Appliance Standards and Rulemaking Federal Advisory Committee (ASRAC)



### ASRAC Working Group Topic History

February 26, 2013

 Common expectations of ASRAC

1. Develop creative, cost

- effective solutions to maximize energy savings and opportunities;

2. Create an understanding of how codes and standards affect other agencies, and effort to have standards mesh and balance existing national and international standards;

3. Validate modeling used by DOE;

4. Streamline rulemaking efforts and be sure focus is on developing outcomes that the Department can actually utilize; and

5. Promote U.S. manufactu ring, while negotiated rulemaking may be key focus, other areas that the Committee may be expected to help.

 Commercial HVAC, WH, and Refrigeration Working Group ( FORMED )

 Commercial Labeling Working Group

1. Before deciding to charter a working group, ASRAC ha s recommended that DOE summarize the responses to the request for information (RFI)

– 77 FR 75400

– regarding the potential for establishing labeling requirements for covered commercial and industrial equipment, including
information about the technical an d economic feasibility of labeling such equipment, the extent to which labeling would assist consumers in making purchasing decisions, the potential for significant energy savings resulting from labeling, the potential content and format of prospective la bels for each type of equipment, the ideal location of placement for any such labels, and prospective burdens on manufacturers associated with labeling of covered equipment. Summary of the RFI responses will be distributed to ASRAC by mid

- April and ASRAC

w ill consider if a working group should be formed to assist with forming commercial labeling strategies recommendations or if it is a task for ASRAC to take on itself.

 Other ideas for consideration and further deliberation

1. Test procedures raise a lot of que stions and tend to have confusion surrounding their interpretation. Maybe an opportunity to develop a working group that can put some effort into ensuring test procedures are interpreted the same way.

2. Many of the rulemakings appear to have lack of duty cyc le information on the product and this can cause delay or issues. A working group could help track rulemakings that are coming up and ensure duty cycle information is made available.

3. Rulemakings for fans and pumps.

4. Develop a cross

- cutting working group tha t can assist with coordinating test procedures and rulemaking standards to avoid instances where a new test procedure would change the measured energy and by consequence negatively change the effect of current standards. Concerns about using de minimis rat ionale to not adjust the standard to reflect changes.

5. Develop process to validate models used by DOE

6. Address the timing of test procedures and standards to avoid missed deadlines, which have real implications in terms of lost savings for consumers. Can AS RAC or a working help DOE by gathering lessons learned from all of the past rulemaking efforts and form recommendations for DOE to implement in their rulemaking procedures.Appliance Standards and Rulemaking Federal Advisory Committee (ASRAC)

7. ASRAC should discuss the set of criteria that would identify rulemakings best suit ed for negotiated efforts.

 Critical mass among stakeholders, as way of ensuring that the working group can have balanced representation

 Coming to the table before or after preliminary analysis. It may be valuable in instances that rulemaking is starting from scratch to have stakeholders come to the table to influence the test procedure and metric, which are needed before preliminary analys is can take place.

 It’s important to understand the process of forming working groups and what “balance” means in reference to ensuring that membership is balanced on ASRAC and its working

groups. Balance refers to the process of ensuring that members of working groups are selected on the basis of established records of distinguished service in their professional community and their knowledge relevant to the function of the working group. This process includes ensuring (to the extent possible) that there i s even representation from all affected stakeholders (i.e., advocates, manufacturers, utilities, etc.).

8. Test procedure for residential water heaters.

9. A working group could be formed to recommend a way to streamline cross

- cutting issues in
instances that th ere are multiple standards for one product. Similarly, there may be products that are a part of a second (different) product. So the standard for the first product (the product alone) essentially affects the standard for the second product (where the origi nal product is a component). Perhaps a working group could come up with a way to address these cross

- cutting

issues.

10. Establish a process by which a group of people could petition DOE to do something related to Appliance and Equipment Standards.

 Plug loads in homes and businesses seem to be an area that is growing rapidly, perhaps ASRAC can start looking at the options for DOE to take on plug loads and promoting efficiency other than by product level (e.g., by home, size of home, size of building, per
functi on).



### June 27, 2013

 Commercial and Industrial Labeling Request For Information

1. Concern about not having formal scope that Committee could react to. DOE is willing to move with the convening report.

 Commercial/Industrial Pumps ( FORMED )



### September 12, 2013

 Certification and Enforcement Statistics

1. Commercial HVAC, WH, and Refrigeration Working Group agreed that the certification and enforcement statistical requirements should be reviewed. Determined that it was a potentially good suggestion, but the broad sco pe may suggest more time to think about in more detail. Ultimately decided to “shelf” the idea for a future discussion.

 Verification Program

1. Commercial HVAC, WH, and Refrigeration Working Group had discussion regarding verification programs (different subg roups had different views)Appliance Standards and Rulemaking Federal Advisory Committee (ASRAC)

 CRE

– group supports DOE required manufacturer funded verification testing program. Agreement from members present on call and in room for verification program that has minimum burden is the best approach. Framework details could be worked out by end of October. CRE members request more time to finalize their recommendation

 Boiler and Water Heater

– Group believes that verification should be addressed as a continuation of this negotiated rulemaking group and does support specific verification requirements for companies not participating in a voluntary recognized program. The group believes the object is currently being served by the proven voluntary industry program, as well as the current DOE enforcement authority. Cert and enforc ement statistical analysis needs to be completed in parallel to development of a verification program. Group thinks that DOE should consider other options for verifying ratings published on the CCMS website.

 HVAC

– Group believes that verification testing should be addressed as a continuation of this negotiated rulemaking group. There should be very distinct delineation between
verified and non

- verified listings in CCMS. Group to give guidelines by end of October on what a voluntary verification program sho uld be.

2. Discussion led to idea of a separate broader Working Group regarding verification.

3. Ultimate decision made for DOE to release a request for information (RFI), compile comments, summarize, and distribute to ASRAC for their input. \

 System based standa rds versus product based standards

1. Discuss offline to scope and for further ASRAC discussion and consideration.



### June 6, 2014

 Manufactured Housing ( FORMED )

 Residential Regional Standards Enforcement Working Group ( FORMED )

 Commercial Ice Makers (AHRI letter )

1. 8 members on record opposed the formation of the working group (given that DOE is continuing to address the concerns of AHRI and there is a mechanism in place for doing that and view that it is later in the process).

 Process Rule Consideration

1. The pace a t which standards are being refreshed and simultaneous updating of the test procedures that feed those standards may warrant an ASRAC discussion synchronization of the

process.

 Stakeholder Engagement

1. Discussion about DOE trying to make more of an effort t o engage stakeholder groups and give ample notice regarding stakeholder engagement meetings.



### December 1, 2014

 Characterization of Connected Equipment

1. Form ASRAC Working Group as a vehicle for engaging industry in an open voluntary consensus
process to develop characterization protocols.

 Working Group to come first and develop list and rank the products for which the concentration would be. Or ASRAC could also have a discussion and rank the products andAppliance Standards and Rulemaking Federal Advisory Committee (ASRAC)

then limit the working group’s action to the first couple of products that ASRAC feels important.

2. Decided that DOE will take back to develop set of criteria to help ASRAC decide in its next meeting. Part of the charter would be to list the products that the working group should
consider.