### 202-234-4433 Neal R. Gross & Co., Inc. Page 1 U.S. DEPARTMENT OF ENERGY + + + + + PUBLIC MEETING ON THE NOTICE OF PROPOSED RULEMAKING FOR TEST PROCEDURES FOR RESIDENTIAL FURNACES AND BOILERS

+ + + + + TUESDAY, AUGUST 18, 2009

+ + + + + The Public Meeting convened at 9:00 a.m. in Room 8E-089 of the U.S. Department of Energy, 1000 Independence Avenue, S.W., Washington, D.C., Doug Brookman, Facilitator, presiding. PRESENT: DOUG BROOKMAN, Facilitator, Public Solutions, Inc. KARIM AMRANE, Ph.D., Air-Conditioning, Heating & Refrigeration Institute (AHRI) ERIC S. ANDERSEN, Pacific Northwest National Laboratory (PNNL) ASHLEY ARMSTRONG, Navigant Consulting BELINDA CARR, Energetics, Inc. ADAM DARLINGTON, Navigant Consulting LANCE DeLAURA, Southern California Gas Company (SoCALGAS), Sempra Energy Utilities BRENDA EDWARDS, Department of Energy (DOE) GARY FERNSTROM, Pacific Gas & Electric (PG&E) CYRIL E. FOWBLE, IV, Lennox International KYLE E. GILLEY, Lennox International WILLIAM M. HEALY, Ph.D., United State Department of Commerce, National Institute of Standards and Technology (NIST) MOHAMMED KHAN, Department of Energy (DOE)

### 202-234-4433 Neal R. Gross & Co., Inc. Page 2

ALEX LEKOV, Lawrence Berkeley National Laboratory (LBNL) ROGER D. MARRAN, Energy Kinetics, Inc. KAREN B. MEYERS, Rheem Heating & Cooling JIM RANFONE, American Gas Association

KRISTEN RAYMOND, Department of Justice HARVEY SACHS, Ph.D., American Council for an Energy-Efficient Economy (ACEEE) FRANK STANONIK, Air-Conditioning, Heating, and Refrigeration Institute (AHRI) ERIC STAS, Department of Energy (DOE) JOHN MICHAEL TALBOTT, P.E., Talbott Consulting

JAMES T. VERSHAW, Trane Residential Systems JENNIFER WILLIAMSON, Pacific Northwest National Laboratory (PNNL)

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TABLE OF CONTENTS

AGENDA ITEM PAGE

Welcome . . . . . . . . . . . . . . . . . . . .4

Opening Remarks, Introduction and Agenda Review . . . . . . . . . . . . . .6

Rulemaking Overview . . . . . . . . . . . . . .9

Brief Opening Remarks from

Interested Parties. . . . . . . . . . . 11

Rulemaking Steps, Rulemaking History, and Discussion of Proposed Amendments . . . 20

Adjourn

### 202-234-4433 Neal R. Gross & Co., Inc. Page 4 1 P-R-O-C-E-E-D-I-N-G-S

2 9:04 a.m.

3 FACILITATOR BROOKMAN: Good 4 morning, everybody. Welcome. This is the 5 U.S. Department of Energy's Public Meeting on 6 the Notice of Proposed Rulemaking for Test 7 Procedures for Residential Furnaces and 8 Boilers. My name is Doug Brookman from Public 9 Solutions in Baltimore. Nice to see you. I 10 don't see too many new faces, a few. This is 11 your opportunity to comment on the proposed 12 test procedure and we look forward to hearing 13 from you as the day proceeds. 14 It's our tradition to give 15 everyone a chance to introduce him or herself. 16 So we'll do this and we'll be testing the 17 microphones as we do. Please, name and 18 organizational affiliation. 19 MR. MARRAN: Roger Marran with 20 Energy Kinetics. 21 MS. MEYERS: Karen Meyers, Rheem 22 Manufacturing.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 5 1 MS. RAYMOND: Kristen Raymond, 2 Department of Justice. 3 MR. FERNSTROM: Gary Fernstrom, 4 Pacific Gas and Electric Company. 5 MR. DeLAURA: Lance DeLaura, Sempka 6 Energy Utilities.7 DR. AMRANE: Karim Amrane, Air8 Conditioning Heating and Refrigeration 9 Institute. 10 DR. SACHS: Harvey Sachs, American 11 Council for an Energy-Efficient Economy. 12 MR. VERSHAW: Jim VerShaw with

13 Trane. 14 MR. GILLEY: Kyle Gilley, Lennox. 15 MR. FOWBLE: Cyril Fowble with

16 Lennox. 17 MR. STAS: Eric Stas, DOE General 18 Counsel's Office. 19 MR. KHAN: Mohammed Khan, DOE.

20 FACILITATOR BROOKMAN: John? 21 MR. TALBOTT: John Talbott, 22 Consulting for NIST.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 6 1 DR. HEALY: Bill Healy from NIST. 2 MR. DARLINGTON: Adam Darlington, 3 Navigant Consulting. 4 FACILITATOR BROOKMAN: Did that

5 work? 6 MR. DARLINGTON: Adam Darlington, 7 Navigant Consulting.

8 FACILITATOR BROOKMAN: That worked. 9 MS. ARMSTRONG: Ashley Armstrong, 10 Navigant Consulting. 11 MR. LEKOV: Alek Lekov, Lawrence 12 Berkeley National Laboratory. 13 FACILITATOR BROOKMAN: Thank you. 14 MS. WILLIAMSON: Jennifer 15 Williamson, Pacific Northwest National 16 Laboratory. 17 MR. ANDERSON: Eric Anderson, 18 Pacific Northwest National Laboratory.

19 FACILITATOR BROOKMAN: Thanks. 20 Thanks to all of you. Maybe there will be 21 some others joining us as we go on here. I'm 22 going to do a brief review of the agenda and

### 202-234-4433 Neal R. Gross & Co., Inc. Page 7 1 then we're going to launch right square into 2 the material. I think all of you received, as 3 you registered, a copy of the PowerPoint 4 slides that will be the focus of both 5 presentation and discussion for the day, also 6 a copy of the Federal Register Notice and a 7 statement, I see, from Energy Kinetics. 8 Following -- well, to the agenda 9 review, immediately following this agenda 10 review we're going to have a brief rulemaking 11 overview and following that overview, there's 12 an opportunity for any of you that wish to do 13 so to make brief summary remarks about your 14 concerns and issues that you wish to raise. 15 Following that, we will proceed 16 with a presentation on Rulemaking Steps, 17 Rulemaking History and Discussion of Proposed 18 Amendments. We'll take a break mid-morning, 19 probably 10:30 or 10:45ish and then a more 20 detailed presentation, discussion, Q&A, based 21 on the proposed amendments. We'll see how 22 this proceeds. If we need to keep going

### 202-234-4433 Neal R. Gross & Co., Inc. Page 8 1 passed lunch, we'll take lunch at noon and 2 then following lunch, there's additional 3 opportunity for other issues to be raised and 4 also for individuals to make final remarks. 5 So that's the plan for the day. I 6 will see -- our intention is to do this 7 officially and still provide everybody a 8 chance to say everything they wish to say. 9 Okay? So then I'd just ask for your 10 consideration. Please try and keep your 11 remarks focused. Say your name each time for 12 the record. I'm going to be cuing people by 13 name as best I can. Please say your name each 14 time you speak for the record. Get the 15 microphone close to you so we pick this up. 16 This meeting will be fully recorded. There 17 will be a transcript of the entire meeting 18 available and it will be posted on the 19 Building Technologies website. And so thanks 20 for your consideration. Please turn your cell 21 phones on silent mode and if you can keep your 22 remarks as targeted and focused as possible,

### 202-234-4433 Neal R. Gross & Co., Inc. Page 9 1 that will help. Okay.

2 So then Mohammed. 3 MR. KHAN: Good morning, everyone. 4 Welcome and thank you for participating in 5 today's public meeting on the U.S. Department 6 of Energy's Notice of Proposed Rulemaking on 7 Test Procedures for Residential Furnaces and 8 Boilers. My name is Mohammed Khan and I'm the 9 DOE's Project Manager for this Rulemaking 10 activity. I'll be providing a brief overview 11 of this Rulemaking effort which is in response 12 to the Energy Independence and Security Act of 13 2007 requiring DOE to establish test 14 procedures for measuring the energy 15 consumption of furnaces and boilers during the 16 standby mode and off-mode, off-operations. 17 Following me will be Mr. John 18 Talbot of Talbot Consulting, Incorporated, and 19 he will be providing details on proposed test 20 procedure amendments. 21 MR. FERNSTROM: Gary Fernstrom, 22 PG&E. Could you speak a little closer to the

### 202-234-4433 Neal R. Gross & Co., Inc. Page 10 1 microphone, please?

2 MR. KHAN: Is that better?

3 MR. FERNSTROM: Yes.

4 MR. KHAN: There are several 5 purposes of today's meeting. First, we want 6 to present the Department's proposed test 7 procedure amendments and explain the 8 methodology, specifically how DOE applied the 9 requirements of the EISA Act in the context of 10 residential furnaces and boilers. 11 Second, we want to have a two-way 12 discussion. We want to convey the key points 13 and concepts associated with this rulemaking 14 as well as hear and listen to your thoughts 15 and potential concerns. And lastly, we want 16 to describe what are the next steps and what 17 you should anticipate from the Department. 18 I can't overemphasize the 19 importance of your participation today and 20 whatever written comments you might provide 21 us. You're all encouraged to ask questions and 22 add to today's exchange. Additionally,

### 202-234-4433 Neal R. Gross & Co., Inc. Page 11 1 everyone is invited to submit written comments 2 and please let me remind you that the comment 3 period closes on the 13th of October. Before 4 we proceed, at this juncture we want to 5 provide an opportunity for interested parties 6 to provide their opening remarks.

7 FACILITATOR BROOKMAN: As I 8 understand it, one person has requested to 9 speak and we want to provide an opportunity 10 for others that wish to chime in as well. 11 Roger, do you wish to make brief remarks? 12 MR. MARRAN: Yes, thank you Doug. 13 Roger Marran with Energy Kinetics. At the 14 back of your handout there's a copy of my 15 written remarks. All right, several points; 16 I think the first thing is I was taking 17 advantage of the statement that said in 18 today's NOPRs, it's tentatively concluded that 19 standby mode and off-mode fossil fuel energy 20 consumption is accounted for and I think that 21 speaks to further direction than I am looking

22 at here.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 12 1 So the first item is that we 2 believe the current minimum efficiency 3 standard AFUE causes severe restraint for 4 trade and efficiency progress in the 5 residential boiler market. The rating 6 procedure for boilers doesn't properly reflect 7 the real performance efficiency in boilers 8 supplying each of American homes. It's based 9 on the incorrect concept of hydronic heating 10 systems installed operations. 11 Item two says, "We have been 12 advised in the past meetings that there's 13 almost universal agreement among those 14 required to use the rating standard that the 15 AFUE rating for boilers really needs to be 16 fixed". The current AFUE rating for boilers 17 inhibited the market from advancing 18 significant energy efficient improvements in 19 hydronic home heating systems by consistently 20 overrating the seasonal efficiency of boilers 21 and ignoring the domestic hot water function

22 also.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 13 1 Item three, the Department of 2 Energy has not introduced an effective rating 3 for combination heat and hot water systems 4 which also offer significant potential for 5 energy conservation improvements. Item four, 6 is in the AFUE test procedure. While 7 indicating a very specific test procedure, the 8 test points reflects a rating essentially 9 equal to steady state combustion efficiency. 10 A well-run test can actually have a resultant 11 AFUE which is higher than the steady state 12 combustion efficiency. This is supported with 13 several points. 14 The first one, Item 4.1, the 15 procedure doesn't take into account that most 16 boilers are high thermal mass devices. That's 17 changing more so in recent years but still the 18 majority of the sales and as installed, 19 maintain a temperature for much of the heating 20 season. Item 4.2, by maintaining temperature, 21 the subject to standby loss is not accounted 22 for in the test.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 14 1 Item three, the test temperatures 2 of 120 and 140 aren't representative of the 3 typical hydronic heating system. Item 4.4, 4 the boilers experience jacket losses both when 5 running and also in standby which occurs for 6 the mass majority of heating season hours. 7 So, steady state jacket losses can range from 8 two to six percent are not accounted for. 9 Item 4.5 the Department of Energy has 10 stipulated in the standard it seems that these 11 losses contribute to heating the home even 12 though in most instances, they are not located 13 within the heated space, so jacket losses do, 14 in fact, count as efficiency losses. 15 If we go to Item 4.6 on the 16 following page, the standard doesn't account 17 for energy saving controls and operation that 18 reduce standby losses and increase annual 19 efficiency. So in the current rating system, 20 a lower performing boiler can actually receive 21 a higher rating than a better performing 22 boiler as these factors aren't accounted for.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 15 1 So if we move to Item five, for 2 furnaces due to concerns having to relieve 3 pressure from the California Energy 4 Commission, this is going back several years, 5 it was agreed that because of installation 6 location, jacket losses are now deducted from 7 the ratings for furnaces. The standard for 8 furnaces and boilers should be the same. 9 Item 5.1, the current standard, by 10 not including jacket losses, encourages 11 manufacturers to minimally insulate the 12 boilers. The lack of insulation can actually 13 contribute to higher AFUE rating because it 14 reduces the steady state flue gas temperature. 15 Item 5.2, in the ASHRAE 124 standard to 16 develop a combined heat and hot water 17 appliance, the application for AFUE for the 18 heating season creates a conflict. The hot 19 water portion of the test, the jacket losses 20 are considered a loss, whereas for the heating 21 portion of the test it considers losses a 22 gain.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 16 1 To combine the two tests, 2 obviously, creates an engineering 3 incompatibility. So Item 6, the input/output 4 rating procedure, similar to that envisioned 5 in the forward thinking ASHRAE 155, commercial 6 boiler standard, could provide a definition of 7 jacket loss and improved seasonal energy 8 efficiency analysis. Supporting that are two 9 items. At time of the development of the 10 current AFUE procedure, adequate 11 instrumentation was not economically available 12 for an input/output test. It's my belief that 13 this conclusion was developed only for

14 furnaces. 15 Today, the input/output test can

16 be far more accurate and run on a current 17 procedure -- than the current procedure and 18 should improve accuracy of comparative ratings 19 data. So current water heater test procedures 20 actually do involve essentially input/output

21 test measurements. 22 So Item 6.2 support that is also,

### 202-234-4433 Neal R. Gross & Co., Inc. Page 17 1 we'd encourage improved insulation of boilers 2 which would represent a significant 3 contribution to energy conservation for all. 4 And finally, on Item 7, the AFUE's prescribed 5 for boilers and furnaces, although a separate 6 metric should be used to develop -- should be 7 developed to provide better information for 8 consumers due to the energy delivered to 9 conditioned space. There's some inherent 10 differences between the two. 11 So in Item 7.1 to support that, 12 energy efficiency and renewable energy in the 13 National Renewable Energy Lab report indicates 14 very high efficiency in boiler and hydronic 15 distribution systems and very high 16 distribution losses in conventional ducted 17 distribution systems typically used with 18 furnaces. As such the distribution efficiency 19 can have an overarching impact on the amount 20 of energy that's delivered to conditioned 21 space and the overall energy consumed to heat 22 residences with barium boilers and furnaces as

### 202-234-4433 Neal R. Gross & Co., Inc. Page 18 1 separate appliances. 2 Item 7.2 says the combination of 3 the appliance efficiency and the respective 4 distribution efficiency would provide a better 5 comparative indicator of annual efficiency and 6 more transparency to consumers. So in 7 summary, between different studies that have 8 been done and reports that are out there, if 9 we take a look at the delivered efficiency 10 really should be incorporated into these -- 11 into the test standards to get a better 12 direction for actual efficiency of the 13 appliances. 14 So in a nutshell, we've got some 15 real good opportunities, very good 16 opportunities here to improve overall 17 delivered efficiency to homes and reduce fuel 18 consumption and we really should have a 19 standard that supports the actual performances 20 of the equipment in real life applications in

21 real homes. 22 FACILITATOR BROOKMAN: Okay.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 19 1 MR. MARRAN: Thank you. 2 FACILITATOR BROOKMAN: Thank you. 3 And as Roger noted, this -- his listing of 4 specific issues and concerns are there in the 5 record for everybody to see today. Okay, any 6 additional thoughts, ideas, summary remarks 7 here at the outset before we launch into the 8 content. Harvey Sachs. 9 DR. SACHS: Harvey Sachs, ACEEE. 10 I'd like to thank Roger for his thought 11 provoking observations on the AFUE test, even 12 if it's on the periphery of our work today, 13 and note that it underscores a much larger 14 issue of the need for updating of our rating

15 methods and standards across the board. I 16 realize the pressures that DOE is under with 17 the Consent Decree but we at ACEEE would hope 18 that we can find mechanisms to work together 19 on rating methods and standards that are a 20 little bit more innovation friendly and 21 reflect a little bit better what we understand 22 today about performance of technologies in the

### 202-234-4433 Neal R. Gross & Co., Inc. Page 20 1 field, information that just was not available 2 to the developers of these tests a quarter 3 century ago. 4 FACILITATOR BROOKMAN: Okay, thank 5 you. Thanks, Harvey. 6 Additional comments here at the 7 outset before we launch into a rather detailed 8 explanation of this test procedure? Okay, 9 proceed, Mohammed. 10 MR. KHAN: This one outlines the 11 steps for the Furnace and Boiler Rulemaking. 12 It's the Department's goal to be as 13 transparent as possible in its rulemaking 14 efforts and for this particular rulemaking 15 there are three major stages of public 16 interaction. On July 27th DOE published a 17 NOPR in the Federal Register. Today we're 18 conducting the public meeting and following 19 the 75-day comment period, and after DOE has 20 analyzed all received written comments, we 21 will publish the final rule. 22 Regulatory history, I'd like to

### 202-234-4433 Neal R. Gross & Co., Inc. Page 21 1 summarize some of the key regulatory points 2 relevant to furnace and boilers. First, on 3 May 12th, 1997 DOE published its current 4 applicable test procedure which includes the 5 AFUE energy factor and heating seasonal 6 efficiency metrics. It's codified at 10 CFR 7 Part 430, Subpart B, Appendix N. Second, as

8 a result of the most recent amendments were 9 applicable energy conservation standards. The 10 current standards were published on November 11 19th, 2007. Please note that this standard is 12 AFUE based and does not specify standby and 13 off-mode electrical energy conservation

14 standards. 15 These final points regard EISA. 16 The current rulemaking response to the EISA 17 2007 which directs DOE to incorporate a method 18 for measuring standby mode and off-mode energy 19 consumption into its test procedures. EISA 20 also directs DOE to integrate if technically 21 feasible, the standby and off-mode energy 22 consumption into the regulated metric or other

### 202-234-4433 Neal R. Gross & Co., Inc. Page 22 1 energy descriptor. 2 Finally, DOE must consider the 3 most current versions of the International 4 Electric Technical Commission Standards, 62301 5 and 62087 which provide accepted methods of 6 measurement of standby power and energy 7 consumption of electrically powered 8 appliances. I just want to point out that 9 62087 was not applicable because of the 10 products it covers. 11 Now, this slide presents some key 12 points and summarizes the first four major 13 discussion items in our NOPR. First, the 14 Department's approach involved concerning the 15 EISA definitions for standby and off-mode 16 operation and clarifying them in the context 17 of how residential furnaces and boilers 18 actually function. We've equated the EISA 19 definitions for active mode, standby mode and 20 off-mode to the terminology in the test 21 procedure for on-cycle, off-cycle and off-mode 22 respectively.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 23 1 Second, the DOE has determined 2 that the current test procedure already 3 satisfies the EISA requirement for standby 4 mode and off-mode energy consumption as it 5 relates to fossil fuel. AFUE is a current 6 metric and it captures fossil fuel over an 7 entire full year cycle. To satisfy EISA 8 requirement, however, DOE believes it must 9 develop test methods for electrical power 10 consumption and this applies to both fossil 11 fuel and electric furnaces and boilers. 12 Okay, before John comes up and 13 provides additional details, I want to make 14 some other points very clear. AFUE is the 15 current regulatory metric. This rulemaking 16 does not propose to alter AFUE in any way and 17 does not impact a manufacturer's ability to 18 demonstrate compliance with current standards. 19 Also, the current energy conservation20 standards do not stipulate standby and off21 mode. However, standards promulgated after 22 July 1st, 2010 shall incorporate requirements

### 202-234-4433 Neal R. Gross & Co., Inc. Page 24 1 for both standby and off-mode. John? 2 FACILITATOR BROOKMAN: Yes, please. 3 Frank Stanonik. 4 MR. STANONIK: Frank Stanonik, 5 AHRI. Mohammad, I have a question before you 6 leave. Your second bullet there clearly 7 indicates that DOE felt they had to address 8 the question of fossil fuel standby mode and 9 off-mode energy consumption. If you look at 10 the Energy Independence Security Act 2007, and 11 in particular note that it referenced an IEC 12 standard, I think the -- I'm fairly certain 13 the legislative history would indicate that 14 they were looking at standby and off-mode 15 electrical energy consumption. So I'm a 16 little curious why DOE felt that they had to 17 answer this question relative to fossil fuel 18 because I don't think that was the intent of 19 the Energy Independence Security Act of 2007? 20 FACILITATOR BROOKMAN: Were you a 21 part of that negotiation, Frank? 22 MR. STANONIK: We were, yes.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 25 1 FACILITATOR BROOKMAN: Okay, just 2 wanting to get a little more information

3 there. 4 MR. KHAN: Okay, I'm going to 5 respond to that and then I'll let general 6 counsel add, if need be, as well. The way we 7 interpreted it, Energy was -- I don't think it 8 spelled out or segregated electrical versus 9 any kind of fossil fuel. So we interpreted 10 that as meaning all forms of energy that any 11 particular covered appliance would end up 12 using. What we were pointing out here is that 13 AFUE already incorporates standby and off-mode 14 for the fossil fuel part of it only but it's 15 the electrical portions that we are proposing 16 here today for measuring in a test procedure. 17 FACILITATOR BROOKMAN: Go ahead,

18 Frank. 19 MR. STANONIK: Frank Stanonik. And 20 by the way, I agree with the conclusion. I'm 21 just concerned about the possibility that this 22 sets some precedent that this whole question

### 202-234-4433 Neal R. Gross & Co., Inc. Page 26 1 of standby mode and off-mode somehow needs to 2 look at something other than the electrical 3 energy consumption, which I believe again, was 4 the intent of that change in the law. 5 MR. STAS: Eric Stas, DOE. I mean, 6 unfortunately EISA has written on it quite7 broadly. It just says standby mode and off8 mode energy consumption. So if that 9 distinction is there, it didn't make it into

10 the statute. 11 MR. STANONIK: But it specifically 12 in fact, says -- it references, as you can 13 see, using the IEC standard, whatever the 14 number is which is a standard for measuring 15 electrical energy. So, I mean, well, it's -- 16 again, I'd just note that there's some concern 17 about that precedent but we think it really 18 was specific electrical energy. Perhaps 19 there's a way to research that. I don't know. 20 FACILITATOR BROOKMAN: Thank you, 21 Frank. Gary Fernstrom. 22 MR. FERNSTROM: Gary Fernstrom,

### 202-234-4433 Neal R. Gross & Co., Inc. Page 27 1 PG&E. PG&E agrees with DOE's interpretation 2 and believes it's important that we consider 3 standby energy use for both gas and electric 4 where those measures are applicable. Clearly 5 in this case, the gas fuel is accounted for in 6 AFUE but there might be a case with standing 7 pilot lights where it might not be. And I 8 think it's important that standby energy use 9 be considered holistically. 10 MR. STAS: I'll just add one thing, 11 Eric Stas, DOE. I mean, DOE did consider the 12 relevant IEC provisions but the statute 13 doesn't say we're limited just to that. 14 FACILITATOR BROOKMAN: Okay. Yes, 15 please, Roger. 16 MR. MARRAN: Yes, Roger Marran from 17 Energy Kinetics. Our opinion is that the 18 standby or the idle losses that are associated 19 with the off-cycle period are not accounted 20 for accurately relative to real world 21 applications. So although it does exist in 22 the standard, it doesn't properly reflect the

### 202-234-4433 Neal R. Gross & Co., Inc. Page 28 1 real consumption for residential boilers. 2 FACILITATOR BROOKMAN: Okay. Okay. 3 So any additional comments on this stream 4 here? No? Okay. 5 MR. KHAN: Thank you. 6 MR. TALBOTT: Okay, my name is John 7 Talbott and I'm a consultant for NIST, helping 8 out on the EISA test procedure amendments.

9 And I used to work at DOE and I was here when 10 the original test procedures were developed. 11 I'm going to get into the details 12 of what the proposal outlines to satisfy the 13 EISA requirements. The first thing that had 14 to be done is that measurement provisions had 15 to be added to the test procedures and in this 16 case we utilized the international standard to 17 obtain the measurement of the actual power in 18 standby and off-mode. 19 And we titled them P sub SB for 20 Power in the Standby Mode and P sub Off, the 21 Power in the Off-mode. The second thing that 22 had to be done, we had to add an equation for

### 202-234-4433 Neal R. Gross & Co., Inc. Page 29 1 the annual standby mode and off-mode energy, 2 energy use and I'll show you that equation. 3 So that incorporates an actual measure of the 4 standby and off-mode energy consumption. 5 And then thirdly, we had to 6 integrate that into the overall test 7 procedure. We integrated it into the annual 8 standby -- the annual energy use equations and 9 then also without specific amendment, 10 incorporates itself into an energy efficiency 11 quotient. So we think we satisfied everything 12 that EISA has asked us to do. This slide more 13 or less sums it all up on one slide. We had 14 to make some assumptions along the way and 15 we'll discuss this more in detail but the 16 active mode as defined in EISA can be 17 approximated by a test procedure term which is 18 called burner operating hours. Burner 19 operating hours are generally the on period of 20 the furnace of boiler. 21 The non-heating season can be 22 estimated as the duration of 4600 hours. That

### 202-234-4433 Neal R. Gross & Co., Inc. Page 30 1 number is in the existing test procedures. It 2 was used for the pilot light accounting that's 3 in the test procedure for fossil fuel, so we 4 said let's use that and we'll have the same 5 accounting across fossil fuel and electricity. 6 So there's a separate equation that's added to 7 the procedures by today's amendments and it 8 quantifies the annual standby and off-mode 9 electrical energy use and we call it E sub SO,10 the electrical energy in the standby and off11 mode. 12 And as you can see, it's the sum 13 of two terms and it's the wattage measurements 14 that were mentioned before times their 15 duration across a portion of the year, and if 16 you add it all together, you'll get 8,760 17 hours for the year. So this is the annual 18 accounting of the energy use. So it's not 19 wattage, it's watt hours. And then for the 20 next part of the integration, we incorporate 21 that into the already existing annual 22 accounting of electricity and some of the test

### 202-234-4433 Neal R. Gross & Co., Inc. Page 31 1 procedure jockeys out here know all these 2 terms but that's all the existing equation is 3 the energy of auxiliary electric, E sub AE, 4 which previously was the first part of this 5 equation, the burner operating hours times the 6 active mode electricity measurements of the 7 blower, the power burner and the electro -- 8 the intermittent ignition device. 9 We're keeping those equations just 10 as they are. That's the active mode 11 accounting and we're adding the newly 12 developed standby and off-mode electrical 13 energy consumption. And that's it. Now, the 14 implication there is since E sub AE is used in 15 annual operating costs, the operating cost is 16 going to change. Also, since E sub AE is used 17 in an energy efficiency quotient of energy 18 factor, that quotient is going to change. But 19 remember, energy factor is not the regulating 20 metric. AFUE is and AFUE doesn't change

21 because AFUE does not use an E sub A. We're 22 going to emphasize that again.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 32 1 Okay, so the next discussion item 2 in the preamble is the discussion about 3 standards and there's much more detail there,

4 but -- 5 FACILITATOR BROOKMAN: Let's pause. 6 MR. TALBOTT: Okay, all right. 7 FACILITATOR BROOKMAN: Okay, let's 8 pause and see if there are any questions at 9 this point. I've seen more complicated 10 equations. See if there are any questions at 11 this point and then we'll take them. Frank. 12 MR. STANONIK: Frank Stanonik, 13 AHRI. John, the standby mode is defined as 14 essentially the furnace -- well, it's starting 15 the heating season and you don't have anything 16 let's say electrically operating, okay, to 17 include the blower on the furnace as an 18 example. But on a furnace, the typical cycle 19 you have some delay in the blower, right?

20 MR. TALBOTT: Yes.

21 MR. STANONIK: So when the burner 22 goes off, you're still going to have blower

### 202-234-4433 Neal R. Gross & Co., Inc. Page 33 1 operating. So the fact that using burner 2 operating hours, is that any significant -- 3 are we introducing any significant error

4 there?

5 MR. TALBOTT: That's one of the 6 technical points that we're going to get to 7 and discuss in more detail. 8 MR. STANONIK: Okay, okay. 9 FACILITATOR BROOKMAN: Okay, Gary. 10 MR. FERNSTROM: Gary Fernstrom, 11 PG&E. So as long as Frank asked that 12 excellent question which was on my mind as 13 well, the furnace normally drives the 14 thermostat and how may or may not the 15 thermostat load be considered? 16 MR. TALBOTT: I'm not sure I get 17 the distinction. 18 MR. FERNSTROM: Well, there's some 19 load placed on the furnace by the thermostat. 20 There thermostat varies because people use 21 different thermostats than that normally 22 supplied by the manufacturer. So the question

### 202-234-4433 Neal R. Gross & Co., Inc. Page 34 1 is, in standby mode, how may or may not the 2 electrical load of the thermostat be 3 considered? 4 MR. TALBOTT: Okay, I think there's 5 two points in there. You're asking about the 6 electrical energy to run the thermostat to be 7 accounted for in here. We also are going to 8 get to that in later discussions. It's an 9 important point, but then you're also talking 10 about maybe there's some operational stuff 11 that we might be missing. You have to 12 remember that the AFUE test procedure is a 13 more laboratory based. It doesn't even do a 14 complete cycle. It infers the efficiency from 15 limited testing data and so we're not really - 16 - AFUE doesn't get into the complications of 17 different cycling rates or thermostat

18 controls. 19 MR. FERNSTROM: Okay, I was simply 20 asking about the straightforward electrical. 21 MR. TALBOTT: Just the electrical 22 consumption. We'll get to that.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 35 1 FACILITATOR BROOKMAN: Okay, yes. 2 Jim, right? 3 MR. RANFONE: Jim Ranfone, American 4 Gas Association. Good morning. John, just a 5 question. You said that this new factor is 6 not going to impact the standard level but the 7 E sub SO is going to increase the electrical 8 consumption measurement, correct?

9 MR. TALBOTT: Yes. 10 MR. RANFONE: So that the operating 11 costs will also be changed. 12 MR. TALBOTT: Yes, yes. 13 MR. RANFONE: And will that also 14 impact the emissions numbers when you come up 15 with your final calculations because you will 16 be considering more electrical consumption 17 totally? 18 MR. TALBOTT: Yes, yes. 19 MR. RANFONE: Okay, thanks. 20 FACILITATOR BROOKMAN: Okay, let's 21 proceed. 22 MR. TALBOTT: Thank you. Again,

### 202-234-4433 Neal R. Gross & Co., Inc. Page 36 1 the preamble discussion at this point starts 2 to talk about the -- what -- the relationship 3 with standards. And of course, there are the 4 three major points that EISA outlines for 5 standards for this standby and off-mode issue 6 and first off is that it cannot be included in 7 or determined in compliance through current 8 standards. And since AFUE is not changing and 9 AFUE is the current basis of the current 10 standard, then we're safe there. 11 However, after July 1st, 2010, any 12 final standard shall incorporate standby mode 13 and off-mode energy use into a single amended 14 or new standard. And then it also adds that 15 if it's determined and feasible rather than an 16 incorporated metric, you could use a separate 17 standard. So what we're outlining here is the 18 proposed amendments for us. They don't change 19 AFUE so we're okay on the first point. And

20 that these extra measures that are added and 21 the incorporation into the test procedure will 22 allow DOE to address standby mode and off-mode

### 202-234-4433 Neal R. Gross & Co., Inc. Page 37 1 in subsequent standards either by an 2 incorporated metric or a separate standard. 3 FACILITATOR BROOKMAN: Gary

4 Fernstrom.

5 MR. FERNSTROM: So I'm confused 6 about that. If the standby is included in an 7 incorporated metric, would not that be AFUE or 8 are there presently two different metrics that

9 are used?

10 MR. TALBOTT: There's another 11 metric in the test procedure that's not used 12 for standards regulations and it's called 13 energy factor and that would include this 14 extra energy consumption. There could be a 15 possibility that the format of the proposed 16 standard could incorporate an adjustment to 17 the efficiency quotient to account for this. 18 We're saying that the amendments as proposed 19 today can accommodate that and your comments

20 on what would be the best format would be

21 welcomed. 22 MR. STANONIK: Frank Stanonik.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 38 1 FACILITATOR BROOKMAN: Frank, 2 pardon me, let's let Mohammed follow on. 3 MR. KHAN: Mohammed Khan, DOE. I 4 just want to point out that the Department is 5 in its beginning stages of reconsidering the 6 current standards and as we've already 7 indicated, too, after July 1st, 2010, the 8 standby and off-mode needs to be accounted 9 for. So particularly during that period, you 10 know, we invite folks to provide comment on 11 the best ways or approaches to implement a 12 particular descriptor or change to AFUE that

13 would accommodate all of that.

14 FACILITATOR BROOKMAN: Frank. 15 MR. STANONIK: Frank Stanonik from 16 AHRI and I guess, it is the time to ask the 17 question. As Mohammed just mentioned, I think

18 most of us are aware that the furnace 19 rulemaking has been, in one way or another, 20 remanded back to DOE and I just wonder if at 21 this time DOE has a projected schedule as to 22 when the -- this work would be done. Would it

### 202-234-4433 Neal R. Gross & Co., Inc. Page 39 1 be before or after July 1, 2010? 2 MR. KHAN: It's going to be after. 3 So it's going to have to include that to get 4 passed it. That's the answer you're looking 5 for, yes. 6 FACILITATOR BROOKMAN: Okay. 7 MR. STANONIK: Well, not what I was 8 looking for. 9 (Laughter.) 10 FACILITATOR BROOKMAN: Okay, so 11 additional thoughts before we proceed? 12 MR. TALBOTT: Well, this is where 13 Doug broke at that point appropriately because 14 we were sort of saying, you know, just think 15 through it and the concepts have been 16 presented here. The technical details I'm 17 going to get into next. But the concept is 18 we're adding measurement provisions. We're 19 providing an equation for annual accounting. 20 We're integrating it into the existing energy 21 use and efficiency descriptors and you already 22 heard that the next standard is probably going

### 202-234-4433 Neal R. Gross & Co., Inc. Page 40 1 to be after July 1, 2010, so it's got to have 2 something in there about standby and off-mode. 3 And if you're ready, I think we can go, we'll 4 go to the technical details. It's time for 5 some people to nap. 6 All right, the first issue is the 7 burner operating hours approximation. We are 8 proposing that burner operating hours, a test 9 procedure measure, can by used to approximate 10 the active mode duration. Some of the points 11 that Frank made are realized that some of the 12 electrical auxiliaries can run differently 13 than the burner itself. However, the burner 14 itself has electrical components and they may 15 be exactly burner operating hours for their 16 run time. And then the ignition device is 17 something less than that. 18 Typically, the circulating air 19 blower runs longer than the burner does on an 20 average year. There's delay time for the 21 circulating blower to come on and then there 22 is overrun time. You add them up and the Y

### 202-234-4433 Neal R. Gross & Co., Inc. Page 41 1 factors are the test procedure adjustment for 2 that and they are typically greater than one. 3 Igniters are way below one. The burner is 4 probably close to one. Taking that all 5 together, without getting into unduly 6 complicated systems of trying to measure all 7 these standby losses separately, why not pick 8 the test procedure value of burner operating 9 hours and let that be the active mode? And 10 then the prorating of the year becomes the 11 remainder. 12 So it's 8,760 hours in a year 13 minus burner operating hours is the duration 14 of standby and off-mode. 15 FACILITATOR BROOKMAN: Yes, Gary. 16 MR. FERNSTROM: Gary Fernstrom,

17 PG&E. I have a comment on that. On the 18 surface, that seems both simple and 19 reasonable. However, the fan energy use is 20 much, much greater than the other auxiliaries 21 you pointed out. So it would make sense to me 22 to try and make some estimate of the fan run

### 202-234-4433 Neal R. Gross & Co., Inc. Page 42 1 time which is greater than the burn run time, 2 and have a single factor to adjust for that. 3 MR. TALBOTT: Well, that's similar 4 to what is done. Burner operating hours are 5 adjusted because of these run time 6 differences. So the Y factors that are in the 7 test procedure represents an accurate 8 accounting of those differences for active 9 mode and that's the big issue. Remember the 10 active mode electricity consumption of a 11 fossil fuel furnace is on the order of 100 12 hours. Now, this added standby loss, the 13 previously unaccounted for, is something an 14 order of magnitude smaller. And so is it 15 really worth it to go through the extra ordeal 16 of defining these various differences?

17 Remember some furnaces don't have 18 the interrupted ignition. There are some 19 furnaces that the circulating blower is wired 20 to the burner. All those differences would 21 have to be calculated separately in the test 22 procedure to make that slight little

### 202-234-4433 Neal R. Gross & Co., Inc. Page 43 1 accounting difference. We haven't discussed 2 in detail where we mentioned where it said 3 about an order of magnitude difference between 4 the duration of the sum of the standby period 5 and off period compared to active mode.

6 FACILITATOR BROOKMAN: Frank 7 Stanonik. 8 MR. STANONIK: Frank Stanonik, 9 AHRI. First of all, addressing Gary a little 10 bit, we're talking about the standby so, in 11 theory, when nothing is running and so the 12 question to you, John, and this is perhaps at 13 this point, while certainly your learned 14 opinion but by using burner operating hours, 15 isn't it, I'll say, more likely that we're 16 slightly over-estimating the standby?

17 MR. TALBOTT: Yes. 18 MR. STANONIK: We're saying standby 19 starts when the burner stops, but, in fact, 20 the blower is still going.

21 MR. TALBOTT: Yes. 22 MR. STANONIK: Okay, but we've said

### 202-234-4433 Neal R. Gross & Co., Inc. Page 44 1 we're not -- and you know, the blower energy 2 gets counted for. That's been always

3 measured.

4 MR. TALBOTT: Yes. 5 MR. STANONIK: So we're saying that 6 when a burner turns off, that's when we're 7 going to start counting standby. It's a 8 slight overestimation of standby period. 9 MR. TALBOTT: That's right. It 10 will be slight overestimated and the magnitude 11 of it is that using a simplified assumption 12 that there's 800 burner operating hours, then 13 the remainder is 7,900 hours and maybe it's 14 only 7,800. 15 MR. STANONIK: This is obviously 16 new to most of us but for this point, we 17 certainly haven't prepared any serious concern 18 that this is significant. 19 MR. TALBOTT: It's a simplification 20 but it's up front and I think it's -- we're 21 just saying it's a justified simplification 22 considering the alternative which would be

### 202-234-4433 Neal R. Gross & Co., Inc. Page 45 1 multiple measurements associated with the 2 different standby of the blower compared to 3 the burner. It could get very messy quickly. 4 MR. FERNSTROM: So okay, I 5 understand. I was confusing in my question 6 active mode and standby mode. Thank you both. 7 FACILITATOR BROOKMAN: Okay, thank 8 you, Gary. Harvey Sachs? 9 DR. SACHS: John, I very much 10 appreciate the effort to keep the thing 11 understandable and to keep the measurement 12 requirements as simple as possible. I'm very 13 much in sympathy with lumping all of the 14 electrical elements that are operating at the 15 same time. I have no interest in 16 understanding the blower versus the draft 17 inducer or the control board. At the same 18 time, I worry about some potential for gaming 19 if we're not a little bit careful and 20 particularly things I might worry about and do 21 not yet understand would be things like the 22 ceramic igniters that stay on during the

### 202-234-4433 Neal R. Gross & Co., Inc. Page 46 1 entire burner cycle, I'm not sure if we're 2 capturing those and those can well be 400

3 watts. 4 MR. TALBOTT: I believe that's in 5 the active mode accounting that's in the 6 existing test procedures. 7 DR. SACHS: Okay. 8 MR. TALBOTT: It goes a Y factor 9 and it's got the PE Sub IG. 10 FACILITATOR BROOKMAN: Let's see, 11 you wish to comment on this? No? Okay. 12 Sorry, John. 13 MR. TALBOTT: Okay. 14 DR. SACHS: The question is really 15 a hypothetical but what -- at some point as 16 the electronics proliferate, we might not need 17 a trace of electricity used through a complete 18 cycle. Yet, I'm not making this as a formal 19 comment. I'm just not sure that I really have 20 a good insight into what's happening without 21 that beyond your assurances that all the22 electricity is in the non-operating, non### 202-234-4433 Neal R. Gross & Co., Inc. Page 47 1 burner operating powers is really burning very

2 small. 3 MR. TALBOTT: Well, no, we're not 4 missing anything that you're mentioning there 5 about the active mode accounting. We're 6 catching it all and that's in the existing 7 test procedure. What we're only focusing on 8 here by making this assumption is how long is 9 the off and standby period? Is it -- out of 10 the 8,760 hours a year, how much is it and 11 this says it's 7,900. And if it should be 12 7,880 because the blower runs a little longer

13 -- 14 DR. SACHS: That's very helpful,

15 John. 16 FACILITATOR BROOKMAN: Okay, 17 additional thoughts on this? Okay. 18 MR. TALBOTT: All right, then 19 there's one complication with this assumption 20 (Laughter). It doesn't work for electric 21 furnaces. Electric furnaces don't have a 22 burner operating test procedures. So we

### 202-234-4433 Neal R. Gross & Co., Inc. Page 48 1 included equations within the amendments today 2 that allow them to get something like burner 3 operating hours, it's "on hours," and I can 4 just -- this is such an informed group, I can 5 just show you what that equation is. 6 And it's a -- for electric 7 furnaces and boilers, it has a burner 8 operating calculation which is essentially the 9 old heating load, the old famous 2,080 heating 10 load hours times the regular adjustments and 11 the oversizing, divided by the capacity of the 12 unit in BTUs. And that's an approximation of 13 the on time for electric furnace. And that's 14 what you use to do the accounting in the 15 electric furnace provisions. 16 Okay. The next little technical 17 detail is how are we going to use this 18 international standard, and our reading of it19 is pretty straightforward. It's only a four20 page standard and we feel that the furnace 21 blower industry is sophisticated enough to 22 handle it. However, we had to make a couple

### 202-234-4433 Neal R. Gross & Co., Inc. Page 49 1 clarifications and the first one is that for 2 most furnaces and boilers, the standby mode 3 and off-mode, even though the statute asks to 4 make a distinction, sometimes there just isn't 5 a distinction. It's when everything is off, 6 it's the same reading whether it's heating 7 season or non-heating season. And so we say, 8 well, look you don't have to measure it twice. 9 Just measure it once and you're done. 10 The other clarification we made is 11 that we want to make it clear that what we're 12 trying to capture here and what EISA is 13 intending us to capture is all the possible 14 electrical standby loss in the -- onboard the 15 appliance and not to measure something 16 internal into the appliance that wouldn't 17 capture transformers and control circuits that 18 might not be obvious. So we're saying 19 directly in the provision itself that you have 20 to measure the total standby and off-mode. 21 And then another clarification we 22 had to do is that the accuracy requirements

### 202-234-4433 Neal R. Gross & Co., Inc. Page 50 1 spelled out in the International Standard are 2 to be used for this measure and not the 3 accuracy requirements that are in the ASHRAE 4 standard. So just to clarify on that, the 5 ASHRAE standard specifies that electricity be 6 measured with an error no greater than one 7 percent. That's fine for the active mode, the 8 high wattage measurements that are going on in 9 furnace testing and but when we get down to 10 this low wattage measurement, we're deferring 11 to the International Standard for their 12 guidance on how to specify the accuracy and 13 the precision. 14 And so there are differences there 15 and generally, it's a more precise requirement 16 in the International Standard because it's low 17 wattage and we defer to their judgment on when 18 the wattage is so low that you have to really 19 take some different precision steps. So 20 other than those three clarifications, we 21 think the standard, the International Standard 22 is fine and I think we think the furnace

### 202-234-4433 Neal R. Gross & Co., Inc. Page 51 1 industry can handle it. But if there are 2 problems, we defer to the experts out there 3 testing furnaces, if they want to send in some 4 clarifying -- further need for clarification 5 or some real problems with that standard, we 6 would welcome them in the comment period. 7 FACILITATOR BROOKMAN: Yes, please, 8 Cyril. 9 MR. FOWBLE: Cyril Fowble with 10 Lennox International. The only comment I 11 would have to that is that there is a tighter 12 temperature room ambient condition in the IEC 13 standard than there is in the Furnace Test 14 Procedure Standard. So that's something we 15 need to consider especially now it's five 16 degrees CF.3 in the first Furnace Test 17 Procedure, five numbers, I think. It's closer 18 to 20 so that may be something we need to 19 consider.

20 FACILITATOR BROOKMAN: I couldn't 21 tell from your comment what you were advising 22 the Department to do about that.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 52 1 MR. FOWBLE: Oh, sorry, I'm 2 requesting the Department to look into the 3 general condition and the temperature, the 4 ambient temperature requirements of IEC 63.01 5 versus what's the actuary Federal Register 6 requirement for instance.

7 FACILITATOR BROOKMAN: And would 8 you recommend what they do? 9 MR. FOWBLE: My guidance would have 10 them be the same, if you can make them the 11 same, preferably wider for such a procedure

12 standard. 13 FACILITATOR BROOKMAN: Okay. 14 MR. TALBOTT: Okay, so you were 15 involved in the testing of the furnace. 16 MR. FOWBLE: Yes, yes. 17 MR. TALBOTT: Yes, and used the 18 ambient conditions in the ASHRAE standard. 19 MR. FOWBLE: Correct, for this. 20 MR. TALBOTT: Okay, and do you 21 think there is any problem with the accuracy 22 of executing the International Standard at

### 202-234-4433 Neal R. Gross & Co., Inc. Page 53 1 those conditions?

2 MR. FOWBLE: None that I'm aware

3 of. 4 MR. TALBOTT: Thank you. 5 FACILITATOR BROOKMAN: Well, thank 6 you. Okay, so that exchange was John and then 7 Cyril back and forth a few times for the 8 record. Other comments? Frank, did you have 9 a comment on this? 10 MR. STANONIK: Yes, I did, just a - 11 - Frank Stanonik, AHRI. I have a question for 12 John. And, again, I just -- I guess I want to 13 take advantage of the opportunity to make sure 14 I'm understanding what I think I understand. 15 The IEC talks about this -- your uncertainty 16 shall be no more than two percent at the 95 17 percent confidence level. Doesn't that imply 18 you're going to have to take multiple 19 measurements of this?

20 MR. TALBOTT: Yes. 21 MR. STANONIK: Okay.

22 MR. TALBOTT: And there's an

### 202-234-4433 Neal R. Gross & Co., Inc. Page 54 1 appendix in the standard that describes that. 2 And that's what they feel is appropriate for 3 these low measurements that, take a few 4 measurements and then exercise the statistical 5 techniques, framework.

6 MR. STANONIK: So for all the other 7 measurements for this Furnace Test Procedures, 8 you take a measurement with our precise 9 instruments. And so for this one where we 10 might be measuring maybe a watt or something 11 like that, you're going to take several of 12 them. There seems to be some -- I'll say 13 illogic there but maybe not. 14 FACILITATOR BROOKMAN: Harvey

15 Sachs. 16 DR. SACHS: Harvey Sachs, ACEEE. 17 There's relatively little measurement of 18 standby and off-mode energy in the field. The 19 most recent work I'm aware of is by Scott Figg 20 a few years ago and he reported, as I recall, 21 a median for about 30 furnaces in the field of 22 something like eight watts standby and for

### 202-234-4433 Neal R. Gross & Co., Inc. Page 55 1 those furnaces with permanent magnet motors 2 with feedback, the air handler was an 3 additional four watts, so an average of about 4 12. So when you run those numbers out over 5 8,760 hours, we are talking about an amount of 6 electricity that's in the same order of 7 magnitude as the air handler itself. 8 So the magnitudes are not trivial 9 to what Congress has asked the Department to 10 do. The question though is, that I didn't 11 hear an explicit answer, maybe I'm just too 12 dense, to Gary's question, that unlike a water 13 heater, the controller for a furnace is 14 typically remoted to a living space, we call 15 it a thermostat, and that's not always under - 16 - the selection of thermostat is not always 17 under the control of the OEM that provides the

18 furnace. 19 The amount of electricity that 20 thermostat draws should be small but depending 21 on the power supply for that 24 volt or 22 whatever it's using, I just -- I don't hear a

### 202-234-4433 Neal R. Gross & Co., Inc. Page 56 1 specification for how we're including or 2 excluding that thermostat. 3 MR. TALBOTT: Thank you. That was 4 an oversight. We didn't get to that issue in 5 that much detail but the part of the 6 discussion where we said we want the 7 measurement of all the electrical energy, 8 standby and off-mode present, of the 9 appliance, remember this is a program directed 10 at the manufactured covered product.

11 DR. SACHS: I understand that. 12 MR. TALBOTT: Now, that issue that 13 you've raised that the thermostat control 14 energy, may not even be present in the testing 15 lab. They could do the switches by manual 16 control to get through the test procedure. 17 And there is nothing that the manufacturer can 18 do to improve the amount of energy that that 19 thermostat cycle is consuming. So the only -- 20 if we went to capture that and the 21 manufacturers aren't capturing it with this 22 measurement procedure, we would have to add it

### 202-234-4433 Neal R. Gross & Co., Inc. Page 57 1 in on a representative basis which wouldn't 2 distinguish anything between -- from one

3 manufacturer to the other. 4 So if we want to put in a default 5 value for the thermostat control energy of a 6 furnace, we could do that, just to improve the 7 accounting. The only thing that EISA is 8 asking for here is what have you not accounted 9 for that is going to be present in that 10 manufactured device. 11 DR. SACHS: Harvey Sachs, ACEEE. I 12 appreciate that but let me sketch out a 13 scenario that's based on a very, very 14 superficial knowledge and I'm hoping that some 15 of the manufacturers and other experts here 16 can help me but one way I can support that 17 thermostat is with an old style 24-volt Bell 18 transformer and that will give me 24 volt AC 19 and some rather significant core losses, 24 by 20 seven in that transformer. 21 Alternatively, I could move to a 22 solid state device that synthesizes the 24

### 202-234-4433 Neal R. Gross & Co., Inc. Page 58 1 volt or whatever other form I want for my 2 transformer and greatly reduce those losses. 3 We see that in various power supplies today. 4 Because of the national energy use impact, not 5 the individual consumer, we certainly would 6 like at ACEEE to see manufacturers having some 7 small incentive to have the most efficient 8 power supplies possible. I don't know exactly 9 how to do that but I'm not sure it's something 10 we'd just want to sweep away as 11 inconsequential. 12 MR. TALBOTT: I'd like to hear the 13 manufacturer's experience on how the unit is 14 tested and whether they can capture the design 15 difference in that energy consumption through 16 these test procedures.

17 FACILITATOR BROOKMAN: Frank 18 Stanonik. 19 MR. STANONIK: Frank Stanonik, AHRI 20 and John, I'm not going to talk about the 21 experience but more -- I think the more 22 relevant issue is this is not part of the

### 202-234-4433 Neal R. Gross & Co., Inc. Page 59 1 furnace or boiler design. The thermostat is 2 not in the manufacturer's control. It's not 3 part of his design. It is -- recognize, it's 4 part of -- a necessary part of the system, but 5 it's never been something that was in the 6 manufacturer's ability to control. And I 7 think you've captured it properly. If you

8 wanted to somehow account for thermostat 9 energy consumption, you'd probably have to 10 come up with just an assumed fixed value which 11 really doesn't make any difference here. 12 And by the way, I'm not 13 disagreeing with Harvey that, perhaps, there 14 is some need for perhaps a -- I mean, if we're 15 going to look at standby losses or standby 16 energy consumption, perhaps there should be a 17 standby energy consumption criteria for wall 18 thermostats, but I would object to imposing 19 that burden on the furnace and boiler 20 industry. 21 DR. SACHS: Harvey Sachs, again. I 22 very much appreciate that and you may have

### 202-234-4433 Neal R. Gross & Co., Inc. Page 60 1 helped me, Frank, in a way that you wouldn't 2 have wanted to or imagined. If -- let me 3 agree but disagree that the thermostat is an 4 essential component even though the 5 manufacturer does not select it much in the 6 way the air handler is an essential component 7 of the air conditioning system even though the 8 air handler is not directly controlled by the 9 manufacturer in most cases and we run into 10 that problem on the air conditioner side. 11 The point that I'm trying to make 12 is not so much the thermostat's electricity 13 consumption because today there is -- there 14 are marketing reasons why I want to minimize 15 that just to minimize the battery backup on 16 these crazy programmable things. What I'm 17 worried about is the inherent losses depending 18 on the power supply, for the thermostat that 19 is an integral part of the furnace. But I 20 think that may be captured --

21 FACILITATOR BROOKMAN: Let's let 22 this gentleman -- Jim. Jim, say it again. We

### 202-234-4433 Neal R. Gross & Co., Inc. Page 61 1 didn't hear you. 2 MR. VERSHAW: Jim VerShaw with

3 Trane. 4 FACILITATOR BROOKMAN: Thank you. 5 (Off-mic comment.) 6 FACILITATOR BROOKMAN: Jim, you 7 need to get closer to the microphone. Sorry. 8 Thanks very much. 9 MR. VERSHAW: I think that's -- the 10 power supply is usually in the furnace so you 11 know, we don't have any control over what 12 thermostat goes on there. So you can use -- 13 and in the testing process and you asked about 14 that, we usually use manual switches because 15 you're measuring times and whatnot. You don't 16 have a thermostat involved and it just doesn't 17 work out in the testing process. 18 So it would make sense to me for 19 this measurement of standby loss that we would 20 be measuring just the power that the furnace 21 is using and the thermostat's got a big color 22 screen on it. That's going to take a little

### 202-234-4433 Neal R. Gross & Co., Inc. Page 62 1 more power but we can't control that and 2 that's not -- shouldn't be part of the furnace 3 standard. But the transformer doesn't get 4 changed out if you change thermostats, so 5 whatever that's sitting there drawing when 6 there's nothing happening is there. 7 DR. SACHS: Thank you very much. 8 That's what I was hoping. Thank you. 9 FACILITATOR BROOKMAN: Thank you. 10 Gary, do you have a comment or a question? 11 MR. FERNSTROM: Well, regardless -- 12 yes, thank you. Regardless how small the 13 thermostat load is, the furnace won't operate 14 without it and I agree, it's beyond the 15 manufacturer's control but I think some 16 assumption ought to be made about it and 17 included because that's part of the real world 18 performance of these things, and that's really

19 what I want to know out of the tests and the 20 standards and the performance information 21 that's published. 22 FACILITATOR BROOKMAN: Okay, thank

### 202-234-4433 Neal R. Gross & Co., Inc. Page 63 1 you. 2 DR. AMRANE: Karim Amrane, AHRI. 3 Before you go, John, I guess I understand from 4 your comment that DOE has not tested furnaces 5 based on the test procedures you're proposing. 6 MR. TALBOTT: Well, we've got the 7 data from other sources like ACEEE to get the 8 magnitude and Lawrence Berkeley Labs have done

9 some measurements as well. 10 DR. AMRANE: But whether they're 11 used now, they are -- 12 MR. TALBOTT: I don't think there's 13 reports directly using the international 14 standard, you're right. 15 DR. AMRANE: Okay, so are you 16 planning to go to testing? 17 MR. TALBOTT: That's up to DOE. 18 DR. AMRANE: So basically DOE is 19 counting on manufacturers trying test 20 procedures and then that issue is come back to 21 DOE within 75 days?

22 FACILITATOR BROOKMAN: Mohammed.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 64 1 MR. KHAN: Mohammed Khan, DOE. 2 Currently, the Department has no plans for 3 doing any kind of exploratory testing to, I 4 guess, validate, if you will, the 5 appropriateness of the proposed amendments 6 today. But of course, as always, any data, 7 any kind of additional information through the 8 comment submittal process that you would be 9 able to provide is helpful and is needed. 10 FACILITATOR BROOKMAN: Okay, so 11 then we're moving to the next slide. Yes, 12 Mohammed, you're going to set this one up? 13 MR. KHAN: Actually, no, I thought 14 you were going to do that. 15 FACILITATOR BROOKMAN: So then you 16 can see, this is the final substantive slide. 17 And you can see the two bulleted points there. 18 Other than the mentioned clarifications the 19 IEC Standard 62301 is adopted without 20 modification. DOE believes IEC 62301 21 procedure is appropriate for measuring the low 22 wattage that would be encountered when testing

### 202-234-4433 Neal R. Gross & Co., Inc. Page 65 1 furnaces and boilers and reviewing the IEC 2 provisions. 3 DOE sees no conflicts or 4 difficulties for the F&B industry when testing 5 their products and specifically the Department 6 would seek comment on those two points, the 7 adequacy and appropriateness of IEC Standard 8 62301 in general and whether there's a need to 9 modify the part from the provisions by IEC 10 62301 with regard to residential furnaces and 11 boilers. 12 Okay, this is your chance to make 13 more specific comments related to those IEC 14 standard -- that IEC standard. Harvey Sachs. 15 DR. SACHS: Harvey Sachs, ACEEE. 16 I guess my only remaining question is an 17 information item. It wasn't clear to me in my 18 reading of the proposed rule because I don't 19 think it's covered, what manufacturers will 20 actually report to DOE and consumers with 21 respect to standby and off-mode electricity 22 released? Will it simply be folded into the

### 202-234-4433 Neal R. Gross & Co., Inc. Page 66 1 global metrics or will it be separately 2 reported? 3 MR. KHAN: Mohammed Khan, DOE. I 4 guess with any regulatory descriptors, as of 5 right now we have a AFUE. Manufacturers are 6 going to be required to comply with that and 7 then also report that. As to your question 8 about whether it be combined or lumped in with 9 AFUE or be a separate, that's something that, 10 you know, we're still going to be working on 11 as we go through the rulemaking process. But 12 just to be clear, whatever the regulatory or13 whatever regulation for the standby or off14 mode in addition to the active mode which is 15 now AFUE, will need to be complied with and 16 also reported. 17 DR. SACHS: Harvey Sachs again. 18 I'm a little confused. Are you saying that 19 manufacturers will report the P sub SB and P 20 sub O to you? 21 MR. KHAN: I'm sorry, those 22 particular values, no, but you know, if for

### 202-234-4433 Neal R. Gross & Co., Inc. Page 67 1 example, we have a certain value that would be 2 the regulatory value for standby or off-mode 3 is those values that would be reported. 4 DR. SACHS: That would be the time 5 and motion over the year.

6 MR. KHAN: Correct. 7 FACILITATOR BROOKMAN: Additional

8 comments?

9 No? Go ahead. 10 MR. STANONIK: If I could go off on 11 something -- Frank Stanonik, AHRI. Mohammed, 12 you indicated that DOE at least at this stage, 13 didn't have any intent to do some of its own 14 testing using 60 -- IEC 62301. And yet, we 15 have determined that when the next -- or not 16 when -- when the final rulemaking of the 17 furnace requirements comes out some time in 18 the second half of 2010, that it will include 19 some -- address in some way the standby 20 consumption. 21 I see a disconnect there. How 22 will DOE be able to get some idea of what

### 202-234-4433 Neal R. Gross & Co., Inc. Page 68 1 would be an appropriate standard for standby 2 consumption unless you run some of your own 3 tests to see what is representative of 4 equipment? 5 MR. KHAN: Mohammed Khan, DOE. 6 Frank, that's actually a very valid point. I 7 guess I really can't answer that with definity 8 for this point but in some manner they 9 probably will investigate that and incorporate 10 in its analysis process as it normally does to 11 come up with a level of a standard which would 12 be deemed appropriate.

13 FACILITATOR BROOKMAN: Lance? 14 MR. DeLAURA: Lance DeLaura, with 15 the Sempra Energy Utilities. This is not a 16 comment but more of a question. I've heard a 17 lot of clarifying questions and discussion but 18 I guess my question is from the lack of 19 additional discussion is it workable from the 20 customer's perspective? I'm interested for 21 the end use customer. Is any of this 22 rulemaking going to impact our customers

### 202-234-4433 Neal R. Gross & Co., Inc. Page 69 1 adversely?

2 FACILITATOR BROOKMAN: I note that 3 Lance is looking at the manufacturers in the 4 room at this moment. Yes, Cyril. 5 MR. FOWBLE: Cyril Fowble from 6 Lennox International. You know, from our 7 analysis, we fail to see any effects at all. 8 FACILITATOR BROOKMAN: Okay, thank 9 you. 10 MR. VERSHAW: Jim VerShaw with 11 Trane. This is a measurement procedure, 12 right, it has nothing to do with what gets 13 reported, so we'll have to wait and see what 14 comes out in the revised standards and see how 15 that's going to effect customers and 16 everything else. Jim VerShaw again with

17 Trane; one more comment. 18 In reading through this before the 19 meeting, it wasn't clear and it was talked 20 about with the thermostat thing, but I would 21 recommend that the standard be made very 22 explicit on the setup procedure for the

### 202-234-4433 Neal R. Gross & Co., Inc. Page 70 1 measurement of the standby power. I mean, you 2 look through the international standard and 3 you got A through F of different types and you 4 looking through there and they're talking 5 about breadmakers and radar ranges and the 6 like. And I'm going, I don't see a furnace in 7 here, and if you know how furnaces are 8 installed around the country, sometimes there 9 is a power switch next door, that's Type B. 10 Other ones have a thermostat, that's Type C. 11 A thermostat is not in the 12 appliance. So, I mean, I think you need to 13 take a look at that international standard and 14 look at what you're going to finally publish 15 and make sure it's very explicit how everybody 16 needs to test this so that there's no way that 17 somebody can test it differently than somebody 18 else. So it's always done the same way and 19 that seems to be the most gray area that I saw 20 going through there.

21 FACILITATOR BROOKMAN: Excellent. 22 I couldn't tell from your comment, is the

### 202-234-4433 Neal R. Gross & Co., Inc. Page 71 1 international standard as written, is it 2 explicit and specific enough?

3 MR. VERSHAW: No. 4 FACILITATOR BROOKMAN: No, right, 5 okay. And so would you then be able to say 6 that such things that should be listed

7 enumerated?

8 MR. VERSHAW: The standard that DOE 9 publishes ought to be explicit on how to turn 10 the furnace on and off for the power mode and 11 be explicit about the thermostat requirements, 12 whether there is -- either you do it without 13 thermostat or whatever you decide to do. I 14 would recommend you would not have a 15 thermostat on the thing. Just measure the 16 power that the furnace has on standby. 17 FACILITATOR BROOKMAN: Okay, that's 18 a helpful comment. Thank you. Yes, Mohammed. 19 MR. KHAN: Mohammed Khan, DOE. I 20 appreciate that very much and those kinds of 21 comments specifically are welcome in the 22 written comments. So, please submit those

### 202-234-4433 Neal R. Gross & Co., Inc. Page 72 1 kind of comments. 2 FACILITATOR BROOKMAN: Yes, and I 3 think just to be more specific, the Department 4 would really enjoy as specific as you can be 5 on these points because they rely on your 6 experience. Gary. 7 MR. FERNSTROM: Gary Fernstrom from 8 PG&E. I would agree that it makes sense to do 9 the test without any thermostat connected 10 because it seems like that's the way they're 11 going anyway. However, I think some factor 12 might want to be considered to account for 13 what that energy use might be. And I'd like 14 to make a comment going back to Lance's 15 question about how the outcome of this 16 proceeding may or may not adversely effect

17 customers. 18 I think to the contrary, there is 19 a way where customers can be favorably 20 effected and that would be if the standby 21 power in furnaces could be reduced with say 22 electronic power supplies as opposed to

### 202-234-4433 Neal R. Gross & Co., Inc. Page 73 1 magnetic transformers as Harvey suggested. 2 That would reduce annual electric standby use 3 and if that could be properly measured, and 4 then incorporated into the standard, that 5 would be a good thing and something that would 6 benefit customers. 7 FACILITATOR BROOKMAN: Okay, thank 8 you. Harvey Sachs. 9 DR. SACHS: This is Harvey Sachs, 10 ACEEE. Mohammed, I think that Jim VerShaw has 11 raised a very important point. I have mumbled 12 a little bit to Karim Amrane, who is sitting 13 next to me and we, outside AHRI, are certainly 14 willing to work with the manufacturers on a 15 quick effort to establish the conditions of 16 test, as Jim is suggesting if that would be 17 helpful. We think everybody has a common 18 interest in having that set of rules clear and 19 consistent so we now have a game plan. 20 MR. KHAN: Mohammed Khan, DOE. 21 Harvey, any such activity like that, that 22 would result in very meaningful and useful

### 202-234-4433 Neal R. Gross & Co., Inc. Page 74 1 information as always, will be very 2 appreciated. Thank you.

3 FACILITATOR BROOKMAN: Frank 4 Stanonik. 5 MR. STANONIK: Frank Stanonik, 6 AHRI. Just a different point and I just want 7 to, I guess, confirm something. The 8 definition of the seasonal off-switch, it just 9 says a switch and I guess I just want to 10 confirm that DOE recognizes that might be 11 either a manual or an automatically operated 12 switch? That was a question, not very well,

13 but -- 14 FACILITATOR BROOKMAN: John, can 15 you take that one? 16 MR. TALBOTT: Okay, I just put the 17 actual provision that's in the test procedure 18 up there. This is what you're talking about 19 now. There may be some clarification or 20 expansion. I would love to see the -- 21 recommend something right here, right now and 22 we could mark it up. But we're under the

### 202-234-4433 Neal R. Gross & Co., Inc. Page 75 1 impression that again, we don't know but are 2 there designs that are clearly marked to say 3 that the summertime use of a furnace not 4 connected to an air conditioner, could be 5 truly off, disconnected from the power source 6 and that's what that's about. And if you have 7 a design feature that exactly does that, and 8 this is a precedent that is already 9 established in all test procedures. 10 The manual control, gas manual 11 heater, we specify that if there's a switch 12 that says, "OFF" and it's right there, we're 13 not going to measure that off season loss. 14 And there's a couple other test procedures 15 across a whole suite of test procedures that 16 makes that determination. Similar to that, if 17 you've got a clear enough indication to the 18 user that you can turn this thing truly off,

19 don't measure the -- don't account for the 20 off-mode, standby loss. 21 MR. KHAN: Mohammed Khan, DOE. 22 Frank, I just want to get to your point about

### 202-234-4433 Neal R. Gross & Co., Inc. Page 76 1 the definition and whether DOE has any 2 concerns for the distinction of it being a 3 manual switch or an automatic switch. The 4 definition as proposed in 2.9 says, "When 5 activated". It does not make any distinction 6 about how that activation is done. So whether 7 it be manual or automatic, I don't think it

8 matters. 9 MR. STANONIK: Okay, well, thanks 10 Mohammed. That's how I was reading it. I was 11 just kind of looking to make sure that's what 12 the intent was. 13 MR. KHAN: Yes, that's it. 14 FACILITATOR BROOKMAN: Harvey? 15 DR. SACHS: Harvey Sachs, ACEEE. I 16 understand what this says. I'm trying to map 17 it into my experience and if, for example, 18 there were a hard switch on the furnace that 19 turns it off, I can actually do at my house, 20 that also means I'm turning off the power 21 supply to the thermostat. And if I think of 22 that as a seasonal switch, it's saying, you

### 202-234-4433 Neal R. Gross & Co., Inc. Page 77 1 can turn it off and come October, you will 2 need to reprogram that thermostat. The day of 3 the round funny one is almost over. That's 4 another story, Jim. 5 But let me say for the record that 6 my wife and I have had four programmable 7 thermostats in the last 30 years and were able 8 to program the first one. It had little 9 buttons you stuck around the perimeter. My 10 wife has a graduate degree in controls 11 engineering. (Laughter). 12 But leaving that point aside, it's 13 just not clear to me operationally what it 14 means to have a seasonal switch in 2009 and 15 beyond given the level of support the 16 thermostat requires 365 days a year. 17 MR. TALBOTT: But you do encourage 18 its existence if it can be worked out and this 19 provision is encouraging it. 20 DR. SACHS: Okay. 21 MR. TALBOTT: And if it needs to be 22 clarified, that's what we'd be interested in

### 202-234-4433 Neal R. Gross & Co., Inc. Page 78 1 hearing.

2 FACILITATOR BROOKMAN: Frank 3 Stanonik. 4 MR. STANONIK: Frank Stanonik, 5 AHRI. To Harvey's question and I suggest 6 maybe it's a little easier if you think of a 7 boiler, and particularly since regulations are 8 in place that not too far off boilers will be 9 provided with what is shorthandily called an 10 outdoor temperature reset, and let's just 11 imagine that somebody is clever enough to 12 incorporate into the outdoor temperature reset 13 something that says, "Oh, if I see a 14 temperature above 60 degrees for X number of 15 days or hours, I'm assuming it's no longer 16 winter", and deactivates the boiler, that 17 would be a seasonal switch. 18 DR. SACHS: Of course, I'm -- 19 Harvey Sachs again. I'm living in Roger 20 Marran's world in which all boilers are 21 integrated with a water heater. 22 MR. STANONIK: Well, they're not

### 202-234-4433 Neal R. Gross & Co., Inc. Page 79 1 all.

2 FACILITATOR BROOKMAN: Mohammed? 3 MR. KHAN: Mohammed Khan, DOE. 4 Frank, I just want to make a point about the 5 automatic temperature reset control device 6 that you were talking about regarding the 7 boilers. In our definition, when we were 8 talking about the switch, we were talking 9 about a switch that would be integral to the 10 appliance, something that's shipped with it, 11 it's manufactured that way, it was built that 12 way, shipped that way, installed that way. I 13 just want to be clear that I don't think at 14 this point the Department would be recognizing 15 an automatic temperature reset device on a 16 boiler as part of that definition unless it is 17 an integral component of the boiler, meaning 18 that it's going to be supplied with it, 19 installed with it, and that the boiler won't 20 function unless that particular device is 21 connected to it. 22 I actually want to make that

### 202-234-4433 Neal R. Gross & Co., Inc. Page 80 1 clear. 2 MR. STANONIK: Frank Stanonik, 3 AHRI. I think you just described what is the 4 impending regulation. It will come with it. 5 The boiler won't operate unless it's installed 6 and I expect the manufacturers will be 7 providing it because otherwise it's an unknown 8 that they, in fact, will now need to control 9 DR. SACHS: Harvey Sachs, ACEEE. 10 It was, as I recall, a feature that was a 11 consensus among many parties, including the 12 manufacturers and everybody loved it except 13 OGC but that's a political statement. 14 FACILITATOR BROOKMAN: The first 15 one of the day. Okay, moving back to the 16 technical content. Roger Marran, yes. 17 MR. MARRAN: Thanks, Doug. Roger 18 Marran with Energy Kinetics, just a follow on 19 statement. One of the things I think that 20 goes back to my opening remarks on this is 21 we're moving forward to have energy saving 22 controls on residential boilers. These energy

### 202-234-4433 Neal R. Gross & Co., Inc. Page 81 1 saving controls can have an overarching impact 2 on the real delivered energy efficiency the 3 conditioned space and hot water. These 4 controls, in themselves, do have an energy 5 consumption with them, electrically. So we're 6 now in a position where there's going to be a 7 mandate to put better controls on boilers to 8 help improve the real delivered efficiency but 9 because AFUE specifically excepts the use of 10 controls in the test standard, so they don't 11 have any impact on the standard, that you'd 12 get a better efficiency in efficiency control, 13 but you'll get a lower efficiency in this test 14 because now you're going to have an electrical 15 consumption that's associated with it. 16 So it really is imperative that we 17 have a better test standard that's going to 18 reflect the impact of higher efficiency 19 controls to be able to not only distinguish 20 between the controls, but why it's so 21 important to have these controls on the 22 equipment to get better performance moving

### 202-234-4433 Neal R. Gross & Co., Inc. Page 82 1 forward. 2 FACILITATOR BROOKMAN: Okay, John

3 Talbott? 4 MR. TALBOTT: That's a bigger point 5 than I was going to make. Just to clarify this 6 provision that we are including and that 7 business about the off-switch and seasonal 8 differences, it's a difference we're looking 9 for there. If there is an expected difference 10 between the off-mode that there's something11 done between the heating season and the non12 heating season. It could be a lower wattage 13 in that, for instance, the manufacturers 14 decide, "I'm going to shut down with this 15 switch only the components that are associated 16 with the heating and I'm going to leave the 17 thermostat hot", or something like that. That 18 would be an off-mode wattage that is 19 considerably less than the standby wattage and 20 then those differences would be reflected in 21 the annual accounting. 22 So it's not just an on and off

### 202-234-4433 Neal R. Gross & Co., Inc. Page 83 1 issue. It's an expected difference between 2 standby mode and off-mode. 3 FACILITATOR BROOKMAN: Okay, thanks 4 for that clarification. Okay, so then I would 5 refer you again to Slide 15. Any additional 6 and perhaps final comments in IEC Standard 7 62301 and these last items that people have 8 been raising? Then now is an opportunity for 9 anybody that wishes to do so to make a closing 10 remark, summary comments, any additional 11 issues that people wish to raise at this time? 12 Yes, Jim. 13 MR. RANFONE: Jim Ranfone, AGA, 14 just a question of scope. I realize you're 15 going to be requiring this on electric 16 furnaces now. Would that also apply to an air 17 handler that has a heating element to it, for 18 example, a heat pump? Are they considered 19 electric furnaces? Was that within the scope 20 of this rulemaking? I guess that's a DOE 21 question. 22 MR. KHAN: I can try. Mohammed

### 202-234-4433 Neal R. Gross & Co., Inc. Page 84 1 Khan, DOE. Heat pumps are not part of this 2 rulemaking, it's fossil fuel furnaces and 3 electric furnaces. 4 MR. RANFONE: But the electric, Jim 5 Ranfone again. The electric segment of a heat 6 pump which would be an air handler with an 7 electrical, you know, element in it, is that 8 considered an electric furnace by DOE and 9 would that be considered -- included in this 10 rulemaking as another measurement that has to 11 be taken for that product line, for the air

12 handler? 13 MR. KHAN: Yes, Mohammed Khan, DOE. 14 The intention here is not to separate or pull 15 out any portions of any particular product. 16 And since the heat pump, I believe is covered 17 under the AC line of products, it would be

18 looked at there. 19 MR. RANFONE: Again, Jim Ranfone. 20 I'm not sure I understand. So is the air 21 handler that has an electric element to it, 22 considered an electric furnace and included in

### 202-234-4433 Neal R. Gross & Co., Inc. Page 85 1 the current DOE test procedure? I guess 2 that's really the basic question because it 3 operates as an electric furnace.

4 MR. KHAN: Yes. 5 MR. RANFONE: It's got a blower, 6 it's got heating elements. 7 MR. KHAN: Okay, well, basically, 8 I'm going to have to say no at this point. 9 MR. RANFONE: Okay. 10 MR. KHAN: It will not be covered.

11 MR. RANFONE: Is there a reason for 12 that because it's not part of this test 13 procedure or -- 14 MR. KHAN: Well, as I was trying to15 explain, because that is a -- I guess a sub16 component or component of the heat pump, which 17 is covered under the AC rule, it will not be

18 covered here. 19 MR. RANFONE: Okay. The second 20 question -- oh, I'm sorry, go ahead. 21 FACILITATOR BROOKMAN: That's it. 22 Eric Stas.

### 202-234-4433 Neal R. Gross & Co., Inc. Page 86 1 MR. STAS: Eric Stas, DOE. Let me 2 just add that the standby provisions apply to 3 all of our covered products so just because 4 you're not covered under the furnace and 5 boiler test procedure in pursuing standards, 6 you'll probably be caught in the AC heat pump 7 section, so it's not -- I don't think it's a 8 free pass.

9 MR. RANFONE: For water heaters or 10 any other product then. 11 MR. STAS: Standby is going to 12 apply to everything after July 1st, 2010. 13 MR. RANFONE: Okay, thank you. The 14 second question is, a few years ago the 15 Department proposed an energy factor for 16 electrical consumption of fossil furnaces, oil 17 and gas to measure electrical consumption. I 18 think we used to call it SUF factor but they 19 weren't applying it to electric furnaces at 20 that time. They took that electrical 21 consumption back to source. I don't see that 22 as part of this rulemaking. I think the

### 202-234-4433 Neal R. Gross & Co., Inc. Page 87 1 argument back then was that DOE did not have 2 the authority to measure electrical 3 consumption back to source. Is that still the 4 case today or could this rulemaking be 5 included to add that separate energy factor 6 which wouldn't be part of a minimum efficiency 7 program to include source electrical 8 consumption?

9 FACILITATOR BROOKMAN: John

10 Talbott. 11 MR. TALBOTT: As you know, there is 12 an energy factor in the existing test 13 procedure and that applies to electric

14 furnaces. But and these amendments would 15 change that quotient but for electric 16 furnaces, it's assigned 100 percent efficiency 17 and AFUE equals energy factor. And that's 18 unfortunate because it probably shouldn't but 19 that was simplifying an assumption that was 20 made early in the test procedure development 21 and the ASHRAE standard 103 does incorporate 22 a different energy factor for electric

### 202-234-4433 Neal R. Gross & Co., Inc. Page 88 1 furnaces, but that's not on DOE's list, I 2 don't believe, to address within this topic. 3 MR. RANFONE: This is Jim Ranfone, 4 AGA, I think with some of the recent studies 5 like the National Academy of Science came out 6 and basically said that, you know, energy use

7 should be measured at the source. And I was 8 asking DOE to consider that. I think perhaps 9 that may be something that should be 10 considered at least as part of this rulemaking 11 to put it on the table and see where we go 12 from there, because if we're all interested 13 in, you know, reducing energy consumption, 14 then it should be done totally not just on the 15 site. Thank you.

16 FACILITATOR BROOKMAN: So that sort 17 of comment would be very helpful in your 18 written comments, Jim. 19 MR. RANFONE: Okay, thank you. 20 FACILITATOR BROOKMAN: Thank you, 21 yes, Gary.

22 MR. FERNSTROM: PG&E has advocated

### 202-234-4433 Neal R. Gross & Co., Inc. Page 89 1 for that over many rulemakings. 2 FACILITATOR BROOKMAN: Thank you 3 for that voice of support. Any -- then, now 4 is the opportunity for people to make 5 additional comments, raise additional issues, 6 ask additional questions. I think we're now - 7 - have now completed the presentation material 8 and the material that the Department wanted to 9 cover. Okay, yes. 10 MR. KHAN: Thank you. As Doug 11 already mentioned at the onset, this was -- 12 the whole thing was captured via transcript 13 which will be available in the next upcoming 14 weeks. Again, I want to remind you about the 15 importance of the written comments. There 16 were a lot of good points made today and the 17 Department would definitely appreciate a 18 follow-up as a written form, and this 19 information here is just to remind you once 20 again how to submit that. 21 And again, I want to point out and 22 remind you please, that the cutoff date for

### 202-234-4433 Neal R. Gross & Co., Inc. Page 90 1 receiving those comments are October 13, 2009 2 and when you do submit that, please include 3 the pertinent information. And again, thank 4 you very much and it looks like one other 5 question. 6 MR. STANONIK: Yes, in the mail 7 address, the note for ASHRAE Standard Cooling 8 equipment, I assume that's a typo? 9 MR. KHAN: Why did you have to 10 point that out, Frank? 11 MR. STANONIK: Because if I send my 12 comments in, they get lost. (Laughter) 13 MR. KHAN: I will make sure that 14 gets fixed and -- yes, thank you.

15 FACILITATOR BROOKMAN: And the 16 evaluation form is a part of your packet. 17 Please take 30 seconds and fill out the 18 evaluation form. Thanks to all. 19 (Whereupon, at 10:35 a.m. the 20 above-entitled matter concluded.)

21

22

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