US DEPARTMENT OF ENERGY 

DRAFT ISSUE PAPER 

WORKSHOP ON COMMERCIAL WATER HEATERS, BOILERS, 

. FURNACES, AIR CONDITIONERS AND HEAT PUMPS 

APRIL 14 AND 15,1998 

 EE-TP-98-101 COMMENT 02CC

US DEPARTMENT OF ENERGY 

DRAFT ISSUE PAPER 

WORKSHOP ON COMMERCIAL WATER HEATERS, BOILERS, 

FURNACES, AIR CONDITIONERS AND HEAT PUMPS 

APRIL 14 AND 15, 1998 
TEST PROTOCOLS FOR COMMERCIAL WATER HEATERS 

Introduction 

The Energy Policy Act of 1992 (EPAct) requires that commercial water heaters meet certain 

energy efficiency requirements, and that these requirements be demonstrated through the use of 

generally accepted iqdustry test procedures developed or recognized by the American Society of 

Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE), as referenced in 

ASHRAEmS Standard 90.1 and in effect on June 30, 1992. Addendum 90. lb was approved on 

January 25, 1992, and will be the version of the standard referred to when determining applicable 

test procedures for commercial water heaters. The following is a presentation of several issues 

related to the determination and application of test procedures that manufacturers are required to 

implement in order to verify conformance of commercial water heaters to EPAct energy efficiency 

standards. These issues are being presented for discussion and consideration in the development 

of a proposed rule related to commercial water heaters. 

Clarification of Coverage and Definitions 

Table 1 1.1 of ASHRAE Standard 90.1 b, hereafter referred to as Table 1 1.1, categorizes water 

heaters into three main categories of coverage: water heating equipment covered by The National 

Appliance Energy Conservation Act of 1987 (NAECA ), other water heating equipment, and 

unfired storage tanks. Water heaters are then fitrther subdivided into several subcategories 

according to basic type (e.g. storage, instantaneous and pool heater), fuel type, input rating and 

storage volume. NAECA is basically the law that sets energy efficiency requirements for 

residential appliances, whereas EPAct is geared towards commercial appliances. Excluding pool 

heaters, there are two test procedures referenced, The Department of Energy (DOE) Test 

Procedure 10 CFR, Part 430, Subpart By Appendix E which is applied to NAECA-covered 

products, and the American National Standards Institute (ANSI) test procedure for gas water 

heaters, ANSI Z21.10.3-1990, to be applied to other water heating equipment. There are no test 

procedures referenced for testing of unfired storage tanks. The scopes of coverage and 

definitions differ among EPAct, Table 1 1.1, and the referenced test procedures. These 

differences can lead to cofision when determining efficiency requirements and applicable test 

procedures for a given product. The Department is considering clarimg Table 11.1 in order to 

insure the application of the proper test procedure to commercial water heating products. The 

following section, "General Coverage Issues," addresses these coverage-related issues from a 

general perspective, and the subsections following the "General Coverage Issues" section address 

the coverage-related issues in more detail with respect to the different types of water heaters 

covered by EPAct. * 

General Coverage Issues 

The draft version of Standa~d 90.1-1989R contains Table 7.2.2, which is a revised version of 

Table 1 1.1 that appears to clarifjr many of differences among the scopes of coverage and 

definitions given in EPAct, NAECA, Table 1 1.1, and the test procedures referenced by Table 

11.1. 

* EPAct and NAECA are amendments to the Energy Policy and Conservation Act (EPCA). 

1 

 EE-TP-98-101 COMMENT 02CC

TEST PROTOCOLS FOR COMMERCIAL WATER HEATERS 

Introduction 

The Energy Policy Act of 1992 (EP Act) requires that commercial water heaters meet certain 

energy efficiency requirements, and that these requirements be demonstrated through the use of 

generally accepted iQdustry test procedures developed or recognized by the American Society of 

Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE), as referenced in 

ASHRAEIIES Standard 90.1 and in effect on June 30, 1992. Addendum 90.1b was approved on 

January 25, 1992, and will be the version of the standard referred to when determining applicable 

test procedures for commercial water heaters. The following is a presentation of several issues 

related to the determination and application of test procedures that manufacturers are required to 

implement in order to verify conformance of commercial water heaters to EP Act energy efficiency 

standards. These issues are being presented for discussion and consideration in the development 

of a proposed rule related to commercial water heaters. 

Clarification of Coverage and Definitions 

Table 11.1 of ASHRAE Standard 90.1b, hereafter referred to as Table 11.1, categorizes water 

heaters into three main categories of coverage: water heating equipment covered by The National 

Appliance Energy Conservation Act of 1987 (NAECA ), other water heating equipment, and 

unfired storage tanks. Water heaters are then further subdivided into several subcategories 

according to basic type (e.g. storage, instantaneous and pool heater), fuel type, input rating and 

storage volume. NAECA is basically the law that sets energy efficiency requirements for 

residential appliances, whereas EP Act is geared towards commercial appliances. Excluding pool 

heaters, there are two test procedures referenced, The Department of Energy (DOE) Test 

Procedure 10 CFR, Part 430, Subpart B, Appendix E which is applied to NAECA-covered 

products, and the American National Standards Institute (ANSI) test procedure for gas water 

heaters, ANSI Z21.1O.3-1990, to be applied to other water heating equipment. There are no test 

procedures referenced for testing of unfired storage tanks. The scopes of coverage and 

definitions differ among EPAct, Table 11.1, and the referenced test procedures. These 

differences can lead to confusion when determining efficiency requirements and applicable test 

procedures for a given product. The Department is considering clarifying Table 11.1 in order to 

insure the application of the proper test procedure to commercial water heating products. The 

following section, "General Coverage Issues," addresses these coverage-related issues from a 

general perspective, and the subsections following the "General Coverage Issues" section address 

the coverage-related issues in more detail with respect to the different types of water heaters 

covered by EP Act. • 

General Coverage Issues 

The draft version of Standard 90.1-1989R contains Table 7.2.2, which is a revised version of 

Table 11.1 that appears to clarify many of differences among the scopes of coverage and 

definitions given in EPAct, NAECA, Table 11.1, and the test procedures referenced by Table 

11.1. 

• EPAct and NAECA are amendments to the Energy Policy and Conservation Act (EPCA). 

1 
Questions and Request for Comment 

(1) Would it be beneficial to include a table similar in format to Table 7.2.2 of 90.1R in the 

proposed rule in order to clarifL the categories of coverage for commercial water heaters? 

(2) ANSI 221.10.3-1990 has been revised. The current version, 221.10.3-1993, contains no 

modification of the test procedures for thermal efficiency and standby loss. Should the 

reference to this test procedure in Table 11.1 be updated to the 1993 version? 

Electric Storage Water Heaters 

ANSI 221.10.3- 1990 is the test procedure required for testing of products not covered by 

NAECA. This test procedure covers gas water heaters including storage water heaters with input 

ratings above 75,000 Btulh (22 kW). Table 1 1.1 contains a footnote indicating that the test 

procedure can be applied to electric water heaters with modifications given in the footnote. Table 

11.1 does not indicate that EPAct-covered storage water heaters have input-to-volume ratios less 

than 4,000 Btu/h per gallon of storage. Furthermore, NAECA covers electric storage water 

heaters with input ratings less than or equal to 12 kW (4 1,000 Btu/h), but Table 1 1.1 does not 

indicate whether the scope of the ANSI test procedure can be lowered fiom 22 kW to 12 kW in 

order to accommodate EPAct-covered electric water heaters with input ratings between 12 and 

22 kW. 

Questions and Request for Comment 

(1) Should Table 11.1 be clarified to indicate that electric water heaters covered under the 

category of "Other Water Heating Equipment" have an input-to-volume ratio less than 

4,000 Btu/h/gal as defined by EPAct? 

(2) Is there any reason why the ANSI test procedure should not be applicable to electric 

storage water heaters with input ratings between 12 and 22 kW? 

Electric Instantaneous Water Heaters 

Electric instantaneods water heaters are not clearly itemized under the category of "Other Water 

Heating Equipment" within Table 1 1.1. Therefore, it is not immediately clear which test 

procedure applies to this category of water heaters. EPAct requires instantaneous water heaters 

with storage volumes of 10 gallons or more to have a standby loss no greater than 2.3 + 

67Measured Storage Volume (in % per hour), and makes no distinction among the fuel types. 

Note that EPAct does not require instantaneous water heaters with storage volumes less than 10 

gallons to meet standby loss requirements, only thermal efficiency requirements. Thermal 

efficiency is assumed to be equal to 98% for immersed electric heating elements; therefore, no 

thermal efficiency testing is required for this category. 

Questions and Request for Comment 

(1) Should Table 11.1 be clarified to directly address the category of electric instantaneous 

water heaters with the EPAct requirement for standby loss for instantaneous water 

heaters? 

 EE-TP-98-101 COMMENT 02CC

Questions and Request for Comment 

(1) Would it be beneficial to include a table similar in format to Table 7.2.2 of90.1R in the 

proposed rule in order to clarify the categories of coverage for commercial water heaters? 

(2) ANSI Z21.1 0.3-1990 has been revised. The current version, Z21.1 0.3-1993, contains no 

modification of the test procedures for thermal efficiency and standby loss. Should the 

reference to this test procedure in Table 11.1 be updated to the 1993 version? 

Electric Storage Water Heaters 

ANSI Z2l.1O .3-1990 is the test procedure required for testing of products not covered by 

NAECA. This test procedure covers gas water heaters including storage water heaters with input 

ratings above 75,000 Btu/h (22 kW). Table 11.1 contains a footnote indicating that the test 

procedure can be applied to electric water heaters with modifications given in the footnote. Table 

11.1 does not indicate that EPAct-covered storage water heaters have input-to-volume ratios less 

than 4,000 Btulh per gallon of storage. Furthermore, NAECA covers electric storage water 

heaters with input ratings less than or equal to 12 kW (41,000 Btulh), but Table 1l.1 does not 

indicate whether the scope of the ANSI test procedure can be lowered from 22 kW to 12 kW in 

order to accommodate EPAct-covered electric water heaters with input ratings between 12 and 

22kW. 

Questions and Request for Comment 

(1) Should Table 1l.1 be clarified to indicate that electric water heaters covered under the 

category of "Other Water Heating Equipment" have an input-to-volume ratio less than 

4,000 Btulhlgal as defined by EPAct? 

(2) Is there any reason why the ANSI test procedure should not be applicable to electric 

storage water heaters with input ratings between 12 and 22 kW? 

Electric Instantaneous Water Heaters 

Electric instantaneous water heaters are not clearly itemized under the category of "Other Water 

Heating Equipment" within Table 11.1. Therefore, it is not immediately clear which test 

procedure applies to this category of water heaters. EP Act requires instantaneous water heaters 

with storage volumes of 10 gallons or more to have a standby loss no greater than 2.3 + 

67IMeasured Storage Volume (in % per hour), and makes no distinction among the fuel types. 

Note that EPAct does not require instantaneous water heaters with storage volumes less than 10 

gallons to meet standby loss requirements, only thermal efficiency requirements. Thermal 

efficiency is assumed to be equal to 98% for immersed electric heating elements~ therefore, no 

thermal efficiency testing is required for this category. 

Questions and Request for Comment 

(1) Should Table 11.1 be clarified to directly address the category of electric instantaneous 

water heaters with the EP Act requirement for standby loss for instantaneous water 

heaters? 

2 
(2) Should Table 11.1 be clarified to indicate that the ANSI test procedure (standby loss only) 

should be applied to electric instantaneous water heaters having an input rating greater 

than 12 kW (41,000 Btu/h), an input-to-volume ratio of at least 4,000 Btu/h/gal and a 

storage volume greater than 10 gallons? 

Gas Storage Water Heaters 

NAECA provides coverage for all gas storage water heaters with input ratings less than 75,000 

Btulhour. Table 1 1.1, footnote c states additional limitations from the DOE Test Procedure. 

However, these limitations do not change the NAECA coverage as Table 1 1.1 could be 

interpreted to imply. 

Questions and Request for Comment 

(1) Should Table 11.1 be clarified to indicate that the ANSI test procedure should be applied 

only for gas storage water heaters with input ratings greater than 75,000 Btuh and an 

input-to-volqme ratio less than 4,000 BtuMgal? 

Gas Fired Instantaneous Water Heaters 

Table 1 1.1 indicates that NAECA-covered gas instantaneous water heaters are those with input 

ratings of 200,000 Btu/h or less and that the DOE Test Procedure applies. Although, the scope of 

the current DOE Test Procedure does not coincide precisely with the NAECA definition of gasfired instantaneous water heaters, NAECA coverage still applies, However, since Table 11.1 

references the DOE Test Procedure, there is some interpretation required to determine what is 

meant by NAECA-covered water heating equipment and therefore which products fall into the 

"other" category. 

What if, for example, a water heater with an input rating of 40,000 Btu/h and a storage capacity 

of 4 gallons is to be rated? The input rating is well below the 200,000 Btu/h upper limit imposed 

by NAECA, and the input to volume ratio is 10,000 Btu/h/gal., which is greater than NAECA's 

4,000 Btu/h/gal. threshold. Thus the heater would appear to fall into the category of NAECAcovered product. However, if one relies on footnote c of Table 1 1.1, this product would not be 

tested by the DOE Test Procedure; therefore, one might interpret that this product would fall in 

the category of EPAct-covered products and would be tested using the ANSI test procedure. 

Questions and Request for Comment 

(1) Should Table 1 1.1 be clarified to indicate that only gas-fired instantaneous water heaters 

with input ratings greater than 200,000 Btuh are EPAct-covered products? 

Oil Fired Instantaneous Water Heaters 

Table 1 1.1 indicates that NAECA covered oil instantaneous water heaters are those with input 

ratings of 210,000 Btu/h or less and that the DOE Test Procedure applies. The current version of 

the DOE Test Procedure does not address oil instantaneous water heaters. Although, the scope of 

the current DOE Test Procedure does not coincide precisely with the NAECA definition of oilfired instantaneous water heaters, NAECA coverage still applies. However, since Table 1 1.1 

references the DOE Test Procedure, there is some interpretation required to determine what is 

 EE-TP-98-101 COMMENT 02CC

(2) Should Table 11.1 be clarified to indicate that the ANSI test procedure (standby loss only) 

should be applied to electric instantaneous water heaters having an input rating greater 

than 12 kW (41,000 Btulh), an input-to-volume ratio of at least 4,000 Btu/h/gal and a 

storage volume greater than 10 gallons? 

Gas Storage Water Heaters 

NAECA provides coverage for all gas storage water heaters with input ratings less than 75,000 

Btu/hour. Table 11.1, footnote estates additional limitations from the DOE Test Procedure. 

However, these limitations do not change the NAECA coverage as Table 11.1 could be 

interpreted to imply. 

Questions and Request for Comment 

(1) Should Table 11.1 be clarified to indicate that the ANSI test procedure should be applied 

only for gas storage water heaters with input ratings greater than 75,000 Btulh and an 

input-to-volqme ratio less than 4,000 Btu/h/gal? 

Gas Fired Instantaneous Water Heaters 

Table 11.1 indicates that NAECA-covered gas instantaneous water heaters are those with input 

ratings of 200,000 Btulh or less and that the DOE Test Procedure applies. Although, the scope of 

the current DOE Test Procedure does not coincide precisely with the NAECA definition of gasfired instantaneous water heaters, NAECA coverage still applies. However, since Table 11.1 

references the DOE Test Procedure, there is some interpretation required to determine what is 

meant by NAECA-covered water heating equipment and therefore which products fall into the 

"other" category. 

What if, for example, a water heater with an input rating of 40,000 Btulh and a storage capacity 

of 4 gallons is to be rated? The input rating is well below the 200,000 Btulh upper limit imposed 

by NAECA, and the input to volume ratio is 10,000 Btu/h/gal., which is greater than NAECA's 

4,000 Btu/h/gal. threshold. Thus the heater would appear to fall into the category ofNAECAcovered product. However, if one relies on footnote c of Table 11.1, this product would not be 

tested by the DOE Test Procedure; therefore, one might interpret that this product would fall in 

the category ofEPAct-covered products and would be tested using the ANSI test procedure. 

Questions and Requfst for Comment 

(1) Should Table 11.1 be clarified to indicate that only gas-fired instantaneous water heaters 

with input ratings greater than 200,000 Btulh are EPAct-covered products? 

Oil Fired Instantaneous Water Heaters 

Table 11.1 indicates that NAECA covered oil instantaneous water heaters are those with input 

ratings of210,000 Btulh or less and that the DOE Test Procedure applies. The current version of 

the DOE Test Procedure does not address oil instantaneous water heaters. Although, the scope of 

the current DOE Test Procedure does not coincide precisely with the NAECA definition of oilfired instantaneous water heaters, NAECA coverage still applies. However, since Table 11.1 

references the DOE Test Procedure, there is some interpretation required to determine what is 

3 
meant by NAECA-covered water heating equipment and therefore which products fall into the 

"other" category. 

Questions and Request for Comment 

(1) Should Table 11.1 be clarified to indicate that all oil-fired instantaneous water heaters with 

input ratings greater than 210,000 Btulh are EPAct-covered products? 

Commercial Water Heater or Packaged Boiler? 

Some equipment designed to fbnction as a packaged boiler can also provide service water heating. 

In other words, the equipment could be used in place of a water heater. EPAct does not 

distinguish boilers based on their application. The energy efficiency rating required by EPAct for 

packaged boilers is combustion efficiency. The combustion efficiency rating method is quite 

different from the thermal efficiency rating method which is required for commercial water 

heaters. Boilers could be compared to commercial water heaters by implementing the commercial 

water heater test procedure 

Questions and Request for Comment 

(1) To what extent is equipment that heats water used for purposes that are different from 

those anticipated at the time of manufacture? How can EPAct efficiency requirements and 

test procedufes be applied to these products? 

(2) Should the efficiency requirements and test procedure for measuring the thermal efficiency 

of commercial water heaters be applicable to packaged boilers, if they are used for service 

water heating, in order to allow comparison between commercial packaged boilers and 

commercial water heaters? 

(3) Which test procedure, if any, should be used to test boilers as commercial water heaters? 

Standby Loss Testing and Unfired Storage Tanks 

Standby Loss Testing 

Under EPAct, some commercial water heaters and hot water storage tanks need not be tested for 

heat or standby losses. EPAct indicates that storage water heaters, instantaneous water heaters, 

and unfired hot water storage tanks do not have to meet standby loss or heat loss requirements 

specified in EPAct if they have a storage capacity of more than 140 gallons, and the tank surface 

area is thermally insulated to R-12.5 (or greater), and if a standing pilot light is not used. 

Questions and Request for Comment 

(1) Should the K-value be considered to be an "effective9' R-value which would account for 

heat losses through the insulation due to thermal bridges? 

(2) If the insulation value is to be considered an "effective" R-value, what method should be 

used to determine the "effective" R-value in order to verify whether an item is exempt 

from testing for standby loss? 

 EE-TP-98-101 COMMENT 02CC

meant by NAECA-c£)vered water heating equipment and therefore which products fall into the 

"other" category. 

Questions and Request for Comment 

(1) Should Table 11.1 be clarified to indicate that all oil-fired instantaneous water heaters with 

input ratings greater than 210,000 Btulh are EPAct-covered products? 

Commercial Water Heater or Packaged Boiler? 

Some equipment designed to function as a packaged boiler can also provide service water heating. 

In other words, the equipment could be used in place of a water heater. EP Act does not 

distinguish boilers based on their application. The energy efficiency rating required by EPAct for 

packaged boilers is combustion efficiency. The combustion efficiency rating method is quite 

different from the thermal efficiency rating method which is required for commercial water 

heaters. Boilers could be compared to commercial water heaters by implementing the commercial 

water heater test procedure 

Questions and Request for Comment 

(1) To what extent is equipment that heats water used for purposes that are different from 

those anticipated at the time of manufacture? How can EP Act efficiency requirements and 

test procedures be applied to these products? 

(2) Should the efficiency requirements and test procedure for measuring the thermal efficiency 

of commercial water heaters be applicable to packaged boilers, if they are used for service 

water heating, in order to allow comparison between commercial packaged boilers and 

commercial water heaters? 

(3) Which test procedure, if any, should be used to test boilers as commercial water heaters? 

Standby Loss Testing and Unfired Storage Tanks 

Standby Loss Testing 

Under EP Act, some commercial water heaters and hot water storage tanks need not be tested for 

heat or standby losses. EP Act indicates that storage water heaters, instantaneous water heaters, 

and unfired hot water storage tanks do not have to meet standby loss or heat loss requirements 

specified in EP Act if they have a storage capacity of more than 140 gallons, and the tank surface 

area is thermally insulated to R-12.5 (or greater), and if a standing pilot light is not used. 

Questions and Request for Comment 

(1) Should the R:'value be considered to be an "effective" R-value which would account for 

heat losses through the insulation due to thermal bridges? 

(2) If the insulation value is to be considered an "effective" R-value, what method should be 

used to determine the "effective" R-value in order to verify whether an item is exempt 

from testing for standby loss? 

4 
Unfired Storage Tanks 

EPAct requires unfired hot water storage tanks with volumes less than or equal to 140 gallons 

and having a tank surface area that is insulated to less than R-12.5 to exhibit a heat loss rate not 

to exceed 6.5 Btu/h per square foot of tank surface area. Table 11.1 does not reference a test 

procedure to determine this heat loss rate. There do not appear to be any test procedures 

currently available t6at address the testing of unfired hot water storage tanks to determine the rate 

of heat loss per unit of tank surface area. However, the revision of AS- Standard 1 18.1- 

1993R (review draft) contains a method for testing water heating equipment with continuously 

operating pumps that might be applied to unfired storage tanks to determine rate of heat loss. 

Questions and Request for Comment 

(1) What test procedures are available for use in determining the rate of heat loss per square 

foot of tank surface area? 

(2) If procedures are available, which should DOE require? If not, is a new procedure needed? 

 EE-TP-98-101 COMMENT 02CC

Unfired Storage Tanks 

EP Act requires unfired hot water storage tanks with volumes less than or equal to 140 gallons 

and having a tank surface area that is insulated to less than R-12.5 to exhibit a heat loss rate not 

to exceed 6.5 Btulh per square foot of tank surface area. Table 11.1 does not reference a test 

procedure to determine this heat loss rate. There do not appear to be any test procedures e 

currently available that address the testing of unfired hot water storage tanks to determine the rate 

of heat loss per unit of tank surface area. However, the revision of ASHRAE Standard 118.1-

1993R (review draft) contains a method for testing water heating equipment with continuously 

operating pumps that might be applied to unfired storage tanks to determine rate of heat loss. 

Questions and Request for Comment 

(1) What test procedures are available for use in determining the rate of heat loss per square 

foot of tank surface area? 

(2) Ifprocedures are available, which should DOE require? Ifnot, is a new procedure needed? 

5 
ASHRAE STANDARD 90.1 b, TABLE 11.1 - Minimum Performance of Water Heating Equipment 

'For detailed references see Section 14. 

b~onsistent with National Appliance Energy Conservation Act (NAECA) of 1987. 

'DOE Test Procedures apply to electric and gas storage water heaters with rated volumes 220 gallons and gas instantaneous water heaters with 

input ratings of 50,000 to 200,000 Btuh. 

d~ll except those water heaters covered by NAECA. 

'When testing an electric storage water heater for standby loss using the test procedures of Section 2.9 of 221.10.3-1990~~, the electrical supply 

voltage shall be maintained within f 1% of the center of the voltage range specified on the water heater nameplate. Also, when needed for 

calculations, the thermal efficiency (Et) shall be 98%. 

When testing an oil water heater using the test procedures of Section 2.8 and 2.9 of 221.10.3-1990~~, the following modifications will be made: 

A vertical length of flue pipe shall be connected to the flue gas outlet of sufficient height to establish the minimum draft specified in the 

manufacturer's installation instructions. All measurements of oil consumption will be taken by instruments with an accuracy of f 1% or 

better. 

The burner rate shall be adjusted to achieve an hourly Btu input rate within G!% of the manufacturer's specified input rate with the CO2 

reading as specified by the manufacturer with smoke no greater than I and the fuel pump pressure within f 1% of the manufacturer's 

specification. f Heat loss of tank surface area (~tulft~) based on 80°F water-air temperature difference. 

'V is rated storage volume in gallons as specified by the manufacturer. 

h VT is the storage volume in gallons as measured during the test to determine standby loss. VT may differ from V, but it is within tolerances 

allowed by the applicable 221 and UL standards. Accordingly, for the purpose of estimating the standby loss requirement using the rated volume 

shown on the rating plate, VT should be concerned as no less than 0.95V for gas and oil water heaters and no less than 0.90V for electric water 

Thermal 

Efficiency 

E& 

278 

2 78 

r 78 

r 80 

2 77 

Standby Loss 

(%1hrjh 

50.30+27NT 

11 .3+114N~ 

21 .3+95NT 

-- 

12.3+67N~ 

16.5 ~tuhlft~ 

Note f 

Test 

Methoda 

DOE Test 

Procedure 10 

CFR, 

Part 4302 

ANSI 221.56 

1989@ 

ANSI 

221.10.3 

1 990~~~~ 

Category 

NAECA 

Covered 

Water 

Heating 

~~ui~t~ 

Other 

Water 

Heating 

equipt 

Unfired 

Storage 

Tanks 

vTh 

allc 

allC 

all 

all 

all 

all 

all 

all 

all 

< 10 

210 

all 

Energy 

~acto? 

r0.93-0.00132V 

20.62-0.0019V 

20.62-0.0019V 

20.59-0.0019V 

20.59-0.0019V 

Input to 

VT Ratio 

(rntuhl 

< 4,000 

< 4,000 

24,000 

24,000 

Type 

all 

storage 

instantaneous 

storage 

instantaneous 

pool heater 

storage 

storage1 

instantaneous 

Fuel 

electric 

gas 

gas 

oil 

oil 

gasloil 

electric 

gasloil 

Input Rating 

5 12 kW 

175,000 Btuh 

~00,000 ~t~h~ 

51 05,000 Btuh 

1210,000 Btuh 

all 

1155,000 Btuh 

>I 55,000 Btuh 

 EE-TP-98-101 COMMENT 02CC

ASH RAE STANDARD 90 1 b, TABLE 11.1 - Minimum Performance of Water Heating Equipment 

Category Type 

NAECA all 

Covered 

Water 

Heating 

EquiptD 

Other 

Water 

Heatin~ 

equipt 

Unfired 

Storage 

Tanks 

storage 

instantaneous 

storage 

instantaneous 

pool heater 

storage 

storage/ 

instantaneous 

Fuel 

electric 

gas 

gas 

oil 

oil 

Input Rating 

::;;12kW 

::;;75,000 Btuh 

::;;200,000 BtuhC 

::;;105,000 Btuh 

::;;210,000 Btuh 

gas/oil all 

electric all 

gas/oil ::;;155,000 Btuh 

>155,000 Btuh 

. aFor detailed references see Section 14. 

alf 

allc 

all 

all 

all 

all 

all 

all 

all 

< 10 

~ 10 

all 

Input to 

VT Ratio 

(Btuh/gal)h 

< 4,000 

< 4,000 

~ 4,000 

~ 4,000 

Test 

Methoda Energy 

Factor!' 

DOE Test ~0.93-0.00132V 

Procedure 10 ~0.62-0.0019V 

CFR, 2 ~0.62-0.0019V 

Part 430 ~0.59-0.0019V 

ANSI Z21.56 

198966 

ANSI 

Z21.10.3 

199065,e 

~0.59-0.0019V 

bConsistent with National Appliance Energy Conservation Act (NAECA) of 1987. 

Thermal 

Efficiency 

Et% 

~78 

~78 

~ 78 

~80 

~77 

Standby Loss 

(%/hr)h 

::;;0.30+27NT 

::;;1.3+114NT 

::;;1.3+95NT 

::;;2.3+67NT 

::;;6.5 Btuhm' 

Note f 

cDOE Test Procedures apply to electric and gas storage water heaters with rated volumes ~O gallons and gas instantaneous water heaters with 

input ratings of 50,000 to 200,000 Btuh. 

d All except those water heaters covered by NAECA. 

ewhen testing an electric storage water heater for standby loss using the test procedures of Section 2.9 of Z21.10.3-199065, the electrical supply 

voltage shall be maintained within ±1 % of the center of the voltage range specified on the water heater nameplate. Also, when needed for 

calculations, the thermal efficiency (Et) shall be 98%. . 

When testing an oil water heater using the test procedures of Section 2.8 and 2.9 of Z21.10.3-199065, the following modifications will be made: 

A vertical length of flue pipe shall be connected to the flue gas outlet of sufficient height to establish the minimum draft specified in the 

manufacturer's installation instructions. All measurements of oil consumption will be taken by instruments with an accuracy of ±1 % or 

better. 

The burner rate shall be adjusted to achieve an hourly Btu input rate within ±2% of the manufacturer's specified input rate with the CO2 

reading as specified by the manufacturer with smoke no greater than 1 and the fuel pump pressure within ±1 % of the manufacturer's 

specification. 

fHeat loss of tank surface area (Btu/ft2) based on 80°F water-air temperature difference. 

gv is rated storage volume in gallons as specified by the manufacturer. 

hVT is the storage volume in gallons as measured during the test to determine standby loss. VT may differ from V, but it is within tolerances 

allowed by the applicable Z21 and UL standards. Accordingly, for the purpose of estimating the standby loss requirement using the rated volume 

shown on the rating plate, VT should be concerned as no less than 0.95V for gas and oil water heaters and no less than 0.90V for electric water 

heaters. 
TEST PROTOCOLS FOR COMMERCIAL BOILERS AND FURNACES 

Introduction 

EPACT-1992 referenced ASHRAE Standard 90.1-1989 for the test procedures to be used for the 

determination of the energy efficiency standards for commercial space heating equipment 

including packaged steam and hot water boilers and warm air furnaces. ASHRAE/IES Standard 

90.1-1989 in turn referenced four industry test standards for gas-fired boilers with input greater 

than 300,000 Btu/h, and three test standards for oil-fired boilers with input greater than 300,000 

Btu/h. For warm air furnaces with input capacity equal to or greater than 225,000 Btu/h, 

Addendum 90.1i-1993 to ASHRAliT 90.1-1 989 referenced one standard for gas-fired furnaces and 

one standard for oil-fired furnaces. The specifications for energy performance tests in those 

referenced standards are in most cases similar to each other. However, there are some differences 

with respect to test set-up, test procedure, test conditions and calculation procedures in the four 

referenced standards for gas-fired boilers and the three referenced standards for oil-fired boilers. 

Because of the differences in the test specifications, a boiler tested by these different test 

standards may produce different efficiency values. The difference may be minor but may also be 

significant. A review of those differences is presented below to facilitate discussion of the issues. 

Another issue that needs discussion concerns the size of the boilers to be covered by a DOE test 

procedure. While an upper limit was specified in EPCA for residential central furnaces and boilers, 

EPACT does not specify an upper limit for commercial boilers and furnaces. Comments and 

suggestions are requested from this workshop in helping DOE at developing appropriate DOE 

test and rating procedures that can be applied to equipment without conflicting requirements fiom 

different standards. This would allow for a consistent and equitable comparison among equipment 

using the same type of fuel or using different types of fuels. 

Definition of "Packaged Boiler" 

EPACT specifies coverage for packaged boiler and defines it as "a boiler that is shipped complete 

with heating equipment, mechanical draft equipment, and automatic controls; usually shipped in 

one or more sections," but the statute does not specify an upper limit for its capacity. (EPACT 

Sec. 122(a)(3)(1 l)(B)). Several existing industry standards and conventions address the definition 

in different ways. 

Hydronics Institute Standard-1989 defines packaged boiler as "a boiler-burner unit factory 

assembled and wired," and HI'S Directory of I=B=R ratings lists boilers with gross output up 

to 13.5 million Btu/h. 

UL 726-1995 (Sec.5) defines "boiler assembly" for oil-fired boilers as "factory-built and shall 

include all the essential components necessary for its normal function as intended, and may be 

shipped as two or more major subassemblies." UL 726 does not specify a capacity limit. (This 

is similar to EPACT.) 

ANSI 221.13- 1993a has no definition for packaged boiler, but ANSI 221.13 limits coverage 

for gas-fired boilers to less than 12.5 million Btu/h. 

ASME PTC4.1 covers all types of steam boilers with no size limit. 

 EE-TP-98-101 COMMENT 02CC

TEST PROTOCOLS FOR COMMERCIAL BOILERS AND FURNACES 

Introduction 

EPACT-1992 referenced ASHRAE Standard 90.1-1989 for the test procedures to be used for the 

determination of the energy efficiency standards for commercial space heating equipment 

including packaged stearn and hot water boilers and warm air furnaces. ASHRAEIIES Standard 

90.1-1989 in tum referenced four industry test standards for gas-fired boilers with input greater 

than 300,000 Btulh, and three test standards for oil-fired boilers with input greater than 300,000 

Btulh. For warm air furnaces with input capacity equal to or greater than 225,000 Btulh, 

Addendum 90.li-1993 to ASHRAE 90.1-1989 referenced one standard for gas-fired furnaces and 

one standard for oil-fired furnaces. The specifications for energy performance tests in those 

referenced standards are in most cases similar to each other. However, there are some differences 

with respect to test set-up, test procedure, test conditions and calculation procedures in the four 

referenced standards for gas-fired boilers and the three referenced standards for oil-fired boilers. 

Because of the differences in the test specifications, a boiler tested by these different test 

standards may produce different efficiency values. The difference may be minor but may also be 

significant. A review of those differences is presented below to facilitate discussion of the issues. 

Another issue that n~eds discussion concerns the size of the boilers to be covered by a DOE test 

procedure. While an upper limit was specified in EPCA for residential central furnaces and boilers, 

EP ACT does not specifY an upper limit for commercial boilers and furnaces. Comments and 

suggestions are requested from this workshop in helping DOE at developing appropriate DOE 

test and rating procedures that can be applied to equipment without conflicting requirements from 

different standards. This would allow for a consistent and equitable comparison among equipment 

using the same type of fuel or using different types of fuels. 

Definition of "Packaged Boiler" 

EP ACT specifies coverage for packaged boiler and defines it as "a boiler that is shipped complete 

with heating equipment, mechanical draft equipment, and automatic controls; usually shipped in 

one or more sections," but the statute does not specifY an upper limit for its capacity. (EPACT 

Sec. 122(a)(3)(11)(B». Several existing industry standards and conventions address the definition 

in different ways. 

• Hydronics Institute Standard-1989 defines packaged boiler as "a boiler-burner unit factory 

assembled and wired," and HI's Directory ofI=B=R ratings lists boilers with gross output up 

to 13.5 million Btulh. 

• UL 726-1995 (Sec.5) defines "boiler assembly" for oil-fired boilers as "factory-built and shall 

include all the essential components necessary for its normal function as intended, and may be 

shipped as two or more major subassemblies." UL 726 does not specifY a capacity limit. (This 

is similar to EPACT.) 

• ANSI Z21.13-1993a has no definition for packaged boiler, but ANSI Z21.13 limits coverage 

for gas-fired boilers to less than 12.5 million Btulh. 

• ASME PTC4.1 covers all types of steam boilers with no size limit. 

7 
Questions and Request for Comments: 

(1) Is the EPACTYs definition for packaged boiler clear enough? To what extent, if any, are 

custom-designed, field-assembled boilers excluded? Is a size limit implicit in the definition 

of "commercial packaged boiler," and if so what is the maximum capacity? 

Thermal vs. Combustion Efficiency; Jacket Losses 

EPACT defines efficiency in terms of combustion efficiency for boilers and thermal efficiency for 

furnaces. In general, Errjrt = EmC - LJ, where Errjrt is the thermal efficiency based on inputoutput method, EQC is the combustion efficiency based on flue loss method, and LJ is the jacket 

loss. Existing industry standards address these efficiencies in different ways. 

Hydronics Institute Standard-1989 contains test methods for both thermal efficiency (called 

overall efficiency) and combustion efficiency for boilers. It does not give a test method for 

jacket loss. HI'S rating directory lists only combustion efficiencies. 

ANSI 22 1.13- 1993a specifies combustion efficiency for gas-fired indoor boilers and thermal 

efficiency for outdoor boilers. It has a method for flue loss calculation but no method for a 

jacket loss test. 

UL 726-1995 spkcifies a performance test method (by flue loss) for oil-fired boilers but no 

method for calculating flue losses to obtain combustion efficiency values. 

ASME PTC4.1 has detailed tests and calculation methods to ascertain both thermal efficiency 

and combustion efficiency for steam boilers. They include the parasitic electric energy 

consumption as an input in the efficiency calculation and provide a default graph for jacket 

losses, as well as a method for jacket loss testing if preferred. 

Furnaces 

ANSI 22 1.47- 1993 names its section on efficiency testing for gas-fired &maces as "thermal 

efficiency," but the calculation is by flue loss method. Therefore, the thermal efficiency is 

equivalent to combustion efficiency. It describes methods for both flue loss calculation and 

jacket loss testing, but the jacket loss is not used in its thermal efficiency formula. 

UL 727-1994 contains a performance test method (by flue loss) for oil-fired furnaces, but no 

methods for flue loss calculation nor for jacket loss testing to obtain an efficiency value. 

Questions and Request for Comments: 

(1) Efficiency: (1) In cases where EPACT specifies thermal efficiency and ASHRAE 90.1 test 

procedures listed in ASHRAE 90.1 measure combustion efficiency, should DOE require a 

procedure to measure thermal efficiency directly, or should it specifl a method for 

correcting combustion efficiencies with jacket losses to obtain thermal efficiencies? (2) If a 

8 

 EE-TP-98-101 COMMENT 02CC

Questions and Request for Comments: 

(1) Is the EPACT's definition for packaged boiler clear enough? To what extent, ifany, are 

custom-designed, field-assembled boilers excluded? Is a size limit implicit in the definition 

of "commercial packaged boiler," and if so what is the maximum capacity? 

Thermal VS. Combustion Efficiency; Jacket Losses 

EP ACT defines efficiency in terms of combustion efficiency for boilers and thermal efficiency for 

furnaces. In general, Effyt = Effyc - LJ , where Effyt is the thermal efficiency based on inputoutput method, Effyc is the combustion efficiency based on flue loss method, and LJ is the jacket 

loss. Existing industry standards address these efficiencies in different ways. 

Boilers 

• Hydronics Institute Standard-1989 contains test methods for both thermal efficiency (called 

overall efficiency) and combustion efficiency for boilers. It does not give a test method for 

jacket loss. HI's rating directory lists only combustion efficiencies. 

• ANSI Z21.13-1993a specifies combustion efficiency for gas-fired indoor boilers and thermal 

efficiency for outdoor boilers. It has a method for flue loss calculation but no method for a 

jacket loss test. 

• UL 726-1995 specifies a performance test method (by flue loss) for oil-fired boilers but no 

method for calculating flue losses to obtain combustion efficiency values. 

• ASME PTC4.1 has detailed tests and calculation methods to ascertain both thermal efficiency 

and combustion efficiency for steam boilers. They include the parasitic electric energy 

consumption as an input in the efficiency calculation and provide a default graph for jacket 

losses, as well as a method for jacket loss testing if preferred. 

Furnaces 

• ANSI Z21.47-1993 names its section on efficiency testing for gas-fired furnaces as "thermal 

efficiency," but the calculation is by flue loss method. Therefore, the thermal efficiency is 

equivalent to combustion efficiency. It describes methods for both flue loss calculation and 

jacket loss testing, but the jacket loss is not used in its thermal efficiency formula. 

• UL 727-1994 contains a performance test method (by flue loss) for oil-fired furnaces, but no 

methods for flue loss calculation nor for jacket loss testing to obtain an efficiency value. 

Questions and Requ~st for Comments: 

(1) Efficiency: (1) In cases 'where EPACT specifies thermal efficiency and ASHRAE 90.1 test 

procedures listed in ASHRAE 90.1 measure combustion efficiency, should DOE require a 

procedure to measure thermal efficiency directly, or should it specify a method for 

correcting combustion efficiencies with jacket losses to obtain thermal efficiencies? (2) If a 

8 
jacket loss correction is called for, does this loss actually exist in the case of indoor 

equipment? (3) ASME PTC4.1 includes parasitic .electric energy in its efficiency 

calculation. Should parasitic electric energy be considered in combustion efficiency or 

thermal efficiency calculations? (4) As the term is generally used for furnaces, is "thermal 

efficiency" taken in practice to mean the same thing as combustion efficiency, as suggested 

by ANSI 221.47-1993? 

(2) Jacket Loss: Not all the ASHRAE 90.1-1989 referenced test standards include test and 

calculation methods for jacket loss. ASME PTC 4.1 provides a graph for jacket loss and a 

test method also. ANSI Z21.47 provides test procedure. (1) If a jacket loss term is 

needed, should a single method be selected for jacket loss test for both boilers and 

furnaces? (2) Should laboratory test results be adjusted to (average ?) outdoor 

conditions? 

Uniformity of Test Conditions, Test Setup, and Procedures 

EPACT references ASHRAE 90.1 - 1989 for test methods. ASHRAE 90.1 - 1989, Addendum 

90.1 i- 1993, and the public review version 90.1R reference several industrial test standards that 

specie different test conditions and test setups, including type of fuel to be used, tolerance on 

input rate, input inlet and outlet water temperatures, instrumentation for temperature 

measurement, specifications for flue pipe length and insulation, and length of steady state testing 

period. The following table lists some of the differences: 

Boilers 

Item 

Applicability 

Test fiiel specification 

Heat input rate 

Duration of steady state 

test 

Inlet water temp. 

Outlet water temp. 

c 

Water temp. rise (At) 

Flue gas temp. 

ANSI 221.13 

Gas Fuel 

By 

manufacturer 

+I- 2% rated 

Not specified 

80F +/-I0 F 

180F+/-2F 

100 F 

Average of 9 

traverse 

Vertical flue length 

HI Std-1989 

Gas or Oil 

#2 or 4,5,6 fuel 

oil 

100-105% rated 

30 min. 

- 

200F 

120F to 165 F 

9 Thermocouple 

grid 

Horizontal flue length 

Vent insulation to test 

plane 

UL 726-95 

Oil fuel 

Non-residue 

fuel oil 

+/- 2% rated 

45 min. 

- 

+I- 2 F 

- 

Average of 9 

traverse 

2 ft. (if <400 

kI3tu/h) 

Uninsulated 

ASME PTC4.1 

Steam Prod. 

By manufacturer 

Rated 

2 runs, 4 hrs. 

each 

- 

Not less than 200 

F 

- 

Average 

Traverse 

2 ft. (if vertical 

outlet) 

R7 Insulation 

- 

Uninsulated 

- 

- 

 EE-TP-98-101 COMMENT 02CC

jacket loss correction is called for, does this loss actually exist in the case of indoor 

equipment? (3) ASME PTC4.1 includes parasitic.electric energy in its efficiency 

calculation. Should parasitic electric energy be considered in combustion efficiency or 

thermal efficiency calculations? (4) As the term is generally used for furnaces, is "thermal 

efficiency" taken in practice to mean the same thing as combustion efficiency, as suggested 

by ANSI Z21.47-1993? 

(2) Jacket Loss: Not all the ASHRAE 90.1-1989 referenced test standards include test and 

calculation methods for jacket loss. ASME PTC 4.1 provides a graph for jacket loss and a 

test method also. ANSI Z21.47 provides test procedure. (1) Ifajacket loss term is 

needed, should a single method be selected for jacket loss test for both boilers and 

furnaces? (2) Should laboratory test results be adjusted to (average ?) outdoor 

conditions? 

Uniformity of Test Conditions, Test Setup, and Procedures 

EPACT references ASHRAE 90.1-1989 for test methods. ASHRAE 90.1-1989, Addendum 

90.1 i-1993, and the public review version 90.1 R reference several industrial test standards that 

specifY different test conditions and test setups, including type of fuel to be used, tolerance on 

input rate, input inlet and outlet water temperatures, instrumentation for temperature 

measurement, specifications for flue pipe length and insulation, and length of steady state testing 

period. The following table lists some ofthe differences: 

Boilers 

Item ANSIZ21.13 HI Std-1989 UL 726-95 ASME PTC4.1 

Applicability Gas Fuel Gas or Oil Oil fuel Steam Prod. 

Test fuel specification By #2 or 4,5,6 fuel Non-residue By manufacturer 

manufacturer oil fuel oil 

Heat input rate +/- 2% rated 100-105% rated +/- 2% rated Rated 

Duration of steady state Not specified 30 min. 45 min. 2 runs, 4 hrs. 

test each 

Inlet water temp. 80F +/-10 F - - - Outlet water temp. 180F+/-2F 200F +/- 2F Not less than 200 

F 

VVatertemp. rise (At) 100F 120Fto165F - - Flue gas temp. Average of9 9 Thermocouple Average of9 Average 

traverse grid traverse Traverse 

Vertical flue length 5 ft'/4 ft. 2ft 5 ft./3ft. - (>400kBtulh) (if horizontal (direct vent) 

outlet) 

Horizontal flue length 2 ft. (if <400 2 ft. (if vertical - - kBtulh) outlet) 

Vent insulation to test Uninsulated R 7 Insulation Uninsulated - plane 

9 
Furnaces 

Questions and Request for Comments: 

Item 

Test fuel specification 

Heat input rate 

Duration of steady-state test 

Flue gas temp. 

Vertical flue length 

Flue insulation , 

(1) Besides the ones listed in the above table, there are other minor differences among the 

various test standards. In cases where more than one procedure is applicable to the same 

product, do the different procedures yield the same result? If not, which procedure is the 

sounder in each instance? 

(2) Once final action is taken on proposed ASHRAE standard 90. lR, DOE may be called 

upon to consider adopting the new version. That would raise the question of whether for 

comparison purposes, DOE would want to have a uniform test standard. Should uniform 

test conditions be adopted for boiler test procedures? If so, should the basis a single 

standard or a compromise of the four referenced standards? Should one single set of 

boiler water inlet and outlet temperatures under steady state condition be specified? And 

what should be their values? Consideration of a more uniform standard may also raise the 

following additional questions: 

ANSI 221.47 (Gas) 

By manufacturer 

Rated +I- 2% 

30 min. 

Average of 9 traverse 

5R. 6 in. 

Uninsulated 

a) UL 727 (for oil-fired furnaces) has no flue loss calculation procedure. Should 

procedure specified in HI Std-1989 (for oil-fired boilers) be adopted for oil-fired furnaces? 

IJL 727-1994 (Oil) 

By manufacturer 

Rated +I- 2% 

45 min. 

Single thermocouple at center 

No less than 2 R. 

Uninsulated 

b) For flue gas temperature measurement, should a 9-thermocouple grid be an option 

instead of the single temperature sensor measured successively at 9 points? 

c) All referenced standards except HI Std-1989 specifL test flue pipe without insulation. 

To obtain a more accurate flue gas temperature for the flue loss method, should insulation 

of the flue pipe up to the temperature measurement plane be required ? 

Provisions for Unusual Design Features 

Some boilers are designed for low water temperature applications such as for radiant floor 

heating. Some are offered for both high and low temperature applications. Some gas-fired 

boilers are condensing boilers. Modular boilers are sold as a packaged boiler. Some boilers and 

fbrnaces are of the modulating type where ASHRAE 90.1-1989 specifies efficiency ratings at both 

the maximum and the minimum firing rates. Some boilers are for both hot water and steam 

applications. 

 EE-TP-98-101 COMMENT 02CC

Furnaces 

Item ANSI Z21.47 (Gas) UL 727-1994 (Oil) 

Test fuel specification By manufacturer By manufacturer 

Heat input rate Rated +/- 2% Rated +/- 2% 

Duration of steady-state test 30 min. 45 min. 

Flue gas temp. Average of 9 traverse Single thermocouple at center 

Vertical flue length 5ft. 6 in. No less than 2 ft. 

Flue insulation " Uninsulated Uninsulated 

Questions and Request for Comments: 

(1) Besides the ones listed in the above table, there are other minor differences among the 

various test standards. In cases where more than one procedure is applicable to the same 

product, do the different procedures yield the same result? If not, which procedure is the 

sounder in each instance? 

(2) Once final action is taken on proposed ASHRAE standard 90.1R, DOE may be called 

upon to consider adopting the new version. That would raise the question of whether for 

comparison purposes, DOE would want to have a uniform test standard. Should uniform 

test conditions be adopted for boiler test procedures? If so, should the basis a single 

standard or a compromise of the four referenced standards? Should one single set of 

boiler water inlet and outlet temperatures under steady state condition be specified? And 

what should be their values? Consideration of a more uniform standard may also raise the 

following additional questions: 

a) UL 727 (fur oil-fired furnaces) has no flue loss calculation procedure. Should 

procedure specified in HI Std-1989 (for oil-fired boilers) be adopted for oil-fired furnaces? 

b) For flue gas temperature measurement, should a 9-thermocouple grid be an option 

instead of the single temperature sensor measured successively at 9 points? 

c) All referenced standards except HI Std-1989 specify test flue pipe without insulation. 

To obtain a more accurate flue gas temperature for the flue loss method, should insulation 

of the flue pipe up to the temperature measurement plane be required ? 

Provisions for Unusual Design Features 

Some boilers are designed for low water temperature applications such as for radiant floor 

heating. Some are offered for both high and low temperature applications. Some gas-fired 

boilers are condensing boilers. Modular boilers are sold as a packaged boiler. Some boilers and 

furnaces are of the modulating type where ASHRAE 90.1-1989 specifies efficiency ratings at both 

the maximum and the minimum firing rates. Some boilers are for both hot water and steam 

applications. 

" 

10 
Questions and Request for Comments: 

(1) Should two test conditions with respect to water inlet and outlet temperatures be specified 

for hot water boilers for high temperature and low temperature applications ? 

(2) None of the referenced test standards specie test procedure for condensing 

boilerslfbmaces. Should test procedure for condensate measurement be developed for 

condensing boilers and fbrnaces ? If so, should procedure in ASHRAE 103-1 993 be 

considered/adopted ? 

(3) Should DOE adopt the two rating conditions (at the maximum and the minimum input 

rates) for modulating boilerslfi~maces as specified in ASHRAE 90.1-1 989 ? 

(4) Should a single boiler be tested for a modular boiler package ? 

e 

(5) Should a hot waterlsteam boiler be tested on steam only ? 

 EE-TP-98-101 COMMENT 02CC

Questions and Request for Comments: 

(1) Should two test conditions with respect to water inlet and outlet temperatures be specified 

for hot water boilers for high temperature and low temperature applications? 

(2) None of the referenced test standards specify test procedure for condensing 

boilers/furnaces. Should test procedure for condensate measurement be developed for 

condensing boilers and furnaces? If so, should procedure in ASHRAE 103-1993 be 

considered/adopted? 

(3) Should DOE adopt the two rating conditions (at the maximum and the minimum input 

rates) for modulating boilers/furnaces as specified in ASHRAE 90.1-1989 ? 

(4) Should a single boiler be tested for a modular boiler package? 

.. (5) Should a hot water/steam boiler be tested on steam only? 

11 
TEST PROTOCOLS FOR COMMERCIAL AIR CONDITIONERS AND HEAT PUMPS 

Introduction 

The Energy Policy Act of 1992 (EPAct) requires that commercial air conditioners and heat pumps 

meet certain energy efficiency requirements and that these requirements be demonstrated through 

the use of generally accepted industry test procedures developed or recognized by ASHRAE. The 

. relevant Air-conditioning and Refrigeration Institute test procedures referenced in ASHRAE 

Standard 90.1 appear generally unambiguous and straightforward, with the possible exception of 

the treatment of external static pressure requirements for testing these products. 

Minimum External Static Pressure Requirement 

According to ARI standards referenced in ASHRAE 90.1 applicable to small and large 

commercial package air conditioning and heating equipment, systems with indoor fans intended 

for use with field-installed ducts shall be tested when operating against the minimum external 

static pressure specified in these standards. The minimum external static pressure is prescribed in 

a table listing different levels of external resistance depending on system capacity; larger values of 

minimum external resistance are prescribed for larger-capacity systems on the assumption that 

larger systems are connected to longer duct systems with more bends and other flow obstructions. 

Critics have observed that external static pressures specified by the ARI are lower than generally 

encountered in commercial buildings, potentially leading to an overstated efficiency rating. Others 

counter that the present procedure is adequate for the purpose of comparing products relative to 

one another, and a change would be unnecessarily burdensome. 

The topic of the minimum external static pressure requirement was brought up in written 

comments at the occasion of DOE'S September 25, 1997 workshop on Residential Central Air 

Conditioner and Heat Pump Test Procedures. At that time a decision was made to leave the 

minimum external static pressure requirement unchanged with possible reconsideration of this 

issue at the time of adoption by the U.S. of the applicable IS0 Standard. 

DOE would like to obtain comments on the minimum external resistance required for small and 

large commercial package air conditioning and heat pump systems. 

Questions and Request for Comments: 

(1) Is the minimum external resistance specified in ARI standards for commercial air 

conditioning and heating equipment representative of the resistance experienced in the 

field, and if not, what are the appropriate resistance values? 

(2) Does the prelent ARI standards introduce an error, and if so, how significant is the error? 

 EE-TP-98-101 COMMENT 02CC

TEST PROTOCOLS FOR COMMERCIAL AIR CONDITIONERS AND HEAT PUMPS 

Introduction 

The Energy Policy Act of 1992 (EP Act) requires that commercial air conditioners and heat pumps 

meet certain energy efficiency requirements and that these requirements be demonstrated through 

the use of generally accepted industry test procedures developed or recognized by ASHRAE. The 

relevant Air-conditioning and Refrigeration Institute test procedures referenced in ASHRAE 

Standard 90.1 appear generally unambiguous and straightforward, with the possible exception of 

the treatment of external static pressure requirements for testing these products. 

Minimum External Static Pressure Requirement 

According to ARI standards referenced in ASHRAE 90.1 applicable to small and large 

commercial package air conditioning and heating equipment, systems with indoor fans intended 

for use with field-installed ducts shall be tested when operating against the minimum external 

static pressure specified in these standards. The minimum external static pressure is prescribed in 

a table listing different levels of external resistance depending on system capacity; larger values of 

minimum external resistance are prescribed for larger-capacity systems on the assumption that 

larger systems are connected to longer duct systems with more bends and other flow obstructions. 

Critics have observer! that external static pressures specified by the ARI are lower than generally 

encountered in commercial buildings, potentially leading to an overstated efficiency rating. Others 

counter that the present procedure is adequate for the purpose of comparing products relative to 

one another, and a change would be unnecessarily burdensome. 

The topic of the minimum external static pressure requirement was brought up in written 

comments at the occasion of DOE's September 25, 1997 workshop on Residential Central Air 

Conditioner and Heat Pump Test Procedures. At that time a decision was made to leave the 

minimum external static pressure requirement unchanged with possible reconsideration of this 

issue at the time of adoption by the U. S. of the applicable ISO Standard. 

DOE would like to obtain comments on the minimum external resistance required for small and 

large commercial package air conditioning and heat pump systems. 

Questions and Request for Comments: 

(1) Is the minimum external resistance specified in ARI standards for commercial air 

conditioning and heating equipment representative of the resistance experienced in the 

field, and if not, what are the appropriate resistance values? 

(2) Does the pre~ent ARI standards introduce an error, and if so, how significant is the error? 

12 
SAMPLING, CERTIFICATION AND ENFORCEMENT 

Introduction 

DOE is seeking to establish sampling regimes for compliance certification and enforcement that 

strike an appropriate"balance between cost and reliability. In order to promote the efficient use of 

energy, and to protect the interest of the users of the covered equipment, compliance certification 

seeks to provide the maximum possible assurance that the efficiency of the covered products 

meets the mandated minimum standards. From a statistical viewpoint, it is impossible to ensure 

with 100 percent confidence that the energy efficiency of any basic model actually meets the 

minimum standard unless the entire population is tested. This being impractical, a subset of the 

population is typically tested, and the performance of the general population is estimated based 

upon the sample results, using statistically-based methods. 

Compliance testing and certification is conducted initially with respect to all covered products and 

then prior to the introduction of new covered products into the marketplace. Enforcement testing 

is that which is conducted in response to a claim that a particular covered product which has been 

certified to be in compliance actually is not. 

Statistical Sampling 

The risk of a product being falsely determined to be out of compliance (manufacturer's risk) is 

balanced against the risk of a product being falsely determined to be in compliance (consumer's 

risk) by establishing a reasonable sampling and testing regime. The design of the sampling plan is 

intended to determine an accurate assessment of product performance, within specified confidence 

limits, without impo;ing an undue testing or economic burden on manufacturers. 

The Code of Federal Regulations (CFR), in 10 CFR Part 430 5430.23 outlines sampling plans for 

compliance testing for appliances covered by EPCA. Typically, the sampling plans for compliance 

determination consist of testing a representative sample to insure that . . . (ii) Any represented 

value of energy efficiency . . . shall be no greater than the lower of (A) the mean of the sample or 

(B) the lower XX confidence limit of the true mean divided by K, where the values for XX and K 

vary with product type. XX, the confidence limit, typically ranges from 90 to 99 percent, while 

K, an adjustment factor, typically ranges from 0.9 to 0.99. The specific values for XX and K for a 

particular product are selected based on an expected level of variability in product performance 

and measurement uncertainty. 

Implicit in the described sampling plan for compliance is the need to have a sample size of at least 

two units in order to perform the statistical procedure. The plan also assumes that a 

representative sample of a product can be obtained from the product population. There is no 

upper limit on the size of the sample for compliance testing. 

The sampling plan for enforcement testing of appliances is listed in 10 CFR Part 430 (5430.70, 

Appendix B. This sppling plan is based on the statistical t-test yielding 97.5 percent probability 

of obtaining a determination of compliance when the true mean efficiency is equal to the 

applicable standard. It is a double sampling procedure which requires a minimum initial sample 

size of four units, and which could result in testing of as many as twenty units, depending on the 

 EE-TP-98-101 COMMENT 02CC

SAMPLING, CERTIFICATION AND ENFORCEMENT 

Introduction 

DOE is seeking to establish sampling regimes for compliance certification and enforcement that 

strike an appropriate"balance between cost and reliability. In order to promote the efficient use of 

energy, and to protect the interest of the users of the covered equipment, compliance certification 

seeks to provide the maximum possible assurance that the efficiency of the covered products 

meets the mandated minimum standards. From a statistical viewpoint, it is impossible to ensure 

with 100 percent confidence that the energy efficiency of any basic model actually meets the 

minimum standard unless the entire population is tested. This being impractical, a subset of the 

population is typically tested, and the performance of the general population is estimated based 

upon the sample results, using statistiCally-based methods. 

Compliance testing and certification is conducted initially with respect to all covered products and 

then prior to the introduction of new covered products into the marketplace. Enforcement testing 

is that which is conducted in response to a claim that a particular covered product which has been 

certified to be in compliance actually is not. 

Statistical Sampling 

The risk ofa product being falsely determined to be out of compliance (manufacturer's risk) is 

balanced against the risk of a product being falsely determined to be in compliance (consumer's 

risk) by establishing a reasonable sampling and testing regime. The design of the sampling plan is 

intended to determine an accurate assessment of product performance, within specified confidence 

" limits, without imposing an undue testing or economic burden on manufacturers. 

The Code of Federal Regulations (CFR), in 10 CFR Part 430 §430.23 outlines sampling plans for 

compliance testing for appliances covered by EPCA. Typically, the sampling plans for compliance 

determination consist of testing a representative sample to insure that ... (ii) Any represented 

value of energy efficiency ... shall be no greater than the lower of (A) the mean of the sample or 

(B) the lower XX confidence limit of the true mean divided by K, where the values for XX and K 

vary with product type. XX, the confidence limit, typically ranges from 90 to 99 percent, while 

K, an adjustment factor, typically ranges from 0.9 to 0.99. The specific values for XX and K for a 

particular product are selected based on an expected level of variability in product performance 

and measurement uncertainty. 

Implicit in the described sampling plan for compliance is the need to have a sample size of at least 

two units in order to perform the statistical procedure. The plan also assumes that a 

representative sample of a product can be obtained from the product population. There is no 

upper limit on the size of the sample for compliance testing. 

The sampling plan for enforcement testing of appliances is listed in 10 CFR Part 430 §430.70, 

Appendix B. This s~pling plan is based on the statistical t-test yielding 97.5 percent probability 

of obtaining a determination of compliance when the true mean efficiency is equal to the 

applicable standard. It is a double sampling procedure which requires a minimum initial sample 

size of four units, and which could result in testing of as many as twenty units, depending on the 

13 
variability of the measurement results. Manufacturer's risk is less for the enforcement testing than 

for the compliance testing, due to the statistical procedure utilized. 

At this time, the Department is considering implementing a sampling plan for compliance testing 

of commercial products which is similar in format to the existing sampling plans for other 

products, with the details of the specific confidence intervals and adjustment factors to be 

determined for each product type. 

Questions and Request for Comments 

(1) What is the appropriate sample size for each product to be tested? 

(2) How should sample units be selected? 

(3) Where should testing be performed and by whom? 

(4) How should compliance be determined from test results, e.g. by employing arithmetic 

averaging or statistical confidence intervals? 

(5) Should derating or other special adjustment factors be used? 

(6) Should the scheme applied in enforcement differ from that used for compliance? 

(7) Should the enforcement sampling plan be used to determine the validity of labeling 

representations? 

Sampling Limited and Heterogeneous Populations 

Many products to be covered by the test procedure are produced in limited numbers, either 

because of their large size or because of the number of variations in design demanded by their 

purchasers. This complicates the determination of a sampling plan due to concerns about 

excessive test burden and cost considerations. The Department is considering various means of 

limiting the number of basic models to be tested by grouping similar products or implementing 

some form of analytical procedure to supplement testing results. 

In the case of commercial water heaters, the referenced test procedure, ANSI 221.10.3-1 990 (and 

1993) does not specify the characteristics necessary to determine a representative basic model for 

energy efficiency testing. However, the current version of ASHRAE Standard 1 18.1 - 1993 

Method of Testing for Rating Commercial Gas, Electric, and Oil Water Heaters contains a 

provision for rating models that are not tested. 

Some industry organizations have programs in place or under development to certify the 

performance characteristics of certain covered products. These programs may include both 

repetitive and random testing of many products. Typically, products which meet certain standards 

are listed in a publication or database. Testing may be conducted in-house or at third party testing 

laboratories depending on the program. 

 EE-TP-98-101 COMMENT 02CC

variability of the measurement results. Manufacturer's risk is less for the enforcement testing than 

for the compliance testing, due to the statistical procedure utilized. 

At this time, the Department is considering implementing a sampling plan for compliance testing 

of commercial products which is similar in format to the existing sampling plans for other 

products, with the details of the specific confidence intervals and adjustment factors to be 

determined for each product type. 

Questions and Requ~st for Comments 

(1) What is the appropriate sample size for each product to be tested? 

(2) How should sample units be selected? 

(3) Where should testing be performed and by whom? 

(4) How should compliance be determined from test results, e.g. by employing arithmetic 

averaging or statistical confidence intervals? 

(5) Should derating or other special adju~tment factors be used? 

(6) Should the scheme applied in enforcement differ from that used for compliance? 

(7) Should the enforcement sampling plan be used to determine the validity of labeling 

representations? 

Sampling Limited and Heterogeneous Populations 

Many products to be covered by the test procedure are produced in limited numbers, either 

because of their large size or because of the number of variations in design demanded by their 

purchasers. This complicates the determination of a sampling plan due to concerns about 

excessive test burden and cost considerations. The Department is considering various means of 

limiting the number of basic models to be tested by grouping similar products or implementing 

some form of analytical procedure to supplement testing results. 

In the case of commercial water heaters, the referenced test procedure, ANSI Z21.10.3-1990 (and 

1993) does not specifY the characteristics necessary to determine a representative basic model for 

energy efficiency testing. However, the current version of ASHRAE Standard 118.1-1993 

Method of Testing for Rating Commercial Gas, Electric, and Oil Water Heaters contains a 

provision for rating models that are not tested. 

Some industry organizations have programs in place or under development to certifY the 

performance characteristics of certain covered products. These programs may include both 

repetitive and random testing of many products. Typically, products which meet certain standards 

are listed in a publication or database. Testing may be conducted in-house or at third party testing 

laboratories depending on the program. 

14 
Questions and Request for Comments 

(1) Are special provisions needed for very large capacity, site-assembled, or low production 

quantity units? 

(2) Can products be grouped as minor variations on a more limited number of basic models? 

If so, how many models need to be tested, and what is the best way to extrapolate the 

results to other products within a group? Is simulation testing a valid approach? Should 

limits be placed on its use? 

(3) Should the proposed rule address the water heater issue in a manner consistent with that 

presented in ASHRAE 1 18.1 - 1993? 

(4) What relevant experience do other organizations, like the Air-conditioning and 

RefrigeratiorP Institute, American Boiler Manufacturers Association, Gas Appliance 

Manufacturers Association, or the Califonria Energy Commission, have to address this 

problem? 

 EE-TP-98-101 COMMENT 02CC

Questions and Request for Comments 

(1) Are special provisions needed for very large capacity, site-assembled, or low production 

quantity units? 

(2) Can products be grouped as minor variations on a more limited number of basic models? 

If so, how many models need to be tested, and what is the best way to extrapolate the 

results to other products within a group? Is simulation testing a valid approach? Should 

limits be placed on its use? 

(3) Should the proposed rule address the water heater issue in a manner consistent with that 

presented in ASHRAE 118.1-1993? 

(4) What relevant experience do other organizations, like the Air-conditioning and 

RefrigeratioIf Institute, American Boiler Manufacturers Association, Gas Appliance 

Manufacturers Association, or the California Energy Commission, have to address this 

problem? 

15 
EQUIPMENT LABELING 

Introduction 

Within 12 months of prescribing test procedures under EPCA section 343 [42 USC 63 141 for any 

class of covered equipment, the Secretary is required to prescribe a corresponding labeling rule. A 

proposed labeling rule must be published in the Federal Register, and a comment period (of not 

less than 45 days' duration) allowed to present oral and written data, views, and arguments. The 

date for displaying the labels is 12 month from the date the rule is prescribed. The labeling 

disclosures are stated in EPCA sections 344(b), (c), and (e) [42 USC 63 15 (b), (c), and (e)]. 

According to EPCA Section 344 (b), the rule shall require that each article of covered equipment, 

discloses by label, the energy efficiency of such article, determined in accordance with the test 

procedures. The required disclosure may also include estimated operating costs and energy use, 

also determined in accordance with the test procedures. 

According to EPCA Section 344 (c), the rule shall include such requirements as the Secretary 

determines are likely to assist purchasers in decision-making. These include requirements and 

directions for label display and requirements for including additional information that the 

Secretary determines necessary to provide adequate information to purchasers. The additional 

information can relate to energy efficiency, energy use, and other measures of energy 

consumption as well as instructions for the maintenance, use, or repair of the covered equipment. 

According to EPCA Section 344 (e), the rule shall provide that labeling indicate the energy 

efficiency of the equipment on the permanent nameplate or other nearby permanent marking. It is 

also required to prominently display this item in new equipment catalogs used by the manufacturer 

to advertise the equipment. The labeling shall also include such other markings as the Secretary 

determines necessary solely to facilitate enforcement of the standards established for such 

equipment under section 342. 

The Department is interested in receiving feedback and comments to help resolve the issues 

related to justification for labeling under EPAct, label location and contents, and labeling of mixed 

component systems 

Justification for Labeling 

The labeling provisions for all industrial equipment (including commercial HVAC and water 

heating equipment) are subject to section 344(h) of EPCA, 42 U.S.C. 63 15(h), which states in 

essence that the Secgetary of Energy shall not promulgate labeling rules for any class of industrial 

equipment unless the Secretary has determined that the following three criteria are met: (1) such 

labeling is technologically and economically feasible with respect to such class; (2) significant 

energy savings will likely result frorn the labeling; and (3) the labeling is likely to assist consumers 

in making purchasing decisions. 

DOE would like comments frorn manufacturers about their specific situations and anticipated 

difficulties, as well as suggestions regarding how problems can be solved and burdens minimized. 

 EE-TP-98-101 COMMENT 02CC

EQUIPMENT LABELING 

Introduction 

Within 12 months of prescribing test procedures under EPCA section 343 [42 USC 6314] for any 

class of covered equipment, the Secretary is required to prescribe a corresponding labeling rule. A 

proposed labeling rule must be published in the Federal Register, and a comment period (of not 

less than 45 days' duration) allowed to present oral and written data, views, and arguments. The 

date for displaying the labels is 12 month from the date the rule is prescribed. The labeling 

disclosures are stated in EPCA sections 344(b), (c), and (e) [42 USC 6315 (b), (c), and (e)]. 

According to EPCA Section 344 (b), the rule shall require that each article of covered equipment, 

discloses by label, the energy efficiency of stich article, determined in accordance with the test 

procedures. The required disclosure may also include estimated operating costs and energy use, 

also determined in accordance with the test procedures. 

According to EPCA Section 344 ( c), the rule shall include such requirements as the Secretary 

determines are likely to assist purchasers in decision-making. These include requirements and 

directions for label display and requirements for including additional information that the .. Secretary determines necessary to provide adequate information to purchasers. The additional 

information can relate to energy efficiency, energy use, and other measures of energy 

consumption as well as instructions for the maintenance, use, or repair of the covered equipment. 

According to EPCA Section 344 ( e), the rule shall provide that labeling indicate the energy 

efficiency of the equipment on the permanent nameplate or other nearby permanent marking. It is 

also required to prominently display this item in new equipment catalogs used by the manufacturer 

to advertise the equipment. The labeling shall also include such other markings as the Secretary 

determines necessary solely to facilitate enforcement of the standards established for such 

equipment under section 342. 

The Department is interested in receiving feedback and comments to help resolve the issues 

related to justification for labeling under EP Act, label location and contents, and labeling of mixed 

component systems 

Justification for Labeling 

The labeling provisions for all industrial equipment (including commercial HV AC and water 

heating equipment) are subject to section 344(h) ofEPCA, 42 U.S.c. 6315(h), which states in 

essence that the Sec\etary of Energy shall not promulgate labeling rules for any class of industrial 

equipment unless the Secretary has determined that the following three criteria are met: (1) such 

labeling is technologically and economically feasible with respect to such class; (2) significant 

energy savings will likely result from the labeling; and (3) the labeling is likely to assist consumers 

in making purchasing decisions. 

DOE would like comments from manufacturers about their specific situations and anticipated 

difficulties, as well as suggestions regarding how problems can be solved and burdens minimized. 

16 
Questions and Request for Comments 

(1) Are there specific problems with individual classes of covered equipment which affect the 

technical feasibility and economic justification for labeling? Examples of such problems 

could include the physical space availability for the label, the physical location of the unit, 

the cost of adding the energy descriptor values to current labels/nameplates or of 

redesigning the nameplate, etc. 

(2) What energy savings, if any, would result if labels were required for the different classes of 

covered equipment? Are some labeling schemes better than others in this regard? 

(3) Would labels assist customers in making purchasing decisions with respect to the 

individual classes of covered equipment? In particular, what are the perceived benefits, if 

any, to the following stakeholders involved in the decision making process: contractors, 

building owners and managers, architects, retailers, manufacturers and distributors, trade 

associations, and international consumers? What are the implications of the fact that 

commercial equipment are often purchased based on catalog information without being 

seen beforehand by the purchasers? 

Label Location and Contents 

Under EPACT, labels are required to "(1) indicate the energy efficiency of the equipment on the 

permanent nameplate attached to such equipment or other nearby permanent marking; (2) 

prominently display the energy efficiency of the equipment in new equipment catalogs used by the 

manufacturer to advtrtise the equipment; and (3) include such other markings as the Secretary 

determines necessary, solely to facilitate enforcement of the standards established for such 

equipment under section 342." 

EPCA directs the Secretary to require that the energy efficiency of each covered equipment be 

"prominently" displayed "in equipment catalogs and other material used to market the 

equipment." EPCA section 344(e)(2). Implementing this provision would require catalogs and 

other marketing materials for equipment to prominently display the same energy efficiency 

descriptor rating that would appear on the equipment label. Further authority for such a 

requirement is provided in section 344(c)(3) of EPCA, which authorizes adoption of requirements 

"likely to assist purchasers in making purchasing decisions," including required disclosure in 

"printed matter which is displayed or distributed at the point of sale". 

DOE seeks suggestions concerning the location of the label and detail of information that might 

appear on it, as well as the burden associated with preparing/placing it. 

Questions and request for comments 

(1) For which of the covered equipment classes the current nameplates can be modified to 

accommodate the information required by EPACT? How could the energy efficiency data 

be prevented,from getting overwhelmed by other information on the nameplate? How 

could the energy efficiency information be displayed in a consistent manner? 

 EE-TP-98-101 COMMENT 02CC

Questions and Request for Comments 

(1) Are there specific problems with individual classes of covered equipment which affect the 

technical feasibility and economic justification for labeling? Examples of such problems 

could include the physical space availability for the label, the physical location of the unit, 

the cost of aading the energy descriptor values to current labels/nameplates or of 

redesigning the nameplate, etc. 

(2) What energy savings, if any, would result iflabels were required for the different classes of 

covered equipment? Are some labeling schemes better than others in this regard? 

(3) Would labels assist customers in making purchasing decisions with respect to the 

individual classes of covered equipment? In particular, what are the perceived benefits, if 

any, to the following stakeholders involved in the decision making process: contractors, 

building owners and managers, architects, retailers, manufacturers and distributors, trade 

associations, and international consumers? What are the implications of the fact that 

commercial equipment are often purchased based on catalog information without being 

seen beforehand by the purchasers? 

Label Location and Contents 

Under EPACT, labels are required to "(1) indicate the energy efficiency of the equipment on the 

permanent nameplate attached to such equipment or other nearby permanent marking; (2) 

prominently display the energy efficiency of the equipment in new equipment catalogs used by the 

manufacturer to adv~rtise the equipment; and (3) include such other markings as the Secretary 

determines necessary, solely to facilitate enforcement of the standards established for such 

equipment under section 342." 

EPCA directs the Secretary to require that the energy efficiency of each covered equipment be 

"prominently" displayed "in equipment catalogs and other material used to market the 

equipment." EPCA section 344(e)(2). Implementing this provision would require catalogs and 

other marketing materials for equipment to prominently display the same energy efficiency 

descriptor rating that would appear on the equipment label. Further authority for such a 

requirement is provided in section 344(c)(3) ofEPCA, which authorizes adoption of requirements 

"likely to assist purchasers in making purchasing decisions," including required disclosure in 

"printed matter which is displayed or distributed at the point of sale". 

DOE seeks suggestions concerning the location of the label and detail of information that might 

appear on it, as well as the burden associated with preparing/placing it. 

Questions and request for comments 

(1) For which of the covered equipment classes the current nameplates can be modified to 

accommodate the information required by EP ACT? How could the energy efficiency data 

be prevented"from getting overwhelmed by other information on the nameplate? How 

could the energy efficiency information be displayed in a consistent manner? 

17 
(2) For the covered equipment classes where the current nameplates can not accommodate 

energy efficiency information, what would make a label 'nearby' and 'permanent'? 

(3) What would constitute the "prominent" display of energy efficiency information in new 

equipment catalogs? 

(4) What other markings could be necessary solely to facilitate the enforcement of the 

standards? Could energy efficiency markings be required on import documents to assist 

enforcement kfforts by identifying equipment that comply with EPCA? 

(5) Should DOE consider including additional data beyond the efficiency ratings for the 

purposes of enforcement of the statute. Such data might include, for example, reference to 

the ASW 90.1 test procedures, operating conditions for the rated efficiency, 

comparative efficiency ranking within a class of products, or other consumer information. 

Labeling of Mixed Component Systems 

Some commercial equipment covered by EPACT are comprised of separate components, often 

hrnished by different manufacturers, raising questions of how these products should be labeled 

and by whom. 

For residential appliances, for split system condenser-evaporator coil systems, the required labels 

contain energy efficiency ratings which are either (1) the energy efficiency rating of the 

condenser-evaporator coil combination that is the particular manufacturer's most commonly sold 

combination for that condenser model; or (2) the energy efficiency rating of the actual condenserevaporator coil combination comprising the system to which the label is to be attached. 

EPCA 42 USC 63 15 (b) requires that the information on the labels be determined in accordance 

with test procedures8under 42 USC 63 14. With mixed systems, there are too many combinations 

to test them all, and residential air conditioners use a computer simulation, with only the highest 

sales combination tested. 42 USC 63 14 provides little guidance regarding a computer simulation, 

and so DOE may need to explicitly add this provision in order to ensure that labeling for 

commercial equipment is no more burdensome than that for residential appliances. 

Questions and Request for Comments 

(1) Should component manufacturers or system integrators be responsible for developing/ 

affixing the labels? 

(2) If manufacturers are responsible for labeling, how would one address the fact that they do 

not control selection of the balance of the system? If system integrators are responsible, is 

it possible to develop custom labels for different combinations of components? 

(3) Under what circumstances, if any, should computer simulation results to be used to 

calculate system efficiency ratings to appear on labels? 

 EE-TP-98-101 COMMENT 02CC

(2) For the covered equipment classes where the current nameplates can not accommodate 

energy efficiency information, what would make a label 'nearby' and 'permanent'? 

(3) What would constitute the "prominent" display of energy efficiency information in new 

equipment catalogs? . 

(4) What other markings could be necessary solely to facilitate the enforcement of the 

standards? Could energy efficiency markings be required on import documents to assist 

enforcement 'efforts by identifying equipment that comply with EPCA? 

(5) Should DOE consider including additional data beyond the efficiency ratings for the 

purposes of enforcement of the statute. Such data might include, for example, reference to 

the ASHRAE 90.1 test procedures, operating conditions for the rated efficiency, 

comparative efficiency ranking within a class of products, or other consumer information. 

Labeling of Mixed Component Systems 

Some commercial equipment covered by EP ACT are comprised of separate components, often 

furnished by different manufacturers, raising questions of how these products should be labeled 

and by whom. 

For residential appliances, for split system condenser-evaporator coil systems, the required labels 

contain energy efficiency ratings which are either (1) the energy efficiency rating of the 

condenser-evaporator coil combination that is the particular manufacturer's most commonly sold 

combination for that condenser model; or (2) the energy efficiency rating of the actual condenserevaporator coil combination comprising the system to which the label is to be attached. 

EPCA 42 USC 6315 (b) requires that the information on the labels be determined in accordance 

with test procedures"under 42 USC 6314. With mixed systems, there are too many combinations 

to test them all, and residential air conditioners use a computer simulation, with only the highest 

sales combination tested. 42 USC 6314 provides little guidance regarding a computer simulation, 

and so DOE may need to explicitly add this provision in order to ensure that labeling for 

commercial equipment is no more burdensome than that for residential appliances. 

Questions and Request for Comments 

(1) Should component manufacturers or system integrators be responsible for developing! 

affixing the labels? 

(2) Ifmanufacturers are responsible for labeling, how would one address the fact that they do 

not control selection of the balance of the system? If system integrators are responsible, is 

it possible to develop custom labels for different combinations of components? 

(3) Under what circumstances, if any, should computer simulation results to be used to 

calculate system efficiency ratings to appear on labels? 

18