### US DEPARTMENT OF ENERGY

DRAFT ISSUEPAPER

WORKSHOP ON COMMERCIALWATER HEATERS, BOILERS,

. 

### FURNACES, AIR CONDITIONERSAND HEAT PUMPS

APRIL 14AND 15,1998 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 COMMERCIALWATER HEATERS


### Introduction The Energy Policy Act of 1992(EPAct) requires that commercial water heaters meet certain energy efficiencyrequirements, and that these requirements be demonstrated through the use of generally accepted iqdustry test procedures developed or recognized by the American Society of Heating, Refrigeratingand Air-Conditioning Engineers (ASHRAE), as referenced in ASHRAEmS Standard 90.1 and in effect on June 30, 1992.Addendum 90.lbwas approved on January 25, 1992, and will be the version of the standard referred to when determining applicable test procedures for commercialwater heaters. The following is a presentation of several issues related to the determination and applicationof test procedures that manufacturers are required to implement in order to verify conformance ofcommercial water heaterstoEPAct energy efficiency standards. These issues arebeing presented for discussion and consideration in the development ofa proposed rule related to commercialwater heaters.


### Clarificationof Coverage and Definitions Table 1 1.1ofASHRAE Standard 90.1 b, hereafter referred to as Table 11.1, categorizes water heaters into three main categories of coverage: water heating equipment coveredby The National ApplianceEnergy Conservation Act of 1987 (NAECA), 

### other water heating equipment, and unfired storagetanks. Water heaters are then fitrther subdivided into several subcategories according to basic type (e.g. storage, instantaneous and pool heater), fueltype, input rating and storage volume. NAECA is basically the law that setsenergy efficiencyrequirements for residential appliances, whereas EPAct is geared towards commercial appliances. Excluding pool heaters, there aretwo test proceduresreferenced, The Department ofEnergy (DOE) Test Procedure 10 CFR, Part 430, Subpart

### By AppendixE which is applied to NAECA-covered products, and the American National Standards Institute (ANSI) test procedure for gaswater heaters, ANSI Z21.10.3-1990,to be applied to other water heating equipment. There are no test proceduresreferenced for testing ofunfired storagetanks. The scopesofcoverage and definitionsdiffer among EPAct, Table 1 1.1,and the referenced test procedures. These differences can lead to cofisionwhen determining efficiencyrequirements and applicabletest procedures for a givenproduct. The Department is considering clarimgTable 11.1in order to insurethe application of the proper test procedure to commercial water heating products. The following section, "General CoverageIssues," addresses these coverage-related issues from a general perspective, and the subsections followingthe "General Coverage Issues" section address the coverage-related issues in more detail with respect to the different types ofwater heaters covered by EPAct.* 

### General Coverage Issues The draft version of Standa~d 90.1-1989R containsTable 7.2.2,which is a revised version of Table 1 1.1that appearsto clarifjr many ofdifferences among the scopes ofcoverage and definitionsgiven in EPAct, NAECA, Table 1 1.1,and the test proceduresreferenced by Table 11.1.

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



### 1 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 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 ofthe standard referred to when determining applicable test procedures for commercial water heaters. The following is a presentation ofseveral issues related to the determination and application oftest procedures that manufacturers are required to implement in order to verify conformance ofcommercial water heaters to EP Act energy efficiency standards. These issues are being presented for discussion and consideration in the development ofa proposed rule related to commercial water heaters.
Clarification ofCoverage and Definitions Table 11.1 ofASHRAE Standard 90.1b, hereafter referred to as Table 11.1, categorizes water heaters into three main categories ofcoverage: 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 ofEnergy (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 ofunfired storage tanks. The scopes ofcoverage 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 ofthe 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 ofwater heaters covered by EP Act.•
General Coverage Issues The draft version ofStandard 90.1-1989R contains Table 7.2.2, which is a revised version of Table 11.1 that appears to clarify many ofdifferences among the scopes ofcoverage 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

### Questionsand

### Request for Comment (1) Would it be beneficialto include a table similar in format to Table 7.2.2of90.1Rin the proposed rule in orderto clarifLthe categories of coverage for commercial water heaters? (2) ANSI 221.10.3-1990has been revised. The current version, 221.10.3-1993, contains no modificationofthe test procedures for thermal efficiency and standby loss. Shouldthe reference to this test procedure in Table 11.1be updated to the 1993version? Electric StorageWater Heaters ANSI 221.10.3-1990is the test procedure required for testing ofproducts not covered by NAECA. This test procedure covers gas water heatersincluding storage water heaters with input ratings above 75,000 Btulh (22 kW). Table 11.1contains a footnoteindicatingthat the test procedure can be applied to electric water heaters with modificationsgiven in the footnote. Table 11.1does not indicate that EPAct-covered storage water heaters have input-to-volume ratios less than 4,000 Btu/hper gallon of storage. Furthermore, NAECA covers electric storage water heaterswith input ratings less than or equal to 12kW (4 1,000Btu/h), but Table 1 1.1does not indicate whether the scope of the ANSI test procedure can be lowered fiom 22 kW to 12kW in order to accommodateEPAct-covered electric water heaters with input ratings between 12 and 22 kW. 

### QuestionsandRequest for Comment (1) Should Table 11.1be clarifiedto 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) Isthere any reason why the ANSI test procedure should not be applicableto electric storage water heaters with input ratings between 12 and 22 kW?
Electric Instantaneous Water Heaters Electricinstantaneods 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 appliesto this category ofwater heaters. EPAct requires instantaneouswater heaters with storagevolumes of 10gallons or more to have a standby loss no greaterthan 2.3

## + 67Measured Storage Volume (in %

### per hour), and makes no distinction among the fueltypes. Note that EPAct does not require instantaneouswater heaters with storagevolumes less than 10 gallonsto meet standby loss requirements, only thermal efficiencyrequirements. Thermal efficiency is assumed to be equal to 98% for immersed electricheating elements; therefore, no thermal efficiency testing is required for this category. 

### QuestionsandRequest for Comment (1) Should Table 11.1be clarified to directly address the category ofelectricinstantaneous water heaters with the EPAct requirement for standby loss for instantaneous water heaters? 

### Questions andRequest for Comment (1) Would it be beneficial to include a table similar in format to Table 7.2.2 of90.1Rin the proposed rule in order to clarify the categories ofcoverage for commercial water heaters? (2) ANSI Z21.10.3-1990 has been revised. The current version, Z21.10.3-1993, contains no modification ofthe 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 ofproducts 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 ofstorage. 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 ofthe 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 andRequest 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 ofwater heaters. EPAct 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 andRequest for Comment (1) Should Table 11.1 be clarified to directly address the category ofelectric instantaneous water heaters with the EP Act requirement for standby loss for instantaneous water heaters?



### 2

### (2) Should Table 11.1be clarifiedto indicate that the ANSI test procedure (standby loss only) shouldbe appliedto electric instantaneous water heaters having an input rating greater than 12

### kW (41,000Btu/h), an input-to-volume ratio of at least 4,000 Btu/h/gal and a storagevolume greater than 10gallons?
Gas StorageWater Heaters NAECA provides coveragefor all gas storagewater heaters with input ratings less than 75,000 Btulhour. Table 1 1.1, footnote c states additional limitationsfromthe DOE Test Procedure. However, these limitationsdo not changethe NAECA coverage as Table 1

### 1.1could be interpretedto imply. 

### Questions andRequest for Comment (1) Should Table 11.1be clarified to indicate that the ANSI test procedure shouldbe applied only for gas storage water heaters with input ratings greater than 75,000Btuh and an input-to-volqme ratio less than 4,000 BtuMgal?
GasFired InstantaneousWater Heaters Table 1 1.1indicates that NAECA-covered gas instantaneous water heaters are those with input ratings of200,000Btu/h or less and that the DOE Test Procedure applies. Although, the scope of the current DOE Test Procedure does not coincideprecisely with the NAECA definitionofgasfired instantaneous water heaters, NAECA coverage still applies, However, since Table 11.1 references the DOE Test Procedure, there is some interpretationrequired 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 heaterwith 

### an input rating of40,000 Btu/h and a storage capacity of4 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 10,000Btu/h/gal., which is greaterthan NAECA's 4,000 Btu/h/gal.threshold.Thus the heater would appearto fall into the category ofNAECAcovered product.However, ifone 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 of EPAct-covered products and would be tested using the ANSI test procedure. 

### Questionsand Request for Comment (1) Should Table 1 1.1be clarifiedto indicate that only gas-fired instantaneous water heaters with input ratings greater than 200,000 Btuh areEPAct-covered products?
Oil Fired InstantaneousWater Heaters Table 11.1indicates that NAECA covered oil instantaneous water heaters are those with input ratings of210,000 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 currentDOE 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 interpretationrequired to determine what is (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 ofat 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 andRequest 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 of200,000 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 ofgasfired 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 of40,000 Btulh and a storage capacity of4 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, ifone relies on footnote c ofTable 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 andRequfst 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 ofoilfired 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 thereforewhich products fall into the "other" category. 

### QuestionsandRequest for Comment (1) Should Table 11.1be clarifiedto indicate that all oil-fired instantaneous water heaters with input ratings greater than 210,000 Btulh are EPAct-covered products?
CommercialWater Heater or Packaged Boiler? Some equipment designed to fbnction as a packaged boiler can also provide servicewater heating. In other words, the equipment could be used in place ofa water heater. EPAct does not distinguish boilers based on their application. The energy efficiencyrating required by EPAct for packaged boilers is combustion efficiency. The combustion efficiencyrating method is quite different from the thermal efficiencyrating method which is required for commercialwater heaters. Boilers couldbe comparedto commercialwater heaters by implementingthe commercial water heatertest procedure 

### QuestionsandRequest for Comment (1) To what extent is equipment that heats water used for purposes that are different from those anticipated at the time ofmanufacture? How can EPAct efficiencyrequirements and test procedufes be applied to these products? (2) Shouldthe efficiencyrequirements and test procedure for measuring the thermal efficiency ofcommercial water heatersbe applicableto packaged boilers, ifthey areused 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 storagetanks need not be tested for heat or standby losses. EPAct indicates that storagewater heaters, instantaneouswater heaters, and unfired hot water storage tanks do not have to meet standby loss or heat loss requirements specified in EPAct ifthey have a storage capacity ofmore than 140gallons, and the tank surface area is thermally insulatedto R-12.5 (or greater), and ifa standing pilot light is not used. 

### QuestionsandRequest for Comment (1) Shouldthe K-valuebe consideredto be an "effective9' R-value which would account for heat losses through the insulationdue to thermal bridges? (2) Ifthe insulationvalue is to be considered an "effective" R-value, what method should be used to determinethe "effective" R-value in order to verify whether an item is exempt from testing for standby loss? meant by NAECA-c£)vered water heating equipment and therefore which products fall into the "other" category. 

### Questions andRequest for Comment (1) Should Table 11.1 be clarified to indicate that all oil-firedinstantaneous 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 ofa 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 andRequest for Comment (1) To what extent is equipment that heats water used for purposes that are different from those anticipated at the time ofmanufacture? How can EPAct efficiency requirements and test procedures be applied to these products? (2) Should the efficiency requirements and test procedure for measuring the thermal efficiency ofcommercial water heaters be applicable to packaged boilers, ifthey are used for service water heating, in order to allow comparison between commercial packaged boilers and commercial water heaters? (3) Which test procedure, ifany, 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 EP Act ifthey have a storage capacity ofmore than 140 gallons, and the tank surface
area is thermally insulated to R-12.5 (or greater), and ifa standing pilot light is not used. 

### Questions andRequest 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) Ifthe 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 StorageTanks EPAct requiresunfired hot water storagetanks with volumes less than or equal to 140

### gallons and having a tank surface area that is insulatedto 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 procedureto determinethis heat loss rate. There do not appear to be any test procedures currently availablet6at address the testing ofunfired hot water storagetanks to determinethe rate ofheat loss per unit oftank surface area. However, the revision ofAS- Standard 1

### 18.1- 1993R 

### (review draft) contains a method for testing water heating equipment with continuously operatingpumps that might be applied to unfired storage tanks to determine rate ofheat loss. 

### Questionsand

### Request for 

### Comment (1) 

### What test procedures are availableforuse in determining the rate ofheat loss per square foot oftank surface area? 

### (2) Ifprocedures are available, which should 

### DOE require? Ifnot, is a new procedure needed? 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 Btulh per square foot oftank 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 ofunfired hot water storage tanks to determine the rate ofheat loss per unit oftank surface area. However, the revision ofASHRAE 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 ofheat loss. 

### Questions andRequest for Comment (1) What test procedures are available for use in determining the rate ofheat loss per square foot oftank surface area? (2) Ifprocedures are available, which should DOE require? Ifnot, is a new procedure needed?

5ASHRAE STANDARD 90.1b, TABLE 

### 11.1 

# - Minimum Performance 

### of Water Heating Equipment

'For detailed referencessee Section 14. b~onsistent with NationalAppliance Energy ConservationAct (NAECA) of 1987. 'DOE Test Proceduresapplyto electric and gas storage water heaterswith 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 heaterfor standby loss usingthe test proceduresof Section 2.9 of 221.10.3-1990~~, the electricalsupply voltage shall be maintained within f 1%of the center of the voltage range specified on the water heater nameplate. Also, when neededfor calculations,the thermal efficiency (Et) shall be 98%. When testing an oil water heater usingthe test procedures of Section 2.8 and 2.9 of 221.10.3-1990~~, the following modificationswill be made: A vertical length of flue pipe shall be connectedto the flue gas outlet of sufficient heightto establish the minimumdraft specified inthe 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 adjustedto achieve an hourly Btu input ratewithin 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 pressurewithin f 1% of the manufacturer's specification. fHeat loss of tank surface area (~tulft~) based on 80°F water-air temperature difference. 'V is rated storage volume in gallonsas specified by the manufacturer. h VTisthe storage volume in gallons as measured during the test to determine standby loss. VTmay differ from V, but it iswithin tolerances allowed by the applicable221 and UL standards. Accordingly, for the purpose of estimating the standby loss requirement usingthe ratedvolume shown on the rating plate, VTshould be concerned as no lessthan 0.95V for gas and oil water heaters and no lessthan 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 ASHRAE STANDARD 90 1b, TABLE 11.1

- Minimum Performance ofWater 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. dAll 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 % ofthe center ofthe 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% ofthe 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 % ofthe manufacturer's specification.
fHeat loss oftank 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. VTmay differfrom 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, VTshould 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 PROTOCOLSFOR COMMERCIALBOILERSAND FURNACES
Introduction EPACT-1992 referenced ASHRAE Standard 90.1-1989for the test procedures to be used for the determinationofthe energy efficiency standardsfor commercial spaceheating equipment including packaged steam and hot water boilers and 

### warm air furnaces. ASHRAE/IES Standard 90.1-1989in turn referenced four industrytest standards for gas-fired boilers with input greater than 300,000 Btu/h, and three test standardsfor oil-fired boilers with input greaterthan 300,000 Btu/h. For warm air furnaces with input capacity equal to or greater than 225,000 Btu/h, Addendum 90.1i-1993to ASHRAliT 90.1-1 989 referenced one standard for gas-fired furnaces and one standard for oil-fired furnaces. The specificationsfor energy performance tests in those referenced standards are in most cases similarto 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 threereferenced standards for oil-fired boilers. Because ofthe differencesin the test specifications, a boiler tested by these differenttest standardsmay produce different efficiencyvalues. The differencemay be minor but may also be significant.Areview ofthose differencesis presented below to facilitatediscussion ofthe issues. Another issuethat needs discussion concernsthe size ofthe boilers tobe covered by aDOE test procedure.While an upper limit was specified in EPCA for residential central furnaces and boilers, EPACT does not specify an upper limit for commercialboilers and furnaces. Comments and suggestions are requested from this workshop in helping DOE at developing appropriateDOE test and rating proceduresthat can be applied to equipmentwithout conflicting requirements fiom different standards.This would allow for a consistent and equitable comparison among equipment using the sametype offuel or using differenttypes offuels.
Definition of "Packaged Boiler" EPACT specifies coverage for packaged boiler and defines it as "a boilerthat is shipped complete with heating equipment, mechanical draft equipment, and automatic controls;usually shipped in one or more sections," but the statutedoes not specify an upper limit for its capacity. (EPACT Sec. 122(a)(3)(1 l)(B)). Several existing industry standardsand conventions address the definition in different ways. HydronicsInstitute Standard-1989defines packaged boiler as "a boiler-burner unit factory assembled and wired," and HI'SDirectory ofI=B=Rratings lists boilers with gross output up to 13.5million Btu/h.


### UL 726-1995 (Sec.5)defines "boiler assembly" for oil-fired boilers as "factory-built and shall include all the essential componentsnecessary 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 similarto EPACT.)
ANSI 221.13-1993ahas no definitionforpackaged boiler, but ANSI 221.13 limits coverage for gas-fired boilers to less than 12.5million Btu/h.
ASME PTC4.1 covers all types of steamboilers with no size limit. 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 ofthe 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 ofthe 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 ofthose differences is presented below to facilitate discussion ofthe issues. Another issue that**n~eds** discussion concerns the size ofthe 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 offuel or using different types offuels.


### Definition of"Packaged Boiler" EPACT specifies coverage for packaged boiler and defines it as "aboiler 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 ofsteam boilers with no size limit.



### 7

### Questionsand

### Request for Comments: (1) Is the EPACTYs definition for packaged boiler clear enough? To what extent, ifany, are custom-designed, field-assembledboilers excluded?Is a sizelimit 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 ofcombustion efficiencyforboilers and thermal efficiencyfor furnaces. In general, Errjrt=

### EmC 

# - LJ,where Errjrtis the thermal efficiency based on inputoutput method, EQC is the combustionefficiencybased on flue loss method, and LJis thejacket loss. Existing industry standards address these efficiencies in different ways.

Hydronics Institute Standard-1989 contains test methods forboth thermal efficiency (called overall efficiency) and combustionefficiency forboilers. It does not give a test method for jacket loss. HI'Srating directorylists only combustion efficiencies.
ANSI 221.13-1993aspecifies combustion efficiencyfor gas-fired indoorboilers and thermal efficiencyfor outdoorboilers. It has a method for flue loss calculationbut no method for a jacket loss test.


### UL 726-1995 spkcifies aperformancetest 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 steamboilers. They include the parasitic electricenergy consumption as an input in the efficiency calculation and provide a default graph forjacket losses, as well as a method forjacket losstesting ifpreferred.
Furnaces
ANSI 22

### 1.47-1993names its section on efficiencytesting for gas-fired &maces as "thermal efficiency," but the calculationis by flue loss method. Therefore, the thermal efficiency is equivalent to combustionefficiency. It describes methods for both flue loss calculation and jacket loss testing, but thejacket loss is not used in its thermal efficiencyformula.


### UL 727-1994 contains a performancetest method (by flue loss) for oil-fired furnaces, but no methods for flue loss calculationnor forjacket loss testing to obtain an efficiencyvalue. 

### Questionsand

### Request for Comments: (1) Efficiency: (1) In caseswhere EPACT specifiesthermal efficiency and ASHRAE 90.1 test procedureslisted in ASHRAE 90.1measure combustionefficiency, shouldDOE require a procedureto measure thermal efficiency directly, or should it specifl a method for correcting combustionefficiencies with jacket lossesto obtain thermal efficiencies? (2) 

### Ifa 8 Questions andRequest 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 ifso what is the maximum capacity?
Thermal VS. 

### Combustion Efficiency; Jacket Losses 

### EPACT defines efficiency in terms ofcombustion 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 thejacket 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 forjacket losses, as well as a method forjacket loss testing ifpreferred.
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 thejacket 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 forjacket 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 withjacket losses to obtain thermal efficiencies? (2) Ifa
8

### jacket loss correction is called for, does this loss actually exist in the case of indoor equipment? (3) ASME PTC4.1 includes parasitic .electricenergy in its efficiency calculation. Should parasitic electricenergybe considered in combustion efficiency or thermal efficiency calculations? (4) 

### As the term is generallyused for furnaces, is "thermal efficiency" taken in practice to mean the samething as combustion efficiency, as suggested by ANSI 221.47-1993? (2) Jacket Loss: Not all the ASHRAE 90.1-1989 referenced test standardsincludetest and calculation methods forjacket loss. ASME PTC 4.1 provides a graph forjacket loss and a test method also. ANSI Z21.47provides test procedure. (1) If ajacket loss term is needed, should a single method be selected forjacket loss test forboth boilers and furnaces? (2) Should laboratory test results be adjustedto (average ?) 

### outdoor conditions? Uniformity ofTest Conditions, Test Setup, and Procedures EPACT referencesASHRAE 90.1 

## -1989fortest methods. ASHRAE 90.1 

## -1989,Addendum 90.1 i- 1993, and the public review version 90.1Rreference severalindustrialtest standards that specie differenttest conditions and test setups, including type offuel to be used, tolerance on input rate, input inlet and outlet water temperatures, instrumentation for temperature measurement, specificationsfor fluepipe length and insulation, and length of steady statetesting period. The following table lists some ofthe 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 gastemp. ANSI 221.13 Gas Fuel By manufacturer +I-

### 2% rated Not specified
80F+/-I0 F 180F+/-2F
100F Average of9 traverse Vertical flue length 

### HI Std-1989 Gas or Oil 

### #2 or 4,5,6 fuel oil 100-105% rated 30min.



# - 200F
120Fto 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 SteamProd. By manufacturer
Rated 2 runs, 4 hrs. each 

## - Not less than 200 F 

## - Average Traverse



### 2 

### ft. (ifvertical outlet) R7 Insulation 

## -
Uninsulated 

## -

- jacket loss correction is called for, does this loss actually exist in the case ofindoor 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 forjacket loss. ASME PTC 4.1 provides a graph forjacket loss and a test method also. ANSI Z21.47 provides test procedure. 

### (1) Ifajacket loss term is needed, should a single method be selected forjacket loss test for both boilers and furnaces? (2) Should laboratory test results be adjusted to (average ?) outdoor conditions? 

### Uniformity ofTest Conditions, Test Setup, and Procedures EPACT references ASHRAE 90.1-1989 for test methods. ASHRAE 90.1-1989, Addendum 90.1i-1993, and the public review version 90.1R reference several industrial test standards that specifY different test conditions and test setups, including type offuel 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 ofsteady 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 ofsteady 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) (ifhorizontal (direct vent) outlet) Horizontal flue length 2 ft. (if<400 2 

### ft. (ifvertical



# - - kBtulh) outlet) Vent insulation to test Uninsulated R

### 7 Insulation Uninsulated



# - plane

9

### Furnaces



### QuestionsandRequest for Comments: Item Test fuel specification Heat input rate Duration of steady-statetest 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 applicableto the same product, do the differentprocedures yield the same result? Ifnot, 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 adoptingthe new version. That would raise the question ofwhether for comparison purposes, DOE would want to have auniform test standard. Should uniform test conditionsbe adopted forboiler test procedures? If so, should the basis a single standard or a compromiseofthe four referenced standards? Should one single set of boiler water inlet and outlet temperatures under steady stateconditionbe specified? And what shouldbe their values? Consideration ofa 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. Singlethermocouple at center No less than 2 

### R. Uninsulated

b) For flue gas temperature measurement, should a 9-thermocouplegrid be an option instead ofthe singletemperature sensormeasured 

### successively at 9 points?

c) All referenced standards except

### HI Std-1989 specifLtest 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 ?


### Provisionsfor Unusual Design Features Someboilers 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. Modularboilers are sold as a packaged boiler. Some boilers and fbrnaces are ofthe modulatingtype where ASHRAE 90.1-1989 specifiesefficiency ratings at both the maximum and the minimum firing rates. Some boilers are forboth hot water and steam applications. 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 ofsteady-state test 30 min. 45 min. Flue gas temp. Average of9 traverse Single thermocouple at center Vertical flue length 5ft. 6 in. No less than 2 ft. Flue insulation 

### " Uninsulated Uninsulated



### Questions andRequest 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? Ifnot, 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 ofwhether for comparison purposes, DOE would want to have a uniform test standard. Should uniform test conditions be adopted for boiler test procedures? Ifso, should the basis a single standard or a compromise ofthe 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 ofa 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 ofthe 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 ofthe 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 ofthe 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

### QuestionsandRequest for Comments: (1) 

### Shouldtwo test conditionswith respectto water inlet and outlet temperaturesbe specified for hot water boilers for high temperature and low temperature applications ? 

### (2) 

### None ofthe referencedtest standards specietest procedure for condensing boilerslfbmaces. Should test procedure for condensatemeasurement 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 90.1-1989 ? (4) 

### Should a single boiler be tested for a modular boiler package ?

e (5) 

### Should a hot waterlsteam boiler be tested on steam only ? Questions andRequest 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 ofthe referenced test standards specify test procedure for condensing boilers/furnaces. Should test procedure for condensate measurement be developed for condensing boilers and furnaces? Ifso, 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 specifiedin 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 PROTOCOLSFOR COMMERCIAL AIR CONDITIONERS AND HEAT PUMPS
Introduction The Energy Policy Act of 1992(EPAct)requires that commercial air conditionersand heat pumps meet certain energy efficiencyrequirements and that these requirements be demonstrated through the use ofgenerally accepted industrytest procedures developed or recognized by ASHRAE. The

. 

### relevant Air-conditioning and Refrigeration Institutetest procedures referenced in ASHRAE Standard 90.1appear generallyunambiguous and straightforward,with the possible exception of the treatment ofexternal static pressure requirements for testing these products.
Minimum External StaticPressure Requirement According to 

### ARI standardsreferenced in ASHRAE 90.1 applicableto small and large commercialpackage air conditioning and heating equipment, systemswith indoorfans intended for use with field-installed ducts shallbe tested when operating against the minimum external staticpressure specified in these standards. The minimum external staticpressure is prescribed in atable listing different levels ofexternal resistance depending on system capacity; larger values of minimum external resistance are prescribed for larger-capacity systems on the assumptionthat larger systems are connected to longer duct systems with more bends and other flow obstructions. Critics have observedthat external static pressures specified by the 

### ARI are lower than generally encountered in commercial buildings, potentially leading to an overstated efficiencyrating. Others counter that the present procedure is adequate for the purpose ofcomparingproducts relativeto one another, and a changewould be unnecessarily burdensome.
The topic ofthe minimum external static pressure requirement was brought up in written comments at the occasion ofDOE'SSeptember 25, 1997workshop on Residential Central Air Conditioner and Heat Pump Test Procedures. At that time a decisionwas made to leavethe minimum external static pressure requirement unchanged with possible reconsideration ofthis issue at the time of adoptionby the U.S. ofthe applicableIS0 Standard.
DOE would liketo obtain comments on the minimum external resistancerequired for small and large commercialpackage air conditioning and heat pump systems. 

### Questionsand

### Request for Comments: (1) Isthe minimum external resistance specified in 

### ARI standardsfor commercial air conditioning and heating equipment representative ofthe resistance experienced

### in the field, and ifnot, what arethe appropriateresistance values? (2) 

### Does the prelent

## ARI standards introduce an error, and if so, how significantis the error? TEST PROTOCOLS FOR COMMERCIALAIR 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 ofgenerally 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 ofexternal 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 ofexternal 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 ofcomparing products relative to one another, and a change would be unnecessarily burdensome.
The topic ofthe minimum external static pressure requirement was brought up in written comments at the occasion ofDOE'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 ofthis issue at the time ofadoption by the U.S. ofthe 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 andRequest for Comments: (1) Is the minimum external resistance specified in ARI standards for commercial air conditioning and heating equipment representative ofthe resistance experienced 

### in the field, and ifnot, what are the appropriate resistance values? (2) Does the**pre~ent** ARI standards introduce an error, and ifso, how significant is the error?

12

### SAMPLING, CERTIFICATIONAND ENFORCEMENT
Introduction 

### DOE is seekingto establish sampling regimes for compliance certification and enforcementthat strike an appropriate"balance between cost and reliability. In order to promote the efficient use of energy, and to protect the interest ofthe users of the covered equipment, compliance certification seeksto provide the maximum possible assurancethat the efficiency ofthe covered products meets the mandated minimum standards. From a statisticalviewpoint, it is impossible to ensure with 100percent confidencethat the energy efficiencyof any basic model actually meets the minimum standardunless 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 certificationis conducted initially with respect to all covered products and then prior to the introductionofnew covered products into the marketplace. Enforcement testing is that which is conducted in responseto a claimthat a particular covered product which has been certifiedto be in compliance actually is not. 

### StatisticalSampling The risk ofa product being falsely determinedto be out ofcompliance (manufacturer's risk) is balanced againstthe risk ofa product being falsely determinedto be in compliance (consumer's risk) by establishinga reasonable sampling and testing regime. The design of the samplingplan 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 ofFederal Regulations (CFR), in 10CFR Part 430 5430.23 outlines sampling plans for compliancetesting for appliances covered by EPCA. Typically, the sampling plans for compliance determination consist of testing a representative sampleto insure that



### ... 

### (ii) Any represented value ofenergy efficiency



### ..

### . shallbe no greaterthan the lower of (A) the mean ofthe sample or (B) the lower

### XX confidencelimit of the true mean dividedby K, where the values for 

### XX and K vary with product type. 

### XX, the confidencelimit, typically ranges from 90 to 99 percent, while K, an adjustmentfactor, typically ranges from 0.9 to 0.99. The specific values for 

### XX and K for a particular product are selectedbased on an expected level ofvariability in product performance and measurement uncertainty. Implicit in the described sampling plan for complianceis the need to have a sample size ofat least two units in order to perform the statistical procedure. The plan also assumes that a representative sampleof a product can be obtained fromthe product population. There is no upper limit on the size ofthe sample for compliancetesting.
The sampling plan for enforcementtesting of appliances

### is listed in 10

### CFR 

## Part 430 (5430.70, Appendix B. This spplingplan is based on the statistical t-test yielding 97.5 percent probability ofobtaining a determinationofcompliance when the true mean efficiency is equal to the applicable standard. It is a double samplingprocedure which requires a minimum initial sample size offourunits, and which could result in testing ofas many astwenty units, depending on the 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 efficientuse of energy, and to protect the interest ofthe users ofthe covered equipment, compliance certification seeks to provide the maximum possible assurance that the efficiency ofthe covered products meets the mandated minimum standards. From a statistical viewpoint, it is impossible to ensure with 100 percent confidence that the energy efficiency ofany basic model actually meets the minimum standard unless the entire population is tested. This being impractical, a subset ofthe population is typically tested, and the performance ofthe 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 ofnew 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 ofcompliance (manufacturer's risk) is balanced against the risk ofa product being falsely determined to be in compliance (consumer's risk) by establishing a reasonable sampling and testing regime. The design ofthe sampling plan is intended to determine an accurate assessment ofproduct performance, within specified confidence 

### " limits, without imposing an undue testing or economic burden on manufacturers.
The Code ofFederal 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 oftesting a representative sample to insure that

... (ii) Any represented value ofenergy efficiency

... shall be no greater than the lower of(A) the mean ofthe sample or (B) the lower XX confidence limit ofthe 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 ofvariability in product performance and measurement uncertainty. Implicit in the described sampling plan for compliance is the need to have a sample size ofat least two units in order to perform the statistical procedure. The plan also assumes that a representative sample ofa product can be obtained from the product population. There is no upper limit on the size ofthe sample for compliance testing.

The sampling plan for enforcement testing ofappliances 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 ofobtaining a determination ofcompliance when the true mean efficiency is equal to the applicable standard. It is a double sampling procedure which requires a minimum initial sample size offour units, and which could result 

### in testing ofas many as twenty units, depending on the

13

### variability ofthe measurement results. Manufacturer's risk is less for the enforcementtesting than for the compliancetesting, due to the statistical procedure utilized.
At this time, the Department is consideringimplementing a sampling plan for compliancetesting ofcommercial products which is similar in format to the existing sampling plans for other products, with the details ofthe specific confidence intervals and adjustment factorsto be determined for each product type. 

### QuestionsandRequest 

### for Comments (1) What is the appropriate sample sizefor each product to be tested? (2) How should sampleunitsbe selected? (3) Where shouldtesting be performed and by whom? (4) How should compliance be determined from test results, e.g.by employing arithmetic averaging or statisticalconfidence intervals? (5) 

### Should derating or other special adjustmentfactorsbe used? (6) 

### Should the scheme applied in enforcementdiffer 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 coveredby the test procedure are produced in limited numbers, either because oftheir large size or because of the number of variationsin design demanded by their purchasers.This complicatesthe determinationof a samplingplan dueto concernsabout excessivetest burden and cost considerations. The Department is considering various means of limiting the number ofbasic models to be tested by grouping similarproducts or implementing some form ofanalytical procedure to supplementtesting results.
In the case of commercial water heaters, the referenced test procedure, ANSI 221.10.3-1 990 (and 1993)does not specifythe characteristicsnecessary to determine a representative basic model for energy efficiencytesting. However, the current version ofASHRAE Standard 1 18.1 

## - 1993 Method ofTesting for Rating Commercial Gas, Electric, and Oil Water Heaters contains a provision for rating modelsthat are not tested.
Some industry organizationshave programs in place or under development to certify the performance characteristicsofcertain covered products. These programs may includeboth repetitive and random testing ofmany products. Typically, productswhich meet certain standards are listed in a publication or database.Testing may be conductedin-house or at third party testing laboratoriesdepending on the program. variability ofthe 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 ofcommercial products which is similar in format to the existing sampling plans for other products, with the details ofthe 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 oflabeling representations? Sampling Limited and Heterogeneous Populations Many products to be covered by the test procedure are produced in limited numbers, either because oftheir large size orbecause ofthe number ofvariations in design demanded by their purchasers. This complicates the determination ofa sampling plan due to concerns about excessive test burden and cost considerations. The Department is considering various means of limiting the number ofbasic models to be tested by grouping similar products or implementing
some form ofanalytical procedure to supplement testing results.

In the case ofcommercial 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 ofASHRAE Standard 118.1-1993 Method ofTesting 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 ofcertain covered products. These programs may include both repetitive and random testing ofmany 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

### Questionsand

### 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 ofbasic models? If so, how many models need to be tested, and what is the best way to extrapolate the resultsto other productswithin a group? Is simulation testing avalid 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, likethe Air-conditioning and RefrigeratiorP Institute, AmericanBoilerManufacturersAssociation, Gas Appliance ManufacturersAssociation, or the CalifonriaEnergy Commission, have to addressthis problem? 

### Questions andRequest 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 ofbasic models? Ifso, 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 RefrigeratioIfInstitute, 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 ofprescribing test procedures under EPCA section 343 [42 USC 63 141for any class ofcovered equipment, the Secretary is required to prescribe a correspondinglabeling rule. A proposed labelingrule must be published in the Federal Register, and a comment period (ofnot less than 45 days' duration) allowed to present oral and written data, views, and arguments. The date for displaying the labels is 12month fromthe date the rule is prescribed. The labeling disclosuresare stated in EPCA sections 344(b), (c), and (e) [42USC 63 15 (b), (c), and (e)]. According to EPCA Section 344 (b), the rule shall require that each article ofcovered equipment, disclosesby label, the energy efficiencyof such article, determinedin accordancewith the test procedures. The required disclosuremay also include estimated operating costs and energy use, also determinedin 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 directionsfor label display and requirements for including additional informationthat the Secretarydetermines necessaryto provide adequate informationto purchasers. The additional information can relate to energy efficiency, energyuse, and other measures ofenergy consumption as well as instructions forthe maintenance, use, or repair of the covered equipment. According to EPCA Section 344 (e), the rule shall provide that labeling indicatethe energy efficiency ofthe equipment on the permanent nameplate or other nearby permanent marking. It is also required to prominently displaythis item in new equipment catalogsused by the manufacturer to advertisethe equipment. The labeling shall also include such other markings asthe Secretary determines necessary solelyto facilitate enforcement ofthe standardsestablished for such equipment under section 342. The Department is interestedin receiving feedback and commentsto help resolve the issues related tojustification for labelingunder EPAct, label location and contents, and labeling ofmixed component systems


### Justification for Labeling The labeling provisions for all industrial equipment (including commercialHVAC and water heating equipment) are subjectto section 344(h) ofEPCA, 42 U.S.C.63 15(h),which statesin essencethat the SecgetaryofEnergy shall not promulgate labeling rules for any class ofindustrial equipment unless the Secretaryhas determinedthat the followingthree criteria are met: (1) such labeling is technologically and economically feasiblewith respect to such class; (2) significant energy savingswill likely result frorn the labeling; and (3) the labeling is likely to assist consumers 

### in making purchasing decisions.
DOE would like commentsfrorn manufacturers about their specific situationsand anticipated difficulties, as well as suggestionsregarding how problems can be solved and burdens minimized. EQUIPMENT LABELING
Introduction Within 12 months ofprescribing test procedures under EPCA section 343 [42 USC 6314] for any class ofcovered 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 (ofnot 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 ofcovered equipment, discloses by label, the energy efficiency ofstich 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 ofenergy consumption as well as instructions for the maintenance, use, or repair ofthe covered equipment. According to EPCA Section 344 (e), the rule shall provide that labeling indicate the energy efficiency ofthe 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 ofthe standards established for such equipment under section 342.
The Department is interested in receiving feedback and comments to help resolve the issues related tojustification for labeling under EPAct, label location and contents, and labeling ofmixed 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 ofEnergy shall not promulgate labeling rules for any class ofindustrial 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

### QuestionsandRequest for Comments (1) 

### Are there specificproblems with individual classes ofcovered equipmentwhich affectthe technical feasibility and economic justification for labeling? Examples of such problems could includethe physical space availabilityfor the label, the physical location of the unit, the cost of adding the energy descriptorvalues to current labels/nameplatesor of redesigningthe nameplate, etc. (2) 

### What energy savings,if any, would result iflabels were required for the different classes of covered equipment?Are some labeling schemesbetter than others in this regard? (3) Would labels assist customersin making purchasing decisions with respect to the individual classes of covered equipment? In particular, what are the perceived benefits, if any, to the following stakeholdersinvolved in the decision making process: contractors, building owners and managers, architects,retailers, manufacturers and distributors,trade associations, and international consumers?What arethe implicationsof the fact that commercial equipment are often purchased based on catalog information without being seenbeforehand 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 ofthe equipment in new equipment catalogsused by the manufacturerto advtrtisethe equipment; and (3) include such other markings asthe Secretary determines necessary, solelyto facilitateenforcementof the standardsestablished for such equipment under section 342."
EPCA directs the Secretaryto require that the energy efficiency ofeach covered equipment be "prominently" displayed "in equipment catalogs and other material used to market the equipment." EPCA section 344(e)(2). Implementingthis provision would require catalogs and other marketing materials for equipment to prominently display the same energy efficiency descriptorrating that would appear on the equipment label.Further authority for such a requirementis provided in section 344(c)(3) ofEPCA, which authorizes adoption ofrequirements "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 suggestionsconcerning the location ofthe label and detail ofinformationthat might appear on it, as well as the burden associated with preparing/placingit. 

### Questions andrequest for comments (1) For which of the covered equipment classes the current nameplates can be modified to accommodatethe information required by EPACT? How could the energy efficiencydata be prevented,from getting overwhelmed by other information on the nameplate? How could the energy efficiency informationbe displayed in a consistent manner? 

### Questions andRequest for Comments (1) Are there specific problems with individual classes ofcovered equipment which affect the technical feasibility and economicjustification for labeling? Examples ofsuch problems could include the physical space availability for the label, the physical location ofthe unit, the cost ofaading the energy descriptor values to current labels/nameplates or of redesigning the nameplate, etc. (2) What energy savings, ifany, 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 ofcovered 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 ofthe 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 ofthe equipment on the permanent nameplate attached to such equipment or other nearby permanent marking; (2) prominently display the energy efficiency ofthe 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 ofthe standards established for such equipment under section 342."
EPCA directs the Secretary to require that the energy efficiency ofeach 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 ofrequirements "likely to assist purchasers in making purchasing decisions," including required disclosure in "printed matter which is displayed or distributed at the point ofsale".
DOE seeks suggestions concerning the location ofthe label and detail ofinformation that might appear on 

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

### Questions andrequest for comments (1) For which ofthe 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 efficiencyinformation, what would make a label 'nearby' and 'permanent'? (3) 

### What would constitutethe "prominent" display ofenergy efficiency information in new equipment catalogs? (4) 

### What other markings could be necessary solelyto facilitatethe enforcement ofthe standards?Could energy efficiency markings be required on import documentsto assist enforcementkfforts by identifying equipment that comply with EPCA? (5) 

### Should DOE considerincluding additional databeyond the efficiencyratings for the purposes ofenforcementof 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 ofMixed Component Systems Some commercial equipment covered by EPACT are comprised of separatecomponents, often hrnished by different manufacturers, raising questions ofhow these products should be labeled and by whom.
For residential appliances, for split system condenser-evaporatorcoil systems, the required labels contain energy efficiency ratings which are either (1) 

### the energy efficiencyrating ofthe condenser-evaporatorcoil combination that is the particular manufacturer's most commonly sold combinationfor that condensermodel; or (2)

### the energy efficiency rating ofthe 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 procedures8under 42 

### USC 6314. 

### With mixed systems, there aretoo many combinations to test them all, and residential air conditioners use a computer simulation, with only the highest sales combinationtested. 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

### andRequest

### for Comments (1) 

### Should component manufacturers or system integratorsbe responsible for developing/ affixingthe labels? (2) 

### Ifmanufacturers are responsiblefor labeling, how would one address the fact that they do not control selectionof the balance ofthe system? If system integrators are responsible, is it possibleto develop custom labels for different combinationsofcomponents? (3) 

### Under what circumstances,if any, should computer simulationresults to be used to calculate system efficiencyratings to appear on labels? (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 ofenergy efficiency information in new equipment catalogs?

. (4) What other markings could be necessary solely to facilitate the enforcement ofthe 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 ofenforcement ofthe 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 ofproducts, or other consumer information. Labeling 

### ofMixed Component Systems Some commercial equipment covered by EPACT are comprised ofseparate components, often furnished by different manufacturers, raising questions ofhow 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 ofthe condenser-evaporator coil combination that is the particular manufacturer's most commonly sold combination for that condenser model; or (2) the energy efficiency rating ofthe 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 andRequest 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 ofthe balance ofthe system? Ifsystem integrators are responsible, is it possible to develop custom labels for different combinations ofcomponents? (3) Under what circumstances, ifany, should computer simulation results to be used to calculate system efficiency ratings to appear on labels?

18