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. manufacturing, 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 has 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 and 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 labels 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 

will 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 questions 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 cycle 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 that 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 rationale 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 ASRAC 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 suited 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 analysis 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 is 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 there 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 original 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 

function).

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 scope 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 subgroups 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 enforcement 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 should 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 standards 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 at 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 to 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 and 
Appliance 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.