, if

technically feasible, all DOE test procedures for covered consumer products to account for

standby mode and offmode energy consumption. (A brief description of EISA 2007, along with

the relevant legislative language, is provided as Attachment A.) Of particular note here, the

legislation requires DOE to amend the test procedure for direct heating equipment (of which

unvented heaters are one subcategory) by March 31, 2010.

By way of background, the unvented heater test procedure is found at Title 10 ofthe

Code of Federal Regulations (10 CFR) 430.23(g) and 10 CFR part 430, subpart B, appendix G.

This procedure applies to both electric and fossil-fueled unvented heaters. This procedure only

requires measurement ofinput energy rate (e.g. Btu'slhour). Output energy rate is simply

equated to input energy rate. This energy rate is converted by mathematical constants to either

dollars per million Btu's output and/or annual energy consumption. (Annual energy

consumption is calculated only for electric heaters that are the primary heating source for the

entire house. Supplemental heaters and unvented heaters using either natural gas, propane, or oil

only require calculation of dollars per million Btu's.) As currently written, this procedure

generally reflects the lack of any appreciable energy performance difference among models of

this product subcategory. To date, this product subcategory has not been subject to any labeling

requirements or energy conservation standards. As mentioned above, pursuant to EISA 2007,

DOE must now include provisions to measure standby and offmode energy use in the test

procedures used for these and many other products. This brings up the question ofwhether

unvented heaters use energy in standby offmodes. DOE anticipates that such test procedure

amendments could identify an opportunity for energy performance improvements in unvented

heater models. DOE is interested in gathering information that will help it to fulfill the

requirements of EPCA, as amended, without causing undue burden to the industry.

DOE realizes that this product subcategory presents a unique set of circumstances when

addressing EISA 2007, particularly regarding the EISA 2007 provisions on energy conservation

standards. First, unlike other test procedures, appendix G does not include energy efficiency or

energy use metrics that would allow for the integration ofstandby and offmode energy use. As

(i) Printed with soy ink on recycled paper
a consequence, there currently exists no basis to establish what EISA 2007 would call a single or

integrated standard for unvented heaters.

Second, standby mode energy use (defined as energy use during the heating season when

the heater is not on) could be considered as effective in heating the space as active mode energy

use. Therefore, DOE is evaluating the appropriateness ofmeasuring this energy use or its

possible inclusion in an energy conservation standard.

Finally, off mode energy consumption (defined as non-heating season energy

consumption) could be considered energy use and, accordingly, could be minimized by

prescribing a separate energy conservation standard. However, defining a representative off

mode for this subcategory is difficult because of the lack of data on consumer use. Specifically,

DOE is not currently aware of data on the fraction ofthe year heaters are unplugged or otherwise

disconnected from the energy source, and the extent to which pilot lights are turned off during

the non-heating season. This unique set of circumstances forms the basis ofthis inquiry.

Definitions

To aid in responding to the questions below, the following definitions of "active mode,"

"standby mode," and "offmode" apply:

• "Active mode" is the period during the heating season when the burner or heating

element is on.

• "Standby mode" is the period during the heating season when the main burner or heating

element is not on.

• "Off mode" is the entire non-heating season, unless there is disconnection from the

energy source.

The duration ofthe heating and non-heating seasons for these products can be assumed to be

the same as the representative values used for all other DOE test procedures for heating

products, i.e., 4160 hours heating season and 4600 hours non-heating season. One

complication for this subcategory is the possibility ofthe product being placed out ofservice

during the heating season. This possibility would impact the accounting ofoff mode and

standby mode. For example, these out-of-service hours during the heating season could be

debated as more appropriately offmode rather that standby mode. Nonetheless, rather than

sorting out this complication at this time, DOE believes the above proposed simplified

definitions are sufficient to allow for informative answers to the following questions.

However, your views on this complication are welcome.

Questions

In light ofthe above, DOE would appreciate your answers to the following questions:

I. Do you manufacture, and are you aware of other manufacturer models of, fossil-fueled

unvented heaters that have measurable fossil-fueled standby and offmode energy use (e.g.,

pilot lights)? (fso, what is your estimate ofthe range ofthe energy use rates for such models

(btulhour)?
2. Do you manufacture, and are you aware of other manufacturer models of, fossil-fueled

unvented heaters that have measurable electrical standby and off mode energy use? Ifso

what is your estimate ofthe range of energy use rate (watts)?

3. Do you manufacture, and are you aware of other manufacturer models of, electric unvented

heaters that have measurable electric standby and offmode energy use? Ifso what is your

estimate ofthe range of energy use rate (watts)?

4. Ideally, the ranges of energy use rates above could be converted to ranges of annual

consumption values if a reasonably representative range of annual hours of off mode usage

can be defined. Are you aware of data or studies that would aid DOE in defining

representative annual hours ofoffmode use for the types of produets discussed above? If

so, please identify them and add your thoughts on the accuracy and relevance ofthe data.

5. Absent DOE-prescribed representative hours ofoff mode, what is your view about a limited

test procedure that only requires measurement and disclosure of energy use rate (i.e., wattage

and/or pilot light btu/hour)? Additionally, what is your view on a potential subsequent

regulation based only on energy use rate?

6. Is the Standard 6230 I ofthe International Electrotechnical Commission, Household

Electrical Appliances - Measurement ofStandby Power, sufficient and appropriate to

measure electric standby and/or off mode energy use rate? In your answer, please explain

why they are, or not, sufficient.

DOE requests that answers be provided not later than April 8, 2009, in order to allow the

Department sufficient time to incorporate such information into its test procedure rulemaking for

direct heating equipment, which is being conducted pursuant to EISA 2007. It is important to

note that the current ongoing standards rulemaking for direct heating equipment will not be

impacted by the possible test procedure amendments discussed here. Should you have any

questions, please feel free to contact Mohammed Khan of my staff at (202) 586-7892.

Sincerely,

~~/--'- Supervisor--Regulatory

Appliance Standards

Building Technologies Program

Energy Efficiency and Renewable Energy

Enclosure
ATTACHMENT A

The Energy Independence and Security Act of2007 (EISA 2007), Pub. L. 110-140,

amended the Energy Policy and Conservation Act (42 U.S.C. 6291 et seq.; EPCA), and in

relevant part, directs DOE to amend its test procedures to include measures ofstandby mode and

offmode energy consumption, unless such measures are already fully incorporated in the current

test procedure or would be technically infeasible to prescribe (EISA 2007, section 310; 42 U.S.c.

6295(gg)(2)(A)). The EISA 2007 amendments to EPCA further direct DOE to amend the test

procedures to integrate such energy consumption into the overall energy efficiency, energy

consumption, or other energy descriptor for that product. Ifamending the test procedure in this

manner is technically infeasible, DOE must prescribe a separate standby mode and off mode

energy use test procedure, iftechnically feasible. Any such amendment must consider the most

current versions ofthe International Electrotechnical Commission (IEC) Standard 62301 and

IEC Standard 62087. For residential water heaters, direct heating equipment, and pool heaters,

DOE must prescribe any such amendment to the test procedures by March 31,2010. (EISA

2007, section 310; 42 U.S.C. 6295(gg)(2)(B)(v))

Unvented heaters are a class of direct heating equipment. DOE's test procedure currently

does not include provisions for measuring or accounting for "standby mode" or "offmode"

energy use, as defined by EISA 2007. Accordingly, the test procedure would need to be

amended to include such accounting.

Legislative language from EISA 2007
"(2) TEST PROCEDURES

"(A) TN GENERAL.--Test proceduresfor all covered products shall be amended pursuant to

section 323 to include standby mode and offmode energy consumption, taking into consideration

the most current versions o{Standards 62301 and 62087 ofthe International Electrotechnical

Commission, with such energy consumption integrated into the overall energy efficiency, energy

consumption, or other

energy descriptorfor each covered product, unless the SecretOlY determines that

"(i) the current test proceduresfor a covered product alreadyfully account for and incorporate

the standby mode and offmode energy consumption ofthe covered product; or

"(Ii) such an integrated test procedure is technically infeasible for a particular covered product,

in which case the Secretary shall prescribe a separate standby mode and offmode energy use

test procedure for the covered product, iftechnically feasible.

"(B) DEADLINES--The test procedure amendments required by subparagraph (A) shall be

prescribed in afinal rule no later than the following dates:

"(i) December 31, 2008,for battery chargers and external power supplies.

"(Ii) March 31, 2009,for clothes dryers, room air conditioners, andfluorescent lamp ballasts.

"(iii) June 30, 2009, for residential clothes washers.

"(iv) September 30, 2009,for residentialfurnaces and boilers.

"(v) March 31, 20l0,for residential water heaters, direct heating equipment, and pool heaters.

"(vi) March 31, 2011, for residential dishwashers, ranges and ovens, microwave ovens, and

dehumidifiers.

"(C) PRIOR PRODUCT STANDARDS--The test procedure amendments adopted pursuant to

subparagraph (B) shall not be used to determine compliance with product standards established

prior to the adoption ofthe amended test procedures.
"(3) INCORPORATION INTO STANDARD.

"(A) IN GENERAL.--Subject to subparagraph (8), based on the test procedures required under

paragraph (2), any final rule establishing or revising a standardfor a covered product, adopted

after July I, 2010, shall incorporate standby mode and offmode energy use into a single

amended or new standard, pursuant to subsection (0), iffeasible.

"(B) SEPARATE STANDARDS.--ljnotfeasible. the Secretary shall prescribe within the final

rule a separate standardfor standby mode and offmode energy consumption, ifjustified under

subsection (0).
Department of Energy

Washington, DC 20585

March 23, 2009

Mr. Dave Barrett

President

Monessen Hearth Systems, Inc.

149 Cleveland Drive

Paris, KY 40301-9782

RE: Request for information regarding possible standby and off mode energy use for unvented

heaters

Dear Mr. Barrett:

As you may know, section 310 ofthe Energy Independence and Security Act of 2007

(EISA 2007), Pub. L. 110-140, amended the Energy Policy and Conservation Act (EPCA). In

the relevant part, EISA 2007 requires the U.S. Department of Energy (DOE) to amend, if

technically feasible, all DOE test procedures for covered consumer products to account for

standby mode and off mode energy consumption. (A brief description of EISA 2007, along with

the relevant legislative language, is provided as Attachment A.) Of particular note here, the

legislation requires DOE to amend the test procedure for direct heating equipment (of which

unvented heaters are one subcategory) by March 31, 20 IO.

By way of background, the unvented heater test procedure is found at Title 10 ofthe

Code of Federal Regulations (10 CFR) 430.23(g) and 10 CFR part 430, subpart B, appendix G.

This procedure applies to both electric and fossil-fueled unvented heaters. This procedure only

requires measurement ofinput energy rate (e.g. Btu's!hour). Output energy rate is simply

equated to input energy rate. This energy rate is converted by mathematical constants to either

dollars per million Btu's output and/or annual energy consumption. (Annual energy

consumption is calculated only for electric heaters that are the primary heating source for the

entire house. Supplemental heaters and unvented heaters using either natural gas, propane, or oil

only require calculation of dollars per million Btu's.) As currently written, this procedure

generally reflects the lack of any appreciable energy performance difference among models of

this product subcategory. To date, this product subcategory has not been subject to any labeling

requirements or energy conservation standards. As mentioned above, pursuant to EISA 2007,

DOE must now include provisions to measure standby and off mode energy use in the test

procedures used for these and many other products. This brings up the question ofwhether

unvented heaters use energy in standby offmodes. DOE anticipates that such test procedure

amendments could identify an opportunity for energy performance improvements in unvented

heater models. DOE is interested in gathering information that will help it to fulfill the

requirements of EPCA, as amended, without causing undue burden to the industry.

DOE realizes that this product subcategory presents a unique set of circumstances when

addressing EISA 2007, particularly regarding the EISA 2007 provisions on energy conservation

standards. First, unlike other test procedures, appendix G does not include energy efficiency or

energy use metrics that would allow for the integration ofstandby and offmode energy use. As

*Printed with soy ink on recycled paper.
a consequence, there currently exists no basis to establish what EISA 2007 would call a single or

integrated standard for unvented heaters.

Second, standby mode energy use (defined as energy use during the heating season when

the heater is not on) could be considered as effective in heating the space as active mode energy

use. Therefore, DOE is evaluating the appropriateness ofmeasuring this energy use or its

possible inclusion in an energy conservation standard.

Finally, off mode energy consumption (defined as non-heating season energy

consumption) could be considered energy use and, accordingly, could be minimized by

prescribing a separate energy conservation standard. However, defining a representative off

mode for this subcategory is difficult because ofthe lack of data on consumer use. Specifically,

DOE is not currently aware of data on the fraction ofthe year heaters are unplugged or otherwise

disconnected from the energy source, and the extent to which pilot lights are turned off during

the non-heating season. This unique set of circumstances forms the basis ofthis inquiry.

Definitions

To aid in responding to the questions below, the following definitions of "active mode,"

"standby mode," and "off mode" apply:

• "Active mode" is the period during the heating season when the burner or heating

element is on.

• "Standby mode" is the period during the heating season when the main burner or heating

element is not on.

• "Off mode" is the entire non-heating season, unless there is disconnection from the

energy source.

The duration ofthe heating and non-heating seasons for these products can be assumed to be

the same as the representative values used for all other DOE test procedures for heating

products, i.e., 4160 hours heating season and 4600 hours non-heating season. One

complication for this subcategory is the possibility ofthe product being placed out ofservice

during the heating season. This possibility would impact the accounting of offmode and

standby mode. For example, these out-of-service hours during the heating season could be

debated as more appropriately offmode rather that standby mode. Nonetheless, rather than

sorting out this complication at this time, DOE believes the above proposed simplified

definitions are sufficient to allow for informative answers to the following questions.

However, your views on this complication are welcome.

Questions

In light ofthe above, DOE would appreciate your answers to the following questions:

I. Do you manufacture, and are you aware of other manufacturer models of, fossil-fueled

unvented heaters that have measurable fossil-fueled standby and offmode energy use (e.g.,

pilot lights)? Ifso, what is your estimate ofthe range ofthe energy use rates for such models

(btu/hour)?
2. Do you manufacture, and are you aware of other manufacturcr models of, fossil-fuelcd

unvented heaters that have measurable electrical standby and offmode energy use? Ifso

what is your estimate ofthe range of energy use rate (walts)?

3. Do you manufacture, and are you aware of other manufacturer models of, electric unvented

heaters that have measurable electric standby and off mode energy use? Ifso what is your

estimate ofthe range of encrgy use rate (walts)?

4. Ideally, thc ranges of energy use rates above could be converted to ranges of annual

consumption values if a reasonably representative range of annual hours of off mode usage

can be defined. Are you aware of data or studies that would aid DOE in defining

representative annual hours of offmode use for the types of products discussed above? If

so, picase identify them and add your thoughts on the accuracy and relevance ofthe data.

5. Absent DOE-prescribed representative hours of off mode, what is your view about a limited

test procedure that only requires measurement and disclosure of energy use rate (i.e., wattage

and/or pilot light btulhour)? Additionally, what is your view on a potential subsequent

regulation based only on energy use rate?

6. Is the Standard 62301 ofthe International Electrotechnical Commission, Household

Electrical Appliances - Measurement 0/Standby Power, sufficient and appropriate to

measure electric standby and/or offmode energy use rate? In your answer. please cxplain

why they are, or not, sufficient.

DOE requests that answers be provided not later than April 8,2009, in order to allow the

Department sufficient time to incorporate such infonnation into its test procedure rulemaking for

direct heating equipment, which is being conducted pursuant to EISA 2007. It is important to

note that the current ongoing standards rulemaking for direct heating equipment will not be

impacted by the possible test procedure amendments discussed here. Should you have any

questions, please feel free to contact Mohammed Khan of my staff at (202) 586-7892.

Sincerely,

L~(/~ Supervisor--Regulatory

Appliance Standards

Building Technologies Program

Energy Efficiency and Renewablc Energy

Enclosurc
ATTACHMENT A

The Energy Independence and Security Act of2007 (EISA 2007), Pub. L. 110-140,

amended the Energy Policy and Conservation Act (42 U.S.C. 6291 et seq.; EPCA), and in

relevant part, directs DOE to amend its test procedures to include measures ofstandby mode and

offmode energy consumption, unless such measures are already fully incorporated in the current

test procedure or would be technically infeasible to prescribe (EISA 2007, section 310; 42 U.S.c.

6295(gg)(2)(A)). The EISA 2007 amendments to EPCA further direct DOE to amend the test

procedures to integrate such energy consumption into the overall energy efficiency, energy

consumption, or other energy descriptor for that product. Ifamending the test procedure in this

manner is technically infeasible, DOE must prescribe a separate standby mode and off mode

energy use test procedure, iftechnically feasible. Any such amendment must consider the most

current versions ofthe International Electrotechnical Commission (IEC) Standard 62301 and

IEC Standard 62087. For residential water heaters, direct heating equipment, and pool heaters,

DOE must prescribe any such amendment to the test procedures by March 31,2010. (EISA

2007, section 310; 42 U.S.C. 6295(gg)(2)(B)(v))

Unvented heaters are a class of direct heating equipment. DOE's test procedure currently

does not include provisions for measuring or accounting for "standby mode" or "offmode"

energy use, as defined by EISA 2007. Accordingly, the test procedure would need to be

amended to include such accounting.

Legislative language from EISA 2007
"(2) TEST PROCEDURES

"(A) TN GENERAL.--Test proceduresfor all covered products shall be amended pursuant to

section 323 to include standby mode and offmode energy consumption, taking into consideration

the most current versions o{Standards 62301 and 62087 ofthe International Electrotechnical

Commission, with such energy consumption integrated into the overall energy efficiency, energy

consumption, or other

energy descriptorfor each covered product, unless the SecretOlY determines that

"(i) the current test proceduresfor a covered product alreadyfully account for and incorporate

the standby mode and offmode energy consumption ofthe covered product; or

"(Ii) such an integrated test procedure is technically infeasible for a particular covered product,

in which case the Secretary shall prescribe a separate standby mode and offmode energy use

test procedure for the covered product, iftechnically feasible.

"(B) DEADLINES--The test procedure amendments required by subparagraph (A) shall be

prescribed in afinal rule no later than the following dates:

"(i) December 31, 2008,for battery chargers and external power supplies.

"(Ii) March 31, 2009,for clothes dryers, room air conditioners, andfluorescent lamp ballasts.

"(iii) June 30, 2009, for residential clothes washers.

"(iv) September 30, 2009,for residentialfurnaces and boilers.

"(v) March 31, 20l0,for residential water heaters, direct heating equipment, and pool heaters.

"(vi) March 31, 2011, for residential dishwashers, ranges and ovens, microwave ovens, and

dehumidifiers.

"(C) PRIOR PRODUCT STANDARDS--The test procedure amendments adopted pursuant to

subparagraph (B) shall not be used to determine compliance with product standards established

prior to the adoption ofthe amended test procedures.
"(3) INCORPORATION INTO STANDARD.

"(A) IN GENERAL.--Subject to subparagraph (8), based on the test procedures required under

paragraph (2), any final rule establishing or revising a standardfor a covered product, adopted

after July I, 2010, shall incorporate standby mode and offmode energy use into a single

amended or new standard, pursuant to subsection (0), iffeasible.

"(B) SEPARATE STANDARDS.--ljnotfeasible. the Secretary shall prescribe within the final

rule a separate standardfor standby mode and offmode energy consumption, ifjustified under

subsection (0).
Department of Energy

Washington, DC 20585

March 23,2009

Oreck Corporation

565 Marriott Drive

Suite 300

Nashville, TN 37214-5022

Attn: Marketing Department

RE: Request for information regarding possible standby and off mode energy use for unvented

heaters

To Whom It May Concern:

As you may know, section 310 ofthe Energy Independence and Security Act of 2007

(EISA 2007), Pub. L. 110-140, amended the Energy Policy and Conservation Act (EPCA). In

the relevant part, EISA 2007 requires the U.S. Department of Energy (DOE) to amend, if

technically feasible, all DOE test procedures for covered consumer products to account for

standby mode and off mode energy consumption. (A brief description of EISA 2007, along with

the relevant legislative language, is provided as Attachment A.) Of particular note here, the

legislation requires DOE to amend the test procedure for direct heating equipment (of which

unvented heaters are one subcategory) by March 31, 20 IO.

By way of background, the unvented heater test procedure is found at Title 10 ofthe

Code of Federal Regulations (10 CFR) 430.23(g) and 10 CFR part 430, subpart B, appendix G.

This procedure applies to both electric and fossil-fueled unvented heaters. This procedure only

requires measurement of input energy rate (e.g. Btu'slhour). Output energy rate is simply

equated to input energy rate. This energy rate is converted by mathematical constants to either

dollars per million Btu's output and/or annual energy consumption. (Annual energy

consumption is calculated only for electric heaters that are the primary heating source for the

entire house. Supplemental heaters and unvented heaters using either natural gas, propane, or oil

only require calculation of dollarS per million Btu's.) As currently written, this procedure

generally reflects the lack of any appreciable energy performance difference among models of

this product subcategory. To date, this product subcategory has not been subject to any labeling

requirements or energy conservation standards. As mentioned above, pursuant to EISA 2007,

DOE must now include provisions to measure standby and off mode energy use in the test

procedures used for these and many other products. This brings up the question of whether

unvented heaters use energy in standby offmodes. DOE anticipates that such test procedure

amendments could identify an opportunity for energy performance improvements in unvented

heater models. DOE is interested in gathering information that will help it to fulfill the

requirements of EPCA, as amended, without causing undue burden to the industry.

DOE realizes that this product subcategory presents a unique set of circumstances when

addressing EISA 2007, particularly regarding the EISA 2007 provisions on energy conservation

standards. First, unlike other test procedures, appendix G does not include energy efficiency or

energy use metrics that would allow for the integration ofstandby and offmode energy usc. As

*Printed with soy ink on recycled paper
a consequence, there currently exists no basis to establish what EISA 2007 would call a single or

integrated standard for unvented heaters.

Second, standby mode energy use (defined as energy use during the heating season when

the heater is not on) could be considered as effective in heating the space as active mode energy

use. Therefore, DOE is evaluating the appropriateness ofmeasuring this energy use or its

possible inclusion in an energy conservation standard.

Finally, offmode energy consumption (defined as non-heating season energy

consumption) could be considered energy use and, accordingly, could be minimized by

prescribing a separate energy conservation standard. However, defining a representative off

mode for this subcategory is difficult because of the lack of data on consumer use. Specifically,

DOE is not currently aware of data on the fraction ofthe year heaters are unplugged or otherwise

disconnected from the energy source, and the extent to which pilot lights are turned off during

the non-heating season. This unique set of circumstances forms the basis ofthis inquiry.

Definitions

To aid in responding to the questions below, the following definitions of "active mode,"

"standby mode," and "off mode" apply:

• "Active mode" is the period during the heating season when the burner or heating

clement is on.

• "Standby mode" is the period during the heating season when the main burner or heating

element is not on.

• "Off mode" is the entire non-heating season, unless there is disconnection from the

energy source.

The duration ofthe heating and non-heating seasons for these products can be assumed to be

the same as the representative values used for all other DOE test procedures for heating

products, i.e., 4160 hours heating season and 4600 hours non-heating season. One

complication for this subcategory is the possibility ofthe product being placed out ofservice

during the heating season. This possibility would impact the accounting ofoff mode and

standby mode. For example, these out-of-service hours during the heating season could be

debated as more appropriately offmode rather that standby mode. Nonetheless, rather than

sorting out this complication at this time, DOE believes the above proposed simplified

definitions are sufficient to allow for informative answers to the following questions.

However, your views on this complication are welcome.

Ouestions

In light ofthe above, DOE would appreciate your answers to the following questions:

I. Do you manufacture, and are you aware of other manufacturer models of, fossil-fueled

unvented heaters that have measurable fossil-fueled standby and off mode energy use (e.g.,

pilot lights)? [fso, what is your estimate ofthe range ofthe energy use rates for such models

(btulhour)?
2. Do you manufacture, and are you aware of other manufacturer models of, fossil-fueled

unvented heaters that have measurable electrical standby and offmode energy use? Ifso

what is your estimate ofthe range of energy use rate (watts)?

3. Do you manufacture, and are you aware of other manufacturer models of, electric unvented

heaters that have measurable electric standby and offmode energy use? [fso what is your

estimate ofthe range of energy use rate (watts)?

4. Ideally, the ranges of energy use rates above could be converted to ranges of annual

consumption values if a reasonably representative range of annual hours of off mode usage

can be defined. Are you aware of data or studies that would aid DOE in defining

representative annual hours ofoffmode use for the types of products discussed above? If

so, please identify them and add your thoughts on the accuracy and relevance ofthe data.

5. Absent DOE-prescribed representative hours ofoff mode, what is your view about a limited

test procedure that only requires measurement and disclosure of energy use rate (i.e., wattage

and/or pilot light btu/hour)? Additionally, what is your view on a potential subsequent

regulation based only on energy use rate?

6. [s the Standard 6230 I ofthe International Electrotechnical Commission, Household

Electrical Appliances - Measurement ofStandby Power, sufficient and appropriate to

measure electric standby and/or off mode energy use rate? In your answer, please explain

why they are, or not, sufficient.

DOE requests that answers be provided not later than April 8,2009, in order to allow the

Department sufficient time to incorporate such information into its test procedure rulemaking for

direct heating equipment, which is being conducted pursuant to EISA 2007. It is important to

note that the current ongoing standards rulemaking for direct heating equipment will not be

impacted by the possible test procedure amendments discussed here. Should you have any

questions, please feel free to contact Mohammed Khan of my staff at (202) 586-7892.

Sincerely,

/~~~~> Ronald P. Lewis

Supervisor--ReguIatory

Appliance Standards

Building Technologies Program

Energy Efficiency and Renewable Energy

Enclosure
ATTACHMENT A

The Energy Independence and Security Act of2007 (EISA 2007), Pub. L. 110-140,

amended the Energy Policy and Conservation Act (42 U.S.C. 6291 et seq.; EPCA), and in

relevant part, directs DOE to amend its test procedures to include measures ofstandby mode and

offmode energy consumption, unless such measures are already fully incorporated in the current

test procedure or would be technically infeasible to prescribe (EISA 2007, section 310; 42 U.S.c.

6295(gg)(2)(A)). The EISA 2007 amendments to EPCA further direct DOE to amend the test

procedures to integrate such energy consumption into the overall energy efficiency, energy

consumption, or other energy descriptor for that product. Ifamending the test procedure in this

manner is technically infeasible, DOE must prescribe a separate standby mode and off mode

energy use test procedure, iftechnically feasible. Any such amendment must consider the most

current versions ofthe International Electrotechnical Commission (IEC) Standard 62301 and

IEC Standard 62087. For residential water heaters, direct heating equipment, and pool heaters,

DOE must prescribe any such amendment to the test procedures by March 31,2010. (EISA

2007, section 310; 42 U.S.C. 6295(gg)(2)(B)(v))

Unvented heaters are a class of direct heating equipment. DOE's test procedure currently

does not include provisions for measuring or accounting for "standby mode" or "offmode"

energy use, as defined by EISA 2007. Accordingly, the test procedure would need to be

amended to include such accounting.

Legislative language from EISA 2007
"(2) TEST PROCEDURES

"(A) TN GENERAL.--Test proceduresfor all covered products shall be amended pursuant to

section 323 to include standby mode and offmode energy consumption, taking into consideration

the most current versions ofStandards 62301 and 62087 ofthe International Electrotechnical

Commission, with such energy consumption integrated into the overall energy efficiency, energy

consumption, or other

energy descriptorfor each covered product, unless the SecretOlY determines that

"(i) the current test proceduresfor a covered product alreadyfully account for and incorporate

the standby mode and offmode energy consumption ofthe covered product; or

"(Ii) such an integrated test procedure is technically infeasible for a particular covered product,

in which case the Secretary shall prescribe a separate standby mode and offmode energy use

test procedure for the covered product, iftechnically feasible.

"(B) DEADLINES--The test procedure amendments required by subparagraph (A) shall be

prescribed in afinal rule no later than the following dates:

"(i) December 31, 2008,for battery chargers and external power supplies.

"(Ii) March 31, 2009,for clothes dryers, room air conditioners, andfluorescent lamp ballasts.

"(iii) June 30, 2009, for residential clothes washers.

"(iv) September 30, 2009,for residentialfurnaces and boilers.

"(v) March 31, 20l0,for residential water heaters, direct heating equipment, and pool heaters.

"(vi) March 31, 2011, for residential dishwashers, ranges and ovens, microwave ovens, and

dehumidifiers.

"(C) PRIOR PRODUCT STANDARDS--The test procedure amendments adopted pursuant to

subparagraph (B) shall not be used to determine compliance with product standards established

prior to the adoption ofthe amended test procedures.
"(3) INCORPORATION INTO STANDARD.

"(A) IN GENERAL.--Subject to subparagraph (8), based on the test procedures required under

paragraph (2), any final rule establishing or revising a standardfor a covered product, adopted

after July I, 2010, shall incorporate standby mode and offmode energy use into a single

amended or new standard, pursuant to subsection (0), iffeasible.

"(B) SEPARATE STANDARDS.--ljnotfeasible. the Secretary shall prescribe within the final

rule a separate standardfor standby mode and offmode energy consumption, ifjustified under

subsection (0).
Department of Energy

Washington, DC 20585

March 23, 2009

Mr. Rett Rasmussen

President

Rasmussen Gas Logs 7 Grills

12028 East Philadelphia Street

Whittier, CA 90601-3925

RE: Request for information regarding possible standby and off mode energy use for unvented

heaters

Dear Mr. Rasmussen:

As you may know, section 310 ofthe Energy Independence and Security Act of2007

(EISA 2007), Pub. L. 110-140, amended the Energy Policy and Conservation Act (EPCA). In

the relevant part, EISA 2007 requires the U.S. Department of Energy (DOE) to amend, if

technically feasible, all DOE test procedures for covered consumer products to account for

standby mode and offmode energy consumption. (A brief description ofEISA 2007, along with

the relevant legislative language, is provided as Attachment A.) Of particular note here, the

legislation requires DOE to amend the test procedure for direct heating equipment (of which

unvented heaters are one subcategory) by March 31, 20 IO.

By way of background, the unvented heater test procedure is found at Title 10 ofthe

Code ofFederal Regulations (10 CFR) 430.23(g) and 10 CFR part 430, subpart B, appendix G.

This procedure applies to both electric and fossil-fueled unvented heaters. This procedure only

requires measurement ofinput energy rate (e.g. Btu'slhour). Output energy rate is simply

equated to input energy rate. This energy rate is converted by mathematical constants to either

dollars per million Btu's output and/or annual energy consumption. (Annual energy

consumption is calculated only for electric heaters that are the primary heating source for the

entire house. Supplemental heaters and unvented heaters using either natural gas, propane, or oil

only require calculation of dollars per million Btu's.) As currently written, this procedure

generally reflects the lack of any appreciable energy performance difference among models of

this product subcategory. To date, this product subcategory has not been subject to any labeling

requirements or energy conservation standards. As mentioned above, pursuant to EISA 2007,

DOE must now include provisions to measure standby and offmode energy use in the test

procedures used for these and many other products. This brings up the question of whether

unvented heaters use energy in standby off modes. DOE anticipates that such test procedure

amendments could identify an opportunity for energy performance improvements in unvented

heater models. DOE is interested in gathering information that will help it to fulfill the

requirements of EPCA, as amended, without causing undue burden to the industry.

DOE realizes that this product subcategory presents a unique set of circumstances when

addressing EISA 2007, particularly regarding the EISA 2007 provisions on energy conservation

standards. First, unlike other test procedures, appendix G does not include energy efficiency or

energy use metrics that would allow for the integration ofstandby and offmode energy use. As

*Printod with soy ink on recycled paper
a consequence, there currently exists no basis to establish what EISA 2007 would call a single or

integrated standard for unvented heaters.

Second, standby mode energy use (defined as energy use during the heating season when

the heater is not on) could be considered as effective in heating the space as active mode energy

use. Therefore, DOE is evaluating the appropriateness ofmeasuring this energy use or its

possible inclusion in an energy conservation standard.

Finally, off mode energy consumption (defined as non-heating season energy

consumption) could be considered energy use and, accordingly, could be minimized by

prescribing a separate energy conservation standard. However, defining a representative off

mode for this subcategory is difficult because ofthe lack of data on consumer use. Specifically,

DOE is not currently aware of data on the fraction ofthe year heaters are unplugged or otherwise

disconnected from the energy source, and the extent to which pilot lights are turned off during

the non-heating season. This unique set of circumstances forms the basis ofthis inquiry.

Definitions

To aid in responding to the questions below, the following definitions of "active mode,"

"standby mode," and "off mode" apply:

• "Active mode" is the period during the heating season when the burner or heating

element is on.

• "Standby mode" is the period during the heating season when the main burner or heating

element is not on.

• "Off mode" is the entire non-heating season, unless there is disconnection from the

energy source.

The duration ofthe heating and non-heating seasons for these products can be assumed to be

the same as the representative values used for all other DOE test procedures for heating

products, i.e., 4160 hours heating season and 4600 hours non-heating season. One

complication for this subcategory is the possibility ofthe product being placed out ofservice

during the heating season. This possibility would impact the accounting of offmode and

standby mode. For example, these out-of-service hours during the heating season could be

debated as more appropriately offmode rather that standby mode. Nonetheless, rather than

sorting out this complication at this time, DOE believes the above proposed simplified

definitions are sufficient to allow for informative answers to the following questions.

However, your views on this complication arc welcome.

Ouestions

In light ofthe above, DOE would appreciate your answers to the following questions:

I. Do you manufacture, and are you aware of other manufacturer models of, fossil-fueled

unvented heaters that have measurable fossil-fueled standby and offmode energy use (e.g.,

pilot lights)? lfso, what is your estimate ofthe range ofthe energy use rates for such models

(btulhour)?
2. Do you manufacture, and are you aware of other manufacturer models of, fossil-fueled

unvented heaters that have measurable electrical standby and off mode energy use? Ifso

what is your estimate ofthe range of energy use rate (watts)?

3. Do you manufacture, and are you aware of other manufacturer models of, electric unvented

heaters that have measurable electric standby and off mode energy use? Ifso what is your

estimate ofthe range of energy use rate (watts)?

4. Ideally, the ranges of energy use rates above could be converted to ranges of annual

consumption values if a reasonably representative range of annual hours ofoff mode usage

can be defined. Are you aware of data or studies that would aid DOE in defining

representative annual hours of off mode use for the types ofproducts discussed above? If

so, please identify them and add your thoughts on the accuracy and relevance ofthe data.

5. Absent DOE-prescribed representative hours of off mode, what is your view about a limited

test procedure that only requires measurement and disclosure of energy use rate (i.e., wattage

and/or pilot light btu/hour)? Additionally, what is your view on a potential subsequent

regulation based only on energy use rate?

6. Is the Standard 62301 ofthe International Electrotechnical Commission, Household

Electrical Appliances - Measurement ofStandby Power, sufficient and appropriate to

measure electric standby and/or off mode energy use rate? In your answer, please explain

why they are, or not, sufficient.

DOE requests that answers be provided not later than April 8, 2009, in order to allow the

Department sufficient time to incorporate such information into its test procedure rulemaking for

direct heating equipment, which is being conducted pursuant to EISA 2007. It is important to

note that the current ongoing standards rulemaking for direct heating equipment will not be

impacted by the possible test procedure amendments discussed here. Should you have any

questions, please feel free to contact Mohammed Khan of my staff at (202) 586-7892.

Sincerely,

~~/c1~ Ronald P. Lewis

Supervisor--Regulatory

Appliance Standards

Building Technologies Program

Energy Efficiency and Renewable Energy

Enclosure
ATTACHMENT A

The Energy Independence and Security Act of2007 (EISA 2007), Pub. L. 110-140,

amended the Energy Policy and Conservation Act (42 U.S.C. 6291 et seq.; EPCA), and in

relevant part, directs DOE to amend its test procedures to include measures ofstandby mode and

offmode energy consumption, unless such measures are already fully incorporated in the current

test procedure or would be technically infeasible to prescribe (EISA 2007, section 310; 42 U.S.c.

6295(gg)(2)(A)). The EISA 2007 amendments to EPCA further direct DOE to amend the test

procedures to integrate such energy consumption into the overall energy efficiency, energy

consumption, or other energy descriptor for that product. Ifamending the test procedure in this

manner is technically infeasible, DOE must prescribe a separate standby mode and off mode

energy use test procedure, iftechnically feasible. Any such amendment must consider the most

current versions ofthe International Electrotechnical Commission (IEC) Standard 62301 and

IEC Standard 62087. For residential water heaters, direct heating equipment, and pool heaters,

DOE must prescribe any such amendment to the test procedures by March 31,2010. (EISA

2007, section 310; 42 U.S.C. 6295(gg)(2)(B)(v))

Unvented heaters are a class of direct heating equipment. DOE's test procedure currently

does not include provisions for measuring or accounting for "standby mode" or "offmode"

energy use, as defined by EISA 2007. Accordingly, the test procedure would need to be

amended to include such accounting.

Legislative language from EISA 2007
"(2) TEST PROCEDURES

"(A) TN GENERAL.--Test proceduresfor all covered products shall be amended pursuant to

section 323 to include standby mode and offmode energy consumption, taking into consideration

the most current versions o{Standards 62301 and 62087 ofthe International Electrotechnical

Commission, with such energy consumption integrated into the overall energy efficiency, energy

consumption, or other

energy descriptorfor each covered product, unless the SecretOlY determines that

"(i) the current test proceduresfor a covered product alreadyfully account for and incorporate

the standby mode and offmode energy consumption ofthe covered product; or

"(Ii) such an integrated test procedure is technically infeasible for a particular covered product,

in which case the Secretary shall prescribe a separate standby mode and offmode energy use

test procedure for the covered product, iftechnically feasible.

"(B) DEADLINES--The test procedure amendments required by subparagraph (A) shall be

prescribed in afinal rule no later than the following dates:

"(i) December 31, 2008,for battery chargers and external power supplies.

"(Ii) March 31, 2009,for clothes dryers, room air conditioners, andfluorescent lamp ballasts.

"(iii) June 30, 2009, for residential clothes washers.

"(iv) September 30, 2009,for residentialfurnaces and boilers.

"(v) March 31, 20l0,for residential water heaters, direct heating equipment, and pool heaters.

"(vi) March 31, 2011, for residential dishwashers, ranges and ovens, microwave ovens, and

dehumidifiers.

"(C) PRIOR PRODUCT STANDARDS--The test procedure amendments adopted pursuant to

subparagraph (B) shall not be used to determine compliance with product standards established

prior to the adoption ofthe amended test procedures.
"(3) INCORPORATION INTO STANDARD.

"(A) IN GENERAL.--Subject to subparagraph (8), based on the test procedures required under

paragraph (2), any final rule establishing or revising a standardfor a covered product, adopted

after July I, 2010, shall incorporate standby mode and offmode energy use into a single

amended or new standard, pursuant to subsection (0), iffeasible.

"(B) SEPARATE STANDARDS.--ljnotfeasible. the Secretary shall prescribe within the final

rule a separate standardfor standby mode and offmode energy consumption, ifjustified under

subsection (0).
Department of Energy

Washington, DC 20585

March 23, 2009

Mr. Ricovrei

Managing Director

Park 80 Plaza West Floor 4

Saddle Brook, NJ 07663-5808

RE: Request for infonnation regarding possible standby and off mode energy use for unvented

heaters

Dear Mr. Ricovrei:

As you may know, section 310 ofthe Energy Independence and Security Act of2007

(EISA 2007), Pub. L. I 10-140, amended the Energy Policy and Conservation Act (EPCA). In

the relevant part, EISA 2007 requires the U.S. Department ofEnergy (DOE) to amend, if

technically feasible, all DOE test procedures for covered consumer products to account for

standby mode and off mode energy consumption. (A brief description of EISA 2007, along with

the relevant legislative language, is provided as Attachment A.) Of particular note here, the

legislation requires DOE to amend the test procedure for direct heating equipment (of which

unvented heaters are one subcategory) by March 31, 20 IO.

By way of background, the unvented heater test procedure is found at Title 10 ofthe

Code of Federal Regulations (10 CFR) 430.23(g) and 10 CFR part 430, subpart B, appendix G.

This procedure applies to both electric and fossil-fueled unvented heaters. This procedure only

requires measurement ofinput energy rate (e.g. Btu'slhour). Output energy rate is simply

equated to input energy rate. This energy rate is converted by mathematical constants to either

dollars per million Btu's output and/or annual energy consumption. (Annual energy

consumption is calculated only for electric heaters that are the primary heating source for the

entire house. Supplemental heaters and unvented heaters using either natural gas, propane, or oil

only require calculation of dollars per million Btu's.) As currently written, this procedure

generally reflects the lack of any appreciable energy perfonnance difference among models of

this product subcategory. To date, this product subcategory has not been subject to any labeling

requirements or energy conservation standards. As mentioned above, pursuant to EISA 2007,

DOE must now include provisions to measure standby and offmode energy use in the test

procedures used for these and many other products. This brings up the question ofwhether

unvented heaters use energy in standby off modes. DOE anticipates that such test procedure

amendments could identify an opportunity for energy perfonnance improvements in unvented

heater models. DOE is interested in gathering infonnation that will help it to fulfill the

requirements of EPCA, as amended, without causing undue burden to the industry.

DOE realizes that this product subcategory presents a unique set of circumstances when

addressing EISA 2007, particularly regarding the EISA 2007 provisions on energy conservation

standards. First, unlike other test procedures, appendix G does not include energy efficiency or

energy use metrics that would allow for the integration ofstandby and off mode energy use. As

a consequence, there currently exists no basis to establish what EISA 2007 would call a single or

integrated standard for unvented heaters. *

Printed with soy ink on recycled paper
Second, standby mode energy use (defined as energy use during the heating season when

the heater is not on) could be considered as effective in heating the space as active mode energy

use. Therefore, DOE is evaluating the appropriateness of measuring this energy use or its

possible inclusion in an energy conservation standard.

Finally, off mode energy consumption (defined as non-heating season energy

consumption) could be considered energy use and, accordingly, could be minimized by

prescribing a separate energy conservation standard. However, defining a representative off

mode for this subcategory is difficult because ofthe lack of data on consumer use. Specifically,

DOE is not currently aware of data on the fraction ofthe year heaters are unplugged or otherwise

disconnected from the energy source, and the extent to which pilot lights are turned off during

the non-heating season. This unique set of circumstances forms the basis ofthis inquiry.

Definitions

To aid in responding to the questions below, the following definitions of "active mode,"

"standby mode," and "off mode" apply:

• "Active mode" is the period during the heating season when the burner or heating

element is on.

• "Standby mode" is the period during the heating season when the main burner or heating

element is not on.

• "Off mode" is the entire non-heating season, unless there is disconnection from the

energy source.

The duration ofthe heating and non-heating seasons for these products can be assumed to be

the same as the representative values used for all other DOE test procedures for heating

products, i.e., 4160 hours heating season and 4600 hours non-heating season. One

complication for this subcategory is the possibility ofthe product heing placed out ofservice

during the heating season. This possibility would impact the accounting of off mode and

standby mode. For example, these out-of-service hours during the heating season could be

debated as more appropriately offmode rather that standby mode. Nonetheless, rather than

sorting out this complication at this time, DOE believes the above proposed simplified

definitions arc sufficient to allow for informative answers to the following questions.

However, your views on this complication are welcome.

Ouestions

In light ofthe above, DOE would appreciate your answers to the following questions:

I. Do you manufacture, and are you aware of other manufacturer models of, fossil-fueled

unvented heaters that have measurable fossil-fueled standby and off mode energy use (e.g.,

pilot lights)? lfso, what is your estimate ofthe range ofthe energy use rates for such models

(btu/hour)?
2. Do you manufacture, and are you aware of other manufacturer models of, fossil-fueled

unvented heaters that have measurable electrical standby and offmode energy use? Ifso

what is your estimate ofthe range of energy use rate (watts)?

3. Do you manufacture, and are you aware of other manufacturer models of, electric unvcnted

heaters that have measurable electric standby and offmode energy use? If so what is your

estimate ofthe range of energy use rate (watts)?

4. Ideally, the ranges of energy use rates above could be converted to ranges of annual

consumption values if a reasonably representative range of annual hours of off mode usage

can be defined. Are you aware of data or studies that would aid DOE in defining

representative annual hours of offmode use for the types of products discussed above? If

so, please identifY them and add your thoughts on the accuracy and relevance ofthe data.

5. Absent DOE-prescribed representative hours of offmode, what is your view about a limited

test procedure that only requires measurement and disclosure of energy use rate (i.e., wattage

and/or pilot light btu/hour)? Additionally, what is your view on a potential subsequent

regulation based only on energy use rate?

6. Is the Standard 6230 I ofthe International Electrotechnical Commission, Household

Electrical Appliances - Measurement ofStandby Power, sufficient and appropriate to

measure electric standby and/or offmode energy use rate? In your answer, please explain

why they are, or not, sufficient.

DOE requests that answers be provided not later than April 8, 2009, in order to allow the

Department sufficient time to incorporate such information into its test procedure rulemaking for

direct heating equipment, which is being conducted pursuant to EISA 2007. It is important to

note that the current ongoing standards rulemaking for direct heating equipment will not be

impacted by the possible test procedure amendments discussed here. Should you have any

questions, please feel free to contact Mohammed Khan ofmy staff at (202) 586-7892.

Sincerely,

/'-P?/c

Ronald P. Lewis

Supervisor--Regulatory

Appliance Standards

Building Technologies Program

Energy Efficiency and Renewable Energy

Enclosure
ATTACHMENT A

The Energy Independence and Security Act of2007 (EISA 2007), Pub. L. 110-140,

amended the Energy Policy and Conservation Act (42 U.S.C. 6291 et seq.; EPCA), and in

relevant part, directs DOE to amend its test procedures to include measures ofstandby mode and

offmode energy consumption, unless such measures are already fully incorporated in the current

test procedure or would be technically infeasible to prescribe (EISA 2007, section 310; 42 U.S.c.

6295(gg)(2)(A)). The EISA 2007 amendments to EPCA further direct DOE to amend the test

procedures to integrate such energy consumption into the overall energy efficiency, energy

consumption, or other energy descriptor for that product. Ifamending the test procedure in this

manner is technically infeasible, DOE must prescribe a separate standby mode and off mode

energy use test procedure, iftechnically feasible. Any such amendment must consider the most

current versions ofthe International Electrotechnical Commission (IEC) Standard 62301 and

IEC Standard 62087. For residential water heaters, direct heating equipment, and pool heaters,

DOE must prescribe any such amendment to the test procedures by March 31,2010. (EISA

2007, section 310; 42 U.S.C. 6295(gg)(2)(B)(v))

Unvented heaters are a class of direct heating equipment. DOE's test procedure currently

does not include provisions for measuring or accounting for "standby mode" or "offmode"

energy use, as defined by EISA 2007. Accordingly, the test procedure would need to be

amended to include such accounting.

Legislative language from EISA 2007
"(2) TEST PROCEDURES

"(A) TN GENERAL.--Test proceduresfor all covered products shall be amended pursuant to

section 323 to include standby mode and offmode energy consumption, taking into consideration

the most current versions o{Standards 62301 and 62087 ofthe International Electrotechnical

Commission, with such energy consumption integrated into the overall energy efficiency, energy

consumption, or other

energy descriptorfor each covered product, unless the SecretOlY determines that

"(i) the current test proceduresfor a covered product alreadyfully account for and incorporate

the standby mode and offmode energy consumption ofthe covered product; or

"(Ii) such an integrated test procedure is technically infeasible for a particular covered product,

in which case the Secretary shall prescribe a separate standby mode and offmode energy use

test procedure for the covered product, iftechnically feasible.

"(B) DEADLINES--The test procedure amendments required by subparagraph (A) shall be

prescribed in afinal rule no later than the following dates:

"(i) December 31, 2008,for battery chargers and external power supplies.

"(Ii) March 31, 2009,for clothes dryers, room air conditioners, andfluorescent lamp ballasts.

"(iii) June 30, 2009, for residential clothes washers.

"(iv) September 30, 2009,for residentialfurnaces and boilers.

"(v) March 31, 20l0,for residential water heaters, direct heating equipment, and pool heaters.

"(vi) March 31, 2011, for residential dishwashers, ranges and ovens, microwave ovens, and

dehumidifiers.

"(C) PRIOR PRODUCT STANDARDS--The test procedure amendments adopted pursuant to

subparagraph (B) shall not be used to determine compliance with product standards established

prior to the adoption ofthe amended test procedures.
"(3) INCORPORATION INTO STANDARD.

"(A) IN GENERAL.--Subject to subparagraph (8), based on the test procedures required under

paragraph (2), any final rule establishing or revising a standardfor a covered product, adopted

after July I, 2010, shall incorporate standby mode and offmode energy use into a single

amended or new standard, pursuant to subsection (0), iffeasible.

"(B) SEPARATE STANDARDS.--ljnotfeasible. the Secretary shall prescribe within the final

rule a separate standardfor standby mode and offmode energy consumption, ifjustified under

subsection (0).
Department of Energy

Washington. DC 20585

March 23, 2009

Mr. Ricovrei

Managing Director

23600 Aurora Road

Bedford Heights OH 44146-1712

RE: Request for information regarding possible standby and off mode energy use for unvented

heaters

Dear Mr. Ricovrei:

As you may know, section 310 ofthe Energy independence and Security Act of 2007

(EISA 2007), Pub. L. 110-140, amended the Energy Policy and Conservation Act (EPCA). In

the relevant part, EISA 2007 requires the U.S. Department of Energy (DOE) to amend, if

technically feasible, all DOE test procedures for covered consumer products to account for

standby mode and offmode energy consumption. (A brief description of EISA 2007, along with

the relevant legislative language, is provided as Attachment A.) Of particular note here, the

legislation requires DOE to amend the test procedure for direct heating equipment (of which

unvented heaters are one subcategory) by March 31, 20 IO.

By way of background, the unvented heater test procedure is found at Title 10 ofthe

Code ofFederal Regulations (10 CFR) 430.23(g) and 10 CFR part 430, subpart B, appendix G.

This procedure applies to both electric and fossil-fueled unvented heaters. This procedure only

requires measurement ofinput energy rate (e.g. Btu's!hour). Output energy rate is simply

equated to input energy rate. This energy rate is converted by mathematical constants to either

dollars per million Btu's output and/or annual energy consumption. (Annual energy

consumption is calculated only for electric heaters that are the primary heating source for the

entire house. Supplemental heaters and unvented heaters using either natural gas, propane, or oil

only require calculation of dollars per million Btu's.) As currently written, this procedure

generally reflects the lack of any appreciable energy performance difference among models of

this product subcategory. To date, this product subcategory has not been subject to any labeling

requirements or energy conservation standards. As mentioned above, pursuant to EISA 2007,

DOE must now include provisions to measure standby and offmode energy use in the test

procedures used for these and many other products. This brings up the question ofwhether

unvented heaters use energy in standby offmodes. DOE anticipates that such test procedure

amendments could identitY an opportunity for energy performance improvements in unvented

heater models. DOE is interested in gathering information that will help it to fulfill the

requirements of EPCA, as amended, without causing undue burden to the industry.

DOE realizes that this product subcategory presents a unique set of circumstances when

addressing EISA 2007, particularly regarding the EISA 2007 provisions on energy conservation

standards. First, unlike other test procedures, appendix G does not include energy efficiency or

energy use metrics that would allow for the integration ofstandby and offmode energy use. As

a consequence, there currently exists no basis to establish what EISA 2007 would call a single or

integrated standard for unvented heaters.

*Printed with soy ink on recycled paper
a consequence, there currently exists no basis to establish what EISA 2007 would call a single or

integrated standard for unvented heaters.

Second, standby mode energy use (defined as energy use during the heating season when

the heater is not on) could be considered as effective in heating the space as active mode energy

use. Therefore, DOE is evaluating the appropriateness ofmeasuring this energy use or its

possible inclusion in an energy conservation standard.

Finally, offmode energy consumption (defined as non-heating season energy

consumption) could be considered energy use and, accordingly, could be minimized by

prescribing a separate energy conservation standard. However, defining a representative off

mode for this subcategory is difficult because ofthe lack of data on consumer use. Specifically,

DOE is not currently aware of data on the fraction ofthe year heaters are unplugged or otherwise

disconnected from the energy source, and the extent to which pilot lights are turned off during

the non-heating season. This unique set of circumstances forms the basis ofthis inquiry.

Definitions

To aid in responding to the questions below, the following definitions of "active mode,"

"standby mode," and "off mode" apply:

• "Active mode" is the period during the heating season when the burner or heating

element is on.

• "Standby mode" is the period during the heating season when the main burner or heating

element is not on.

• "Offmode" is the entire non-heating season, unless there is disconnection from the

energy source.

The duration ofthe heating and non-heating seasons for these products can be assumed to be

the same as the representative values used for all other DOE test procedures for heating

products, i.e., 4160 hours heating season and 4600 hours non-heating season. One

complication for this subcategory is the possibility ofthe product being placed out ofservice

during the heating season. This possibility would impact the accounting of off mode and

standby mode. For example, thesc out-of-service hours during the heating season could be

debated as more appropriately offmode rather that standby mode. Nonetheless, rather than

sorting out this complication at this time, DOE believes the above proposed simplified

definitions are sufficient to allow for informative answers to the following questions.

However, your views on this complication are welcome.

Ouestions

In light ofthe above, DOE would appreciate your answers to the following questions:

I. Do you manufacture, and are you aware of other manufacturer models of, fossil-fueled

unvented heaters that have measurable fossil-fueled standby and offmode energy use (e.g.,

pilot lights)? lfso, what is your estimate ofthe range ofthe energy use rates for such models

(btu/hour)?
2. Do you manufacture, and are you aware of other manufacturer models of, fossil-fueled

unvented heaters that have measurable electrical standby and off mode energy use? Ifso

what is your estimate ofthe range of energy use rate (watts)?

3. Do you manufacture, and are you aware of other manufacturer models of, electric unvented

heaters that have measurable electric standby and offmode energy use? Ifso what is your

estimate ofthe range of energy use rate (watts)?

4. Ideally, the ranges of energy use rates above could be converted to ranges of annual

consumption values if a reasonably representative range of annual hours of off mode usage

can be defined. Are you aware of data or studies that would aid DOE in defining

representative annual hours of offmode use for the types of products discussed above? If

so, please identify them and add your thoughts on the accuracy and relevance ofthe data.

5. Absent DOE-prescribed representative hours of offmode, what is your view about a limited

test procedure that only requires measurement and disclosure of energy use rate (i.e., wattage

and/or pilot light btu/hour)? Additionally, what is your view on a potential subsequent

regulation based only on energy use rate?

6. Is the Standard 62301 ofthe International Electrotechnical Commission, Household

Electrical Appliances - Measurement ofStandby Power, sufficient and appropriate to

measure electric standby and/or offmode energy use rate? In your answer, please explain

why they are, or not, sufficient.

DOE requests that answers be provided not later than April 8, 2009, in order to allow the

Department sufficient time to incorporate such infonnation into its test procedure rulemaking for

direct heating equipment, which is being conducted pursuant to EISA 2007. It is important to

note that the current ongoing standards rulemaking for direct heating equipment will not be

impacted by the possible test procedure amendments discussed here. Should you have any

questions, please feel free to contact Mohammed Khan ofmy staff at (202) 586-7892.

Sincerely,

Ronald P. Lewis

Supervisor--Regulatory

Appliance Standards

Building Technologies Program

Energy Efficiency and Renewable Energy

Enclosure
ATTACHMENT A

The Energy Independence and Security Act of2007 (EISA 2007), Pub. L. 110-140,

amended the Energy Policy and Conservation Act (42 U.S.C. 6291 et seq.; EPCA), and in

relevant part, directs DOE to amend its test procedures to include measures ofstandby mode and

offmode energy consumption, unless such measures are already fully incorporated in the current

test procedure or would be technically infeasible to prescribe (EISA 2007, section 310; 42 U.S.c.

6295(gg)(2)(A)). The EISA 2007 amendments to EPCA further direct DOE to amend the test

procedures to integrate such energy consumption into the overall energy efficiency, energy

consumption, or other energy descriptor for that product. Ifamending the test procedure in this

manner is technically infeasible, DOE must prescribe a separate standby mode and off mode

energy use test procedure, iftechnically feasible. Any such amendment must consider the most

current versions ofthe International Electrotechnical Commission (IEC) Standard 62301 and

IEC Standard 62087. For residential water heaters, direct heating equipment, and pool heaters,

DOE must prescribe any such amendment to the test procedures by March 31,2010. (EISA

2007, section 310; 42 U.S.C. 6295(gg)(2)(B)(v))

Unvented heaters are a class of direct heating equipment. DOE's test procedure currently

does not include provisions for measuring or accounting for "standby mode" or "offmode"

energy use, as defined by EISA 2007. Accordingly, the test procedure would need to be

amended to include such accounting.

Legislative language from EISA 2007
"(2) TEST PROCEDURES

"(A) TN GENERAL.--Test proceduresfor all covered products shall be amended pursuant to

section 323 to include standby mode and offmode energy consumption, taking into consideration

the most current versions o{Standards 62301 and 62087 ofthe International Electrotechnical

Commission, with such energy consumption integrated into the overall energy efficiency, energy

consumption, or other

energy descriptorfor each covered product, unless the SecretOlY determines that

"(i) the current test proceduresfor a covered product alreadyfully account for and incorporate

the standby mode and offmode energy consumption ofthe covered product; or

"(Ii) such an integrated test procedure is technically infeasible for a particular covered product,

in which case the Secretary shall prescribe a separate standby mode and offmode energy use

test procedure for the covered product, iftechnically feasible.

"(B) DEADLINES--The test procedure amendments required by subparagraph (A) shall be

prescribed in afinal rule no later than the following dates:

"(i) December 31, 2008,for battery chargers and external power supplies.

"(Ii) March 31, 2009,for clothes dryers, room air conditioners, andfluorescent lamp ballasts.

"(iii) June 30, 2009, for residential clothes washers.

"(iv) September 30, 2009,for residentialfurnaces and boilers.

"(v) March 31, 20l0,for residential water heaters, direct heating equipment, and pool heaters.

"(vi) March 31, 2011, for residential dishwashers, ranges and ovens, microwave ovens, and

dehumidifiers.

"(C) PRIOR PRODUCT STANDARDS--The test procedure amendments adopted pursuant to

subparagraph (B) shall not be used to determine compliance with product standards established

prior to the adoption ofthe amended test procedures.
"(3) INCORPORATION INTO STANDARD.

"(A) IN GENERAL.--Subject to subparagraph (8), based on the test procedures required under

paragraph (2), any final rule establishing or revising a standardfor a covered product, adopted

after July I, 2010, shall incorporate standby mode and offmode energy use into a single

amended or new standard, pursuant to subsection (0), iffeasible.

"(B) SEPARATE STANDARDS.--ljnotfeasible. the Secretary shall prescribe within the final

rule a separate standardfor standby mode and offmode energy consumption, ifjustified under

subsection (0).
Department of Energy

Washington, DC 20585

March 23, 2009

Mr. James York

Rinnai American Corporation

103 International Drive

Peachtree City, GA 30269-1911

RE: Request for information regarding possible standby and offmode energy use for unvented

heaters

Dear Mr. York:

As you may know, section 310 ofthe Energy Independence and Security Act of2007

(EISA 2007), Pub. L. 110-140, amended the Energy Policy and Conservation Act (EPCA). In

the relevant part, EISA 2007 requires the U.S. Department of Energy (DOE) to amend, if

technically feasible, all DOE test procedures for covered consumer products to account for

standby mode and offmode energy consumption. (A brief description of EISA 2007, along with

the relevant legislative language, is provided as Attachment A.) Of particular note here, the

legislation requires DOE to amend the test procedure for direct heating equipment (of which

unvented heaters are one subcategory) by March 31, 20 IO.

By way of background, the unvented heater test procedure is found at Title 10 ofthe

Code of Federal Regulations (10 CFR) 430.23(g) and 10 CFR part 430, subpart B, appendix G.

This procedure applies to both electric and fossil-fueled unvented heaters. This procedure only

requires measurement ofinput energy rate (e.g. Btu'slhour). Output energy rate is simply

equated to input energy rate. Tills energy rate is converted by mathematical constants to either

dollars per million Btu's output and/or annual energy consumption. (Annual energy

consumption is calculated only for electric heaters that are the primary heating source for the

entire house. Supplemental heaters and unvented heaters using either natural gas, propane, or oil

only require calculation of dollars per million Btu's.) As currently written, this procedure

generally reflects the lack of any appreciable energy performance difference among models of

this product subcategory. To date, this product subcategory has not been subject to any labeling

requirements or energy conservation standards. As mentioned above, pursuant to EISA 2007,

DOE must now include provisions to measure standby and offmode energy use in the test

procedures used for these and many other products. This brings up the question of whether

unvented heaters use energy in standby offmodes. DOE anticipates that such test procedure

amendments could identify an opportunity for energy performance improvements in unventcd

heater models. DOE is interested in gathering information that will help it to fulfill the

requirements of EPCA, as amended, without causing undue burden to the industry.

DOE realizes that this product subcategory presents a unique set of circumstances when

addressing EISA 2007, particularly regarding the EISA 2007 provisions on energy conservation

standards. First, unlike other test procedures, appendix G does not include energy efficiency or

energy use metrics that would allow for the integration ofstandby and off mode energy use. As

S Printed with soy ink on recycled paper
a consequence, there currently exists no basis to establish what EISA 2007 would call a single or

integrated standard for unvented heaters.

Second, standby mode energy use (defined as energy use during the heating season when

the heater is not on) could be considered as effective in heating the space as active mode energy

use. Therefore, DOE is evaluating the appropriateness of measuring this energy use or its

possible inclusion in an energy conservation standard.

Finally, off mode energy consumption (defined as non-heating season energy

consumption) could be considered energy use and, accordingly, could be minimized by

prescribing a separate energy conservation standard. However, defining a representative ofT

mode for this subcategory is difficult because ofthe Jack of data on consumer use. Specifically,

DOE is not currently aware of data on the fraction ofthe year heaters are unplugged or otherwise

disconnected from the energy source, and the extent to which pilot lights are turned off during

the non-heating season. This unique set of circumstances forms the basis ofthis inquiry.

Definitions

To aid in responding to the questions below, the following definitions of "active mode,"

"standby mode," and "off mode" apply:

• "Active mode" is the period during the heating season when the burner or heating

element is on.

• "Standby mode" is the period during the heating season when the main burner or heating

element is not on.

• "Offmode" is the entire non-heating season, unless there is disconnection from the

energy source.

The duration ofthe heating and non-heating seasons for these products can be assumed to be

the same as the representative values used for all other DOE test procedures for heating

products, i.e., 4160 hours heating season and 4600 hours non-heating season. One

complication for this subcategory is the possibility ofthe product being placed out ofservice

during the heating season. This possibility would impact the accounting of offmode and

standby mode. For example, these out-of-service hours during the heating season could be

debated as more appropriately offmode rather that standby mode. Nonetheless, rather than

sorting out this complication at this time, DOE believes the above proposed simplified

definitions are sufficient to allow for informative answers to the following questions.

However, your views on this complication are welcome.

Questions

In light ofthe above, DOE would appreciate your answers to the following questions:

I. Do you manufacture, and are you aware of other manufacturer models of, fossil-fueled

unvented heaters that have measurable fossil-fueled standby and offmode energy use (e.g.,

pilot lights)? Ifso, what is your estimate ofthe range ofthe energy use rates for such models

(btu/hour)?
2. Do you manufacture, and are you aware of other manufacturer models of, fossil-fueled

unvented heaters that have measurable electrical standby and off mode energy use? Ifso

what is your estimate ofthe range of energy use rate (watts)?

3. Do you manufacture, and are you aware of other manufacturer models of, electric unvented

heaters that have measurable electric standby and off mode energy use? Ifso what is your

estimate ofthe range of energy use rate (watts)?

4. Ideally, the ranges of energy use rates above could be converted to ranges of annual

consumption values if a reasonably representative range of annual hours of offmode usage

can be defined. Are you aware of data or studies that would aid DOE in defining

representative annual hours ofoffmode use for the types of products discussed above? If

so, please identify them and add your thoughts on the accuracy and relevance ofthe data.

5. Absent DOE-prescribed representative hours of off mode, what is your view about a limited

test procedure that only requires measurement and disclosure of energy use rate (i.e., wattage

and/or pilot light btu/hour)? Additionally, what is your view on a potential subsequent

regulation based only on energy use rate?

6. Is the Standard 6230 I ofthe International Electrotechnical Commission, Household

Electrical Appliances - Measurement 0/Standby Power, sufficient and appropriate to

measure electric standby and/or offmode energy use rate? In your answer, please explain

why they are, or not, sufficient.

DOE requests that answers be provided not later than April 8,2009, in order to allow the

Department sufficient time to incorporate such information into its test procedure rulemaking for

direct heating equipment, which is bcing conducted pursuant to EISA 2007. It is important to

note that the current ongoing standards rulemaking for direct heating equipment will not be

impacted by the possible test procedure amendments discussed here. Should you have any

questions, please feel free to contact Mohammed Khan ofmy staff at (202) 586-7892.

Sincerely,

Ronald

L~/~ P. Lewis

Supervisor--Regulatory

Appliance Standards

Building Technologies Program

Energy Efficiency and Renewable Encrgy

Enclosure
ATTACHMENT A

The Energy Independence and Security Act of2007 (EISA 2007), Pub. L. 110-140,

amended the Energy Policy and Conservation Act (42 U.S.C. 6291 et seq.; EPCA), and in

relevant part, directs DOE to amend its test procedures to include measures ofstandby mode and

offmode energy consumption, unless such measures are already fully incorporated in the current

test procedure or would be technically infeasible to prescribe (EISA 2007, section 310; 42 U.S.c.

6295(gg)(2)(A)). The EISA 2007 amendments to EPCA further direct DOE to amend the test

procedures to integrate such energy consumption into the overall energy efficiency, energy

consumption, or other energy descriptor for that product. Ifamending the test procedure in this

manner is technically infeasible, DOE must prescribe a separate standby mode and off mode

energy use test procedure, iftechnically feasible. Any such amendment must consider the most

current versions ofthe International Electrotechnical Commission (IEC) Standard 62301 and

IEC Standard 62087. For residential water heaters, direct heating equipment, and pool heaters,

DOE must prescribe any such amendment to the test procedures by March 31,2010. (EISA

2007, section 310; 42 U.S.C. 6295(gg)(2)(B)(v))

Unvented heaters are a class of direct heating equipment. DOE's test procedure currently

does not include provisions for measuring or accounting for "standby mode" or "offmode"

energy use, as defined by EISA 2007. Accordingly, the test procedure would need to be

amended to include such accounting.

Legislative language from EISA 2007
"(2) TEST PROCEDURES

"(A) TN GENERAL.--Test proceduresfor all covered products shall be amended pursuant to

section 323 to include standby mode and offmode energy consumption, taking into consideration

the most current versions o{Standards 62301 and 62087 ofthe International Electrotechnical

Commission, with such energy consumption integrated into the overall energy efficiency, energy

consumption, or other

energy descriptorfor each covered product, unless the SecretOlY determines that

"(i) the current test proceduresfor a covered product alreadyfully account for and incorporate

the standby mode and offmode energy consumption ofthe covered product; or

"(Ii) such an integrated test procedure is technically infeasible for a particular covered product,

in which case the Secretary shall prescribe a separate standby mode and offmode energy use

test procedure for the covered product, iftechnically feasible.

"(B) DEADLINES--The test procedure amendments required by subparagraph (A) shall be

prescribed in afinal rule no later than the following dates:

"(i) December 31, 2008,for battery chargers and external power supplies.

"(Ii) March 31, 2009,for clothes dryers, room air conditioners, andfluorescent lamp ballasts.

"(iii) June 30, 2009, for residential clothes washers.

"(iv) September 30, 2009,for residentialfurnaces and boilers.

"(v) March 31, 20l0,for residential water heaters, direct heating equipment, and pool heaters.

"(vi) March 31, 2011, for residential dishwashers, ranges and ovens, microwave ovens, and

dehumidifiers.

"(C) PRIOR PRODUCT STANDARDS--The test procedure amendments adopted pursuant to

subparagraph (B) shall not be used to determine compliance with product standards established

prior to the adoption ofthe amended test procedures.
"(3) INCORPORATION INTO STANDARD.

"(A) IN GENERAL.--Subject to subparagraph (8), based on the test procedures required under

paragraph (2), any final rule establishing or revising a standardfor a covered product, adopted

after July I, 2010, shall incorporate standby mode and offmode energy use into a single

amended or new standard, pursuant to subsection (0), iffeasible.

"(B) SEPARATE STANDARDS.--ljnotfeasible. the Secretary shall prescribe within the final

rule a separate standardfor standby mode and offmode energy consumption, ifjustified under

subsection (0).
Department of Energy

Washington, DC 20585

March 23, 2009

Mr. Warren Shoulders

President

Williams Fumace Company

Colton, CA 92324-1435

RE: Request for information regarding possible standby and off mode energy use for unvented

heaters

Dear Mr. Shoulders:

As you may know, section 310 ofthe Energy Independence and Security Act of2007

(EISA 2007), Pub. L. 110-140, amended the Energy Policy and Conservation Act (EPCA). In

the relevant part, EISA 2007 requires the U.S. Department of Energy (DOE) to amend, if

technically feasible, all DOE test procedures for covered consumer products to account for

standby mode and offmode energy consumption. (A brief description of EISA 2007, along with

the relevant legislative language, is provided as Attachment A.) Of particular note here, the

legislation requires DOE to amend the test procedure for direct heating equipment (of which

unvented heaters are one subcategory) by March 31, 20 IO.

By way ofbackground, the unvented heater test procedure is found at Title 10 ofthe

Code of Federal Regulations (10 CFR) 430.23(g) and 10 CFR part 430, subpart B, appendix G.

This procedure applies to both electric and fossil-fueled unvented heaters. This procedure only

requires measurement ofinput energy rate (e.g. Btu's!hour). Output energy rate is simply

equated to input energy rate. This energy rate is converted by mathematical constants to either

dollars per million Btu's output and/or annual energy consumption. (Annual energy

consumption is calculated only for electric heaters that are the primary heating source for the

entire house. Supplemental heaters and unvented heaters using either natural gas, propane, or oil

only require calculation of dollars per million Btu's.) As currently written, this procedure

generally reflects the lack of any appreciable energy performance difference among models of

this product subcategory. To date, this product subcategory has not been subject to any labeling

requirements or energy conservation standards. As mentioned above, pursuant to EISA 2007,

DOE must now include provisions to measure standby and offmode encrgy use in the test

procedures used for these and many other products. This brings up the question of whether

unvented heaters use energy in standby offmodes. DOE anticipates that such test procedure

amendments could identitY an opportunity for energy performance improvements in unvented

heater models. DOE is interested in gathering information that will help it to fulfill the

requirements of EPCA, as amended, without causing undue burden to the industry.

DOE realizes that this product subcategory presents a unique set of circumstances when

addressing EISA 2007, particularly regarding the EISA 2007 provisions on energy conservation

standards. First, unlike other test procedures, appendix G does not include energy efficiency or

energy use metrics that would allow for the integration ofstandby and off mode energy use. As *

Printed with soy ink on recycled paper
a consequence, there currently exists no basis to establish what EISA 2007 would call a single or

integrated standard for unvented heaters.

Second, standby mode energy use (defined as energy use during the heating season when

the heater is not on) could be considered as effective in heating the space as active mode energy

use. Therefore, DOE is evaluating the appropriateness of measuring this energy use or its

possible inclusion in an energy conservation standard.

Finally, off mode energy consumption (defined as non-heating season energy

consumption) could be considered energy use and, accordingly, could be minimized by

prescribing a separate energy conservation standard. However, defining a representative off

mode for this subcategory is difficult because ofthe lack of data on consumer use. Specifically,

DOE is not currently aware of data on the fraction ofthe year heaters arc unplugged or otherwise

disconnected from the energy source, and the extent to which pilot lights are turned off during

the non-heating season. This unique set of circumstances forms the basis ofthis inquiry.

Definitions

To aid in responding to the questions below, the following definitions of "active mode,"

"standby mode," and "off mode" apply:

• "Active mode" is the period during the heating season when the burner or heating

element is on.

• "Standby mode" is the period during the heating season when the main burner or heating

element is not on.

• "Off mode" is the entire non-heating season, unless there is disconnection from the

energy source.

The duration ofthe heating and non-heating seasons for these products can be assumed to be

the same as the representative values used for all other DOE test procedures for heating

products, i.e., 4160 hours heating season and 4600 hours non-heating season. One

complication for this subcategory is the possibility ofthe product being placed out ofservice

during the heating season. This possibility would impact the accounting of off mode and

standby mode. For example, these out-of-service hours during the heating season could be

debated as more appropriately off mode rather that standby mode. Nonetheless, rather than

sorting out this complication at this time, DOE believes the above proposed simplified

definitions arc sufficient to allow for informative answers to the following questions.

However, your views on this complication are welcome.

Ouestions

In light ofthe above, DOE would appreciate your answers to the following questions:

I. Do you manufacture, and are you aware of other manufacturer models of, fossil-fueled

unvented heaters that have measurable fossil-fueled standby and off mode energy use (e.g.,

pilot lights)? lfso, what is your estimate ofthe range ofthe energy use rates for such models

(btulhour)?
2. Do you manufacture, and are you aware of other manufacturer models of, fossil-fueled

unvented heaters that have measurable electrical standby and off mode energy use? If so

what is your estimate ofthe range of energy use rate (watts)?

3. Do you manufacture, and are you aware of other manufacturer models of, electric unvented

heaters that have measurable electric standby and off mode energy use? Ifso what is your

estimate ofthe range of energy use rate (watts)?

4. Ideally, the ranges of energy use rates above could be converted to ranges of annual

consumption values if a reasonably representative range of annual hours of off mode usage

can be defined. Are you aware of data or studies that would aid DOE in defining

representative annual hours of off mode use for the types of products discussed above? If

so, please identify them and add your thoughts on the accuracy and relevance ofthe data.

5. Absent DOE-prescribed representative hours of off mode, what is your view about a limited

test procedure that only requires measurement and disclosure of energy use rate (i.e., wattage

and/or pilot light btu/hour)? Additionally, what is your view on a potential subsequent

regulation based only on energy use rate?

6. Is the Standard 62301 ofthe International Electrotechnical Commission, Household

Electrical Appliances - Measurement ofStandby Power, sufficient and appropriate to

measure electric standby and/or offmode energy use rate? In your answer, please explain

why they are, or not, sufficient.

DOE requests that answers be provided not later than April 8, 2009, in order to allow the

Department sufficient time to incorporate such information into its test procedure rulemaking for

direct heating equipment, which is being conducted pursuant to EISA 2007. It is important to

note that the current ongoing standards rulemaking for direct heating equipment will not be

impacted by the possible test procedure amendments discussed here. Should you have any

questions, please feel free to contact Mohammed Khan ofmy staff at (202) 586-7892.

Sincerely,

Ronald P. Lewis

Supervisor--Regulatory

Appliance Standards

Building Technologies Program

Energy Efficiency and Renewable Energy

Enclosure
ATTACHMENT A

The Energy Independence and Security Act of2007 (EISA 2007), Pub. L. 110-140,

amended the Energy Policy and Conservation Act (42 U.S.C. 6291 et seq.; EPCA), and in

relevant part, directs DOE to amend its test procedures to include measures ofstandby mode and

offmode energy consumption, unless such measures are already fully incorporated in the current

test procedure or would be technically infeasible to prescribe (EISA 2007, section 310; 42 U.S.c.

6295(gg)(2)(A)). The EISA 2007 amendments to EPCA further direct DOE to amend the test

procedures to integrate such energy consumption into the overall energy efficiency, energy

consumption, or other energy descriptor for that product. Ifamending the test procedure in this

manner is technically infeasible, DOE must prescribe a separate standby mode and off mode

energy use test procedure, iftechnically feasible. Any such amendment must consider the most

current versions ofthe International Electrotechnical Commission (IEC) Standard 62301 and

IEC Standard 62087. For residential water heaters, direct heating equipment, and pool heaters,

DOE must prescribe any such amendment to the test procedures by March 31,2010. (EISA

2007, section 310; 42 U.S.C. 6295(gg)(2)(B)(v))

Unvented heaters are a class of direct heating equipment. DOE's test procedure currently

does not include provisions for measuring or accounting for "standby mode" or "offmode"

energy use, as defined by EISA 2007. Accordingly, the test procedure would need to be

amended to include such accounting.

Legislative language from EISA 2007
"(2) TEST PROCEDURES

"(A) TN GENERAL.--Test proceduresfor all covered products shall be amended pursuant to

section 323 to include standby mode and offmode energy consumption, taking into consideration

the most current versions o{Standards 62301 and 62087 ofthe International Electrotechnical

Commission, with such energy consumption integrated into the overall energy efficiency, energy

consumption, or other

energy descriptorfor each covered product, unless the SecretOlY determines that

"(i) the current test proceduresfor a covered product alreadyfully account for and incorporate

the standby mode and offmode energy consumption ofthe covered product; or

"(Ii) such an integrated test procedure is technically infeasible for a particular covered product,

in which case the Secretary shall prescribe a separate standby mode and offmode energy use

test procedure for the covered product, iftechnically feasible.

"(B) DEADLINES--The test procedure amendments required by subparagraph (A) shall be

prescribed in afinal rule no later than the following dates:

"(i) December 31, 2008,for battery chargers and external power supplies.

"(Ii) March 31, 2009,for clothes dryers, room air conditioners, andfluorescent lamp ballasts.

"(iii) June 30, 2009, for residential clothes washers.

"(iv) September 30, 2009,for residentialfurnaces and boilers.

"(v) March 31, 20l0,for residential water heaters, direct heating equipment, and pool heaters.

"(vi) March 31, 2011, for residential dishwashers, ranges and ovens, microwave ovens, and

dehumidifiers.

"(C) PRIOR PRODUCT STANDARDS--The test procedure amendments adopted pursuant to

subparagraph (B) shall not be used to determine compliance with product standards established

prior to the adoption ofthe amended test procedures.
"(3) INCORPORATION INTO STANDARD.

"(A) IN GENERAL.--Subject to subparagraph (8), based on the test procedures required under

paragraph (2), any final rule establishing or revising a standardfor a covered product, adopted

after July I, 2010, shall incorporate standby mode and offmode energy use into a single

amended or new standard, pursuant to subsection (0), iffeasible.

"(B) SEPARATE STANDARDS.--ljnotfeasible. the Secretary shall prescribe within the final

rule a separate standardfor standby mode and offmode energy consumption, ifjustified under

subsection (0).